INFORMATION ON PERSONAL DATA PROCESSING

Hoverfly Divisione Sam s.r.l., with registered office in via dei Marrucini n. 67– 65127 Pescara p.i. 02113720680, (hereinafter, “Holder”), as data controller inform you pursuant to art. 13 D.Lgs. 30.6.2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 UE Regulation n. 2016/679 (hereinafter, “GDPR”) that you data will be processed in the manner and for the following purposes:

1. Object of the Treatment. The Holder processes personal data, (as name, surname, company name, address, telephone number, e-mail address, bank and payment details) – thereinafter “persona “data” or even “data” – which you gave communicated on the conclusions of contracts for the services of the owner, or following marketing operations.

2. Purpose of treatment. Your personal data are processed:
A) for the following service Purpose: (art. 24 lett. a), b), c) Privacy Code and art. 6 lett. b), e) GDPR),
- conclude contracts for the services of the owner;
- fulfill the pre-contractual, contractual and tax obligations deriving from relations with you;
- fulfill the obligations established by law, by a regulation, by community legislation or by an order of Authority (such as for anti-money laundering);
- exercise the rights of the holder, for example the right to defense in court, or in the preparatory stages to its eventual establishment, from abuses in the use of the same or related services by the User.
B) Only upon your specific and distinct consent (art. 23 and 130 Privacy Code and art. 7 GDPR), per the following Marketing purposes:
- sand you via e-mail, mail and/or sms or/and telephone contacts, newsletter commercial communications, and/or advertising material on products or services, offered by the Holder, and detection of the degree of satisfaction on the quality of services.

Please note if you are already a costumer, we may send you commercial communications relating to services and products of the Holder similar to those you have already used, subject to your disagreement (art. 130 paragraph 4 of the Privacy Code).

3. Method of Treatment The processing of you personal data is carried out by means of operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electric and/or automated processing.
The Holder will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case fo no more than 10 years from the collection of data for the Marketing Purposes.

4. Access to data. Your data may be accessible for the purposes referred in art. 2.A) and 2.B):
- to employees and collaborators of the Holder in Italy and abroad, in their capacity as persons, and/or internal manager of the processing and/or system administrators;
- to third-part companies or other subjects (as an indication , credit institutes, professional firms, consultants, insurance companies for the provision of insurance services, etc) who carry out outsourcing activities on behalf of the Holder, in their capacity on external managers of treatment.

5. Data communication. Without the need of express consent ( art. 24 letter a), b), d) Privacy Code and art. 6 letter b) and c) of the GDPR), the Holder may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies (such as IVASS), judicial authorities, banking institutions, and insurance companies for the provision of insurance services, as well as to those subjects to whom communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controller. Your information will not be diffused.

6. Data transfer. Personal data are stored on servers locate at the headquarters of the owner. In any case, it’s understood that the Holder, if necessary, will have the right to move the servers inside or outside the European Union. In this case, The Holder hereby ensures that the transfer of non- EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of providing data and consequences of refusing to answer. The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we cannot guarantee the service of the art. 2A).
The provision of data for the purposes referred to in art 2B) is optional. You can therefore decide not to give any data or subsequently deny the possibility of processing data already provided; in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services offered by the Data controller . However you will continue to to be entitled to the Services referred to in art. 2A.

8. Rights of the interested party. As an interested party, you have the right set forth in art. 7 of the Privacy Code and art. 15 of the GDPR and precisely the rights of:
i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
ii. get the indication:
a. of the origin of the personal data; b. of the purposes and methods of the processing; c. of the logic applied in case of treatment carried out with the aid of electronic instruments; d. Of the identification details of the owner the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e. the subjects or categories of subjects to whom the personal data may be communicated or who become aware of it in there capacity as designated representative in the territory of the State, managers or agents;
iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations, referred to the letters a and b have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case when this fulfillment proves impossible or involves the use of means that are manifestly disproportionate to the protected right;
iv. oppose in whole or in part: a) for legitimate reasons, the processing of personal data concerning you even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, by e-mail or through traditional marketing methods, telephone and/or mail paper;

It should be noted that the right of opposition of the interested party, set out in point b above, for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition even if only partly. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communicatio9ns or none of the two types of communication.

When applicable, it also has the rights referred to in art. 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of op position) as well as the right of complaint to the Guarantor Authority.

9. Withdrawal of consent. Referred to in art. 23 of the Privacy Code and art. 7 of the GDPR, you can withdraw consent at any time.

10. Modality to exercise rights. You can exercise your rights at any time by sending: - a registered letter to Hoverfly Divisione Sam s.r.l., Via dei Marrucini n. 67– 65127 Pescara;
- an e-mail to: sdc@hoverflysam.it .

11. Holder, managers and agents. The Holder is Hoverfly Divisione Sam s.r.l., with legal office at Via dei Marrucini n. 67– 65127 Pescara (e-mail address: sdc@hoverflysam.it)
The updated list of data processors and data processors is kept at the registered office of the Holder.

12) Changes to the privacy policy. The Holder reserves the right to make changes to this privacy policy at any time by giving notice to Users via e-mail communication, or by accessing the website of the same (www.capri-helicopters.com).