1. Introduction & Data Controller
Sunnypatchzyppy Mediterranean Travel Media Ltd. ("Sunnypatchzyppy", "we", "us", or "our"), operating the domain sunnypatchzyppy.homes, is committed to safeguarding the privacy and personal integrity of our global readership and concierge clients. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed in accordance with the European Union General Data Protection Regulation (EU Regulation 2016/679 - GDPR) and Italian Legislative Decree no. 196/2003 as amended.
Data Controller:
Sunnypatchzyppy Mediterranean Travel Media Ltd.
Company Registration No: IT-88492019-AMF
Registered Address: Via Panoramica 48, 84010 Positano (SA), Italy
Direct Privacy Officer Contact: [email protected]
2. Categories of Information We Collect
We only collect data strictly necessary to deliver high-quality editorial content, manage concierge inquiries, and ensure digital security:
- Directly Provided Information: When you submit an inquiry through our contact portal or newsletter subscription, we receive your full name, email address, chosen travel topics, and specific message text.
- Technical & Browsing Information: IP addresses, browser types, device operating systems, referring URLs, access timestamps, and page interaction times collected via server logs to prevent malicious attacks and maintain network resilience.
- Cookie & Local Storage Preferences: Consent markers recorded in your browser local storage (`localStorage`) to remember cookie preferences and avoid displaying redundant pop-ups.
3. Legal Grounds & Purposes of Processing
We process personal data under the following lawful bases permitted under Article 6 of the GDPR:
- Contractual Necessity & Pre-Contractual Steps: Responding to client inquiries regarding Amalfi Coast trip planning, guides, and concierge services requested via our contact form.
- Legitimate Interests: Protecting the technical integrity of our web servers, analyzing overall readership trends to improve travel guides, and defending against fraud or abuse.
- Explicit Consent: Where you opt in to receive editorial newsletters or allow optional analytic measurements.
4. Data Retention Periods
We maintain data retention protocols to ensure data is not stored longer than strictly necessary:
- Inquiry Correspondence: Retained for 18 months following the conclusion of communication to support follow-up concierge requests, after which it is permanently purged.
- Server Security Logs: Retained for a maximum period of 90 days for firewall monitoring before automatic cyclical deletion.
- Consent Records: Retained in client local storage for up to 365 days unless cleared manually by the user.
5. Sharing & International Transfers
We do not sell, rent, or trade your personal data with third-party advertisers. Data is only accessible to authorized technical staff under strict confidentiality. If technical cloud hosting infrastructure involves processing outside the European Economic Area (EEA), such transfers are governed by standard contractual clauses (SCCs) approved by the European Commission ensuring equivalent data protection safeguards.
6. Your Statutory Rights Under the GDPR
As a data subject, you possess enforceable legal rights regarding your personal data:
- Right of Access (Article 15): Obtain confirmation as to whether your data is being processed and receive a copy of your records.
- Right to Rectification (Article 16): Correct inaccurate or incomplete data concerning you.
- Right to Erasure / "Right to be Forgotten" (Article 17): Request deletion of your personal data when no longer required for legitimate purposes.
- Right to Restriction of Processing (Article 18): Restrict processing under disputed circumstances.
- Right to Data Portability (Article 20): Receive your data in a structured, commonly used, machine-readable format.
- Right to Lodge a Complaint: You have the right to lodge a formal complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali at www.garanteprivacy.it) or your local EU supervisory body.
7. Amendments to This Policy
We may update this Privacy Policy periodically to reflect changes in regulatory standards or site features. Continued use of sunnypatchzyppy.homes following posted revisions constitutes acknowledgment of the updated terms.