Controller

Portofino Divers di Ariodante Borelli
Email: info@portofinodivers.com
Website: portofinodivers.com

1. Introduction

This privacy policy explains what personal data Portofino Divers di Ariodante Borelli collects through this website, for what purposes, and on what legal basis. It also describes your rights as a data subject under the General Data Protection Regulation (EU) 2016/679 (GDPR).

We process personal data only to the extent strictly necessary. We do not use tracking cookies, advertising networks, or any form of behavioral profiling.

2. Website analytics

We use Plausible Analytics, a privacy-focused statistics tool. Plausible is self-hosted on our own server and does not use cookies. It does not collect personal data and does not transmit any information to third parties. The data collected (page views, referrer, country of origin derived from anonymized IP) is aggregate and cannot be traced back to individual visitors.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in understanding how our website is used, with no impact on visitor privacy.

3. Contact form

When you send a message through the contact form on this website, we collect your name, email address, and the content of your message. This data is stored on our own server and used solely to respond to your enquiry. It is not shared with third parties and is deleted once the matter is resolved.

Legal basis: performance of pre-contractual measures or your consent (Art. 6(1)(a)(b) GDPR).

4. Online bookings

Bookings are handled through Planyo, an online reservation system operated by Xtreeme Sagl, Via Cantonale, CH-6633 Lavertezzo, Switzerland. When you make a booking, the data you provide (name, email address, phone number, and any other details required for the reservation) is processed by Planyo on our behalf.

Planyo stores data on Amazon AWS servers located in Switzerland. Switzerland is recognized by the European Commission as providing an adequate level of data protection.

Payment processing is handled by Stripe Payments Europe, Ltd., with registered office at 1 Grand Canal Street Lower, Dublin, Ireland. Stripe processes your payment details (card number, billing address) directly and securely. We do not store or have access to your full payment data. Stripe's processing is governed by their own privacy policy, available at stripe.com/privacy.

Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

5. Drysuit measurement form

The drysuit sizing form available on this website is powered by FormDesigner, a service provided by individual entrepreneur Shamshur Ivan Olegovich, Ukraine. The form is served from our own subdomain (drysuit-measurement.portofinodivers.com) and the measurement data you enter is transmitted to and stored by FormDesigner.

The transfer of data to Ukraine is governed by Standard Contractual Clauses (SCCs) as per Commission Implementing Decision (EU) 2021/914.

Legal basis: performance of a contract / pre-contractual measures (Art. 6(1)(b) GDPR).

6. Newsletter

If you subscribe to our newsletter, your email address is stored and processed by Acumbamail S.L., Avenida Rey Santo 3D, 13001 Ciudad Real, Spain. Acumbamail's servers are located in Spain (EU), so no international data transfer takes place.

Newsletter emails may contain tracking pixels that allow us to see whether an email was opened and which links were clicked. This information is used solely to evaluate and improve our newsletter. You can disable this tracking by setting your email client to not load remote images.

You may unsubscribe from the newsletter at any time by clicking the unsubscribe link included in every email.

Legal basis: your consent (Art. 6(1)(a) GDPR). You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Cookies

This website does not use tracking or analytics cookies. The only cookies set are strictly functional session cookies required for the booking process (Planyo). These cookies exist only for the duration of your session and are automatically deleted when you close your browser. No consent is required for these cookies under the ePrivacy Directive, as they are strictly necessary for a service you have explicitly requested.

8. Server logs

Our web server automatically records standard access log data: IP address, browser type, operating system, referring URL, pages visited, and date/time of access. This data is used exclusively for the security and technical operation of the website and is deleted on a rolling basis. It is not linked to any personal profile.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

9. Your rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you
• Rectify inaccurate or incomplete data
• Erase your data (“right to be forgotten”), where applicable
• Restrict processing in certain circumstances
• Object to processing based on legitimate interests
• Data portability where processing is based on consent or contract and carried out by automated means
• Withdraw consent at any time, without affecting the lawfulness of prior processing

To exercise any of these rights, contact us at info@portofinodivers.com.

You also have the right to lodge a complaint with a supervisory authority. In Italy, this is the Garante per la protezione dei dati personali (www.garanteprivacy.it).

10. Changes to this policy

We may update this policy from time to time to reflect changes in our services or legal obligations. The current version is always available on this page.