INFORMATION NOTICE PURSUANT TO ARTICLE 13 OF EU REGULATION 679/2016

1. Introduction
At MARAVEGE SRL – PENSIONE ACCADEMIA, your privacy and the security of your personal data are of utmost importance. Therefore, we collect and process your data with the utmost care, adopting specific and appropriate technical and organizational measures to ensure full security during processing.
In compliance with Article 13 of the European Regulation 2016/679 (“GDPR” or the “Regulation”) and the Italian Privacy Code (“Privacy Code”), as amended by Legislative Decree 101/2018 (together, the “Legislation”), we inform you that your personal data will be processed in ways that ensure security and confidentiality. Processing will be carried out using paper, IT, and telematic tools, as detailed in this privacy notice.

2. Data Controller
Your personal data is processed by MARAVEGE SRL – PENSIONE ACCADEMIA (hereinafter also referred to as “MARAVEGE SRL” or the “Controller”), headquartered at Fondamenta Bollani 1058, 30123 Venice (Dorsoduro), as the Data Controller under the Regulation.
If you have any questions or requests regarding the processing of your personal data, you may contact the company at any time using the following details:

Data Controller
Company Name: MARAVEGE SRL – PENSIONE ACCADEMIA
Registered Office Address: Fondamenta Bollani 1058 - 30123 Venice (Dorsoduro)
Phone: +39 041 5210188
Email: info@pensioneaccademia.it

3. Type of Data Processed, Purpose, and Legal Basis for Processing
The personal data processed by the Company includes information you provide while navigating or using the online services offered on the website www.pensioneaccademia.it. Examples of data collected include your name, surname, email address, phone number, requests, and browsing data.
The Company does not process special categories of personal data under Article 9 of the GDPR or data relating to criminal convictions and offenses under Article 10 of the GDPR.

Your personal data is processed for the following purposes:

• Enhancing User Experience: To assess your experience using our website and services and ensure the proper functioning of our web pages and content. Processing for this purpose is based on the Controller’s legitimate interest and does not require your explicit consent.
• Compliance with Legal Obligations: To fulfill obligations established by laws, regulations, or EU legislation. Processing for this purpose is necessary to comply with legal obligations and does not require your explicit consent.
• Newsletter Subscription: To manage your subscription to our newsletter. Processing for this purpose is carried out with your specific and free consent.
• Direct Marketing: To carry out promotional activities, including sending newsletters and promotional materials to your email address provided during website registration. Processing for this purpose requires your specific consent unless the communications are about products and/or services similar to those already purchased or subscribed to, for which processing is based on the Controller's legitimate interest.

Personal data is processed exclusively by authorized personnel who have been trained in compliance with privacy regulations and act under precise instructions from the Controller.

4. Data Processors and Recipients
Your personal data may be shared with third parties carefully selected by the Company, which provide adequate guarantees regarding compliance with data protection laws. These entities, if processing data on behalf of MARAVEGE SRL – PENSIONE ACCADEMIA, are appointed as Data Processors pursuant to Article 28 of the GDPR and are required to process data according to the Company's instructions and under its supervision.
Third-party entities may include the following: financial operators, internet service providers, IT service companies, consulting firms, cloud service providers, and publishing companies. Additionally, your data may be shared with third parties operating in fields such as hotel digital marketing in connection with partnership agreements.
A detailed and updated list of such entities is available at the Controller’s office and can be requested by the data subject.
For administrative purposes, your data may also be shared with other companies within the Group. However, your personal data will not be disclosed to third parties for their promotional purposes or distributed in any way.
Your data may also be transmitted to public entities, law enforcement agencies, judicial or administrative authorities, in compliance with legal obligations, for investigating and prosecuting crimes, or for safeguarding public safety.

5. Mandatory or Optional Nature of Data Provision
While providing personal data is voluntary, please note the following:

• Providing data for purposes A) and B) in paragraph 3 is mandatory. Failure to provide such data will make it impossible for the Company to establish any relationship with you or allow access to the website.
• Providing data for purposes C) and D) in paragraph 3 is optional. Failure to provide such data will result in the inability to subscribe to the newsletter or access promotional services offered by the Company.

6. Transfer of Data Outside the EU
Some third parties to whom data is transferred may be located outside the European Union, including in countries where the Company uses cloud services. Such transfers will be made only to countries deemed by the European Commission to provide an adequate level of data protection.
Transfers to third parties located in non-EU countries without adequate data protection levels will occur only with your consent or based on specific agreements (e.g., EU-approved standard contractual clauses) or if necessary for executing a contract or managing your requests.

7. Data Retention
Your data will be stored for a limited period, depending on the processing activity and its purpose:

• Service-related data: Retained for the duration of the service until terminated or unsubscribed.
• Newsletter and promotional data: Retained until the user requests the termination of these activities, and in any case, no later than two years after the last interaction with the Company.

After such periods, your data will be permanently deleted or irreversibly anonymized.

8. Your Rights
Under the GDPR, you have the following rights regarding your personal data:

• Access and Rectification (Articles 15 and 16): Access your data and request corrections or updates.
• Deletion (Article 17): Request deletion of your data under certain conditions.
• Restriction of Processing (Article 18): Request limitation of data processing in specific cases.
• Data Portability (Article 20): Request transfer of your data to another controller.
• Objection (Article 21): Object to processing based on legitimate interest, providing reasons for your request.
• Complaint (Article 77): Lodge a complaint with the competent supervisory authority if you believe your rights have been violated.

To exercise your rights, email info@pensioneaccademia.it or write to MARAVEGE SRL – PENSIONE ACCADEMIA, Fondamenta Bollani 1058, 30123 Venice (Dorsoduro), Italy.

9. Security Measures
The Company adopts appropriate technical, logistical, and organizational measures to ensure the confidentiality, integrity, and security of your personal data. This includes measures to prevent unauthorized access, accidental data loss, or misuse.
However, the Company is not responsible for incorrect or fraudulent information provided directly by the user (e.g., incorrect email address).

10. Changes to This Privacy Policy
The Company may modify this privacy policy over time, particularly to comply with new legal requirements or to adapt to changes in our services. We recommend checking this notice periodically. The updated policy will be published on the Company’s website with the last update date indicated.

11. Last Update
VENICE, 01/12/2024