PRIVACY POLICY ON THE PROTECTION OF PERSONAL DATA AND THE USE OF COOKIES UNDER REGULATION (EU) 2016/679 (“GDPR”)

Dear Customer,

the company Studio PDM cw ith registered office in Via Birago 5, 19125 in La spezia (SP) (hereinafter, the “Company”), is the Data Controller of the data you provide when registering on the site, or otherwise acquired when providing the services you may access. You can send inquiries or communications to the Holder at the email address info@studiopdm.it

Access to the site does not require you to enter your personal information. For the possible use of the online service ‘contacts’ and to have access to other additional services, you will have to enter your personal data in appropriate sections of the site.

The data entered will be processed with security measures appropriate to current technological standards and in compliance with the obligations under the Data Protection Regulation (EU) 2016/679 (“GDPR”).

According to the indicated regulations, such processing will be based on the principles of fairness, lawfulness and transparency and protection of your privacy and rights. The following disclosure relates only to this site and does not cover other sites

web possibly consulted by the user through redirecting links placed in the pages of our site. No data from consulting the Web service is disclosed or diffused.

Therefore, in accordance with Article 13 of the GDPR, we are providing you with the following information:

The Company collects and processes your personal data for financial purposes necessary or instrumental to the provision of services by you1.

requested and provided through this site, including through communication of data to third party companies referred to in Art. 5

of this information (appointed by the Company as data processors) for the purpose of technical and administrative management of the services. Your data may be processed for the internal financial purposes of compiling master lists, bookkeeping, invoicing, creditor management for the fulfillment of all obligations under current regulations, statistical purposes, for communications, and additional services explicitly requested by you.

The legal bases for processing, as the case may be, may be your consent, the performance of a contract to which you are a party or the fulfillment of legal obligations to which the Company is subject as the Data Controller.

The processing of your data may also take place:

(a) to send you information and commercial offerte of services similar to those you purchased when accessing the Site, unless you object to this processing by sending an email to the email address info@speziacarrara.cruises and where you give your express consent,

(b) to send information and commercial offerte, advertising and informative material, effcarry out commercial communications, including interactive ones, carry out direct sales or placement activities of products or services, including those of third parties.

Processing will be effcarried out both manually and using electronic tools, observing all necessary precautions to ensure the security and confidentiality of the information.

Your data may be processed within our Company by all data processors appointed in writing by the Data Controller and trained on the obligations of the Privacy Act.

Data may be disclosed to third parties, solely for technical and operational needs strictly5.

related to the finities listed above and in particular to the following categories of subjects: (a) Entities, professionals, companies or other structures entrusted by us with the processing related to the fulfillment of administrative, accounting, commercial and management obligations connected with the ordinary course of our economic activity, including for finality of credit recovery; (b) To public authorities and administrations for financial purposes related to the fulfillment of legal obligations; (c) Banks, financial institutions or other entities to which the transfer of data is necessary for the finance of our Company’s activities, particularly in connection with the performance by us of contractual obligations assumed towards you.

Your personal data will be stored in the servers available to the Company located in the European Union. The Company does not effect transfers of personal data to countries outside the European Union. Personal data about you will be kept for as long as your contractual relationship with the Company lasts. After the termination of the contractual relationship, the Company will retain personal data related to the performance of the contract for the fulfillment of contractual and legal obligations, including fiscal obligations.

Thereafter, personal data related to the performance of the contract will be retained for a period not exceeding the statutory limitation period for possibly asserting or defending a right in court.

The provision of your personal data is optional, it being understood that the refile to disclose your data or to give your consent to the processing referred to in point 1 of this disclosure will result in our inability to

To conclude the contract and provide any services requested and to fulfill legal obligations. In case of refile of personal data processing under Art. 2 of this notice, the processing will be limited to the full performance of obligations arising from the provision of the services you have requested, as well as the fulfillment of obligations under laws, regulations and EU legislation.

The Data Controller is GIANLUCA DE ZAN, with registered office in via Birago 5, 19125 La Spezia (SP). A list of any data processors is available from the uffici of the Data Controller and can be obtained by sending an email to. info@studiopdm.it

You may exercise your rights against the Data Controller at any time, pursuant to Articles 15-2210.

GDPR, which for your convenience we summarize below. In particular, you have the right:

to obtain the cessation of processing in cases where your personal data are processed for direct marketing files, including in relation to services identical to those already purchased from our Company (so-called right to object);

to obtain information regarding the finities for which your personal data are processed, the period of processing, and the parties to whom the data are disclosed (so-called right of access);

To obtain the rectification or supplementation of inaccurate personal data concerning you (so-called right of rectification);

To obtain the deletion of personal data concerning you in the following cases (a) the data are no longer needed for the fixed purposes for which they were collected; (b) You have withdrawn your consent to the processing of the

data if they are processed on the basis of your consent; (c) You have objected to the processing of personal data about you where it is processed for our legitimate interest; or (d) the processing of your personal data does not comply with the law. However, we point out that the retention of personal data by the Company is lawful if it is necessary to enable it to fulfill a legal obligation or to establish, exercise, or defend a right in court (so-called right of erasure);

To obtain that personal data concerning you be only retained without any other use of them in the following cases (a) You challenge the accuracy of personal data, for the period necessary for us to verifiy the accuracy of such personal data; (b) the processing is unlawful but you still object to the deletion of personal data by us; (c) personal data are necessary for the establishment, exercise or defense of a legal claim; (d) You have objected to the processing and are awaiting verification as to whether our legitimate grounds for processing outweigh those of the data subject (so-called right of limitation);

to receive in a commonly used, machine-readable and interoperable format personal data about you processed by automated means, if they are processed under contract or on the basis of your consent (so-called right of portability).

We also remind you that you have the right to apply to the Guarantor for the Protection of Personal Data (Piazza di Monte Citorio, 121 – 00186 Rome RM) to assert your rights in relation to the processing of your personal data.

Use of cookies

Cookies are small text strings that sites visited by the user send to the user’s terminal (usually the browser), where they are stored and then transmitted back to the same sites on the next visit by the same user.

In the course of browsing a site, the user may also receive cookies on his or her terminal that are sent from different sites or web servers (so-called “third parties”), on which some elements (such as, for example, images, maps, sounds, specific links to pages of other domains) present on the site the same is visiting may reside. The website www.speziacarrara.cruises (hereinafter, the “Site”) uses cookies to make its services simple and efficient for users viewing the pages of the Site.

Users viewing the Site, will see minimal amounts of information placed on the devices in use, whether computers or mobile devices, in small text files called “cookies” saved in directories used by the User’s web browser. There are various types of cookies, some to make the use of the Site more efficacious, others to enable certain features. By analyzing them in detail, our cookies allow you to:

• Store the preferences entered by the visitor;

• Avoid re-entering the same information multiple times during the visit, such as user name and password;

The processing is effperformed by the Owner using automated tools. With the exception of technical cookies, which are strictly necessary for normal browsing, the provision of data is left to the will of the visitor who decides to browse the Site after having read the short-form information (so-called banner) and to take advantage of the services that involve the installation of cookies. Therefore, the user can avoid the installation of cookies, except for technical cookies, by refraining from taking any action at the banner or through the appropriate functions available on the different browsers, described in detail in this policy.

Types of Cookies Used by the Site

Technical Cookies (required)

This type of cookie allows certain sections of the Site to function properly. They fall into two categories:

persistent and sessional:

persistent: once the browser is closed, they are not destroyed but remain fixed until a preset expiration date;

of sessions: are destroyed whenever the browser is closed.

These cookies, always sent from our domain, are necessary to properly display the site and in relation to the technical services offerti, they will therefore always be used and sent, unless the user changes the settings in their browser (thus inficiating certain features or the display of pages on the site).

Analytical cookies

Cookies in this category are used to collect information about site usage. The Site will use this information with regard to anonymous statistical analysis in order to improve the use of the Site and to make the content more interesting and relevant to users’ desires. This type of cookie collects data anonymously about user activity and how they arrived at the Site. Analytical cookies are sent from the Site itself or from third-party domains.

The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) . The information generated by the cookies about your use of the website (including your IP address in an anonymous form) will be transmitted to and stored on Google’s servers. Google will use this information for the purpose of examining your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required by law or where such third parties process this information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You can refit from using cookies by selecting the appropriate setting on your browser, but note that doing so may affect your ability to enjoy certain features of this website. By using this website, you consent to the processing of your data by Google in the manner and for the fixed purposes stated above. You can prevent Google from tracking a cookie that is generated by your use of this website (including your IP address) and processing that data by downloading and installing the browser plugin available at the following web address:

http://tools.google.com/dlpage/gaoptout?hl=en

Analytics cookies from third-party services

These cookies are used for the fine purpose of collecting information about users’ use of the Site in an anonymous form such as: pages visited, dwell time, traffico origins, geographic provenance, age, gender, and interests for the finance of marketing campaigns. These cookies are sent from third-party domains external to the Site.

This type of cookie integrates functionality developed by third parties within the pages of the Site such as icons and preferences expressed in social networks for the fine purpose of sharing content on the site or for the use of third-party software services (such as software to generate maps and additional software that offrono additional services). These cookies are sent from third-party domains and partner sites that offrono their functionality between the pages of the Site.

Pixel markers

This website may use “pixel markers,” which are small graphical files that allow you to track your use of the website. A pixel marker is capable of collecting information such as the IP (Internet protocol) address of the computer that downloaded the page where the marker appears; the URL (Uniform Resource Locator) of the page where the pixel marker appears; the time the page containing the pixel marker was viewed; the type of browser that picked up the pixel marker; and the identification number of any cookies on the computer and previously placed by that server. When exchanging correspondence with users via e-mail messages that support HTML format, “format detection” technology may be used, which allows pixel markers to communicate whether the other party has received and opened the message.

Profilation cookies

These are those cookies necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the Site.

The Site, according to current regulations, is not required to seek consent for technical and analytics cookies that do not allow the user to be identified, as they are necessary to provide the services requested. For all other types of cookies, consent may be expressed by the User in one or more of the following ways:

• By expressly accepting and revoking consent to the use of cookies within the Site. Click here.
• By specific configurations of the browser used or related computer programs used to navigate the pages that make up the Site. Click here.
• By modification of settings in the use of third-party services. Click here.

Last updated June 2022