Newsletter
privacy notice.

The Data Controller is Direttiva Casa S.r.l., trading as ClouCasa^®, with its registered office at Via Maria Barbara Tosatti 31, 00137 Rome, Italy, tax code and VAT number 14157691008, certified email (PEC) direttiva.casa@legalmail.it.

The company is managed by Maria Ippoliti, sole director and legal representative.

For privacy enquiries, contact:

• Privacy email: privacy@cloucasa.it
• Certified email (PEC): direttiva.casa@legalmail.it

The Controller has not appointed a Data Protection Officer (DPO).

For any enquiry about the processing of personal data, you may contact the Controller directly at privacy@cloucasa.it.

The Controller processes personal data provided when subscribing to the newsletter, including:

• email address;
• first and last name, if provided;
• any data concerning interaction with emails, such as opens, link clicks, content preferences and similar information, only where specific consent to personalisation/profiling has been given.

References cited: Regulation (EU) 2016/679; Garante, 19 May 2011, doc. 1823148.

Personal data are processed for:

1. Managing newsletter subscriptions;
2. Sending informational and promotional emails about the Controller’s services, initiatives, updates, editorial content and commercial activities;
3. Any analysis of email interactions to personalise content and message frequency, only with separate, optional consent;
4. Handling requests to exercise rights, objections, withdrawal of consent and unsubscribe requests;
5. Establishing, exercising or defending the Controller’s legal claims, where necessary.

References cited: Regulation (EU) 2016/679; Article 130, Legislative Decree 196/2003; Directive 2002/58/CE; Garante, 19 May 2011, doc. 1823148.

The processing of data for newsletter and promotional emails is based on the subscriber’s prior, freely given, specific, informed and unambiguous consent.

If the Controller intends to personalise or profile communications, this requires separate, optional consent, distinct from the consent needed to subscribe to the newsletter alone.

The Controller must be able to demonstrate the consent given by the subscriber.

References cited: Regulation (EU) 2016/679; Article 130, Legislative Decree 196/2003; Garante, 19 May 2011, doc. 1823148.

Providing the data marked as necessary for subscription is optional, but without an email address the newsletter service cannot be activated.

Declining email marketing consent only prevents receipt of the newsletter. Declining profiling consent does not affect the ability to subscribe to the non-personalised newsletter.

References cited: Regulation (EU) 2016/679; Garante, 19 May 2011, doc. 1823148.

Subscription must involve an affirmative action, such as selecting a dedicated checkbox that is not pre-ticked.

The following do not constitute valid consent:

• silence;
• inactivity;
• pre-ticked boxes;
• combined or undifferentiated wording that bundles separate purposes together.

Procedures that document consent, including an email subscription confirmation system (double opt-in), are recommended.

References cited: Regulation (EU) 2016/679; Garante, 19 May 2011, doc. 1823148.

Outside newsletter subscriptions, the Controller may use a customer’s email address without obtaining fresh consent only within the strict limits of Article 130(4) of the Italian Privacy Code: in the context of the sale of a product or service, for communications about similar products or services, with an easy, free right to object.

This exception does not apply to merely registered users, general contacts, prospective customers who have not become actual customers, or addresses collected for other purposes.

References cited: Article 130, Legislative Decree 196/2003; Italian Supreme Court, Civil Division II, judgment 7555 of 15 March 2023.

Within their respective responsibilities, data may be processed by:

• the Controller’s authorised staff;
• collaborators and advisers assisting with marketing and communications;
• technology providers and newsletter, hosting, CRM, IT support and maintenance platforms;
• parties appointed, where necessary, as data processors under Article 28 GDPR;
• authorities or other parties entitled by law.

Personal data will not be publicly disclosed.

References cited: Regulation (EU) 2016/679.

As a general rule, data are processed within the European Economic Area.

If using technology platforms or suppliers requires a transfer to a third country, it will take place only under the conditions required by the GDPR and with appropriate safeguards.

References cited: Regulation (EU) 2016/679.

Personal data processed for newsletter purposes will be retained until consent is withdrawn or the subscriber exercises the right to object.

The Controller may also arrange periodic deletion or review of addresses that have been inactive for a prolonged period, applying the principles of proportionality and data minimisation.

References cited: Regulation (EU) 2016/679.

You have the right to:

• withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
• object at any time to processing for direct marketing, after which your data will no longer be processed for those purposes.

The right to object to direct marketing must be brought clearly to your attention and must be easy to exercise.

References cited: Regulation (EU) 2016/679.

You may unsubscribe at any time:

• by clicking the unsubscribe link at the bottom of each email;
• by writing to privacy@cloucasa.it.

Unsubscribing must be simple, free and prompt. An opt-out mechanism alone does not replace prior consent where consent is required by law.

References cited: Garante, 21 September 2017, doc. 7221917; Italian Supreme Court, Civil Division II, judgment 7555 of 15 March 2023.

Where provided for by the GDPR, you may exercise the rights of:

• access to personal data;
• rectification of inaccurate data;
• erasure;
• restriction of processing;
• objection;
• data portability, where applicable;
• withdrawal of consent at any time.

To exercise your rights, write to:

• privacy@cloucasa.it
• direttiva.casa@legalmail.it (certified email / PEC)

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).

References cited: Regulation (EU) 2016/679.

Unless specifically stated otherwise, newsletter subscription data are not subject to decisions based solely on automated processing that produce legal or similarly significant effects on you.

If profiling is introduced to personalise content, it will take place only with specific consent and a dedicated or supplemented privacy notice.

References cited: Regulation (EU) 2016/679; Garante, 19 May 2011, doc. 1823148.

Communications must be clearly identifiable as coming from ClouCasa^® / Direttiva Casa S.r.l., without concealing the sender’s identity, and must include a valid contact address for requests to stop further messages.

References cited: Directive 2002/58/CE.

This notice may be amended or updated, including following changes in legislation, organisation or technology. The updated version will be made available through subscription channels or communicated separately.