Villa Fibbia – A journey among Villas and Castles

Below is a text compliant with the GDPR (EU Regulation 2016/679) to be adapted with the specific details of the local authority and, where applicable, the URL of the Voxmail platform.

# Privacy Notice on the processing of personal data for newsletter subscriptions
In accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”), the Municipality of San Giovanni in Persiceto informs data subjects of how personal data collected for the newsletter service is processed.

## 1. Data Controller
The Data Controller is the Municipality of San Giovanni in Persiceto, with registered office at Corso Italia 70, 40017 San Giovanni in Persiceto (BO).

Email: [insert certified email (PEC) address or institutional email address]
Telephone: [insert contact details]

## 2. Data Protection Officer (DPO)
The Municipality’s Data Protection Officer (DPO) is Lepida ScpA.

To contact the DPO:
email: dpo-team@lepida.it
certified email (PEC): segreteria@pec.lepida.it

## 3. Purposes of processing
The personal data provided by the data subject are processed exclusively for the following purposes:

• to manage subscription to the municipality’s newsletter service;
• to send information regarding the activities, services, events, initiatives and official communications of the Municipality of San Giovanni in Persiceto;
• to manage any requests to unsubscribe from the service.

## 4. Legal basis for processing
The legal basis for the processing is the “consent of the data subject”, pursuant to Article 6(1)(a) of the GDPR.

Consent may be withdrawn at any time without affecting the lawfulness of the processing carried out prior to the withdrawal.

## 5. Data processed
For registration, only the data strictly necessary for the provision of the service is collected, such as:

• email address;
• any additional data provided voluntarily by the data subject via the registration form.

Technical data relating to the management of the platform may also be processed (for example, access logs, date and time of registration, confirmation of registration and cancellation).

## 6. Methods of processing
Processing is carried out using IT and telecommunications tools, in accordance with the principles of lawfulness, fairness, transparency, data minimisation and confidentiality as set out in the GDPR, by adopting appropriate technical and organisational measures to ensure data security.

## 7. Data processors
For the technical management of the newsletter service, the Municipality uses the Voxmail platform, whose provider acts as a data processor pursuant to Article 28 of the GDPR, on the basis of a specific contract or other legal instrument.

## 8. Disclosure and dissemination of data
Personal data will not be disclosed.

It may be disclosed exclusively to parties authorised to process the data or to suppliers acting as data processors for the provision of the service, within the limits of the purposes indicated above.

## 9. Data retention
The data will be retained until consent is withdrawn or a request is made to unsubscribe from the newsletter service.

Thereafter, it will be deleted or anonymised, subject to any legal obligations.

## 10. Provision of data
Providing your email address is optional but necessary to subscribe to the newsletter.

Failure to provide this information will prevent the service from being activated.

## 11. Rights of the data subject
The data subject may exercise the following rights, in the cases provided for in Articles 15–22 of the GDPR:

• to access their personal data;
• to request the rectification of such data;
• to obtain erasure;
• to obtain restriction of processing;
• to object to processing in the cases provided for by law;
• request data portability, where applicable;
• withdraw consent at any time.

Requests may be addressed to the Data Controller or the DPO.

The data subject also has the right to lodge a complaint with the Data Protection Authority pursuant to Article 77 of the GDPR.

## 12. Unsubscribing
Every communication sent via the newsletter contains a dedicated link that allows you to unsubscribe automatically from the service at any time.