Video Surveillance Notice

1. Data Controller

1.1 The Data Controller, i.e. the entity responsible for decisions regarding the purposes and methods of personal data processing and the tools used, is Eleìra Luxury Accommodation, located at Via Cavour 5, 12060, Barolo CN, Tel. +39 338 188 1499, Email: eleira.barolo@gmail.com.

2. Subject

2.1 This notice is provided pursuant to and for the purposes of Art. 13 of the GDPR and EDPB Guidelines No. 3/2019, in order to provide you with information about the video surveillance systems, their use, and your rights.

2.2 The video-monitored areas are marked by clearly visible signs, placed in the immediate vicinity of the cameras.

3. Purposes

• Security protection against attempted theft, damage, and vandalism.
• Exercise of rights protected by law, whether in judicial or extrajudicial proceedings.

4. Legal Basis

• Legitimate interest of the Data Controller in preventing theft and protecting property, pursuant to Art. 6(1)(f) of the GDPR.
• Legitimate interest of the Data Controller in protecting its own rights, including the pursuit of criminal offences, pursuant to Art. 6(1)(f) of the GDPR.

5. Recipients of Personal Data

5.1 The recipients — i.e. the parties who may receive the personal data collected — are:

• Persons designated by separate act of the Data Controller, expressly authorised to access the premises where the monitoring stations are located, to operate the systems, and to view the footage, to whom specific instructions are given.
• Law enforcement personnel, such as Public Officials, Judicial Police, or the Judicial Authority, where they make an express request to the Data Controller and the latter is obliged to disclose the footage pursuant to a specific legal obligation.

5.2 The collected data is not further disclosed.

6. Retention Period

6.1 Images recorded for the above purposes are retained in full compliance with the specific regulations, for a period not exceeding 48 hours, save for further retention needs in connection with public holidays or office closures, or special retention needs due to Judicial Police investigations or requests by the Judicial Authority.

7. Categories of Data Processed

7.1 The processing concerns exclusively the video-recorded images captured by the installed cameras.

8. Methods of Processing

8.1 Personal data is processed using computer systems, configured by default to perform the processing as described in this notice.

8.2 The data is stored on digital media.

8.3 We also inform you that no automated decision-making process is performed on your data and no profiling is carried out regarding you.

9. Rights of Data Subjects

9.1 The persons to whom the above personal data refer (so-called "Data Subjects") have the right to exercise their rights in accordance with the methods and within the limits provided for by current privacy regulations.

9.2 In relation to the processing of your personal data, you have the right to ask the Data Controller for:

• Access: you may request confirmation as to whether or not processing of data concerning you is taking place, along with further clarifications regarding the information set out in this notice, as well as to receive the data itself, within reasonable limits.
• Rectification: you may request rectification or supplementation of the data you have provided to us or otherwise in our possession, where inaccurate.
• Erasure / right to be forgotten: you may request that your acquired or processed data be deleted, where it is no longer necessary for our purposes or where there are no ongoing claims or disputes, in the event of withdrawal of consent or your objection to the processing, in the case of unlawful processing, or where there is a legal obligation to erase it.
• Restriction: you may request restriction of the processing of your personal data where one of the conditions set out in Art. 18 of the GDPR applies; in such case, your data will not be processed, except for storage, without your consent, subject to the exceptions set out in paragraph 2 of that same article.
• Objection: you may object at any time to the processing of your data on the basis of a legitimate interest, unless we have overriding legitimate grounds to proceed with the processing, for example for the exercise or defence of legal claims in court.
• Portability: you may request to receive your data, or to have it transmitted to another controller indicated by you, in a structured, commonly used and machine-readable format.

9.3 You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) at <a href="https://www.garanteprivacy.it" target="_blank" class="underline">www.garanteprivacy.it</a>.