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Privacy Notice

This notice explains how your personal data is processed when you use the Privé Area of Habibi.come.to.Italy (referred to below as Habibi), the private space where you find and share the photos of your experience. Please read it before accessing the area. Processing takes place in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Italian law.

1. Who processes your data (Data Controller)

The Data Controller is Maria Munteanu, VAT number 07427720482, based at Via delle Fonti, 5, Pontassieve (FI), Italy. For any request concerning your data, you can write to: ciao@habibicometoitaly.com.

2. What data we process

As part of the Privé Area, we process:

• your name and email address, used to create your personal access to your experience's album;
• photographs of the experience: those uploaded by Habibi and, for experiences where this is enabled, those uploaded by participants. Photographs may show you and the other people who took part in the experience;
• some technical and consent-proof data: your personal access code, the date and time you gave your consents, the IP address from which you gave them, and the version of the notice you accepted. This data serves to prove that consent was collected correctly;
• information on who uploaded each photograph, for experiences where uploading is open to participants.

3. Why we process your data and on what legal basis

a) To give you access to the album and share the experience's photos. We process your data to create your personal access and show you the photos of your experience. The album is shared among all participants of your same experience, since it is an experience lived together: everyone who took part sees the same photos, whoever uploaded them. For some experiences, participants can also upload their own photos; for others, photos are uploaded only by Habibi. Whether you can upload for your experience is shown to you in the Privé Area.
Legal basis: your consent (Art. 6(1)(a) GDPR). Without this consent, we cannot provide you with the Privé Area.

b) To use some images for Habibi's promotional purposes. Only if you expressly authorise us, we may use photographs showing you to promote Habibi, for example on our social media channels and on our website.
Legal basis: your specific and separate consent (Art. 6(1)(a) GDPR). This consent is optional: you can access and fully use the Privé Area even without giving it, and it is revocable at any time.

4. How the shared album works

The album is a common space: you see the photographs of your experience, uploaded by Habibi and, where enabled, by other participants; if you can upload, your own photographs become visible to them too. We ask you to upload only appropriate images and to respect the people shown in them. Habibi may remove inappropriate photographs at any time.

If you do not want one of your photographs to remain in the album, or you want a photograph showing you to be removed, you can write to us at ciao@habibicometoitaly.com and we will remove it.

5. Who your data is shared with

Your data is not disclosed to the public (except for the promotional purpose under letter b, if authorised by you). It may be processed by:

• the other participants of your same experience, limited to the photographs of the shared album, as described in section 4;
• the technical service providers we rely on to operate the service, who act as Data Processors on our behalf.

6. Transfer of data outside the European Union

Some of the providers listed in section 5 may process data on servers located outside the European Union. In that case, the transfer takes place in accordance with the safeguards required by the GDPR.

7. How long we keep your data

We keep your data only for as long as necessary for the purposes for which we process it, according to the following criteria:

• photographs and access to the album are kept for as long as necessary to allow you to view and download them; they are removed once this purpose no longer applies, for example within a reasonable time after the experience ends;
• data proving consent is kept for as long as necessary to protect the parties in case of disputes, in line with applicable limitation periods;
• if you authorise the promotional use (letter b), the images used for that purpose are kept until consent is withdrawn or they are removed from Habibi's channels, whichever comes first.

8. Your rights

At any time, you can exercise the rights set out in Articles 15 to 22 of the GDPR: access your data, request its correction or deletion, restrict or object to its processing, receive your data in a readable format (portability), and withdraw the consents you gave. You can do so by writing to ciao@habibicometoitaly.com.

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) if you believe the processing of your data breaches the law.

9. Withdrawing consent

You can withdraw your consents at any time by writing to ciao@habibicometoitaly.com. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. Withdrawing your consent to the promotional use (letter b) does not prevent you from continuing to use the Privé Area.