Dear customer, In compliance with Articles 13 and 14 of (EU) Regulation 2016/679 – the General Data Protection Regulation (GDPR ), we are hereby informing you about the processing of your personal data by the 3 Zinnen SPA.
1) Purposes and legal basis of processing: Personal data related to customers (name, surname, image, date of birth, gender, tax code, residence, telephone number, bank data and e-mail address, etc.) provided upon purchase of the ski pass, as well as data collected through the use of the ticket itself (for example when it is used to access lifts) shall be processed by 3 Zinnen SPA. The processing of said data is necessary in order to carry out the pre-contractual activities required to purchase the ticket, to execute the relative contract and provide the relevant services required, to comply with the related regulatory, administrative, accounting and tax obligations, to pursue legitimate interests related to the protection of company assets and possible defensive requirements, as well as to carry out statistical data processing in an anonymous and generalised way in order to develop and improve services. The above-mentioned personal data may be used and reprocessed also for specific services activated by costumers (including, but not limited to: “Performance Check”, on-line purchase and re-charge, etc.), or to pursue legitimate interests related to the verification of the lawful use of the ski pass, including via video-surveillance systems (“Gate Camera”) installed at certain lifts in order to compare the picture provided by the user upon purchase with the images detected during access to said lifts, or to examine any refund requests.
2) Categories of recipients of personal data: Your data will be processed for the above purposes using mainly computerised procedures by 3 Zinnen SPA. Moreover, they may be disclosed to other persons working on behalf of the above mentioned recipients who are authorised to process data and to trusted companies carrying out, in their capacity as data processors, various technical or organisational activities on behalf of the above mentioned recipients, such as companies providing administrative, accounting, tax or IT services.
3) Personal data retention period: The data collected shall be retained for the entire duration of the contractual relationship. The data related to the purchase and use of the ticket shall be anonymised within 24 months from the conclusion of the contract and your personal data shall be deleted. If a new ticket is purchased within the above period, the retention period shall recommence from the additional purchase. With specific reference solely to data acquired from the documents provided by customers wishing to obtain reductions in relation to the purchase of ski-passes (e.g. junior, senior, baby discounts, etc.) or refunds of the price of the purchased ticket subject to Article 14 of the General Sales Conditions, such data shall be retained for the time required to comply with the administrative and tax regulations. The images acquired upon access to the lifts equipped with “Gate Camera” video-surveillance systems shall be deleted at the end of the card’s validity period.
4) Provision of data and mandatory nature of consent: the provision of your data is necessary in order to purchase the ski pass and execute the related contract; any refusal to provide such data will therefore mean that it is not possible to conclude the contract or supply the services.
5) Exercise of rights: the GDPR provides the right to access the data related to yourself at any time and to obtain a copy thereof, to correct and supplement them where they are inaccurate or incomplete, to delete them or limit their processing where the necessary conditions are met, to object to processing for reasons related to your specific situation, to request the portability of the data provided where processed in an automated way based on your consent or for the execution of the contract. Likewise, where required, you are entitled to withdraw your consent without prejudice to the lawfulness of the processing based on the consent granted before such withdrawal. The above is without prejudice to your right to petition the Supervisory Authority, including by the filing of a complaint where deemed necessary, for the protection of your personal data and your rights. For any issue related to the processing of your personal data, please contact the 3 Zinnen SPA at: email@example.com.
6) Data protection officer: The data protection officer of the 3 Zinnen SPA (hereinafter DPO) can be contacted at the data controller’s address as well as directly via e-mail at the following address: firstname.lastname@example.org. For more information please visit our website https://www.dreizinnen.com/privacy.
7) Sending of commercial information related to the services offered: Your personal data (name, contact details, e-mail address, mobile phone number) may also be processed, subject to your consent, to send you information related to products or services provided by the 3 Zinnen AG (for example newsletters, promotional and advertising material), or notices of local events organized in the holiday region 3 Zinnen Dolomites by means of e-mail, SMS, MMS, fax, messages to web applications and/or on paper by post, as well as for direct sale and market research purposes, including research related to service quality and satisfaction, via remote communication techniques that use conventional and automated contact methods by means of the above tools. Our mailing service may also be provided with the technical support of third-party companies in their capacity as data processors, to which addresses or mobile phone numbers may be disclosed solely for said purpose; they may not be used otherwise. Your data shall be used until your objection; they shall subsequently be deleted. The disclosure of your data and your consent for the above purposes are optional and their non-disclosure does not affect existing relations and services. However, in their absence, we shall not be able to send you updates and promotions related to new products and services that might be of interest to you.