Privacy policy

This privacy policy(hereinafter, “Privacy Policy”) is provided to you (“You”) and relates to theprocessing of your personal data (“Personal Data”) carried out by:

Ventiventi sagl with registered office in Massagno, Via San Gottardo, 53,
E-mail: info@a2plus.green

in accordance with allapplicable data protection legislation, including the Swiss Federal Act on DataProtection and the EU GDPR.

1. Identity and contact details of the Data Controller

The Data Controller is Ventiventisagl. Since the Data Controller is established in the territory of Switzerland,no representative (“Representative”) has been appointed, pursuant toArticle 27 GDPR.

2. DPO contact information

The Data Controller has not appointed aData Protection Officer(“DPO”)pursuant to Article 37 GDPR. The DPO can be contacted at the following address: info@a2plus.green.

3. Purpose of processing and legal basis for processing

Your personal data will beprocessed:

1. For contractual purposes and/or related to the execution of pre-contractual measures taken at your specific request, as well as to fulfill any legal obligations related to these purposes, such as to allow You to be contacted to evaluate the potential real estate purchase.
2. to send direct marketing communications, newsletters, advertising material, by means of traditional contact systems and automated IT systems, including commercial or promotional communications by email or SMS, or for market research and analysis. In this case, the legal basis is consent, expressed in accordance with this Privacy Policy;
3. for profiling purposes and, in particular, to provide You with personalized services. The legal basis for processing is your consent, expressed in accordance with current legislation and this Privacy Policy;
4. for purposes related to related legal obligations when processing is carried out for the purposes referred to in point (a). In this case, the legal basis is the legal obligation of the Data Controller to process such Personal Data in accordance with the applicable national law.

4. How to express Your consent

You may express consent bysigning a paper, a computerized document, or by flagging specific flagboxes asmade available by the Site.

5. Method and logic of processing

• Personal Data will be processed for the purposes under point a) number 3 of the Privacy Policy (contractual and pre-contractual purposes) by means of automated logic and CRM software, which will allow the best possible management of the contractual execution; 
• Personal Data will be processed for the purposes under point b) number 3 of the Privacy Policy (marketing purposes) through software to send commercial information;
• Personal Data will be processed for the purposes under point c) number 3 (profiling) by means of CRM type software to determine your preferences in order to offer You personalized services and communications. For further details, see the next point of the Privacy Policy; 
• Personal Data will be processed and stored for the purposes under paragraph d), number 3 (legal obligation) through paper tools, automated logic and CRM software to allow the best management of the fulfillment of legal obligations.

6. Automated decision making and profiling

If You consent to theProcessing of your Personal Data to benefit from personalized services throughprofiling, your Personal Data may be subject to an automated decision-makingprocess, with a specific algorithm that will decide which communications arebest suited to your profile or which may be of most interest to You. Theprocessing carried out in this way has, as expected consequences, by way ofexample, the sending of highly profiled commercial communications, the sendingof discounts, the sending of invitations to events considered of interest, etc.

Youhave theright to: 

• obtain human intervention in decision-making by the Data Controller; 
• express your opinion; 
• obtain an explanation of the decision reached by the Data Controller; 
• challenge the decision.

7. Source from of Personal Data

The Data Controller will onlyprocess Personal Data in accordance with this Privacy Policy. Personal Datafrom publicly accessible sources will not be processed.

8. Recipients and possible categories of recipients of Personal Data

The following subjects mayreceive your Personal Data:

• Companies offering information society services, including, in particular, those offering hosting services; 
• accounting firms;
• Data Controller’s partner companies;

9. Categories of Personal Data

The Data Controller may process the following categories of Personal Data:

• biographical data;  
• contact data.

10. Transfer of Personal Data

The Data Controller may transfer Personal Data to entities established incountries outside of Switzerland, the European Union, or to internationalorganizations. These entities include, but are not limited to, communicationcompanies performing activities on behalf of the Data Controller and realestate partners involved in property management and transactions.

The potential destinations for such Personal Data transfers may includeItaly, the U.S.A., and other countries, with the legal basis for each transferclearly identified, such as an adequacy decision for Italy. Should you wish toobtain a copy of your Personal Data or discover the locations where it has beenmade available, you are welcome to send a request to the Data Controller at thespecified addresses.

In accordance with applicable law, the transfer of Personal Data to theseentities, including communication companies and real estate partners, isconducted under the assurance of an adequacy decision. This decision confirmsthat the third country, specific areas within that country, or theinternational organization ensures an adequate level of protection for therights of individuals. Moreover, the Data Controller reserves the right toenter into specific agreements that mandate these entities to implement robustsecurity measures, both organizational and technical, to offer suitableguarantees regarding the protection of rights.

11. Period of retention of Personal Data

• The Personal Data processed and stored for the purposes referred to in point a) and d), number 3 (contractual and pre-contractual purposes and fulfillment of legal obligations) are processed and stored by the Data Controller in accordance with all applicable data protection law, however, for a period of time not exceeding 10 years     from the cessation of the effects of the contract in case of conclusion of the same, unless otherwise required by law; 
• The Personal Data processed for the purposes referred to in point b) number 3 of this statement (marketing purposes) are processed and stored by the Data Controller until You request their cancellation and / or revocation, as a Data Subject; 
• The Personal Data processed for the purposes referred to in point b) number 3 of this statement (marketing purposes) are processed and stored by the Data Controller until You request their cancellation and / or revocation, as a Data Subject;
• Personal Data processed for the purposes set forth in point c) number 3 (preference determination purposes) are processed and stored by the Data Controller for a period of time not exceeding 12 months from collection.

12. Optionality of consent and consequences of non-consent

• In relation to Personal Data processed for the purposes set out in point a) number 3 of this policy (contractual and pre-contractual purposes), the communication of Personal Data is an obligation. If You do not communicate such Personal Data, no contract can be concluded. 
• In relation to Personal Data processed for the purposes set out in point b) number 3 of this policy (marketing purposes), the disclosure of Personal Data is not a contractual obligation. You have the option to provide Personal Data. If You do not provide such Personal Data, the Data Controller will not be able to carry out any marketing activities. 
• With respect to Personal Data processed for the purposes set forth in point c) number 3 of this Privacy Policy (profiling purposes), the disclosure of Personal Data is not a contractual obligation. You have the option to provide Personal Data. If You do not disclose such Personal Data, the Data Controller may not perform any profiling activities. 
• In relation to Personal Data processed for the purposes set out in point d) number 3 of this policy (legal obligations), the disclosure of Personal Data is a legal obligation.

13. Data Subject’s rights: right to object

You, in the quality of “DataSubject”, have the right to object in the following terms:

• the right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data concerning You in accordance with all applicable data protection law. The Data Controller will refrain from further processing your Personal Data, unless the Data Controller demonstrates compelling legitimate grounds for     the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims; 
• when Personal Data is processed for direct marketing purposes, You have the right to object at any time to the processing of Personal Data relating to You carried out for such purposes, including profiling insofar as it is related to direct marketing; 
• if You object to the processing of your Personal Data for direct marketing purposes, your Personal Data will no longer be processed for such purposes. You may object to the processing of     your Personal Data for direct marketing purposes, even if only in part, for example by objecting to the sending of promotional communications by     automated and/or digital means, or to the sending of paper communications and/or the receiving of telephone communications; 
• where your Personal Data is processed for scientific or historical research purposes or for statistical purposes in accordance with all applicable data protection law, You have the right, on grounds relating to your particular situation, to object to the processing of Personal Data, unless the processing is necessary for the performance of a task carried out in the public interest.

14. Your other rights under all applicable data protection law

The Data Controller would alsolike to inform You of the existence of the following rights:

• Right of access: You have the right to obtain confirmation from the Data Controller that Personal Data concerning You is or is not being processed, and to access your Personal Data and specific information, in accordance with all applicable data protection law; 
• Right of rectification: You have the right to obtain from the Data Controller the rectification of inaccurate Personal Data concerning You without undue delay. Taking into account the purposes of the processing, You have the right to obtain the integration of incomplete Personal Data, including by providing a supplementary declaration, in     accordance with all applicable data protection law; 
• Right to data erasure, including the right to withdraw consent: You have the right to obtain from the Data Controller the erasure of your Personal Data without undue delay or to withdraw your consent to the processing, in accordance with all applicable data protection law. You have the right to revoke your consent at any time, without affecting the lawfulness of the processing based on the consent You gave before revocation; 
• Right to restriction of processing: You have the right to obtain from the Data Controller the restriction of processing, in accordance with all applicable data protection law; 
• Right to data portability: You have the right to receive in a structured, commonly used and machine-readable format, your Personal Data provided to the Data Controller and You have the right to transmit it to another data controller without hindrance from the Data Controller, in accordance with all applicable data protection law; 
• Contractor’s right to object to commercial communications: as a contracting party, You have the right to object at any time, free of charge, to receiving commercial communications from the Data Controller; 
• Right to lodge a complaint with the Data  Protection Authority: You have the right to lodge a complaint with the competent Data Protection Authority, to complain about a violation of the rules on the protection of Personal Data, in accordance with all applicable data protection law.

15. How to exercise your rights

You may exercise the rightsindicated in the Privacy Policy by addressing your requests directly to the Data Controller at the email address dpo@a2plus.green, or bysending the relative communication by registered mail with return receipt tothe address Via San Gottardo, 53 – 6900 -Massagno - Switzerland 

You may lodge a complaint withyour competent Data Protection Authority, in accordance with the terms of itsofficial websites.

16. Accessibility of Privacy Policy

The information is accessibleat the Data Controller's offices. If expressly requested, the information mayalso be provided orally, provided the identity of the requester is proven, by atelephone request addressed to the addresses of the Data Controller.

17. Changes

The Data Controller may modifythe Privacy Policy, also to comply with changes in national and/or European Union regulations, or technological innovations. Any new versions of the Privacy Policy will be posted on the Site. We encourage You to periodically check the Privacy Policy. Any changes will be communicated to You through a pop-up on the Site or by other means and/or computer tools. 

If the Data Controller substantially modifies the Privacy Policy, providing for new processing purposes and/or categories of processed Personal Data, the Data Controller will inform You, requesting the necessary consents, by means of a pop-up on the Site or other methods and/or IT tools.