This statement only concerns the website of "TENUTA ESPADA" and not other web sites that may be consulted by the user through the link.

THE DATA CONTROLLER

Following consultation of this site may be processed data on persons identified or identifiable.

The "holder" of their treatment is "TENUTA ESPADA", with legal and operational headquarters in SP52 GALLIPOLI (LECCE) 73017 ITALY

The personal data indicated on this page are processed by "TENUTA ESPADA", for the performance of its activities. Consent, execution of a contract, fulfillment of a legal obligation as well as the pursuit of a legitimate interest are the legal bases that, depending on the data processing carried out on the above-mentioned website, will be pursued.

PLACE OF DATA PROCESSING

The processing operations connected to the web services of this website are carried out in Italy and are managed by the service provider SingleHop and are carried out by technical personnel of Spring Marketing and by others charged by "TENUTA ESPADA" with the task of updating and maintenance. No data deriving from the web service is disseminated. The personal data provided voluntarily by users who send contact requests are used only to perform the service or provision requested also possibly through external service providers.

TYPES OF DATA PROCESSED AND PURPOSES OF PROCESSING

Navigation data

The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the communication protocols of the Internet.

This category of data includes IP addresses or domain names of computers and terminals used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment.

These data, necessary for the use of web services, are also processed for the purpose of:

• Obtain statistical information on the use of services (most visited pages, number of visitors per hour or per day, geographical areas of origin, etc.);
• Check the correct functioning of the services

Data provided by the user

The optional, explicit and voluntary sending of messages to the contact addresses of "TENUTA ESPADA", as well as the completion and submission of forms on the site https://www.tenutaespada.it entail the acquisition of the sender's contact details, necessary for replying, and any other personal data included in the communication.

Specific information will be published in the pages of the site https://www.tenutaespada.it prepared for the provision of certain services.

Cookies and other tracking systems

We do not use cookies for user profiling.

On the other hand, session cookies (not persistent) are used strictly limited to what is necessary for the safe and efficient navigation of the sites. The memorization of the session cookies in the terminals or in the browser is under the control of the user, whereas on the server, at the end of the HTTP sessions, information related to the cookies remain recorded in the logs of the services, with retention times specific to each third party manager of the service. Any data acquired through cookies, and how they are managed, are described in full in the document "cookie policy".

OPTIONALITY OF CONFERRING DATA

Apart from that specified for navigation data, the user is free to provide personal data contained in the application forms to "TENUTA ESPADA" any time you request such data will be provided specific information and, where necessary required consent.

MODE OF TREATMENT

Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are taken to prevent data loss, illegal or incorrect use and unauthorized access. We inform you that, in order to provide a complete service, there are links to other websites operated by other owners. We disclaim any responsibility in case of errors, content, cookies, publications of immoral or illicit content, advertising, banners or files that do not comply with the regulations in force and the respect of the Privacy legislation by sites not managed by us to which reference is made.

DATA RECIPIENTS

The recipients of the data collected following consultation of the site listed above are the following subjects designated by

"TENUTA ESPADA", pursuant to article 28 of the Regulation, as data processors.

• Spring Marketing as the provider of web platform development and maintenance services;
•                                                         in relation to the site as a provider of services for the development, delivery and operational management of technology platforms

The personal data collected will also be processed by the staff of "TENUTA ESPADA", who will act on the basis of specific instructions given as to the purposes and methods of the processing.

Data transfer abroad

The controller uses data processors located in non-EU countries, in particular: with guarantee of adoption of measures such as Standard Contractual Clauses, in the case of U.S. adherence to the international agreement Privacy Shield, or with the consent of those concerned.

RIGHTS OF THE INTERESTED PARTIES

You have the right to obtain from the owner the cancellation (possible right to be forgotten), the limitation, the updating, the rectification, the portability, the opposition to the processing of personal data concerning you, as well as in general you can exercise all the rights provided by Articles 15, 16, 17, 18, 19, 20, 21, 22 of the GDPR, where applicable with respect to the purposes of data processing.

REG.TO UE 2016/679: ARTT. 15, 16, 17, 18, 19, 20, 21, 22 –

1. The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet recorded, and their communication in form

2. The interested party has the right to obtain the indication:
3. the origin of the personal data;
4. the purposes and methods of processing;
5. the logic applied in case of treatment with the aid of electronic instruments;
6. the identification details of the owner, the persons responsible and the representative appointed under article 5, paragraph 2;
7. of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State's territory, data processor(s) or person(s) in charge of the processing, or

3. The interested party has the right to obtain:
4. updating, rectification or, when interested, integration of data;
5. 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;
6. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
7. the portability of data

4. The interested party has the right to object, in whole or in part:
5. for legitimate reasons to the processing of personal data concerning him, even if pertinent to the purpose of collection;
6. to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

RIGHT TO COMPLAIN

Interested parties who believe that the processing of personal data relating to them carried out through this site is in violation of the provisions of the Regulation have the right to lodge a complaint with the Guarantor, as provided for in art. 77 of the Regulation itself, or to take legal action (art. 79 of the Regulation).