PRIVACY POLICY ON THE PROTECTION OF PERSONAL DATA
Marco Simone Golf & Country Club Spa, with registered office in Via di Marco Simone 84/88 – Guidonia Montecelio (hereinafter “Owner”), as the Data Controller, informs interested parties pursuant art. 13 D.Lgs. 30.06.2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the following way and for the following purposes:

OBJECT OF THE PROCESSED DATA
The Data Controller processes personal, identifying and non-sensitive data (for example, but not only, name, surname, telephone, e-mail – later, “personal data” or even “data”) communicated when sending the request to view the portfolio at the website https://www.golfmarcosimone.com/ of the Owner (hereafter, “Site”).

PURPOSE OF THE PROCESSING
a) Personal data collected from the interested parties are processed and used directly to manage the request for information.
b) If the interested provides adequate consent, the data may be processed for commercial communication activities or products of the Data Controller, also by telephone and e-mail (newsletter).

INTERACTION WITH SOCIAL NETWORK AND EXTERNAL PLATFORMS
These services allow you to make interactions with social networks, or other external platforms, directly from the pages of this website. The interactions and information acquired from this site are in any case subject to the User’s privacy settings related to each social network. In the case in which a service of interaction with social networks is installed, it is possible that, even if the Users do not use the service, the same collects traffic data relating to the pages in which it is installed.
STATISTICS
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User’s behavior.

VISUALISATION OF CONTENTS FROM EXTERNAL PLATFORMS
This type of service allows you to view the contents hosted on external platforms directly from the pages of this website and to interact with them. If a service of this type is installed, it is possible that, even if the Users do not use the service, the same collects traffic data relating to the pages in which it is installed.

METHOD OF THE PROCESSING
The processing of your personal data is carried out by the means of the 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 is processed using IT procedures, electronic means and the residual on paper, by internal people specifically appointed or by appointed external managers, on the basis of existing contractual agreements.

SECURITY
The data is stored in computerized, telematic archives, and the residual in paper. The Data Controller has taken security measures to protect your data against the risk of loss, misuse or alteration. In particular: has adopted the measures referred to in Articles 32-34 of the Privacy Code and art. 32 GDPR.

STORAGE PERIOD
The Data Controller will process personal data for the necessary time to fulfill the mentioned purposes and in any case for no more than 10 years from data collection.

LOCATION OF THE DATA PROCESSING
The data will be processed by the Data Controller at its registered and operating office.

COMMUNICATION AND INFORMATION DISTRIBUTION
Personal data will not be disclosed by the Data Controller. The communication to third parties, other than the Data Controller, the internal and external person in charge, and by the appointed data processors, is intended for the pursuit of the indicated purposes and in any case within the limits of the same, to third parties and companies, commercial partners, engaged in the correct and regular pursuit of the purposes described. The data provided by the user can be communicated to the subjects for whom there is a duty of communication under the law or a need for communication to assert the right of the company to the bodies in charge. In any case, processing by third parties must be carried out according to accurateness and in compliance with the requirements of the law in force.

For participants of the events and for members of the amateur sports club Marco Simone:
in compliance with Legislative Decree 196/2003 – the Personal data, even of sensitive nature, given at the time of its participation in the events of Marco Simone Golf and Country Club, as well as those collected by the Company subsequently, will be processed exclusively for purposes related to the management and performance of events, to the participation of the interested party in the Company’s activities – promotional events, convivial events and communications of a commercial nature.
The data may be processed using IT tools or by paper as long as if, in both cases, the security measures are compliant to the current laws.
The data may be communicated to the Italian Golf Federation for institutional purposes, to the people responsible of the organization of events in general, to which the interested party intends to participate and to the partner of the Company who will use them for sending promotional material of the goods or services offered by them to the address of the interested person.
Through the web site www.golfmarcosimone.com, other web channels, the social pages of Marco Simone Golf and the press, information, images and videos relating to participation to events in general, may be distributed. In any case, at the end of the competitions and events, Marco Simone Golf and Country Club Spa will keep the images.
Marco Simone Golf & Country Club assumes no responsibility in case of improper and / or illegal use of images made by third parties. In any case, nothing can be claimed, according to the information above, renouncing irrevocably any right, action or claim.

DATA TRANSFER
The Data Controller does not transfer personal data to third countries or to international organizations.

NATURE OF THE CONFERMENT AND CONSEQUENCES REFUSAL TO ANSWER
The conferment of data is optional and is returned to the will of the subject who wants to know the portfolio prepared by the owner. Failure to provide the data strictly necessary for registration, implies the impossibility of following up the same and the consequent use of the services. Data not expressly indicated as mandatory, may be freely granted by the interested parties. The interested party may subsequently deny the possibility to process data already provided: in this case, he / she will not be able to receive any other communication concerning the owner’s portfolio or other commercial communications of the professional activities carried out by the Owner.

RIGHTS OF THE INTERESTED SUBJECT
According to the art. 7 of the Privacy Code and art. 15 GDPR, the interested party can obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in intelligible form. The interested party has the right to obtain the indication:
a) of the origin of 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, of the responsible and of the designated representative according to article 5, paragraph 2 and art. 3, paragraph 1, GDPR;
e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents.
The interested party has the right to 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 in letters a) and b) have been brought to the attention, also about their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right.
The interested subject has the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him / her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him for sending advertising or direct sales material or for carrying out market research or commercial communication. Where applicable, you also have the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

PROCEDURE OF THE EXERCISE OF THE RIGHTS
You can exercise your rights at any time by sending an email to privacy@golfmarcosimone.it

MINORS
This Website and the Services of the Data Controller are not intended for minors under the age of 18 and the Data Controller does not intentionally collect personal information about minors. If information on minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of users.

HOLDER AND RESPONSIBLE PEOPLE OF THE PROCESSING
The owner is Marco Simone Golf & Country Club Spa. The Owner provides the following email address for each communication: privacy@golfmarcosimone.it. The Data Controller maintains an updated list of the appointed managers, and guarantees that the interested party is consulted at the registered office as indicated above.

CHANGES TO THE PRESENT INFORMATIVE
This information may be subject to variations. It is therefore advisable to regularly check this information and refer to the latest version