PRIVACY POLICY

In accordance with Regulation (EU) 2016/679 (GDPR) and Legislative Decree 196/2003, the following information is provided pursuant to Articles 13 and 14 of the GDPR to all users who visit the site www.sunnycharter.it (“Site”) and who interact with the services offered, including the purchase of charter tours.

1. Data Controller
   The data controller is:
   RUSSO LUCA
    VAT No.: 10698251211
   Registered Office: Via Prota 69, Torre Annunziata (NA) 80058, Italy
   Email: info@sunnycharter.it
   Tel.: +39 3458296937
2. Purposes and Methods of Processing
   The personal data collected will be processed for the following purposes:

• Execution and management of the contract:
  To enable the booking and purchase of the charter tours offered on the Site, as well as for the management of transactions and contractual communications.
• Legal and accounting compliance:
  To comply with the tax, administrative, and accounting obligations provided by current legislation.
• Service improvement and statistical analysis:
  To analyze the use of the Site, monitor performance, and optimize the services offered.
• Informative and promotional communications:
  With the explicit consent of the user, to send marketing communications regarding similar services or commercial initiatives (revocable at any time).

The data will be processed using electronic and/or manual tools, adopting appropriate technical and organizational security measures to protect the data from unauthorized access, loss, or illicit disclosure.

3. Methods of Data Collection
   Personal data is collected through:

• Direct collection from the user:
  Through the completion of booking, registration, or information request forms available on the Site.
• Automatic collection:
  During navigation on the Site, via cookies and similar technologies, which collect information such as IP address, navigation data, browser type and version, and other statistical information useful for service improvement.
• For transactions:
  At the time a purchase is made, with the payment managed through an external secure system (the platform operator is not named).

4. Legal Basis for Processing
   The processing of personal data is based on:

• The execution of a contract or pre-contractual measures (Art. 6, para. b GDPR);
• Compliance with legal obligations (Art. 6, para. c GDPR);
• The legitimate interest of the controller, related to the management of the Site and the optimization of the services (Art. 6, para. f GDPR);
• The explicit consent of the user, for marketing purposes or promotional communications, where required (Art. 6, para. a GDPR).

5. Types of Data Processed
   The personal data collected may include:

• Identifying data:
  First name, last name, address, tax code (when applicable).
• Contact data:
  Email, telephone number.
• Booking-related data:
  Tour details, payment data (without storing the complete card details, managed directly by the external payment system).
• Navigation data:
  IP address, logs, statistical data, and information collected through cookies.

6. Data Communication and Disclosure
   Personal data may be communicated to:

• Technical suppliers:
  Hosting companies, software maintenance and payment gateway providers, appointed as data processors.
• Competent authorities:
  Port Authorities, Italian Revenue Agency, and other institutions, in compliance with legal obligations.
• Operational partners:
  Skippers, onshore assistants, and logistics companies involved in the organization of the tours.

The data will be communicated exclusively to the extent necessary for the execution of the contract and compliance with legal obligations, as well as for the optimization and improvement of the services offered.

7. Duration of Storage
   Personal data will be stored for:

• Contractual purposes:
   Up to 24 months from the last interaction, except in cases of legal disputes.
• Tax obligations:
   10 years from the date of the operation.
• Marketing:
   24 months from the last consent.

8. Data Subject Rights
   Users can exercise the following rights:

• Right of access:
   To know which data is in the possession of the controller.
• Right to rectification or integration:
   To correct or update inaccurate or incomplete data.
• Right to deletion:
   To request the removal of data (right to be forgotten), except in cases where storage is legally required.
• Right to restriction of processing:
   Under specific circumstances.
• Right to object:
   To oppose processing, particularly for marketing purposes.
• Right to data portability:
   To receive their data in a structured, commonly used, and machine-readable format.
• Right to withdraw consent:
   At any time, without prejudice to the lawfulness of processing based on consent given prior to withdrawal.

To exercise these rights, the user can send a written request to:
Email: info@sunnycharter.it.

9. Security Measures
   RUSSO LUCA adopts appropriate technical and organizational measures to ensure the security and confidentiality of personal data, protecting them from unauthorized access, accidental loss, alteration, or illicit disclosure.
10. Cookies and Similar Technologies
    The Site uses cookies and other tracking technologies to improve the user experience and collect statistical information about web traffic. For further details on cookies and management methods, please refer to the Cookie Policy available on the Site.