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PRIVACY POLICY

GIOIE PER TE SRLS Information on the processing of personal data pursuant to EU Regulation 2016/679 (GDPR) and Italian Legislative Decree 196/2003 (Privacy Code) as amended by Legislative Decree 101/2018

Version updated on 02/06/2026


1 — DATA CONTROLLER

The Data Controller for personal data processing is:

GIOIE PER TE SRLS VAT Number: 11004971211 Legal Representative: Giunio Procacci Registered Office: Via Luca Giordano, 16 — 80127 Naples (NA), Italy PEC (Certified Email): gioieperte@pec.it Email: info@gioieperte.com


2 — TYPES OF DATA COLLECTED

2.1 In connection with the use of the website and the purchase of packages, GIOIE PER TE SRLS collects and processes the following categories of personal data:

Data voluntarily provided by the client: — First and last name — Email address — Telephone number — Residential or domicile address — Payment data (managed through the Ecwid platform and its secure payment systems — not retained by GIOIE PER TE SRLS) — Any health-related data voluntarily communicated (allergies, intolerances, relevant medical conditions) — processed solely for the purpose of service provision

Navigation data: — IP address — Browser type and device used — Pages visited and duration of visit — Access data and server logs


3 — PURPOSES AND LEGAL BASIS FOR PROCESSING

3.1 Personal data is processed for the following purposes:

a) Performance of the contract and booking management (art. 6, par. 1, lett. b GDPR) — Processing and confirmation of purchase — Post-purchase contact to finalise holiday details — Management of modifications, cancellations and refunds — Operational communications relating to the booked cruise

b) Compliance with legal obligations (art. 6, par. 1, lett. c GDPR) — Issuance of invoices and tax documents — Accounting and administrative obligations — Data retention for tax purposes

c) Legitimate interest of the Controller (art. 6, par. 1, lett. f GDPR) — Fraud prevention — Website and IT system security — Improvement of services offered

d) Consent of the data subject (art. 6, par. 1, lett. a GDPR) — Sending of commercial communications and newsletters (only with explicit consent) — Use of non-technical cookies (only with consent via the cookie banner)


4 — PROCESSING METHODS AND RETENTION

4.1 Personal data is processed using electronic and IT tools, in compliance with the principles of lawfulness, fairness, transparency, data minimisation and integrity set out in the GDPR.

4.2 Data is retained for the following periods: — Contractual and tax data: 10 years from the conclusion of the contract, pursuant to Italian tax legislation — Navigation data: maximum 12 months — Data for marketing purposes: until consent is withdrawn

4.3 Health-related data voluntarily communicated is processed solely for the provision of the service and deleted at the end of the cruise.


5 — COMMUNICATION AND DISCLOSURE OF DATA

5.1 Personal data may be communicated to: — Providers of nautical services (boat owners, on-board operators) to the extent strictly necessary for the provision of the booked service — Banks and payment systems for transaction management — Ecwid platform for e-commerce management — Accountants and tax consultants for accounting obligations — Public and judicial authorities, where required by law

5.2 Data is not sold, transferred or disclosed to third parties for commercial purposes.

5.3 Some service providers may be located outside the European Union. In such cases, the transfer takes place in compliance with the safeguards provided for by the GDPR (Adequacy Decisions, Standard Contractual Clauses).


6 — COOKIE POLICY

6.1 The website www.gioieperte.com uses technical cookies necessary for the proper functioning of the website and, subject to the user's consent, analytical and profiling cookies.

6.2 Technical cookies: necessary for browsing and website operation. Do not require consent.

6.3 Analytical cookies: used to analyse user behaviour in aggregated and anonymous form (e.g. Google Analytics). Require consent.

6.4 Third-party cookies: cookies from social media platforms or advertising services may be present. Require consent.

6.5 Users can manage or disable cookies through their browser settings or via the cookie banner on the website. Disabling technical cookies may compromise the proper functioning of the website.


7 — RIGHTS OF THE DATA SUBJECT

7.1 Pursuant to arts. 15-22 of the GDPR, the data subject has the right to:

— Access: obtain confirmation of processing and a copy of their personal data — Rectification: obtain correction of inaccurate or incomplete data — Erasure: obtain the deletion of their data ("right to be forgotten"), in the cases provided for by law — Restriction: obtain restriction of processing in the cases provided for by law — Portability: receive their data in a structured, machine-readable format — Objection: object to processing based on legitimate interest or for direct marketing purposes — Withdrawal of consent: withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal

7.2 To exercise their rights, the data subject may send a written request to: — Email: info@gioieperte.com — PEC: gioieperte@pec.it — Post: Via Luca Giordano, 16 — 80127 Naples (NA), Italy

7.3 The Controller will respond to the request within 30 days of receipt.

7.4 The data subject has the right to lodge a complaint with the Italian Data Protection Authority — Garante per la Protezione dei Dati Personali (www.garanteprivacy.it) — if they believe that the processing of their data violates the provisions of the GDPR.


8 — DATA SECURITY

8.1 GIOIE PER TE SRLS implements appropriate technical and organisational measures to protect personal data from unauthorised access, loss, destruction or disclosure, in accordance with art. 32 of the GDPR.

8.2 Payment data is managed exclusively through the Ecwid platform and its secure payment systems (e.g. Stripe, PayPal). GIOIE PER TE SRLS does not retain or have access to clients' credit card or bank account data.


9 — AMENDMENTS TO THE PRIVACY POLICY

9.1 This Privacy Policy may be updated at any time to reflect regulatory or operational changes. The updated version will be published on the website with the date of revision.

9.2 Users are invited to consult this page periodically.

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