Information regarding the handling of personal information

Information regarding the handling of personal information

If you come into contact with Turismo Torino e Provincia s.c.r.l. you may be asked for some personal information. For this reason, we would like to provide you with the following information:

Data Controller’s identity
The Data Controller for data subjects’ personal information is the President of Turismo Torino e Provincia s.c.r.l. with offices in via Maria Vittoria 19 – 10123 Turin.

Contact information for the Data Protection Manager (RPD)
The Data Controller has appointed the Data Protection Manager, who can be contact at the Data Controller’s offices, or via the email address dpo@turismotorino.org

Information recipients
Your personal information handled by the Controller are not divulged, i.e. is not provided to unspecified subjects in any possible form, including being made available or simple consultation. The information may be communicated to workers who are employed by the Controller and to some external subjects who collaborate with them. It may also be communicated to members of Turismo Torino e Provincia s.c.r.l., to subsidiaries and other third parties who are a part of the Turin and province tourist promotion system. It may also, within the strictly necessary limits, be communicated to subjects who must provide goods for the purpose of processing your requests, or to carry out services requested by the Controller. Lastly, it may be communicated to subjects with the right to access said information due to legislation, regulations or EU legislation. In particular, based on the roles and working duties carried out, workers are authorised to handle your personal information, within the limits of their responsibilities and in compliance with the instructions given to them by the Data Controller. External parties who work under the Controller’s authority may also have been authorised to handle information based on the type of service they provide, the handling carried out and the nature of the information handled. External parties to whom the Controller entrusted the handling of personal information have been appointed as Data Processors.

Information Transfer
The Data Controller will not transfer your personal information to other countries or international organisations for any reason. However, we reserve the right to use cloud services; in which case, the service providers will be selected from among those who provide suitable guarantees, as provided for in article 46 GDPR 679/16.

Information storage
The Data Controller stores and handles your personal information for the time required to fulfil the purposes stated. Subsequently, personal data will be stored, and not handled further, for the time set by the current provisions in civil and taxation law.

Data subject’s rights
In reference to articles 15 – right of access, 16 - right to rectification, 17 – right to erasure , 18 – right to restriction of processing, 20 – right to portability, 21 – right to object, 22 right to object to the automated decision-making process of the GDPR 679/16, you can exercise your rights by writing to the Data Controller at the address provided above, or by email to the address dpo@turismotorino.org, specifying the subject of your request, the right you intend to exercise and attaching the photocopy of an ID document that certifies the legitimacy of your request. Further information about the data subject’s right can be found at the bottom of this section.

Complaint proposition
Each of you has the right to propose a complaint to the control authority for residency status.

Automated decision-making processes
The Data Controller does not handle information in any case that consists of automated decision-making processes about your data.

If you go to a Turismo Torino e Provincia s.c.r.l. Information Point, or if you are in the city, visiting an exhibition, museum or any other place of interest, you may be asked to fill out an information request form. In this case:
Information source: The personal information handled is the information you provided by filling out the form.
Purpose of data handling: The personal data are handled for:

processing anonymous statistical data about presences;
processing your requests;
sending promotional communications, information and information and commercial material about activities and initiatives promoted by Turismo Torino e Provincia s.c.r.l. and its partners by email.

Legal basis of handling: The legal basis of handling is:

the Data Controller’s legitimate interest for the purpose stated in point 1,
the carrying out of a contractual or pre-contractual obligation for the purpose stated in point 2,
consent, expressed through unmistakable positive action for the purpose as stated in point 3.

Revoking consent: In reference to article 6 of the GDPR 679/16, the data subject can revoke any consent that may have been provided at any time.
Revoking consent will mean that no information and communications will be sent via email.
Refusal to provide information: Filling out the form is voluntary, therefore refusing to provide information will have no consequences other than limiting the processing of any of your requests.

You ma also meet one of our interviewers. In this case, you must know that:
Information source: The data are collected in anonymous format. The only personal information handled are the ones freely provided by you if you wish to receive communications and information from the Data Controller.
Purpose of data handling The personal data are handled for:

Process anonymous statistical data about presences;
sending promotional communications, information and information and commercial material about activities and initiatives promoted by Turismo Torino e Provincia s.c.r.l. and its partners by email.

Legal basis of handling: the legal basis of handling is:

The Data Controller’s legitimate interest for the purposes as stated in point 1,
consent, expressed through unmistakable positive action for the purpose as stated in point 2.

Refusal to provide information: accepting the interview is voluntary, therefore refusing to provide information will have no consequences other than preventing you from receiving our communications.

Lastly, if you visit a Turismo Torino e Provincia s.c.r.l. Information Point, or you go to visit an exhibition or museum, ask to subscribe to the Torino+Piemonte Card. This is what you need to know in this case:
Information source: The personal information handled is the information you provided by filling out the request form.

Purpose of data handling Your personal information is handled for:

processing your request, issuing and delivering the card;
allowing you to benefit from the discounts and advantages reserved for your,
providing a statement of the services used,
sending promotional communications, information and information and commercial material about activities and initiatives promoted by Turismo Torino e Provincia s.c.r.l. and its partners by email.

Legal basis of handling: the legal basis of handling is:

the carrying out of a contractual or pre-contractual obligation for the purpose stated in points 1, 2 and 3;
consent, expressed through unmistakable positive action for the purpose as stated in point 4.

Profiling and automated processing: The Torino+Piemonte Card uses a type of technology that allows the card to be read only if in direct contact with a reader; therefore, the Torino+Piemonte Card is not a localisation or tracking tool.

Revoking consent: in reference to article 6 of the GDPR 679/16, the data subject can revoke any consent that may have been provided at any time.
Revoking consent will mean that no information and communications will be sent via email.

Refusal to provide information: filling out the form is voluntary; however, it is necessary for the Card to be issued, therefore refusing to provide information will prevent any request from being processed.

Therefore, you can interact with Turismo Torino e Provincia s.c.r.l. and its and its sub-levels for many reasons as below by browsing the website, writing an email or telephoning:

requesting information or informational material
request the Torino+Piemonte Card
book a service
request tourist operator service packages
access the photographic archive and request material
request a contact
forward reports and complaints
propose yourselves as guides, interpreters or companions
send your CV spontaneously
subscribe to the newsletter

In these cases, you must know that:

Information source: The personal information handled is the information you provided by making your requests.

Purpose of data handling: The personal data are always handled for:

processing, or following up your requests;
allowing you to benefit from the discounts and advantages reserved for in some situations,
providing statements of the requests made and services used,
sending promotional communications, information and information and commercial material about activities and initiatives promoted by Turismo Torino e Provincia s.c.r.l. and its partners by email.

Legal basis of handling: the legal basis of handling is:

the carrying out of a contractual or pre-contractual obligation for the purpose stated in points 1, 2 and 3;
consent, expressed through unmistakable positive action for the purpose as stated in point 4.

Revoking consent: in reference to article 6 of the GDPR 679/16, the data subject can revoke any consent that may have been provided at any time.
Revoking consent will mean that no information and communications will be sent via email.

Refusing to provide information: Making the requests above, or sending an application, is always on a voluntary basis; however, in some cases, for example subscribing to the Torino+Piemonte Card, proposing candidacies etc, providing data is necessary, therefore refusing to do so could prevent or affect your requests from being processed or followed up.

Further information about information recipients: Personal information acquired by receiving CVs from people who are applying to be guides, interpreters, companions etc, are entered into the Controller’s databank of “candidates” and are processed by our workers for purposes connected with the evaluation and selection of candidates, or for making other offers of work that are consistent with their professional profile. Information may also be communicated to members of Turismo Torino e Provincia s.c.r.l., to subsidiaries and other third parties who are a part of the Turin and province tourist promotion system.

If you are a hotel or in any case an accommodation facility, the details concerning the prices and features of your facilities, potentially with the identification data of the contact persons, will be disseminated by Turismo Torino e Provincia s.c.r.l. and by other designated organisations according to the provisions of art. 4 R.L. no 22 dated 23 February 1995. In this case:
Data source: the processed data are those provided by you when supplying data pursuant to Art. 4 R.L. 22/1995.
Purpose of processing: the data are processed in order to make public the prices and features of the facilities.
Legal basis of processing: the legal basis of the processing is to comply with a rule of law.
Revoking consent: the data subject may revoke any consent possibly provided, at any time, pursuant to art. 6 of the GDPR 679/16. Processing is not based on consent.
Refusal to provide data: data provision is necessary to comply with the Regional Law; the refusal to provide data may therefore prevent or jeopardise data communication.

Lastly, if your browse our website, you should know that:

Data collection: some information is collected anonymously for a better website management and for statistic purposes. The IT system that supports the website, using specific programmes, produces general, anonymous statistics with aggregate data, that are used to establish which information is of greater or lesser interest, to monitor the system’s service and to identify any crisis areas. Also, for reasons of security and to ensure full availability of services for all users, website traffic control software programmes are used to identify unauthorised entry or information alteration attempts, or any attempts of hacking or damage. In order to offer a quality service, the website requires some information from the browser. Browser preferences, login and pages that are frequently used. This information helps you to understand users’ needs better, to offer an improved service.

Using cookies: the Turismo Torino e Provincia s.c.r.l. website uses third party "cookies".

Information confidentiality: Turismo Torino e Provincia s.c.r.l. does not forward any personal identification information or data to third parties, other than for what is strictly necessary to those who intervene as providers of services or to manage contractual relations and consequent administrative obligations.

To contact persons who represent, or who work at our suppliers, or who are themselves suppliers, and who establish relations and communications with the the Data Controller’s organisations, we state that:

Information source: your personal information is collected from you by our employees and collaborators when you visit or make commercial phone calls, direct contact for participation in meetings, seminars, courses, trade fairs, for our requests for bids, order confirmations, sending and subsequent transactions on order confirmation.

Purpose of data handling: The personal information for the above-mentioned people is processing for purposes connected with managing ongoing or under negotiation contractual relations, including activities prepared for contact, stipulation, management and control of relations with our suppliers, and to fulfil obligations and administrative, customs, legal or fiscal duties regarding supplies.

Legal basis of handling: the legal basis of handling is the execution of a contractual or pre-contractual obligation.

Revoking consent: in reference to article 6 of the GDPR 679/16, the data subject can revoke any consent that may have been provided at any time.
Processing is carried out on a different legal basis to that of acquiring consent.

Refusal to provide data: Professional suppliers or individual companies cannot refuse to provide the necessary data for accounts, administrative and fiscal management of contracts or for the provision of services established. The contacts representing or operating at legal entity suppliers can refuse to provide the Controller with their personal data. Providing personal information is however necessary for a correct, efficient management of contractual relations. Therefore, any refusal to provide said information may affect the contractual relationship.

Processing judicial information: in application of specific legislation (for example, but not limited thereto, the Leg. Decree 163/2006, and Presidential Decree 207/2010) we may need to handle “judicial information”, as defined in letter e) of article 4 of Leg. Decree 196/2003, regarding persons who represent or act in the name of and on behalf of suppliers and potential suppliers. In these cases, “judicial data will be handled to fulfil what is strictly provided for in applicable law and subsequently stored in such ways as to prevent involuntary or unauthorised access.

Lastly, we would like to inform all recipients of email that the content of all emails is to be considered as confidential. Therefore, data and information contained in them or in any attachments are for the exclusive use of recipients. People or subjects other than the recipients themselves, also pursuant to article 616 of Criminal Code, are not authorised to read, copy, amend, or diffuse the message to third parties. Anyone receiving one of our communications in error, must not use it and not forward it to anyone, but must delete it from the mail box and inform the sender. The sender’s authenticity and content are not guaranteed, except for digitally signed documents. Also, pursuant to article 13 GDPR 679/16, we would like to inform you that our archives include email addresses for individuals, companies, bodies with which there has been previous email communication or who have spontaneously provided their email address during direct contact. We use these addresses in respect of the wishes and availability of the Data subjects to receive communications via email from our company. We would also like to inform you that all the post boxes at the domain ".....@turismotorino.org" are company boxes and as such, are used for work-related communications. Therefore, for needs connected with operational activities, any incoming or outgoing message may be read by subjects other than the sender and/or recipient.

Listing of data subject’s rights.
Pursuant to GDPR 679/16, the data subject can exercise specific rights by contacting the Data Controller, including: right to access own personal information; right to request rectification of own personal information; right to request erasure of own personal information, right to request restriction of processing of own personal information; right to request data portability; right to submit a complaint to the relevant data protection control authority. We would like to remind you that if the data subject wishes to have more information about the handling of his/her personal information, or to exercise the above rights, he/she can write to the following address dpo@turismotorino.org

If you intend to purchase products (e.g. tourist cards) or book activities/services on the Turismo Torino e Provincia s.c.r.l.'s internet site, you should be aware that:

Data source: personal data provided will be used for the purposes of setting-up, managing, implementing and/or concluding the on-line sales contract.

Purposes of processing: your personal data are processed in order to:

Manage, administer and process product purchases, sales and post-sale services, for example for administrative tasks, accounting and returns, customer support and communication with the user, including via email, for any issue relating to the order's management or subsequent requests relating to the order;
Comply with the obligations imposed by laws, regulations or EU legislation and to lodge or defend ourselves against a legal claim;
Allow you to take advantage of the discounts and benefits you are entitled to in certain situations,
Send information, promotional communications and informative and commercial material by email concerning the activities and initiatives promoted by Turismo Torino e Provincia s.c.r.l. and its partners.

Legal basis for the processing:

The legal basis for the processing is:

The execution of a contractual or pre-contractual obligation for the purposes set out in paragraphs 1, 2 and 3;
Consent, expressed by means of clear affirmative action, for the purposes set out in paragraph 4.

Withdrawal of consent: With reference to Art. 6 of the GDPR 679/16, the data subject may revoke at any time any consent granted. Withdrawal of consent will result in the discontinuation of information and communications sent by email.

Refusal to provide data:

The provision of personal data and consent to their processing is obligatory.

The potential lack of consent will make it impossible to complete the purchase.

Additional information on data recipients:

The user's personal data may be shared with the company responsible for the management of payments and which operates independently in the capacity of data controller in order to provide the user with on-line sales services. In the event of payment by credit card, key information for the transaction's execution (credit/debit card number, expiry date and security code) will be processed by the appointed company without third parties being able to have access to it in any way. However, this information will never be displayed or stored by the vendor.

If the user provides third-party personal data to the Company (for example, of family members, other customers or potential customers), the user is to ensure that these third parties are informed and have authorised the use of their data as described in this Privacy Policy.

REGISTRATION ON THE WEBSITE www.turismotorino.org:

Should you decide to register on the website turismotorino.org, you should be aware that:

Data source: personal data processed are those provided by yourself for the purposes of registering on the website www.turismotorino.org

Purposes of processing: your personal data are processed in order to:

· Create a personal account,

· Finalise the purchasing process,

· Enable the user to view the status of orders and to receive updates on purchases made,

· Change personal settings and update the account, and view the history of requests,

Manage subscription to the newsletter where the user is not registered.

Legal basis for the processing:

The legal basis for the processing is:

The execution of a contractual or pre-contractual obligation for the purposes set out in paragraphs 1, 2 and 3;
Consent, expressed by means of clear affirmative action, for the purposes set out in paragraphs 1 and 5.

Refusal to provide data:

The provision of personal data and consent to their processing is obligatory.

The potential lack of consent will make it impossible to complete the request.

Right of access: each of you has the right to obtain confirmation of the existence or non-existence of personal data regarding yourselves, and in this case, to request access thereto. Access information also includes the purposes for which it is handled, the categories of personal information involved, recipients or categories of recipients to whom personal data has been or will be communicated.
The data subject also has the right to obtain a copy of the personal information undergoing processing. For other requested copies, the Controller can charge a reasonable amount based on administrative expenses.

Right to rectification: each of you has the right to obtain rectification of any incorrect personal data about yourselves. Depending on the purpose of handling, you may have the right to complete your incomplete personal information, also by submitting a supplementary declaration.

Right of deletion ("right to be forgotten"): in certain circumstances, you have the right to have the personal information that concerns you deleted.

Right to limitation of handling: in certain circumstances, you have the right to obtain a limitation of handling of your personal information. In this case, the respective information will be marked and can only be handled by the Controller for certain purposes.

Right to information portability: in certain circumstances, you have the right to receive your personal information, in a commonly used, legible format and you also have the right to send them to another body without impediment.

Information regarding the handling of personal information

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