Privacy Policy

This document contains a section dedicated to Users in the United States and their privacy rights.
This document contains a section dedicated to Users in Switzerland and their privacy rights.
This document contains a section dedicated to Users residing in Brazil and their privacy rights regarding privacy.

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Data Controller La Sirena s.r.l. Via Toledo, 265 80132 – Naples (NA) – IT VAT: IT0650958121 Tax Code: 06509581218

Email address of the Data Controller: info@lasirenafilicudi.com

Types of Data Collected Among the Personal Data collected by this Application, either independently or through third parties, are: Usage Data; Tracking Tools.

Full details on each type of Personal Data collected are provided in the sections dedicated to this Privacy Policy or through specific informational texts displayed before the collection of such Data. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all data requested by this Application is mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from providing such Data, without affecting the availability of the Service or its operation. Users who are unsure about which Data is mandatory are encouraged to contact the Data Controller. The possible use of Cookies—or other tracking tools—by this Application or the owners of third-party services used by this Application is aimed at providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application.

Methods and Location of Data Processing
Processing Methods The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal staff, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data. These external parties may also be appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

Location The Data are processed at the Data Controller’s operational locations and at any other location where the parties involved in the processing are located. For further information, contact the Data Controller. The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the location of the processing, the User may refer to the section related to the details of Personal Data processing.

Retention Period Unless otherwise specified in this document, Personal Data are processed and stored for the time necessary to fulfill the purpose for which they were collected and may be retained for a longer period due to legal obligations or based on the consent of the Users.

Purpose of Data Processing The User’s Data are collected to allow the Data Controller to provide the Service, fulfill legal obligations, respond to requests or actions, protect its own rights and interests (or those of Users or third parties), detect fraudulent or harmful activities, as well as for the following purposes: Displaying content from external platforms.
For detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Details on the processing of Personal Data.”

Details on the Processing of Personal Data Personal Data is collected for the following purposes and using the following services:

This type of service allows the display of content hosted on external platforms directly from the pages of this Application and allows users to interact with it. These services are often referred to as widgets, which are small elements embedded in a website or application. They provide specific information or perform a particular function, and often allow interaction with the user. However, this type of service may still collect data on web traffic related to the pages where the service is installed, even when users do not interact with it.
Google Fonts (Google LLC) Google Fonts is a font style display service managed by Google LLC that allows this Application to integrate such content into its pages. Personal Data processed: Usage Data; Tracking Tools.
Location of processing: United States – Privacy Policy.
Category of Personal Information collected under CCPA: Information related to internet or other network activities.

Cookie Policy This Application uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Further Information for Users Legal Basis for Processing The Data Controller processes Personal Data relating to the User only if one of the following conditions is met:
The User has given consent for one or more specific purposes.
The processing is necessary for the performance of a contract with the User and/or to take pre-contractual measures.
The processing is necessary to comply with a legal obligation to which the Data Controller is subject.
The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
The processing is necessary for the legitimate interests pursued by the Data Controller or by a third party.
It is always possible to ask the Data Controller to clarify the specific legal basis for each processing, and particularly to specify whether the processing is based on the law, stipulated by a contract, or necessary to conclude a contract.

Further Information on Retention Period Unless otherwise specified in this document, Personal Data are processed and stored for the time necessary to fulfill the purpose for which they were collected, and may be retained for a longer period due to legal obligations or based on the consent of the Users.

Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the execution of that contract is completed.
Personal Data collected for legitimate interests of the Data Controller will be retained until that interest is fulfilled. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When processing is based on the User’s consent, the Data Controller may retain the Personal Data longer until the consent is revoked. Additionally, the Data Controller may be obligated to retain the Personal Data for a longer period to comply with a legal obligation or an order from an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, after the retention period has expired, the right to access, deletion, correction, and data portability can no longer be exercised.

User Rights under the General Data Protection Regulation (GDPR) Users may exercise certain rights regarding their Data processed by the Data Controller.
In particular, within the limits set by law, the User has the right to:
Withdraw consent at any time. The User can withdraw consent for the processing of their Personal Data previously given.
Object to the processing of their Data. The User can object to the processing of their Data when it is based on a legal basis other than consent.
Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the processed Data.
Verify and request correction. The User can verify the accuracy of their Data and request updates or corrections.
Obtain the restriction of processing. The User can request the limitation of processing of their Data. In this case, the Data Controller will not process the Data for any other purposes except for their retention.
Obtain the deletion or removal of their Personal Data. The User can request the deletion of their Data by the Data Controller.
Receive their Data or have them transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format, and, where technically feasible, to have them transferred without hindrance to another controller.
Lodge a complaint. The User can lodge a complaint with the competent data protection authority or take legal action.
Users have the right to obtain information regarding the legal basis for the transfer of Data abroad, including to any international organization governed by international law or constituted by two or more countries, such as the United Nations, as well as information on the security measures adopted by the Data Controller to protect their Data.

Details on the Right to Object
When Personal Data are processed for public interest, in the exercise of official authority vested in the Data Controller, or to pursue the legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are also informed that if their Data are processed for direct marketing purposes, they can object to the processing at any time, free of charge, and without providing any reason. If Users object to processing for direct marketing purposes, the Personal Data will no longer be processed for those purposes. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to Exercise Rights Requests to exercise the User’s rights can be addressed to the Data Controller using the contact details provided in this document. The request is free of charge, and the Data Controller will respond as soon as possible, in any case, within one month, providing the User with all the information required by law. Any corrections, deletions, or restrictions of processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User of these recipients if they request it.

Further Information for Users in Switzerland This section applies to Users in Switzerland and, for these Users, overrides any other information that may differ or conflict with what is contained in the privacy policy.
Further details regarding the categories of Data processed, purposes of processing, categories of recipients of Personal Data, if applicable, retention periods, and other information on Personal Data can be found in the section entitled “Detailed Information on the Processing of Personal Data” within this document.

User Rights under the Federal Data Protection Act (Switzerland) Users can exercise certain rights regarding their Data within the limits of the law, including the following:
Right of access to Personal Data.
Right to object to the processing of Personal Data (which also allows Users to request the restriction of processing, deletion, or destruction of Personal Data, or to prohibit the disclosure of Personal Data to third parties).
Right to receive Personal Data and transfer them to another controller (data portability).
Right to request the correction of incorrect Personal Data.

How to Exercise These Rights Requests to exercise the User’s rights can be addressed to the Data Controller using the contact details provided in this document. These requests are free of charge, and the Data Controller will respond as soon as possible, providing Users with the information required by law.

Further Information for Users in Brazil
This section of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity managing this Application and, if applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “our”, or “us”). This section applies to all Users in Brazil (such Users are hereinafter simply referred to as “you”, “your”, “yourselves”), in accordance with the “Lei Geral de Proteção de Dados” (LGPD), and prevails over any other information that may be inconsistent or conflicting with the provisions contained in this privacy policy. In this part of the document, the term “personal information” is used as defined by the LGPD.

Legal Bases Under Which We Process Your Personal Information
We process your personal information only if one of the legal bases for such processing applies. The legal bases are as follows:
Your consent to the specific processing activities in question;
Compliance with legal obligations that we are required to fulfill;
Performance of norms dictated by laws, regulations, or contracts, agreements, or other similar legal instruments;
Research studies conducted by research entities, preferably based on anonymized personal information;
Performance of a contract and related pre-contractual obligations, should you be a party to such contract;
Exercise of our rights in judicial procedures, administrative procedures, or arbitrations;
Protection of your or a third party’s physical safety or integrity;
Protection of health – within the context of procedures carried out by entities or professionals in the healthcare sector;
Our legitimate interest, provided your fundamental rights and freedoms do not prevail over such interests; and
Credit protection.
For further information regarding the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of Personal Information Processed
For details regarding the categories of personal information we process, please refer to the section “Details on the Processing of Personal Data” in this document.

Why We Process Your Personal Information
To learn more about why we process your personal information, please refer to the sections “Details on the Processing of Personal Data” and “Purposes of Processing the Collected Data” in this document.

Your Privacy Rights in Brazil, How to Submit a Request, and How We Will Handle It

Your Privacy Rights in Brazil You have the right to:
Obtain confirmation of the existence of processing activities related to your personal information;
Access your personal information;
Obtain rectification of incomplete, inaccurate, or outdated personal information;
Obtain anonymization, blocking, or deletion of unnecessary or excessive personal information, or information that is processed in violation of the provisions of the LGPD;
Obtain information regarding your right to give or refuse consent and the consequences of your decision;
Obtain information on third parties with whom we share your personal information;
Upon your explicit request, receive the portability of your personal information (except anonymized data) to other service providers, as long as our trade and industrial secrets are safeguarded;
Obtain the deletion of personal information processed based on your consent, unless one or more exceptions provided in Article 16 of the LGPD apply;
Withdraw your consent at any time;
Submit a complaint regarding your personal information to the ANPD (National Data Protection Authority) or a consumer protection agency;
Object to processing activities where such processing is not in accordance with the law;
Request clear and adequate information regarding the criteria and procedures used in automated decision-making processes; and
Request a review of decisions that affect your interests, made exclusively based on automated processing of your personal information. These include decisions related to profiling your personal, professional, consumer, or creditor characteristics, or other aspects of your personality.
You will never be discriminated against or subject to any unfavorable treatment due to the exercise of your rights.

How to Submit a Request
You may submit an explicit request to exercise your rights free of charge at any time using the contact details provided in this document or through your legal representative.

How and Within What Timeframe We Will Handle Your Request
We will make every effort to respond to your request as quickly as possible. In any case, if it is impossible for us to do so, we will ensure that we communicate the factual or legal reasons preventing us from fulfilling your request immediately or taking action on it. If your personal information is not processed by us, we will indicate the natural or legal person to whom you should direct your requests, if we are able to do so.
If you decide to submit a request for access or a request to confirm the existence of personal data processing, please make sure to specify whether you prefer to receive your personal information in electronic or physical format. You must also let us know if you would like an immediate response, in which case you will receive a simplified response, or if you need a full report. In the latter case, we will respond within 15 days of your request, providing all the information regarding the origin of your personal information, confirmation of whether or not such data exist, all criteria used for processing, and the purposes of such processing, while safeguarding our commercial and industrial secrets.
If you decide to submit a request for rectification, deletion, anonymization, or blocking of personal data, we will ensure that we inform the other parties with whom we shared your personal information about your request, so that they can also comply with it—except in cases where such communication is impossible or excessively costly.

Transfer of Personal Information Outside Brazil in Cases Permitted by Law
We may transfer your personal information outside Brazil in the following cases:
When the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as provided by instruments available under international law;
When the transfer is necessary to defend your life or physical safety or that of third parties;
When the transfer is authorized by the ANPD (National Data Protection Authority);
When the transfer is required by a cooperation agreement in the context of international cooperation;
When the transfer is necessary for the exercise of public order or the provision of a public service;
When the transfer is necessary to fulfill a legal obligation, perform a contract and related pre-contractual obligations, or the normal exercise of rights in judicial, administrative, or arbitration proceedings.

Further information for Users in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information.

Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

Personal Information collected or disclosed: Dati di utilizzo, Strumenti di Tracciamento
Purposes:
Visualizzazione di contenuti da piattaforme esterne
Retention period: for the time necessary to fulfill the purpose
Sold or Shared ℹ️: No
Targeted Advertising: ℹ️: No
Third-parties: Google LLC

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.

Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Further Information on the Processing

Defense in Legal Proceedings The User’s Personal Data may be used by the Data Controller in legal proceedings or in preparatory stages for such proceedings, for the defense against abuses in the use of this Application or its related Services by the User. The User acknowledges that the Data Controller may be required to disclose the Data pursuant to a public authority’s order.

Specific Notices Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual notices regarding specific Services, or the collection and processing of Personal Data.

System Logs and Maintenance For operational and maintenance needs, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information Not Contained in This Policy Additional information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.

Changes to This Privacy Policy The Data Controller reserves the right to make changes to this privacy policy at any time, notifying Users on this page and, if technically and legally feasible, sending a notice to Users via one of the contact details held. Therefore, please frequently consult this page, referring to the date of the last modification at the bottom.
If the changes involve processing activities based on consent, the Data Controller will collect the User’s consent again, if necessary.

Personal Data (or Data) / Personal Information (or Information)
Personal data refers to any information that, directly or indirectly, even in connection with other information, including a personal identification number, makes a natural person identified or identifiable.

Sensitive Personal Information
Sensitive Personal Information refers to all Personal Information that is not publicly available and reveals information considered sensitive under applicable privacy laws.

Usage Data
Usage Data is the information collected automatically through this Application (also by third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User to connect to this Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to send the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, browser and operating system characteristics used by the visitor, various temporal details of the visit (e.g., the time spent on each page), and details about the path followed within the Application, with particular reference to the sequence of pages visited, parameters related to the operating system, and the User’s computing environment.

User
The individual using this Application, who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Processor)
The natural person, legal entity, public authority, or any other body that processes personal data on behalf of the Controller, according to what is outlined in this privacy policy.

Data Controller (or Controller)
The natural or legal person, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the tools used, including security measures related to the operation and use of this Application. The Data Controller, unless otherwise specified, is the entity responsible for this Application.

This Application
The hardware or software tool through which the Users’ Personal Data is collected and processed.

Service
The Service provided by this Application as defined in the respective terms (if any) on this website/application.

Sale
Sale refers to any exchange of Personal Information by the Owner to a third party, in exchange for money or for any other valuable consideration, as defined by applicable U.S. state privacy laws. Please note that sharing Personal Information with a service provider under a written contract that meets the applicable legal requirements does not constitute a Sale of your Personal Information.

Sharing
Sharing refers to any disclosure, rental, release, dissemination, making available, transfer, or any other form of communication of the Personal Information of a consumer by the company to a third party for cross-context behavioral advertising, either for monetary or other valuable consideration, including transactions between a business and a third party relating to cross-context behavioral advertising for a business in which no money is exchanged, as defined by California privacy laws. Please note that sharing Personal Information with a service provider under a written contract that meets California privacy law requirements does not constitute sharing the User’s Personal Information.

Targeted Advertising
Targeted advertising refers to the display of advertisements to a consumer where the ad is selected based on the Personal Information obtained from the consumer’s activities over time and across non-affiliated websites or online applications to predict the consumer’s preferences or interests, as defined by applicable U.S. state privacy laws.

European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document refers to all current member states of the European Union and the European Economic Area.

Cookies
Cookies are Tracking Tools consisting of small portions of data stored within the User’s browser.

Tracking Tool
A Tracking Tool refers to any technology—such as Cookies, unique identifiers, web beacons, integrated scripts, e-tags, and fingerprinting—that enables tracking Users, for example by collecting or saving information on the User’s device.

Legal References
This privacy notice is drafted based on multiple legal frameworks.
Unless otherwise specified, this privacy policy applies exclusively to this Application.

Last modified: January 8, 2025

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