Consorzio 3 Zinnen Dolomites (hereinafter referred to as “3 Zinnen”), having its legal headquarters in I-39038 San Candido - Versciaco (BZ), Via Ombrosa 2/F, Italy, in its quality of Data Controller, in compliance with and to the effects of the provisions of article 13 of EU Regulation number 2016/679 – General Data Protection Regulation (hereinafter referred to as “GDPR”), intends to provide information on how the personal data of clients adhering to the Customer Loyalty Scheme, called “Mountain Club”, shall be treated, as better explained in the corresponding Rules.
Clients can subscribe to the Programme online, on the website www.trecime.com/club
- they simply have to fill in the subscription form and to enter the required data. Along with personal data (first name, last name, date of birth, ZIP code, city), clients also have to indicate an e-mail address, which will be used to send a Profile Activation confirmation email, at the end of the subscription procedure. Once the subscription procedure is over, a unique code will be generated. This unique code is connected to the client and it will be associated to their Mountain Club Card. During the registration phase, clients may also connect their Mountain Club Card to their ski pass by entering its numerical code. In case of participation to the “Friend Days”, clients may also indicate the names of friends to be included in the required tickets with a discounted rate.
The afore-mentioned personal data, as well as the personal data acquired with the use of the Card (such as, for example, data related to the purchases made at the 3 Zinnen points of sale, as well at its commercial partners’ points of sale), and, should the connection be activated, the data related to the type of ski pass and the aggregated information related to the number of uses of the ski lifts turnstiles, will be treated by 3 Zinnen for the management of the activities and services included in the “Mountain Club” Programme Rules, in favour of the owners of the Mountain Club Card, including for the provision of dedicated advantages (such as, for example, exclusive gifts, discounts and services). For this aim, treatment of personal data is therefore required in order to be able to carry out the services included in the “Mountain Club” Programme Rules, as well as to fulfil accounting and tax-related obligations in compliance with the provisions of law, and to seek fulfilment of the legitimate interests related to the execution of organizational, administrative and technical activities connected to the execution of services.
Adhesion to the Programme is optional. However, in order to become a member and request the Card, clients need to release certain personal data. Should clients decide not to release such required personal data, they shall not be able to obtain the Mountain Club Card and to take part in the afore-mentioned Programme.
The e-mail address supplied by the client during registration and subscription to the Programme may be used to send newsletters and communications related to services which are similar to those offered by the Mountain Club Programme, save the possibility that the client may opt out immediately or subsequently from the receipt of such communications, by sending an e-mail to the following e-mail address: email@example.com
Furthermore, with the client’s previous consent, to be released by selecting the specific boxes in the required online form, 3 Zinnen may treat the clients’ personal data for the following further reasons: (i) to carry out marketing activities, such as, for example, 3 Zinnen could e-mail further newsletters and promotional communications, offers and discounts to products, services and events related to 3 Zinnen and to other companies (its commercial partners); (ii) to carry out automatized data analysis, in order to define clients’ consumption preferences and habits, with the aim of improving the offer and of customizing commercial communications. For these aims, release of data and of consents is optional and it has no consequences on the client’s subscription to the Mountain Club Card Programme. However, should such data and such consent not be given, 3 Zinnen will not be able to inform and update the clients by e-mail on third party companies’ promotions, discounts and offers for products and services dedicated to the clients or which might be of interest to the clients, thus preventing the clients from taking advantage of those, or making it difficult for clients to use them (in this case, the clients will have to check the website regularly on their own to become aware of such promotions, offers or discounts).
With regards to the afore-mentioned aims, the Mountain Club Cards’ owners’ data will be treated mainly with computer-based procedures, and may be shared with our personnel authorized to treat such data and/or with third party companies we trust which, in their quality of Data Processors, will carry out some technical and organisational activities on our behalf, such as, for example, administrative or accounting services companies, as well as IT companies.
More specifically, 3 Zinnen uses the service called MailChimp to send out newsletters. This service only memorizes the clients’ names and e-mail addresses. Mailchimp is a platform belonging to the Rocket Science Group LLC, a company having its legal headquarters in the United States of America, and which adheres to the EU - US agreement called “Privacy Shield”. Said agreement includes suitable guarantees to safeguard the interested parties in relation to data transfer to companies located in the USA.
The clients’ personal data will be preserved for the entire duration of the client’s subscription to the Mountain Club Programme and, in any case, after its end, such data will be preserved in compliance with the provisions of law for administrative, accounting and tax-related reasons. Data related to detailed expenses and purchases may still be used for twelve months after their registration for profiling aims, and for twenty-four months for direct marketing purposes.
The GDPR guarantees to each client who owns a Card the right to access their own data at any time and to obtain a copy of said data, as well as to update and integrate them, should they be wrong or incomplete, to erase them or to limit their treatment, where requirements are met, to oppose to their treatment, for reasons connected to their particular situation, to request the portability of data supplied when they are treated in an automatized way on the basis of their consent or for the performance of the contract. Clients also have the right to revoke their consent, where required, without prejudice to the legality of treatment based on the consent given before its revocation. Finally, clients have the right to contact the Data Protection Authority, including by means of a complaint, should it be considered necessary, for the protection of their own personal data and of their rights. For any further questions related to the treatment of personal data, clients can contact 3 Zinnen, in its quality of Data Controller, by sending an e-mail to the following e-mail address: firstname.lastname@example.org