Information provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and Legislative Decree 196/2003 (“Privacy Code”), as amended by Legislative Decree 101/2018, to those who visit the website italianoconangela.com and to those who contact the Data Controller.
1. Data Controller
Angela Provenzali – “Italiano con Angela”
Via Campo all'Aia, 155 – 57030 Procchio, Marciana (LI)
Tax Code: PRVNGL69R43G912P
Email: angelapro@gmail.com – Tel./WhatsApp: +39 333 303 6822
No Data Protection Officer (DPO) has been appointed, as it is not mandatory for the activity carried out.
2. Data processed, purposes and legal bases
a) Browsing data
The systems that make the website work acquire, in normal operation, some technical data (IP address, browser type, date and time of the request, pages visited). They are used to ensure the functioning and security of the site. Legal basis: legitimate interest of the Controller (Art. 6.1.f GDPR). They are kept for the strictly necessary time and in any case no longer than 30 days, except for the investigation of crimes.
b) Contacts via WhatsApp, email and phone
If you write to the Controller via WhatsApp, email or phone, your phone number or email address, name and the information you choose to share will be processed, to respond to your requests, prepare quotes and organise lessons or stays. Legal basis: performance of pre-contractual measures or a contract at your request (Art. 6.1.b GDPR).
By clicking on the WhatsApp buttons you will be directed to the WhatsApp service, provided by WhatsApp Ireland Ltd (Meta group), which processes data as an independent controller according to its own privacy policy.
c) Clients: lessons and rentals
For those who purchase lessons or book an apartment, personal data, contact details and payment information are processed for the performance of the contract (Art. 6.1.b), to comply with tax and accounting legal obligations and, for apartment guests, for communication to the Police Headquarters via the “Alloggiati Web” portal (Art. 109 TULPS), for the tourist tax and for regional statistical communications (Art. 6.1.c GDPR).
d) Statistics (Google Analytics)
Only with your consent (Art. 6.1.a GDPR and Art. 122 of the Privacy Code), the site uses Google Analytics 4 to collect aggregate statistics on visits. Details in the Cookie Policy.
e) Reserved area
The site administration area is reserved for the Controller: the access email address is processed only for authentication and security (Art. 6.1.f GDPR).
f) Newsletter
If you choose to subscribe via the form in the footer, your email address and the subscription date are kept to send you updates on Italian lessons and the Island of Elba. Legal basis: your explicit consent (Art. 6.1.a GDPR). You can revoke it and request deletion at any time by writing to angelapro@gmail.com. We do not share subscribers' addresses for third-party commercial purposes.
3. Nature of provision
The provision of data for purposes b) and c) is optional, but without it it is impossible to respond to requests or execute the contract. For purpose c) the provision is mandatory by law. Consents for purposes d) and f) are free and revocable at any time without consequences for other services.
4. Processing methods
Data is processed with computer and paper tools, with appropriate technical and organisational measures to ensure its security and confidentiality. No automated decision-making or profiling is carried out.
5. Recipients
Data may be communicated to: IT service and hosting providers of the site; accountant and consultants for tax compliance; banks and payment institutions; Public Security Authorities and public bodies when required by law. These parties act as data processors (Art. 28 GDPR) or independent controllers. Data is not disclosed or sold.
6. Extra-EU transfers
Some providers (Google, Meta/WhatsApp, hosting providers) may transfer data to the United States. The transfer takes place on the basis of the European Commission adequacy decision of 10 July 2023 (EU-U.S. Data Privacy Framework) for certified companies, or Standard Contractual Clauses (Art. 46 GDPR).
7. Retention periods
- Information requests not followed by a contract: up to 12 months from the last contact.
- Contractual, tax and accounting data: 10 years (Art. 2220 of the Italian Civil Code).
- Guest registration forms: not kept beyond legal obligations.
- Google Analytics statistical data: 14 months.
- Email address of newsletter subscribers: until consent is revoked or deletion is requested.
8. Your rights
Pursuant to Articles 15–22 GDPR you can request at any time access to your data, rectification, erasure, restriction of processing, portability, and object to processing based on legitimate interest. You can withdraw consent at any time, without prejudice to the lawfulness of prior processing. To exercise your rights write to angelapro@gmail.com: you will receive a reply within 30 days.
You also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it), Piazza Venezia 11, 00187 Rome.
9. Minors
For minors under 14, consent and contract signing must be carried out by the person exercising parental responsibility (Art. 2-quinquies of the Privacy Code).
10. Changes
This privacy policy may be updated. The date of the last update is indicated at the top.