Website Privacy Statement – Rosetti Superyachts S.p.A.

Rosetti Superyachts S.p.A., with registered office at Via Trieste 230, Ravenna – 48122, Italy, Tax Code/VAT No. 00082100397, as Data Controller (“RSY” or “Data Controller”), pursuant to articles 13-14 of EU Regulation 2016/679 (General Data Protection Regulation “GDPR”), provides the following information about personal information protection and security.

The purpose of this document (“Statement”) is to give you adequate information so you can understand how we process your personal information when you browse through our website. You will get all the information you need so you can express your explicit and informed authorization for the processing of your personal information while you browse and use this website. Please note that the majority shareholder of Rosetti Superyachts S.p.A. is Rosetti Marino S.p.A., with registered office at Via Trieste 230, Ravenna – 48122, Italy.

RSY has made a daily commitment to protect the online privacy of those visiting its website, based on what we consider the principles to be respected:

Privacy by default

We believe it is a priority to protect the personal information belonging to each and all of us.

Privacy by design

We have specifically designed our website and the tools it uses in order to interact with you so that the privacy and security of any personal information we process is protected. Personal information needs to be protected from unauthorized access, improper use, sharing, and loss.

Privacy statement

We believe that each one of us should be informed about how their personal information is used in a way that is clear, transparent and easy to understand.

Collection of necessary information and your right to choose

We only handle information that is necessary for the purpose we asked you to provide it, and only the information you authorize us to handle.

Protection of confidentiality in a defined timeframe

We believe your personal information deserves to be handled confidentially and should not be shared without your permission. We also believe that personal information should be handled within a set timeframe that is easily identified.

Generally speaking, any data or personal information that you share with RSY via the website, or that is collected in any way via the website, for the use of the services we offer (“Services”), as described in Paragraph 2 below, will be processed according to the internationally acknowledged principles of lawfulness, correctness, transparency, limitation of purpose and retention, minimization of data, accuracy, integrity and confidentiality. Your personal information may be collected because you provided it voluntarily (if you sign up for our newsletter, for example) or by simply analyzing your actions on the website.

1. Categories of processed personal information.

After you browsed the website, RSY will process the following personal information (also depending on how you decide to use the Services):

The following personal information is processed via the website:

 

1.1 Name, contact details and other personal information.

In various sections of the website you will be asked to enter information such as your name, email address, your country of residence, home address, etc. Furthermore, every time you take part in a survey or a promotion through the website, or when you contact RSY or its customer care team via the contact details on the website, RSY may collect any additional information you decide to provide.

 

1.2 Special categories of personal information.

Some sections of the website include open fields where you can send information to RSY that may contain personal data information. Since these fields are open, you can use them to share (on a voluntary basis, or otherwise) certain sensitive categories of personal information, such as information revealing your race or ethnic group, political opinions, religion or philosophical beliefs, trade union membership, genetic information or biometric data that may unequivocally identify an individual, data relating to your health or sex life, or the sexual orientation of a person.

RSY suggests you do not send such personal information unless it is strictly necessary. Since entering such information is optional, please remember that these special categories of personal information will be processed only with your explicit authorization and in compliance with applicable laws.

 

1.3 Providing third party data.

As mentioned above, there are parts of the website where you can enter text messages that are visible to RSY and that may contain personal information referring to a third party. Therefore, you accept all obligations and legal liability with respect to such third party’s personal information. You shall defend, hold harmless and indemnify RSY from any dispute, demand or request for compensation claimed by the relevant third party whose personal information was processed as a result of you using the website in breach of applicable regulations for the protection of personal information.

 

1.4 Browsing data.

During the course of their operation, the IT systems and software procedures used for the proper functioning of this website acquire certain personal information, whose transmission is required for using Internet communication protocols. This information is not collected by RSY in order to be associated with identified persons. However, given its very nature, users can potentially be identified should it be processed and associated with other data held by third parties.

IP addresses or domain names of the computers used by the users connected to the website, addresses of requested resources in URI notation (Uniform Resource Identifier), the time of the request, the method used for submitting the request to the server, the dimension of the file obtained in response, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters relating to the operating system and to the user’s IT environment, fall under this category of data.

This data is used exclusively to obtain anonymous statistics with regard to the use of the website and to check that the website it is operating correctly, in order to identify any anomalies and/or abuses.

 

1.5 Cookies.

Information on the use of Cookies is available in the Cookie Statement available here.

2. Purpose of processing

RSY will use your personal information collected via the website for the following purposes:

– Control your identity; send you the newsletter if you signed up for this service; send you any information you explicitly requested; locate the dealer, broker closest to you, and provide any other service you may require (“Providing the Service”);

– Send you communications and/or commercial offers and/or and any informative material regarding our brands and models; invite you to events (public or private), fairs and/or boat shows, send you promotional communications, market research and surveys related to products and services offered by RSY or send you our house organ. Depending on the type of communication, we can contact you by email and/or telephone and/or messaging services and/or ordinary mail and/or social networks (“Marketing”);

– Create your profile using profiling cookies, subject to your authorization, collecting and analyzing information about the selections and choices you make on the website and about how you use the website in general. This profile will be used to send you information about other sites and /or services that RSY thinks might be of interest to you, and to show you advertising that may match your preferences. All the algorithms involved in this process are tested on a regular basis to guarantee a proper process is used and in order to prevent errors (“Preferences”);

– Comply with legal obligations whereby RSY must collect and/or process certain types of personal information (“Compliance”);

– Prevent or identify any abusive use of the website or any fraudulent activity (“Abuse/Fraud”).

3. Legal basis and the mandatory or voluntary nature of data processing.

The legal basis used by RSY for processing your personal information, as per the purposes indicated in Paragraph 2 above, is as follows:

Providing the Service(s): processing for this purpose is necessary in order to provide you with the Services and so in order to execute the contract stipulated with you. It is not mandatory to give RSY your personal information for this purpose but it will not be possible to deliver any service if you refuse.

Marketing: the data processing for this purpose is based on your consent. It is not mandatory to give your consent for this purpose but, in the absence of your consent, we will not be able to send you any type of communication, included commercial communication related to one of our products nor invite you to events and/or boat shows. If you give your consent, you will still be free to revoke it at any time.

Preferences: data processing for this purpose requires your authorization expressed via the cookie banner and/or a specific checkbox. You are under no obligation to authorize RSY for this purpose and you are free to withdraw your authorization at any time without suffering any consequence (except you will no longer be able to benefit from the customization of commercial offers from RSY).

Compliance: data processing for this purpose is necessary so that RSY can comply with any legal obligations. When you give your personal information to RSY, it is processed according to applicable regulations, which could require their retention and notification to the authorities to comply with accounting, fiscal or other obligations.

Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activity or abuse in the use of the website.

4. Recipients of your personal information.

Your personal information may be shared with the persons indicated below (“Recipients”):

– Anyone typically acting as the data processor, such as persons, companies or professionals providing assistance and consulting services to RSY for accounting, administration, legal, taxation, financial and debt collection associated with the delivery of the Services;

– Anyone with whom interaction is necessary in order to provide the Services (such as hosting providers or suppliers of platforms for sending mails);

– Anyone authorized by RSY to handle technical maintenance (including maintenance of networking equipment and electronic communications networks);

– Persons authorized by RSY to process personal information as required for actions closely linked to the provision of the Services, whether they are under the obligation of confidentiality or have a suitable legal obligation of confidentiality (e.g. employees of RSY);

– Other companies part of the Rosetti Marino Group for the purpose of internal administration, including the processing of personal information of customers and employees;

– Agencies, authorities or other persons to whom it is mandatory to notify your personal information for the purpose of Compliance, Abuse or Abuse/Fraud prevention, or by order of the authorities.

5. Recipients of your personal information.

In light of the international activities of RSY, some of your personal information may be shared with Recipients who may be located outside the European Economic Area. RSY assures you that the processing of your personal information by these Recipients will comply with applicable regulations. In fact, the transfer of data is executed using appropriate guarantees, such as decisions of appropriateness, Standard Contractual Clauses approved by the European Commission, or other guarantees considered adequate.

More details are available by writing to RSY at the following address: privacy@rosettisuperyachts.it.

6. Retention of personal information.

Personal information processed for Providing the Services will be retained by RSY for the time strictly necessary to achieve this purpose. However, since your personal information was processed in order to supply the Services to you, RSY may retain them for a longer period, especially if necessary for protecting the interests of RSY against potential liability in relation to the Services.

Personal information processed for the purposes of Marketing and Preferences will be retained by RSY until you withdraw the authorization you gave earlier and regularly renewed. After you have withdrawn your authorization, RSY will no longer use your personal information for these purposes, but may retain it, especially if this is necessary to protect the interests of RSY against potential liability based on said processing.

Personal information processed for the purpose of Compliance will be retained by RSY for the period stipulated in the specific legal obligations or in the applicable regulations.

Personal information processed for the purpose of preventing Abuse/Fraud will be retained by RSY for the period strictly necessary for said purpose and thus until the moment when RSY is required to retain them to protect itself legally for notification to the competent authorities of said information.

7. Data Subject rights

Within the framework of legislation that is applicable to data protection, you are entitled to:

– Obtain RSY’s confirmation that the personal information provided is processed or not and, in this case, to access the personal information, pursuant to art. 15 of the GDPR;

– Obtain from RSY the correction of personal information provided that is incorrect, pursuant to art. 16 of the GDPR;

– Obtain from RSY the deletion of personal information that was provided, pursuant to art. 17 of the GDPR;

– Obtain from RSY restriction of processing of the personal information provided, pursuant to art. 18 of the GDPR;

– Verify the “data portability” of the personal information that was provided, pursuant to art. 20 of the GDPR;

– Object to processing of the personal information that was provided, pursuant to art. 21 of the GDPR and/or submit a complaint to the relevant controlling authorities;

  • Withdraw your authorization for Marketing and Preferences purposes.

The majority of personal information supplied to RSY can be amended at any time, including your email preferences.

Please contact us at privacy@rosettisuperyachts.it.

8.Modifications.

RSY may modify or simply update this Statement at any time. RSY therefore suggest you to visit this section on a regular basis in order to become familiar with the most recent and updated version of the Statement.

This PRIVACY STATEMENT RSY is valid from 25th of May, 2018.