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  • Privacy Policy — masseriapetrarolo.com

    Last updated: 22nd Sept 2025

    This website (“Site”) is owned and operated by Island Earth Ltd, a company incorporated in Hong Kong (“Island Earth”, “we”, “us”, “our”). We act as the Data Controller for personal data collected via this Site for international marketing and booking enquiries relating to Masseria Pistola and Masseria Petrarolo.

    Local services in Italy (accommodation, events, ticketing and related on-site services) are provided by Tenuta Petrarolo Pistola Srl (“Pistola Srl”). Where you contract for, or receive, services in Italy, Pistola Srl acts as an independent controller for processing connected to delivering those services (e.g., guest registration required by Italian law, invoicing in Italy).

    If you have questions about this policy or your data, contact us at: 12) Contact below.

    1) What data we collect

    We collect and process the following categories:

    • Contact data: name, email, phone, country.

    • Booking/enquiry data: party size, dates, preferences, event details (e.g., wedding/retreat info).

    • Payment/contact with providers: limited payment metadata if you pay a deposit online (card data handled by our payment processor; we do not store full card numbers).

    • Marketing data: newsletter opt-in status, campaign/UTM data, preferences.

    • Technical data: IP address, device/browser type, pages viewed, cookies and similar technologies (see Cookie Notice).

    • Social/UGC: content you submit (reviews, photos) if you send or upload them.

    We do not intentionally collect special category data (health, beliefs, etc.). Please avoid sharing such information unless necessary (e.g., accessibility/dietary needs); if you do, we process it only to fulfil your request.


    2) Why we process your data (purposes) & legal bases

    • Respond to enquiries, provide quotes, manage availability
      Legal basis: performance of (or steps to enter into) a contract (Art. 6(1)(b) GDPR).

    • Manage bookings and pre-contract steps with agencies/partners
      Legal basis: contract (Art. 6(1)(b)) and our legitimate interests in efficient operations (Art. 6(1)(f)).

    • Send service communications (e.g., confirmations, policy updates)
      Legal basis: contract/legal obligation (Art. 6(1)(b)/(c)).

    • Marketing communications (newsletters, offers) if you opt in
      Legal basis: consent (Art. 6(1)(a)); you can withdraw anytime.

    • Analytics and site improvements
      Legal basis: consent for non-essential cookies (Art. 6(1)(a)); legitimate interests for essential security/diagnostics (Art. 6(1)(f)).

    • Legal/Tax/Compliance (incl. fraud prevention, record-keeping)
      Legal basis: legal obligation (Art. 6(1)(c)) and legitimate interests (Art. 6(1)(f)).

    • On-site service delivery in Italy (guest check-in, visitor logs, invoicing)
      Controller: Pistola Srl as independent controller; legal basis: legal obligation/contract in Italy.


    3) Who we share data with (recipients)

    We share personal data only as needed for the purposes above:

    • Italian operator: Pistola Srl (independent controller for on-site services).

    • Service providers (processors): website hosting/CDN, email/newsletter platform (e.g., Mailchimp), booking/CRM tools, payment processors, cookie consent tool, analytics providers (with IP-anonymization configured where available), IT/security support.

    • Agencies/partners involved in your booking (e.g., StayOne or similar), where you request/consent.

    • Authorities and advisers where required by law, to protect our rights, or in corporate transactions.

    We require processors to sign data processing agreements and follow our instructions.


    4) International transfers

    Island Earth is based outside the EEA (Hong Kong). Where personal data are transferred outside the EEA/UK, we implement appropriate safeguards, including:

    • EU/UK Standard Contractual Clauses (SCCs) with processors/partners; and

    • Additional technical/organizational measures (e.g., encryption, access controls).

    You can request a copy of the relevant safeguards by emailing privacy@masseriapistola.com (commercially sensitive terms may be redacted).


    5) Retention

    We keep personal data only as long as necessary for the purpose collected:

    • Enquiries/quotes: up to 24 months after last contact.

    • Booking/contract records: 10 years (to meet tax/accounting obligations).

    • Marketing data: until you withdraw consent or after 24 months of inactivity.

    • Technical logs/security: typically 12 months (shorter where feasible).

    We will securely delete or anonymise data when no longer required.


    6) Your rights (EEA/UK data subjects)

    Under the GDPR, you have the right to:

    • Access your personal data;

    • Rectify inaccurate or incomplete data;

    • Erase data in certain cases;

    • Restrict processing in certain cases;

    • Data portability (receive data in a structured, machine-readable format and transmit to another controller);

    • Object to processing based on legitimate interests, and to direct marketing at any time;

    • Withdraw consent at any time (does not affect prior lawful processing).

    To exercise rights, contact privacy@masseriapistola.com. You also have the right to lodge a complaint with a supervisory authority, including the Italian Data Protection Authority (Garante per la protezione dei dati personali) or your local authority in the EEA/UK.


    7) Cookies & similar technologies

    We use cookies and similar technologies to run the Site, measure performance, and (with your consent) improve marketing. On your first visit we present a cookie banner that lets you accept or reject non-essential categories (e.g., analytics/marketing). You can change your choices anytime via Cookie Settings in the footer.

    • Essential cookies (strictly necessary): operate basic functions, security, consent storage.

    • Analytics cookies (consent): help us understand visits and improve the Site (configured with IP anonymization where available).

    • Marketing/social cookies (consent): enable social embeds and measure campaigns.

    For details of specific cookies (names, purposes, lifespans), see our Cookie Notice [link] which forms part of this policy.


    8) Newsletters & marketing

    If you opt in, we will send updates about Masseria Pistola/Petrarolo. You can unsubscribe anytime via the link in each email or by contacting us.

    Processor: We currently use Mailchimp (Intuit Inc., USA) to manage newsletters. International transfers are safeguarded by SCCs plus additional measures. Mailchimp processes data under our instructions.


    9) Children

    This Site is not intended for persons under 18. We do not knowingly collect data from children. If you believe a child has provided data, contact us to delete it.


    10) Security

    We use appropriate technical and organisational measures to protect your data, including encryption in transit (TLS), access controls, least-privilege permissions, and vendor due diligence. No method is 100% secure; we continuously review and improve our safeguards.


    11) Changes to this policy

    We may update this policy from time to time. The latest version is posted on this page with the “Last updated” date. Material changes will be highlighted in the banner or by email where appropriate.


    12) Contact

    • Controller: Island Earth Ltd, 7F, Cheung Hing Industrial Building, Hong Kong

    • Email: privacy[at]tenutapistola.com

    • Italian operator (independent controller for local services): Tenuta Petrarolo Pistola Srl, Contrada Petrarolo 16, Petrarolo, Monopoli, Puglia