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Privacy Policy
What is this Privacy Policy for?
This privacy policy is for Hortoflora and its websites www.hortoflorabyseac.it and governs the privacy of our website users and our customers and associates.
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the websites and Giardinoweb. Furthermore the way these websites and our internal systems process, store and protect user data and information will also be detailed within this policy.
The Website
This websites and their owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with all  laws and requirements for user privacy.
At Giardinoeweb, we collect different types of information about our users & customers for five main reasons:
   1. To provide personalised services unique to individual users.
   2. To help us to monitor and improve the services we offer.
   3. To keep customers up to date about the services and products we offer, or that they have subscribed to or purchased.
   4. To fulfil contracted services.
   5. If we have permission from the user, to market promotions and services to them.
Some of our services may have their own specific privacy policy because the services we provide in that instance are different. Please check when you sign up or register just to be sure you know what is happening to your information.
To make it easier for you to read this policy, it is divided into sections.
   1. About us
   2. What data we collect and how we use it
   3. Legal basis
   4. Profiling
   5. How long we keep your data
   6. Registration for clients and subscribers
   7. Other uses of your data
   8. Updating your data
   9. Who we share you data with
   10. Use of cookies
   11. Google Analytics
   12. About advertising
   13. Legal information and how to contact us
   14. Changes to this privacy policy
   15. External Links
About Us
   1. The protection of your privacy and personal information is important to us.  We make sure that not only do we have appropriate security measures in place, but that any other organisation we work with to provide a service also meets the same standard as us.
   2. We will respect your privacy.  You should receive  emails only from us. We will make sure that the boxes that you need to tick if you are happy to receive marketing are presented clearly and at the appropriate time.
   3. We will make it clear at the point at which we request your information, what we are collecting it for and how we are going to use it.
   4. We will collect and use your personal information only if we have your permission or we have sensible, business reasons for doing so, such as collecting enough information to manage your registration or subscription.
   5. We will minimise the amount of information we collect from you to what we need to deliver the services or products you have requested.
   6. We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
   7. We will use personal information only for the purposes for which it was originally collected and we will make sure we delete it securely.
   8. Our website is accessible via the internet.  Please remember that if you post any comments or links on any our sites that they can be read and accessed by anyone and everyone.
   9. If we, our service providers, or our commercial partners transfer any information out of the European Economic Area (EEA), it will only be done with the relevant legal instruments or permissions being in place.
What information do we collect about you when you register and how do we use it?
We collect information on you:
   • When you register for a course or event, including competitions
   • When you contact us for information
   • When you work with us in a commercial capacity, for example, as a sponsor or partner
   • When you sign up for a newsletter
   • When you subscribe to our online materials, either free or paid for
   • When you download an app
   • When you use the website
   • Through cookies
   • If you choose to reveal information through postings
   • If you complete your details on research/feedback questionnaires and
   • When you enter sales promotions and competitions
   • When you are studying in  our centre, please be aware that CCTV footage is automatically recorded on a daily basis for security purposes and kept for approximately 30 days
   • Photos: your photo may be used in our online or print publicity. If you prefer not to have your image used in this way, please inform us in writing: slv.giardino@gmail.com.
Certain services that we provide may involve us collecting extra information (your location, your first language), so that we can better tailor the service we give you. This may also apply to apps that you download or which we provide.
What legal basis do we use for processing your data?
We use a different legal basis depending on the purpose for collecting your data in the first instance.
   • For all data collected to sign up for a service or product such as a newsletter, an event, or a competition, we process the data using Legitimate Interest, i.e. you are able to access an extensive range of information in exchange for supplying your information, and we have a relationship where the balance of benefits is in your favour. You have a choice in the management of your data in this manner and can opt out of processing under this basis at any time.
   • Where you provide data in the course of the purchase of a service or product, we process your data under Contract, i.e. your data is necessary for the fulfilment of the service. Any additional contact, i.e. telling you about another service or product closely related to the service or product you have bought is managed under Legitimate Interest.
   • Any secondary processing of your data, i.e. sharing with third parties, sending you a message on behalf of third parties, transfer to third countries, is managed under Consent.
Under the terms of current data protection legislation, we will always make it as easy as possible for you to opt out of unwanted processing, providing it does not restrict our ability to provide you with the service you have requested.
From time to time, we may use some elements of the data you have provided to target the messages we send you. For example, we may use your location to send you information about an event or service which is happening in the same country or available only to those in that area.
None of this information is collated by wholly automated means and the rights and freedoms of the data subject (you) are safeguarded by suitable measures.
How long do we hold onto your data?
We collect data for a wide range of purposes and we do not have singularly defined retention period as a result. For each individual service or product, we define a carefully assessed timeframe within which we retain your data.
After this, the data is managed to ensure that it is either erased from our system, minimised and retained for legal reasons or pseudonymised and retained on a global suppression list to ensure that you do not receive unwanted messaging from us.

Registering as a subscriber or delegate
The minimum information we need from you to register either as a student, subscriber or delegate is your name, title, address, date of birth, telephone number and email address.  We will only ask you more questions for different services. Unless we say otherwise, you must answer all the registration questions.
We may also ask you some other voluntary questions during registration (for example, demographic questions) so we can gain a clearer understanding of who you are.  This enables us to assess whether you qualify for a free subscription or registration, need to be invited to a specific event or have specific products delivered to you. We may also use these details to create anonymised audience information for our sponsors and partners to facilitate their advertising or commercial decision-making process.
We will process data collect? for the purpose of facilitating your registration or subscription on the basis of Legitimate Interests to deliver the service for which you have registered or subscribed. We will also, on this basis, contact you occasionally about other relevant services and products which we think will interest you. You always have a choice and can opt out of the processing on this basis at any time by contacting us at slv.giardino@gmail.com  with the subject line: Opting out of data processing.
Other uses of your data
We do not sell your data at any time.
Use of children’s data
We only collect or store any personal information about children under the age of 18 in the context of their being a student or subscriber and for the purposes of providing them with the services and products requested.  This is applicable also to young people under 18 and to all those where permission is obtained directly from a legal adult (parent or guardian) to collect this information.
Updating your personal information
Under current data privacy legislation, you have the right to rectify, erase or restrict the processing of your data without undue delay.  You may also request access to the data we hold on you. To do this, write to slv.giardino@gmail  with the subject line Rectify data, restrict or erase data.
Who we share data with
We process any information which we collect when you access these services provided by another organisation under this privacy policy.  Information collected by these other organisations is governed by their own privacy policies.
We can access and release personal information to keep to relevant laws and government requests, to operate our systems properly and to protect both us and our users.
Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA or countries deemed adequate by the EDPB.
Use of Cookies
We use cookies for a number of reasons:
   1. For statistical purposes to track how many users we have and how often they visit our websites. We collect information listings on which of our pages are most frequently visited, and by which types of users and from which countries.
   2. We use other organisations to collect anonymised user information, sometimes through cookies and web beacons, (information embedded in images which allow them to analyse how the website is being used and the number of visitors.
   3. Placing cookies on your computer means we can show you adverts that you might interested in, and allows us to control the number of times you see them and measure how effective the advertising campaign has been. Advertising helps us to keep the site free for you to use. You can find more information on this in the Advertising section of this privacy policy, including how to opt out.  
   4. You can turn cookies off but if you do this, you may not be able to use all services on our websites and you might see more pop-ups and other advertising. This is because we won’t be able to limit what you see by using cookies. However, you will still be able to see our editorial content.
By using the sites, you are agreeing to the use of cookies as described.
Legal Information and how to contact us
Under the currently applicable laws, we have to say who the ‘data controller’ is for Giardinoweb services and products provided via our websites, newsletters, events and other products and services. The data controller is the organisation responsible for protecting information and in our case, is ICO.
If you would like access to or a copy of the personal information we hold about you, to request a correction, or have any questions about how we may use it or to make a complaint, please contact the data manager by email slv.giardino@gmail.com
Requests will be dealt with by the DM and will be responded to within a reasonable period no longer than 30 days.
If you are not satisfied with the way your request was handled, you have the right to lodge a complaint with the supervisory authority.
Changes to our privacy policy
If we make changes to our privacy policy we will show you what they are here.  If these changes are significant, we may also choose to email relevant individual with new details.  If we are required by law, we will obtain your consent to make these changes.
External Links
Although this website only looks to include quality, safe and relevant external links, users are advised adopt a policy of caution before clicking any external web links mentioned throughout this website.
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Adverts and Sponsored Links
This website may contain sponsored links and adverts. These will typically be served through our advertising partners, who may have detailed privacy policies relating directly to the adverts they serve.
Clicking on any such adverts will send you to the advertiser's website through a referral programme which may use cookies and will track the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computer's hard drive. Users should therefore note they click on sponsored external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons, which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages.
Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Resources & Further Information
   • https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio...
   • Privacy and Electronic Communications Regulations 2003
   • Privacy and Electronic Communications Regulations 2003 - The Guide
   • Twitter Privacy Policy
   • Facebook Privacy Policy
   • Google Privacy Policy
   • Linkedin Privacy Policy
   • Mailchimp Privacy Policy
   • Fillable PDF Forms Creation
   • Website Privacy Policy Template
v.3.0 May 2018 Edited & customised by: Giardinoweb

End of Privacy Policy.

Hortoflora by SE.A.C.
Via G.B.Vico, n 96
Ischia (NA)
tel 081984777
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