Privacy notice.

Data controller

The controller is PICIACIA di Vasini Piero & C. S.n.c., registered office at Via Adriatico 49, 47814 Bellaria-Igea Marina (RN) and place of business at the PICIACIA - Spiaggia 46 beach establishment, Via Cristoforo Colombo, 47814 Bellaria-Igea Marina (RN), Italy; VAT number IT03807680404; tax code (codice fiscale) and Companies Register number of Romagna – Forlì-Cesena e Rimini: 03807680404; REA no. RN-309400 (Economic and Administrative Index). For any question about your data, write to info@piciacia.it or call +39 0541 344888. We have not appointed a data protection officer (DPO) because we are not required to: we are not a public body, and our activity does not consist of regular and systematic monitoring of people on a large scale or of processing special categories of data on a large scale (Art. 37 GDPR).

What data we process

The data you give us in the forms, by email, by phone or on WhatsApp: name, email address, phone number, the dates and details of your request (for example umbrellas, sunbeds, chairs and deckchairs, or whether you are bringing your dog), the text of your messages and the language you write in. If you book, also the spot and row assigned, the list price and the agreed price, any deposit (caparra confirmatoria) and, if you use it, the arrival confirmation you give us from the reminder. We also note how your request ended (see below). If you ask us for a change from the “Would you like to change something?” page, also what you ask for (new dates or places, cancellation or something else), the message you write, the day and time of the request and what the booking was like at that moment. When you arrive at the beach we may note the day and time of your arrival and which member of our staff recorded it. If you have paid something in advance, the data of the booking PDF with its verification code (see below).

If you pay online: the amount, what you pay for, date, outcome and any refunds, with the payment codes assigned by PayPal. We never receive your card or PayPal account details; in our PayPal account we see, as for every payment received through PayPal, the name and email of the account or card you paid with. In our payments register we record online payments, deposits (caparra confirmatoria) paid by bank transfer, gift vouchers however they are paid (online, at the beach or by bank transfer) and refunds: amount, date, payment method, what they relate to and their references (for a bank transfer, the payment reference and the day the amount reached our account). If you pay by bank transfer (the deposit or a gift voucher), we see on our account, as our bank statement shows them, the name and IBAN of the person making the transfer, the payment reference, the amount and the date. If you send us the transfer receipt, by email or on WhatsApp, we use it only to check the payment and keep it like the other attachments of your messages. If we have to refund you by bank transfer (for example a deposit paid by bank transfer), we ask you, by email or in a message, for the IBAN and the holder of the account to receive the refund: we use them only for that refund. They remain in the message you send them in, which we keep with your request, and in the records of the refund transfer, which we keep for the period required by accounting and tax obligations (see “How long we keep it”). IBANs the system recognises in messages are never sent to the artificial intelligence service (see “How we reply: drafts prepared with artificial intelligence”).

If you buy a gift voucher: the buyer’s name, email and, if given, phone number, the recipient’s name and the message to write on the voucher, the amount, the payment method, the voucher code, its expiry date and its use. If you choose to have it sent straight to the recipient, also their email address, the language and the day of sending, with the outcome of the delivery (for example if the email bounces). We produce the voucher’s PDF ourselves: it shows the recipient’s name, the message, the code, a QR code and the expiry date and, only if you so choose, the amount; this choice needs no further data. The QR code is for our staff: it opens the voucher’s record in our internal panel, which only authorised people can access. If you buy the voucher on this website you also give us your first and last name, address and country of residence and, if you live in Italy, your Italian tax code (codice fiscale) (if you live abroad, your country’s tax number, if you wish). Your name appears on the voucher as “from …” and our staff see it like the voucher’s other details; your address, country and tax code do not appear on the voucher, the recipient does not see them, and in our system they are stored encrypted, visible only to the controller.

If you enter a gift voucher code in the booking form: the code, which we use only to check the voucher and take it into account for your booking.

If you ask for an invoice: the data needed to make it out, which we ask only of those who request an invoice and only as far as your case requires: name and surname or company name, Italian tax code (codice fiscale) or VAT number (for those abroad, any tax ID of their country or the VAT number with the country prefix), address or registered office, country, email and, if you give them, PEC address and SDI recipient code. Which data is needed in each case is explained in the booking terms, under “Invoices”.

If you order Extras for your arrival: the products, the quantities, the gift note you write and which member of staff delivered them. For products containing alcohol we ask you to declare that you are at least 18: without the declaration the order cannot be placed, and we do not keep it as a separate item.

If you answer the “Welcome back” invitation: your answer (“Yes, I would like to come back” or “Not this year”) and, if you give them, dates, services and message. If you use the “Yes, I’m interested” link in our emails: the proof of consent (see below).

The technical data needed to run and protect the site: IP address, date and time, page requested and browser type, logged by the server. To limit abuse of the forms we use the IP address only in pseudonymised form, as a pseudonymous code, computed with a secret key, from which the address cannot be read, and delete it within 48 hours.

We do not ask for special categories of data, for example about health. If you choose to tell us, for instance for an accessibility need, we use them only to meet that need, on the basis of the explicit consent you give by writing them to us (Art. 9(2)(a) GDPR); you can ask us to delete them at any time. Like the rest of the conversation, these texts may also go through the artificial intelligence service described below.

Data about other people

If you also write on behalf of other people (for example family or friends coming with you), only give us the data that is needed, and only after telling them about this notice: you share their data under your own responsibility. Any data about children you mention (for example their age) is used only to organise the stay. The same applies to the name of the person you give a voucher to and to your message: you give them to us, so please tell that person (you can point them to this notice). We use them only to produce the voucher and its PDF, and keep them with the voucher (see “How long we keep it”). If you ask us to send the voucher straight to the recipient, it is you who gives us their email address, not the recipient: you declare that you are entitled to do so. We use it only to deliver the gift on your behalf, with the voucher email on the chosen day, never for offers or any other communication; the legal basis is the performance of our contract with you and our legitimate interest in delivering the gift you bought (Art. 6(1)(b) and 6(1)(f) GDPR). In the gift email we tell the recipient who we are, who the gift is from and where to read this notice (Art. 14 GDPR); they can object or ask us to delete their address by writing to info@piciacia.it. We keep it with the voucher and delete it together with your data (see “How long we keep it”).

Why we process it and on what legal basis

To answer your enquiries and quote requests, handle your booking and your stay on the beach, and email you the booking summary and a reminder a few days before arrival: processing is necessary to act on your request and on the contract (Art. 6(1)(b) GDPR). If we send you a quote and you do not reply, a few days later (usually 4) we write to you once, by email or, if you only wrote to us on WhatsApp, with a short WhatsApp message, to ask whether you still need it: it is a message about your request, with no prices or offers.

To comply with legal obligations, for example tax and accounting rules (Art. 6(1)(c)).

To handle online payments and bank transfers, refunds (also by bank transfer, with the IBAN you give us) and any disputes, to send you the emails or messages confirming payments and refunds (for example “Bank transfer received”), to issue, send (also to the recipient, if you ask us to) and honour gift vouchers (with their PDF) and to prepare and deliver Extras: the processing is necessary for the contract (Art. 6(1)(b) GDPR); for the accounting of payments, refunds and vouchers (our payments register) and for checking age for products containing alcohol, to comply with the law (Art. 6(1)(c)).

For the data of whoever buys a gift voucher on this website (name, address, country and tax code): to know for certain who bought and paid for the voucher and to handle our relationship with you (withdrawal, refunds, a voucher lost or in the wrong hands), on the basis of the contract (Art. 6(1)(b) GDPR), and to prevent payment fraud and defend our rights in case of a dispute (legitimate interest, Art. 6(1)(f)).

If you fill in the form to buy a gift voucher but do not complete the PayPal payment, we may send you a single email, between 2 and 24 hours later, to remind you that the purchase was not completed, with the link to complete it. It contains no offers or promotions and is never repeated; we do not send it if you have told us not to email you. The legal basis is our legitimate interest in helping you complete a purchase you started (Art. 6(1)(f) GDPR): it is not a promotional message and does not fall under Art. 130(4) of the Italian Privacy Code. You can object at any time, with the link in that email or by writing to info@piciacia.it (Art. 21 GDPR). We delete the data of a purchase never paid for after 90 days (see “How long we keep it”).

For the invoice, if you ask for one: handling your request is necessary for the contract (Art. 6(1)(b) GDPR); issuing the electronic invoice, sending it through the Exchange System (Sistema di Interscambio, SdI) and keeping it in our accounts is a legal obligation (Art. 6(1)(c) GDPR; Presidential Decree 633/1972).

To keep the site and the system secure, prevent abuse and automated submissions and, if needed, establish, exercise or defend our rights (legitimate interest, Art. 6(1)(f)).

To email you offers and news from PICIACIA - Spiaggia 46 (offers for returning guests, opening of bookings, news of the season): if you tick the optional box, on the basis of your consent (Art. 6(1)(a) GDPR and Art. 130 Italian Privacy Code); if you have booked with us, even if you have not ticked the box, but only for services similar to those you booked and at the email address you gave us (Art. 130(4) Italian Privacy Code; legitimate interest, Art. 6(1)(f) GDPR). As a customer you can refuse them right away in the booking form, with the box provided. In both cases you can opt out at any time, free of charge and with no effect on your bookings: with the link in every email or by writing to info@piciacia.it. Withdrawal does not affect what was done before. We never use your phone number for offers.

The “Welcome back” invitation: before the summer we may send you an email asking whether you would like to come back, with no dates or prices. It is an offer like the others: we send it only to people who have already stayed with us and may receive our offers (consent, or a customer who has not refused them, as explained above), from our address info@piciacia.it, in the language of your last stay and with a link to stop receiving them. If you answer “Yes”, we open a request as if you had written to us; if you answer “Not this year”, we simply note it. Answering is optional.

Consent given through the link in our emails: if you cannot yet receive our offers (you have not given consent and are not a customer) and have not opted out, our replies may end with a line “Would you like to receive our offers before anyone else? One click: Yes, I’m interested”. The link opens a page asking you to confirm: opening it is not enough, only your click on the button counts as consent (Art. 6(1)(a) GDPR, Art. 130 of the Italian Privacy Code). As proof we record the day, the time, the text you accepted and that the consent came from the email link. If you opted out in the past, the link does not put you back on the list: to come back, write to us from the same address.

To ask for your opinion on your stay, if you have booked with us: the day after departure we send you a single email with a short satisfaction survey, with no reminders. We do so under Art. 130(4) of the Italian Privacy Code (we tell you when you give us your email to book and in every email, and you can refuse it) and on the basis of our legitimate interest in improving our service (Art. 6(1)(f) GDPR). Answering is optional. We do not send it if you have opted out of our emails; you can refuse it right away in the booking form, with the link in every email or by writing to info@piciacia.it. How we handle the answers is explained in the section “The survey after your stay”.

To run our business: we keep one record per email address (name, phone, language, number of requests and bookings, dates of the first and last contact), so that we recognise you when you come back; we note how each request ended and, if a request for a stay does not become a booking, the reason (for example “no further reply”, “price”, “chose another beach”) and the estimated amount of our offer. A request for a stay that has been waiting for your reply for 10 days is closed automatically, without sending you anything: if you write to us again, it reopens. These notes stay internal, are not used to assess you and have no effect on you (legitimate interest in organising and improving our work, Art. 6(1)(f) GDPR).

Emails you write directly to info@piciacia.it, without using the forms, reach our mailbox like any email. If you reply to one of our emails, or if you already have a recent request, or a booking still to come, from the same address, the system adds them to that request by itself; otherwise they become a request only when the manager of the beach decides that you are a guest (or that the email concerns your request). In either case the name, address, text and language of the email go into the request and into the record of your address, as for requests from the website, and Claude prepares a draft reply (see below). We do not store email attachments on our server: in the request we note the name, type and size of the file, and we read the file from our Gmail mailbox when we open it (our server keeps a temporary copy of it only for as long as it takes to show it). The same goes for the files we send you by email: we read them again from the copy in our mailbox’s “Sent” folder. Attachments are never sent to the artificial intelligence service. Until then the system reads them from the mailbox only to show them to the manager of the beach, without saving them; for those marked “Not a guest” (for example suppliers or advertising) it keeps only the internal code Gmail gives the email, for 60 days, so as not to show them again (legitimate interest in handling our correspondence, Art. 6(1)(f) GDPR). To notice them quickly, the system checks the mailbox about every 15 minutes and alerts the manager of the beach with a phone notification that only says how many new emails there are, without names or texts, and never between 10 pm and 8 am. If a sender is marked “Not a guest” for future emails too, we keep a fingerprint of their address (a code computed with a secret key, from which the address cannot be read) and the name it showed, so as not to show their emails again (same legitimate interest).

Calendar and Wallet pass: if you choose to add your booking to your calendar, to Apple Wallet or to Google Wallet, we prepare the file and the pass on our server with the booking details (in the calendar the dates, service, row and spot, and the payments; in the Apple Wallet pass also name and price; in the Google Wallet pass the dates, service, spot, payments and a code, without your name, email or phone). The pass updates itself. With Apple Wallet your iPhone registers a device code and a notification code with our server: we use them only to tell it, through Apple’s notification service (which receives that code and no booking details), to download the new version. With Google Wallet we write the pass with Google, which handles it under its own terms. During your stay the pass also shows the weather and the sea temperature (data from Open-Meteo.com, read by our server: none of your data reaches Open-Meteo), the flag and the beach notices. The device codes and the pass data on our server are deleted one week after the end of your stay; once on your phone, your calendar and the Wallets handle the data under their own terms (for example iCloud sync). The pass may show a notice when you are near the beach: your phone decides this, we do not receive your location (contract, Art. 6(1)(b) GDPR).

The “Would you like to change something?” page: in the booking summary and in the reminder you will find a personal link that opens a page where you can ask us to change dates or places, to cancel the booking (only before arrival) or something else. The request goes into the conversation of your booking and is read by a member of our staff: the booking does not change until we confirm the change to you by email. If the change raises the price, the confirmation email may contain a link to pay the difference with PayPal, or you pay it at the beach on arrival (contract, Art. 6(1)(b) GDPR).

The booking PDF: if you have paid something in advance (a deposit, the full price, with a gift voucher or online), we attach to the summary and to the email confirming the payment a PDF with the booking details (name, dates, service, spot, price, what you have paid and what is still to pay), a verification code and a QR code. On our server we keep a copy of that data, so that we can check that a PDF shown to us is genuine and up to date: anyone who has the code can also check it on the verification page of our website, which shows the first name with only the initial of the surname, the dates, the service, the spot and the amounts, never email or phone. When you arrive, our staff may scan the QR code to find the booking and record your arrival; to do so even without a network, the device our staff use to read the codes keeps an up-to-date copy of only that day’s data needed for the check, without email or phone, deleted when they leave the panel. The PDF is not a tax document (contract, Art. 6(1)(b) GDPR, and legitimate interest in preventing forged or altered documents, Art. 6(1)(f)).

Do you have to give us your data?

No. But without the data marked as required (with an asterisk) we cannot answer or handle your request. Consent to offers is always optional. The invoice data is required by law: without it we cannot issue an invoice, and you receive the ordinary sales receipt. The recipient’s email address is needed only if you want us to send them the voucher. To buy a voucher on this website we also need your name, address and country and, if you live in Italy, your Italian tax code: without them, you can buy the voucher at the beach or by writing to us.

How we reply: drafts prepared with artificial intelligence

To reply faster we use an artificial intelligence service, Claude, provided by Anthropic. When a request or a message from you arrives, the system sends Anthropic your name, your language, the dates and services requested with our quote, if you have already booked the booking details (dates, services, spot, agreed price and what you have already paid) with the change you ask for from the “Would you like to change something?” page, the text of the latest messages of the conversation (including our internal notes on that request) and any instructions from our staff. Claude prepares a draft reply and, where needed, translates the messages, including our replies. The quote is not calculated by the AI but by our own system, from our price list. If you entered a gift voucher code in the booking form, we tell Anthropic only whether the voucher can be used, with its value and expiry date (or why it cannot), never the code.

Before sending, the system automatically masks the email addresses and phone numbers in the texts; if it cannot, no draft is requested. The rest of the text is sent as written: that is why we ask you not to send us any data your request does not need.

The draft is only a suggestion: every reply is read, corrected where needed and sent by a member of our staff. We take no decision based solely on automated processing (Art. 22 GDPR).

Anthropic (Anthropic Ireland, Limited, Dublin, which relies on Anthropic, PBC, in the United States) processes this data as our processor (Art. 28 GDPR), under its data processing agreement. Under its commercial terms it may not use the data to train its models; it deletes requests and responses within 30 days, except where it must keep them longer to enforce its usage policy or to comply with the law.

We also use Claude to read our price list and to translate our own texts (for example the automatic emails and the survey questions): in those cases it receives no guest data. In addition, we use it to answer our staff’s questions about the figures in our system (for example how many bookings there are in August): Claude receives the question, without email addresses or phone numbers, and only totals and counts, never lists of guests.

Our staff may dictate the instructions for a reply: the voice is turned into text by the speech recognition of the phone or browser (for example Apple’s or Google’s), under their own terms. We receive only the text, never the audio, and keep it only together with the draft. For reply instructions we ask our staff not to dictate email addresses or phone numbers.

Our staff may also dictate a booking taken on the phone. As with reply instructions, the voice is turned into text by the speech recognition of the phone or browser (for example Apple’s or Google’s), under their own terms, and we receive only the text. The text is sent to Anthropic only to fill in the fields of the booking (name, dates, services, spot, the price stated by our staff), after the system has masked the email addresses and phone numbers it recognises, also when spoken, which it fills in itself; our staff always check them before saving. The price is never decided by the artificial intelligence, and a member of our staff checks and saves the booking. The dictated text is not kept.

If you write to us on WhatsApp

You can also write to us on WhatsApp, at +39 0541 344888, the same number as the beach’s phone. Your messages, your number and your WhatsApp profile name reach us through Meta’s WhatsApp Business Platform, the business service of WhatsApp provided by Meta Platforms Ireland Limited (Dublin), which processes this data as our processor (Art. 28 GDPR) under its own data processing terms. For any transfer outside the European Union, Meta relies on the EU-U.S. Data Privacy Framework and on standard contractual clauses (see “Transfers outside the European Union”).

We keep your messages in our request system together with your request, just like emails, and for the same period as other requests (see “How long we keep it”). Photos, videos, voice messages and documents you send us are, as a rule, not stored on our server: in the request we note the name, type and size of the file, and we view the file from WhatsApp, which keeps it only for a limited time (about 30 days). If we need a file for your request (for example the receipt of a bank transfer), we may keep a copy of it on our server together with the request: we delete it with the request, when the request is anonymised at the end of the retention period (see “How long we keep it”) or if you delete the message on WhatsApp. When we open a file, our server keeps a temporary copy of it only for as long as it takes to show it. The files you send us are never sent to the artificial intelligence service. In the same way we keep reactions (emoji) to messages, the reference to the message you are replying to, the answers you give with the buttons of our messages (for example “Yes, I confirm”), your location if you send it to us, and the delivery and read status of our messages. The reminders and notes we add to your request are internal: we do not send them to you.

To prepare a draft reply, the text of the conversation may be processed by Claude (Anthropic) exactly as for emails, but never together with your phone number, which the system removes before sending (see “How we reply: drafts prepared with artificial intelligence”).

The legal basis is taking the steps you ask us to take before a booking and performing the booking itself (Art. 6(1)(b) GDPR), together with our legitimate interest in replying to you and following up your request (Art. 6(1)(f) GDPR).

We never use WhatsApp for advertising and never add you to any list: we write to you on WhatsApp only about your request or your booking. We reply to your messages; we may send you the deposit request with its payment link and a reminder before its deadline (if we offer you the bank transfer, also with our bank details); we may write to you again about your request, for example to ask whether you still need a quote you have not answered. Once 24 hours have passed since your last message, WhatsApp only allows us to write to you with message templates approved by WhatsApp: we use them only to write to you about your request, never for offers or messages sent to everyone. If you no longer want us to write to you on WhatsApp, tell us at any time, including by replying to one of our messages, and we will stop writing to you there. You can also block our number in WhatsApp.

The messages we exchange on WhatsApp are also subject to WhatsApp’s own privacy policy: for its own service, WhatsApp Ireland Limited (Meta group) acts as an independent controller, possibly with transfers to the United States (www.whatsapp.com/legal).

The survey after your stay

We store the survey answers separately from your data: without your name, email, booking, language, time or IP address, under a random code and only with the season and month of your stay. In the booking we only note that you answered, so that we do not ask you again. New answers appear in our system all together once a day, not at the moment you send them, and only the management of the beach can read them, not our other staff.

We do not call them anonymous because in some cases an answer could still be traced back to you: for example if there were few guests in the same month, or if you write something in a comment that makes you recognisable (a name, your umbrella number, a specific episode). That is why we ask you not to write personal data in the text fields. We make no attempt to link answers to guests and we do not use the server’s technical logs for that purpose.

Since we cannot attribute an answer to a person, we cannot act on requests for access, rectification or erasure of survey answers unless you give us information that allows us to recognise yours (Art. 11 GDPR).

After you send it, we may invite you to leave a Google review as well; we offer nothing in return. The review is published by Google (Google Ireland Limited) as an independent controller, with the name of your Google account and under its own privacy policy.

Who can see your data

Within the beach, only the members of staff we authorise to handle requests and bookings can see your data, each of whom has a personal login, has been trained and is bound by confidentiality. Every login and every action that changes data is logged with the name of the person who did it; the replies you receive are signed with the name of the person who wrote them. Our staff cannot export lists or delete data. We do not publish, sell or pass on your data to third parties for their own purposes.

To run the service we rely on a few providers who process the data only on our behalf and on our instructions (processors, Art. 28 GDPR): DigitalOcean, which hosts the site and the request system on a server in London and keeps its backup copies; Google (Google Ireland Limited, Google Workspace service), which runs the info@piciacia.it mailbox through which we receive and send emails; Meta (Meta Platforms Ireland Limited, WhatsApp Business Platform), which delivers the WhatsApp messages you send us and those we send you (see “If you write to us on WhatsApp”); Anthropic, for the drafts and translations described above. For invoices and other tax and accounting obligations we share the necessary data with our accountant (tax adviser), who processes it as our processor or, for the tasks they carry out independently as a professional, as an independent controller, and with the provider of the software we use to issue electronic invoices (processor). The electronic invoice goes through the Exchange System (SdI) of the Italian Revenue Agency (Agenzia delle Entrate), which receives it and processes it as an independent controller for its own tax purposes, and reaches the SDI recipient code or PEC address you gave us, if any. If we use a newsletter service to send offers (for example Brevo or Mailchimp), it receives only the email, name and language of those who may receive them and the reason why (consent or customer).

For online payments we use PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg). We do not give PayPal your name or email: only the amount, a description (for example “Beach stay”) and a code of ours. The data you enter on its page (account, card, name, address) is processed by PayPal as an independent controller under its own privacy statement (www.paypal.com), including for its own anti-money-laundering and anti-fraud obligations; PayPal tells us the outcome of the payment. For bank transfers (for a gift voucher, for the deposit or for a refund), the transfer details are processed by your bank and ours, each as an independent controller, including for its own legal obligations.

If you add your booking to Google Wallet, the pass (dates, service, spot, payments and a code, without your name, email or phone) is kept by Google (Google Ireland Limited) to show it on your phone, under the Google Wallet terms.

When a request arrives, our staff receive a notification on their phone or computer showing the name and the dates requested, never the text of the message. The notification travels encrypted through the push service of the device or browser maker (for example Apple, Google, Mozilla, Microsoft), which cannot read its content.

When an online payment arrives, or our staff mark a bank transfer as arrived, the notification to our staff also shows the amount and what was paid for.

If you gave us your number, we may also reply by phone, text message or WhatsApp (see “If you write to us on WhatsApp”); if you would rather we did not contact you on WhatsApp, please say so in your request.

If you call the beach’s number, our switchboard may record the number you call from, the date, the time, the length of the call and who answered and, if the number is already in our records, your name and your latest booking, and show them to our staff, also as a notification on their phone: we use this to call you back and to link the call to your request or booking (legitimate interest, Art. 6(1)(f) GDPR). We never record what is said. If you call with a hidden number, we do not see it.

We disclose data to public authorities only where the law requires it.

Transfers outside the European Union

The server hosting the site and the request system is in London, in the United Kingdom: the European Commission has recognised that the United Kingdom ensures an adequate level of protection (adequacy decision, renewed until 2031). Its provider, DigitalOcean, is a US company: any access from the United States is covered by the standard contractual clauses of its data processing agreement.

Google, Meta, Anthropic, the notification services and any newsletter service we use may also process data outside the European Union, in particular in the United States. The transfer only takes place with the safeguards required by the GDPR: for Anthropic, the standard contractual clauses approved by the European Commission (Art. 46 GDPR) included in its data processing agreement; for the other providers, the European Commission’s adequacy decision for companies certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR) or, failing that, the standard contractual clauses. You can ask us for a copy of these safeguards at info@piciacia.it.

PayPal, as an independent controller, may transfer data outside the European Union with the safeguards described in its own privacy statement.

How long we keep it

Requests, conversations and bookings, with the related internal notes: up to 5 years from your last contact with us (your last message, booking or stay). This way, if you come back every summer, we still know your history, and we can defend ourselves in case of a dispute. After that period your name, contact details and texts are deleted; only dates, quantities, amounts and the outcome of requests remain, anonymised, for statistics. The emails we exchanged with you in our mailbox, with their attachments, are deleted within the same period. The WhatsApp messages we keep with your request, and the copies of files we have kept, follow the same rule.

Invoices and other tax and accounting documents, with the data you gave us for the invoice: 10 years (Article 2220 of the Italian Civil Code), or longer if by then a tax assessment for the year they relate to is not yet final. An invoice request marked as not needed, or linked to a purchase that was never completed, is deleted, with its data, after 90 days.

Offers by email: until you opt out (withdrawal of consent or objection). After that we keep only your email address with the dates of your consent and of your objection, as proof and so that we do not write to you again, for up to 5 years from the last contact or from your objection, whichever is later; after that only an encrypted fingerprint of the address, from which the email cannot be read back, so that we never write to you again. If you gave us your consent, you stay on the list until you opt out, and in any case for no longer than 5 years from your last contact with us.

Survey answers: the ratings, which contain no data identifying you, are kept to compare seasons; the comments written in the free fields for at most 5 years from the end of the season they refer to.

Switchboard call log (number, date, time, length, who answered and, if the number was already in our records, name and latest booking): 90 days, then it is deleted automatically; if we erase your data at your request, the name and booking disappear from the log at once.

Online payments, deposits paid by bank transfer, refunds and gift vouchers, including vouchers paid at the beach or by bank transfer (our payments register): amounts, dates, payment method, outcome, payment and voucher codes and their uses for the period required by tax law (usually 10 years, Article 2220 of the Italian Civil Code). For the same period, the details of the transfers we receive and of our refund transfers (name and IBAN of the payer or of the person receiving the refund, payment reference, amount and date) remain in our bank statements and accounting records. The voucher buyer’s name, email and phone number, with their address, country and tax code if they bought it on this website, the recipient’s name, their email address (if you asked us to send them the voucher) and the message: up to 5 years after the voucher expires or was used, whichever is later; then they are deleted and the voucher’s record remains only in anonymised form, with the accounting data. If a voucher that was asked for is never paid, the names, phone number, email and postal addresses, tax code and message are deleted after 90 days without activity, together with the conversation of the request, unless it holds anything else (for example a booking). Any invoices follow the rule for invoices.

Extras orders: together with the booking; the gift note is deleted when the booking’s name and contact details are deleted.

“Welcome back” invitations and answers: for the two seasons following the invitation, then deleted; if we delete your record, they are deleted at once. If you answer “Yes”, the request that opens follows the rule for requests.

Proof of consent given through the link in our emails: like the other consents (see “Offers by email”). Emails marked “Not a guest”: only Gmail’s internal code, for 60 days. WhatsApp numbers marked “Not a guest” (for example suppliers or acquaintances): only the number and the name it showed, so that its messages no longer open requests, for 5 years from when we marked it. Email senders marked “Not a guest” for future emails too: the fingerprint of the address and the name it showed, for 5 years from when we marked them. Copy of the booking PDF data and requests made from the “Would you like to change something?” page: as long as the booking; when we remove the names from the booking, we also remove the name from the copy and the message from the request. Our staff’s questions about the figures of our system and their answers: 12 months.

Site statistics: the detail of visits (pages, source, buttons pressed and, only with your consent, the link to a request) and the counts of requests received without consent (by day, kind of form and source) 14 months, then only the daily totals by source remain, without any code; the counter’s anti-abuse code within 48 hours.

Technical and security data: only as long as strictly necessary, usually no more than 12 months for the access logs of the system, 30 days for the web server logs (which contain the IP address) and 48 hours for the anti-abuse limits.

Backup copies: every night we make an encrypted copy of the database, kept for 7 days; in addition, the server provider keeps a weekly copy of the whole server for 4 weeks. Deleted data therefore also disappears from the copies within 5 weeks.

Longer only if needed to establish, exercise or defend a right in a dispute, and only for as long as necessary.

Site statistics

We count visits to the site ourselves, on our own server: no Google Analytics or other third-party service, and no cookies. For every page you open, your browser sends us a short message with: the page’s address and its language; on the first page of a visit, the site you came from (referrer) and any campaign tags in the link (utm_source, utm_medium, utm_campaign) or the type of ad click (gclid, fbclid or msclkid: only its name, never its value); your browser’s language and time zone, from which we estimate the country; the screen width, used only to tell phone, tablet and computer apart. When you leave the page it tells us how long the page was visible (at most 30 minutes per page); when you press WhatsApp, the phone, the email or a Google Maps link to our listing or to a route to us, it tells us which; when you start filling in the booking, contact or gift voucher form, it tells us which form. Of every message we keep the day and the hour, the hour only, without minutes or seconds. The browser does not tell us that a form was sent: we count it ourselves, on the server, when the request arrives (see below).

The counter does not keep your IP address: it uses it only for a moment, to stop abuse (too many messages from the same address), turned into a pseudonymous code, computed with a secret key, from which the address cannot be read, deleted within 48 hours. Like every request to the site, these messages also pass through the web server logs (see “How long we keep it”). Automated programs we recognise, for example those of search engines, are not counted. We build no profiles for advertising and do not use these data for advertising.

To recognise the pages of one visit, your browser keeps a random visit code in the tab (sessionStorage): after 30 minutes without activity a new visit starts, and the browser deletes the code when you close the tab. If you send us a booking request, a message or a gift voucher purchase from the site, the form also sends this code and says whether you had accepted the statistics at that moment. Without your consent the request is only counted by day, kind of form and source of the visit, without marking it on the visit and without recording which request it was.

Only if you accept it in the “Site statistics” notice, your browser keeps a second random code in its local storage (localStorage), replaced by a new one after 13 months: it lets us recognise that a later visit comes from the same browser and, if you send us a request from the site while your consent is on, link it to the visit it came from (where you came from and which pages you saw), so that we understand which channels bring us bookings. If you accept during a visit, the code is added to that visit from the next page you open. On our server we keep only a fingerprint of it, computed with a secret key. If you refuse, close the notice or your browser sends the Global Privacy Control signal, the code is not created and any code already there is deleted; if you withdraw your consent after giving it, the current visit ends and a new one starts, without the code, and the requests you send from then on are no longer linked to a visit. Your choice stays in the browser, with its date, and after 13 months we ask you again; you can change it at any time with “Statistics preferences” at the bottom of every page.

We keep the detail of visits for 14 months; then only the daily totals by source remain, without any code, and a request no longer stays linked to a deleted visit. The data stay with us, on our server (see “Transfers outside the European Union”), and we share them with no one; when we ask for an analysis of the statistics, only the totals (never codes, never people’s names) may be read by the artificial intelligence service described in “How we reply: drafts prepared with artificial intelligence”.

Legal basis: for the count, our legitimate interest in knowing how the site is used and where requests come from (Art. 6(1)(f) GDPR); the visit code in the tab serves only these statistics, made by us and not shared with third parties, which under the Italian data protection authority’s guidelines on cookies and other tracking tools of 10 June 2021 do not require consent. You can still object by writing to info@piciacia.it. We use the code in local storage, and the link between a request and its visit, only with your consent (Art. 6(1)(a) GDPR and Article 122 of the Italian Privacy Code), which you can withdraw at any time with “Statistics preferences”, free of charge and without consequences; withdrawal does not affect what was done before.

Search engines

To be found, we use the search engines’ tools: the site holds the verification files with which Google, Bing and other engines check that the site is ours and, when we publish a new version of the site, we may notify them with the IndexNow protocol, sending them only the addresses of the site’s pages. We also publish a summary of the site for search engines and artificial intelligence assistants (/llms.txt and /llms-full.txt), with only the information already on the pages. In none of these cases do we send any visitor data.

Cookies and external services

The site uses no profiling cookies and no cookies for statistics. In your browser we only store: your choice about statistics, with its date; the visit code in the tab and, if you accept it, the code that recognises the browser (see “Site statistics”); for the length of your visit, your position on each page, so that you return to it when you navigate back; if you chose it, that you prefer to see the Google map. Fonts and images are hosted on our own server.

The only exception is Google’s interactive map on the Contact page, and only if you choose it. By default that page shows a map drawn by us, which contacts no outside service. If you press “Show the Google map”, your browser downloads the map, with its fonts and images, from Google’s servers, and Google (Google Ireland Limited) receives some data, such as your IP address, and may use its own cookies or similar tools. Google processes it as an independent controller under its own privacy policy (policies.google.com/privacy), including transfers to the United States; the legal basis is the consent you give with that click (Art. 6(1)(a) GDPR). Your browser remembers your choice, without cookies, so that the Google map also appears on later visits; you can withdraw it at any time with “Back to the drawn map”. Our address, phone number and email are also at the bottom of every page.

The site also has plain links to our Instagram and Facebook profiles, to our Google Maps listing and to other sites, such as Google Maps for routes: they are only links, they load nothing and send no data to those sites until you open them. If you open one, you enter the destination site, which processes your data as an independent controller under its own privacy notice.

How we protect your data

The site and the forms use encrypted connections only (HTTPS). Only authorised people can access the request system, each with a personal login: with a passkey (for example Face ID or Touch ID) or, for the management of the beach, with a password and a one-time code; every login is logged. The access keys to external services are kept outside the public part of the server, and those entered through the request system are encrypted; the nightly copies of the database are encrypted. Notifications on our staff’s phones show only the essentials (for example name, dates, amount or the caller’s number), never the text of messages. No measure is infallible: should a personal data breach occur, we will act as required by Articles 33 and 34 GDPR.

Your rights

At any time and free of charge you can ask us for access to your data and a copy of it, its rectification or erasure, restriction of processing and data portability, and you can object to processing based on legitimate interest (Arts. 15–21 GDPR). You can object at any time, without giving reasons, to offers and to the survey, including those you receive because you booked (Art. 21(2) and (3)), and withdraw the consent given with the box (Art. 7(3)): with the link in every email or by writing to info@piciacia.it. Once you have opted out, to protect you, ticking the box on the website is no longer enough to put you back on the list: if you change your mind, write to info@piciacia.it from the same email address.

Write to info@piciacia.it: we will reply within one month (extendable by two months for complex requests, in which case we will let you know). To protect your data we may ask you to confirm your identity, for example by writing from the same email address you used for your request. Some data cannot be deleted before its time, for example data that tax law requires us to keep or data needed to defend our rights (Art. 17(3) GDPR). For survey answers, see the dedicated section (Art. 11 GDPR).

If you believe the processing breaches the GDPR, you can lodge a complaint with the Italian data protection authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or with the authority of the country where you live or work.

Children

The site and its forms are meant for adults. If you are under 18, please ask a parent or guardian to write to us and book for you.

Changes

We may update this notice when the site, our services or the law change. The version in force is always the one published on this page, with the date of the last update.