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Information for communication and marketing activities

Statement pursuant to Articles 13 and 14 of EU Regulation 2016/679 Relating to processing carried out for communication and marketing activities

Ultimo aggiornamento: February 4th, 2025

Our work philosophy is always to approach the customer with information deemed to be of actual interest, avoiding invasive or insistent actions that would conflict with our goal of informing and supporting our customers in making the best choices for their own purposes. This document provides information on the processing carried out for communication and marketing activities by the HUMAN COMPANY Group.

  1. Data Controller
    The Data Controllers in question are the companies of the HUMAN COMPANY Group, in particular:

hu holding srl registered office: Via Generale C. A. Dalla Chiesa 13 - 50136 Florence, Italy - Contact details of the Data Protection Officer: [email protected]
Elite Vacanze Gestioni Srl with registered office in Figline e Incisa Valdarno (FI), Via Norcenni 7, tax code/VAT no. 06196120486 - Contact details of the Data Protection Officer: [email protected]
and its subsidiaries:

• hu OPENAIR S.r.l. (P. IVA 00282740976) Real estate holding and Management holding of hu Norcenni Girasole village, hu Park Albatros village, hu Montescudaio village, hu Venezia Camping in Town, hu Altomincio village, Plus Florence, hu Firenze camping in town, Firenze Certosa camping, Tour operator Norcenni Tour, hu at Pra' delle Torri Camping Village, hu at Union Lido Camping Village, hu at Bella Italia Camping Village, hu at Cisano Camping Village
• Roma Camping S.r.l. (P. IVA 00954081006) - Management of hu I Pini village and hu Roma camping in town
• Roma Gestioni S.r.l. (P. IVA 08219321000) - Management Fabulous village
• Società Agricola Le Driadi S.r.l. (P. IVA 05627800484) - Management Palagina la cascina
• Tiber S.r.l. (P. IVA 00995111002) - Management Palagina dimora
• Camping International S.A. (N° TVA: LU13005324) management of hu Birkelt village – Luxembourg
below all defined together “HUMAN COMPANY”

  1. Data processed and its origin
    The contact details used to send this communication were acquired directly from the data subject themselves, or from parties authorised by them, at the time of the data subject's previous contact with one of the Human Company facilities.

Furthermore, any information acquired during subsequent contact with the data subject and interviews/market surveys carried out by any means (paper questionnaires, phone interviews, completion of online forms, etc.) may be processed.

  1. Purpose of the processing and legal basis() of the processing
    (
    ) the "legal bases" are the conditions of lawfulness indicated by EU Regulation 2016/679, Articles 6 and 9, in other words the categories of purposes recognised as lawful
    The purposes of the processing referred to in this statement are:
    a. making first contact in order to request an expression of interest from data subjects and to comply with the obligations imposed by the legislation on the protection of personal data - legal basis(*): -legal- fulfilment [Article 6, paragraph 1, letter c, EU Regulation 2016/679]
    b. commercial activity: marketing, advertising, promotional activities. In particular, contact details, postal and email addresses may be used to send courtesy communications and/or promotional/information material about HUMAN COMPANY's products and commercial initiatives - legal basis: legitimate interest consisting in processing, for direct marketing purposes, the email address used by the data subject to purchase a product or service from HUMAN COMPANY [Article 6, paragraph 1, letter f - Italian Legislative Decree 196/2003, Article 130, paragraph 4] – with regard to other addresses: consent of the data subject [Article 6, paragraph 1, letter a, EU Regulation 2016/679].
    d. conducting market surveys to improve our products/services - legal basis: legitimate interest coinciding with the purpose [Article 6, paragraph 1, letter f, EU Regulation 2016/679]
    f. satisfying requests for information from data subjects - legal basis: legitimate interest of the data subject coinciding with the subject of the request [Article 6, paragraph 1, letter f, EU Regulation 2016/679].

  2. Methods of data processing and storage
    In relation to the aforementioned purposes, the personal data may be processed, including when managed on behalf of other data controllers by hu holding SRL, with paper, IT and telematic tools. This will always be done ensuring utter confidentiality and relevance, and not exceeding the purposes described above in terms of data recording and retention periods.

The email addresses and other contact details for which the data subject has granted use, including for commercial purposes, will be processed and stored for 12 months following the last sending/contact vis-à-vis the data subject or the revocation of consent; in the latter case, for data subjects with no contractual relationship with the Data Controller, in order to satisfy the data subject's request and not repeat unwanted communications even incidentally.

  1. Data processors and appointees
    For the same purposes, the data may be processed by the following categories of appointees and/or data processors:
  • commercial and IT systems management staff
  • our external consultants or suppliers involved in the above activities, appointed as data processors (Article 28, EU Regulation 2016/679) or designated appointees (Article 28, EU Regulation 2016/679)
  1. Who the data may be communicated to
    The personal data in question may always be communicated within the European Union:
  • to our consultants, within the limits necessary to carry out their assignment at our Company, subject to our letter of appointment which imposes the duty of confidentiality and security
  • to other entities who need to access the data for purposes related to organising events or conducting market surveys
    who will have full control of the processing carried out at their own facilities.
    Naturally, all the communication described above is limited only to the data necessary for the recipient to carry out their duties and/or to achieve the purposes connected to the communication itself.
  1. Provision of data and consent
    Communicating and updating your data, as well as consenting to its processing, are obviously optional.
    Not doing so will have no consequence except that the data subject will not be involved in the initiatives promoted by HUMAN COMPANY. It should be noted that any consent given may be revoked at any time without prejudice to the lawfulness of the processing carried out before the revocation.

  2. Rights of the data subject - Contacts
    The data subject has the right:

to ask the Data Controller to access and rectify or erase personal data (where no longer necessary; incomplete, incorrect or collected in breach of the law) or limit the processing of personal data concerning them and oppose its processing
where the processing is carried out by automated (computer) means and to the extent technically possible, to receive any information concerning it in a structured format or have it sent to them or to third parties indicated by them
to withdraw consent at any time (without prejudice to the lawfulness of the processing based on consent prior to withdrawal), obviously for processing performed on this basis
if the response to their requests is unsatisfactory or if they deem it necessary, to lodge a complaint with the Italian Personal Data Protection Authority (http://www.garanteprivacy.it/) To exercise their rights, data subjects may send a communication to [email protected], bearing in mind that it will not be possible to respond to requests received by phone if there is uncertainty about the applicant's identity.