Privacy Policy

The Data Controller processes the following types of Personal Data voluntarily provided by the Data Subject:

Contact Data: first name, last name, address, e-mail address, phone number, pictures, authentication credentials, and any further information sent by the Data Subject.

Fiscal and Payment Data: tax code, VAT number, credit card data, bank account details, etc.

Employment Data: data entered in the curriculum vitae, data on spouse or children, social security data, etc.

Special Data: Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify the natural person, data concerning health or sex life or sexual orientation, collected with the consent of the Data Subject. The Data Subject may withdraw consent at any time.

The Data Controller also processes the following types of Personal Data collected automatically:

Technical Data: Personal Data produced by devices, applications, tools, and protocols such as information about the device used, IP addresses, browser type, type of Internet provider (ISP). This data may leave traces which, combined with unique identifiers and other information, can be used to create profiles of individuals.

Usage Data: such as pages visited, number of clicks, actions taken, duration of sessions, etc.

Location Data: geolocation data that precisely identifies the location of the Data Subject, which may be collected via satellite network (e.g. GPS) or other means, collected with the consent of the Data Subject. The Data Subject may withdraw consent at any time.

If the Data Subject decides not to provide Personal Data for which there is a legal or contractual obligation, or if such data is required for the conclusion of the contract with the Data Controller, it will be impossible for the Data Controller to establish or continue any relationship with the Data Subject.

The Application uses cookies, web beacons, unique identifiers, and other similar technologies to collect the Data Subject’s Personal Data on visited pages, links, and other actions performed during the use of the Application. This data is stored and used the next time the Data Subject browses the Application. The full Cookie Policy can be viewed at the following address: Cookie Policy.

The processing of Personal Data is necessary for:

1. Performance of the contract with the Data Subject, especially for:
   • Fulfillment of any obligations arising from the pre-contractual or contractual relationship.
   • Registration and authentication to allow access and interaction with the Application.
   • Support and contact with the Data Subject to address their requests.
   • Management of payments through credit card, bank transfer, or other methods.
2. Legal obligations, particularly for:
   • Compliance with laws, regulations, and tax obligations.
3. Legitimate interests of the Data Controller, including:
   • Marketing of products and/or services to the Data Subject through email.
   • Management and optimization of technical infrastructure.
   • Security and anti-fraud measures.
   • Analyzing anonymous data for statistical purposes to improve products and services.
4. Consent of the Data Subject, for:
   • Profiling for targeted marketing purposes.
   • Retargeting and remarketing to reach individuals who have previously visited or shown interest in the products or services.
   • Marketing and promotional materials.

The processing of Personal Data is performed through paper-based and computer-based tools with methods strictly related to the specified purposes and the adoption of appropriate security measures.

Personal Data may be processed by:

• Authorized persons who are bound by confidentiality or legal obligations.
• Independent third-party data controllers (e.g., business partners, consultants, IT companies).
• Public authorities to whom Personal Data must be disclosed as per legal obligations.

The subjects listed above must use appropriate measures to protect Personal Data and may only access the necessary data for performing their duties.

Personal Data will not be indiscriminately shared or sold.

If necessary, Personal Data may be transferred to countries outside the European Economic Area (EEA). When transferring Personal Data outside the EEA, the Data Controller will ensure appropriate safeguards are in place, such as contractual agreements based on standard contractual clauses approved by the European Commission.

For more information on the specific guarantees adopted, Data Subjects may contact the Data Controller via email at info@elitedivingagency.com.

Personal Data will be stored for the time necessary to fulfill the purposes for which it was collected:

• For contract execution: the duration of the contractual relationship and for 10 years after termination, as per the ordinary prescription period.
• For legal obligations: as required by law or authorities.
• For consent-based processing: until the consent is revoked.

After the retention period, Personal Data will be deleted or anonymized.

The Data Subject may exercise specific rights regarding the processing of their Personal Data. These rights include:

• The right to access, correct, or delete Personal Data.
• The right to restrict processing or object to processing.
• The right to withdraw consent at any time.
• The right to data portability (i.e., transferring Personal Data to another data controller).
• The right to file a complaint with the supervisory authority or take legal action.

Requests can be made by sending an email to info@elitedivingagency.com. We will address the request within 30 days.

08/01/2025