1. The Data Controller of personal data. Contacts.

The Data Controller is:

Whitecaps S.r.l. with registered office at Via Negri Gaetano 8, 20123 – Milan (MI), reachable at the address: whitecaps@legalmail.it

2. The data processed by the Controller.

The information that the  Controller processes concerns:

• Identification and contact data (first name, last name, email address, phone number) provided by you voluntarily during your interactions with the website’s features and the request for the services offered by the portal, such as - for example - those provided during the completion of the forms present on the same;

• Navigation data, that is, those identification data implicit in the use of Internet communication protocols, acquired by the IT systems and the software procedures responsible for consulting the website. This type of data includes IP addresses or domain names of the computers and terminals used by users, addresses in URI/URL notation (Uniform Resource Identifier/Locator) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user’s operating system and computing environment. These are pieces of information that are not collected to be associated with identified data subjects and are therefore processed anonymously;

• The cookies and other tracking systems, the complete information of which is available at the following link

Data belonging to special categories referred to in art. 9 are not processed, meaning those that can reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data aimed at uniquely identifying a natural person, data related to health or sex life or sexual orientation of the person.

Furthermore, data related to criminal convictions and offenses are not processed (art. 10 GDPR).

3. Purposes of processing.

The Data Controller processes data you provide - upon interaction with the landing page - for the following purposes:

1. Allowing you to use the services made available by the Controller through the internet portal, particularly that of connecting with the page of Immobiliare.it to which the "Pearl of the Oranges" project is sponsored;  

2. With reference to navigation data, exclusively for statistical purposes and in anonymous form, in relation to access and use of the site, for monitoring purposes and improving the functioning and content of the portal itself;

3. For profiling activities understood as the operation of collecting and selecting the information you provide, aimed at analyzing the needs and interests expressed by you towards certain real estate solutions among those proposed by the Controller; this is in order to allow the Controller to identify the best offer in relation to the needs and preferences you have expressed, as well as to send you personalized informational and promotional material on real estate initiatives, projects, and services offered by the Controller;

4. To send you information and updates on real estate projects, services, offers, sales, promotional campaigns, initiatives, and events promoted by the Controller (marketing purposes);

5. To verify your level of satisfaction regarding the services offered by the Controller, also in view of a continuous improvement of their quality.

4. Nature of data provision and consequences of refusal to respond. Legal basis of processing.

1. without your express consent for the purposes referred to in points a), b) of the previous paragraph as they are connected to the services and activities requested by you from the Controller through the use of the portal. The provision of data for these purposes is, therefore, necessary; thus, the eventual failure, partial or inaccurate communication of data and information from you may have the consequence of preventing the Controller from executing the services and activities mentioned;

2. Only with your specific and distinct consent, expressed at the time of filling out the form for registration, for the purposes referred to in letters c), d), e) of paragraph 3 ; if you decide not to grant consent to the processing of data for these purposes, this will not preclude your browsing experience, nor the ability to take advantage of the services offered through the website. We also inform you that at any time you may revoke your consent freely and at no cost through the methods indicated in the following par. 9.

All your personal data are processed by the Controller based on the following legal basis:

• Art. 6, par.1 lett. b) GDPR, since the processing is necessary for the execution of contractual provisions for pre-contractual measures adopted at your request. In particular, all data provided during the interaction with the landing page’s features are strictly necessary for the management and execution of your requests;

• Art. 6, par. 1 Lett. a) GDPR as, with specific regard to the purposes indicated in letters c), d), e), among which is marketing, processing is only possible following your expressed consent. Specifically, consent may be expressed at the time of registration for the landing page

Considering the purposes of the processing as illustrated above, your personal data will be processed without your express consent for the purposes referred to in points a), b) of the previous paragraph as they are connected to the services and activities requested by you from the Controller through the use of the portal. The provision of data for these purposes is, therefore, necessary; thus, the eventual failure, partial or inaccurate communication of data and information from you may have the consequence of preventing the Controller from executing the services and activities mentioned.

All your personal data are processed by the Controller based on the following legal basis:

• Art. 6, par.1 lett. b) GDPR, since processing is necessary for the execution of contractual provisions for pre-contractual measures adopted at your request. In particular, all data provided during the interaction with the landing page’s features are strictly necessary for the management and execution of your requests.

5. Methods of processing execution.

The processing is carried out with tools, both manual and IT and telematic, with organizational and processing logics strictly related to the purposes for which the processing is carried out and in any case in such a way as to guarantee the safety, integrity, and confidentiality of the data themselves in compliance with the organizational, physical, and logical measures provided by current regulations.

6. Communication of personal data.

Your personal data may be communicated to the following categories of recipients or shared with them, within the scope of the purposes mentioned above:

• Data processors identified from time to time;

• Individuals, companies, or professional firms that provide assistance and consulting to the Controller in accounting, administrative, legal, tax, financial matters, and debt collection related to the delivery of the Services;

• Subjects with whom it is necessary to interact for the provision of Services (e.g., hosting providers);

• Subjects delegated to carry out technical maintenance activities (including maintenance of network devices and electronic communication networks);

• Third parties, including international ones, that provide any services in favor of the Controller;

• Companies and professionals used by the Controller in order to protect their rights;

• Subjects, entities, or authorities to which it is mandatory to communicate your personal data due to legal provisions or orders from authorities or to prevent and/or detect any fraudulent activities or abuses in the use of the site and the services offered by the Controller;

• Persons authorized by the Controller to process personal data necessary to carry out activities strictly related to the services, who have committed to confidentiality or have an adequate legal obligation of confidentiality (e.g., employees or collaborators of the Controller).

7. Duration of processing.

Your personal data will be processed for the entire duration of the relationship with the Controller and, subsequently, for the time provided by the applicable regulatory framework, that is, until it will be necessary to process them based on:

• specific regulatory obligations;

• provisions of public authorities;

• obligations related to accounting;

• any reasons related to Justice.

In case there is no maximum duration indicated for the processing of all or some personal data, these may not exceed 10 years from the termination of the existing relationship with the Company.

8. Your rights.

In relation to the data processed by the Controller, you may exercise, at any time, the rights listed below:

In relation to the data processed by the Controller, you may exercise, at any time, the rights listed below:

• right of access, aimed at allowing you to know what data is being processed and all information related to the processing;

• right to rectification, aimed at allowing you to request the modification of data as it is inaccurate or outdated;

• right to restrict processing, aimed at allowing you to limit the processing of your data, provided that one of the assumptions provided by the applicable legislation occurs;

• right to erasure, aimed at allowing you to request the erasure of data;

• right to object, aimed at allowing you to request the cessation of the processing of data;

• right to lodge a complaint with the supervisory authority, aimed at allowing you to promote any reports, complaints, or appeals to the Guarantor for the Protection of Personal Data.

The exercise of your rights can take place through:

1. sending an email to the address: whitecaps@legalmail.it

2. sending a written request addressed to Whitecaps S.r.l., with registered office at Via Negri Gaetano 8, 20123 – Milan (MI).

9. Complaint.

Please be informed that if you believe that the processing of your personal data through this website occurs in violation of the GDPR, you have the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as provided for by art. 77 of the Regulation itself, or to resort to the competent judicial authorities (art. 79 of the GDPR).