Privacy Policy

Privacy policy

This information is provided by PromoTurismoFVG, pursuant to articles 12-14 of Regulation (EU) 2016/679 (GDPR), to guarantee maximum transparency in relation to all processing activities carried out on the personal data of those who visit and interact, in various capacities, with the website www.friuliveneziagiuliashop.it (hereinafter, also: “the Site” accessible via any device (e.g.: PC, smartphone or tablet).

Last update: 01.04.2025

1. Data controller and contact details

The joint controllers of personal data are the following companies:

  • PromoTurismoFVG with registered office: via Locchi n. 19 | 34123 – Trieste, Administrative and operational headquarters: via Della Vecchia Filatura n. 10 | 33035 – Torreano di Martignacco Tax Code: 01218220323 VAT number: 01218220323.
  • Keepup Società Benefit srl with registered office in vicolo Gorgo n. 8 | 33100 – Udine VAT number and tax code 02972550301 in the person of the legal representative pro tempore. Contact details: tel. 0432 1792448 contact email promoturismo@keepupshop.it.
  1. Information on Joint Ownership
  1. What does joint ownership mean?

Joint ownership means that the subjects jointly determine the purposes and means of the processing.

  1. the reason for the joint ownership

The companies shall determine in a transparent manner, by means of an internal agreement, their respective responsibilities for compliance with the obligations arising from the Regulation, in particular with regard to the exercise of the rights of the data subject, and their respective duties to provide the information referred to in Articles 13 and 14, unless and insofar as the respective responsibilities are determined by Union or Member State law to which the controllers are subject.

c. scope of co-ownership

The companies PromoTurismoFVG and Keepup Società Benefit srl are joint owners of the personal data processing activities that are carried out for the following services:

- management of e-commerce, carried out exclusively by Keepup Società Benefit srl, of merchandising products, and verification by PromoTurismoFVG that the e-commerce activity of products under the “Io sono FVG” brand is carried out by Keepup Società Benefit srl, guaranteeing compliance with the institutional prerogatives of the portal.

In particular:

  • Keepup Società Benefit srl takes care of the stipulation, in total autonomy, of the contracts for the online sale of merchandising products, acquiring the names and necessary data of the buyers from the e-commerce module of the website www.friuliveneziagiuliashop.it;
  • Furthermore, Keepup Società Benefit srl takes care of the execution of the sales contract in total autonomy, with the shipment of the goods to the buyer (private or company) or management of the collection on site, where requested;
  • Keepup Società Benefit srl, provides in total autonomy the management of invoicing and all related fiscal and accounting obligations, which are exclusively referable to that company;
  • PromoTurismoFVG, however, has the right to monitor the sales activity, through access to the database of buyers, to ensure that the said marketing always takes place in compliance with the institutional prerogatives of the portal www.friuliveneziagiuliashop.it and the brand it conveys;
  • PromoTurismoFVG provides for the independent management of the Site, which conveys information relating to the Joint Owners and which, in addition to browsing and e-commerce activities (the latter activity managed exclusively by Keepup Società Benefit srl), offers a form for requesting information and for requesting use of the “Io sono FVG” trademark.

Joint ownership refers to the joint or separate acquisition of personal data through these services, and also concerns any other processing operation carried out on the acquired personal data.
Specifically, the following categories of personal data will be acquired:

  • identification data (such as name and surname), contact data (such as email address and telephone number), shipping address and billing address, payment data (such as the payment method used, the cardholder, the card number used), data relating to the product purchased;
  • Browsing data (e.g. IP address, computer domain)

The data acquired refers to the following categories of interested parties:

  • Users of the Site.
  1. How is joint ownership regulated?

In the context of the processing activities carried out under the joint ownership regime, the Parties have agreed that - in internal relationships (i.e. between the Joint Owners) - the company Keepup Società Benefit srl assumes sole responsibility in relation to the phases relating to the management of the sales contract while PromoTurismoFVG assumes sole responsibility in relation to the supervisory activity carried out by it on the sales activity, as well as the management of all activities carried out through the Site with the exception of e-commerce activity.

In any case, all our customers/users can contact each of the companies without distinction for compensation for any damage.

  1. What does this mean for the user?

Even if there is a joint ownership, the parties fulfill their data protection obligations according to their respective responsibilities for the individual stages of the personal data processing processes. In any case, all parties undertake to adopt all appropriate measures to ensure an adequate level of security of the personal data processed over time.

The Parties shall make available to data subjects free of charge the information required pursuant to Articles 13 and 14 of the GDPR in a concise, transparent, intelligible and easily accessible form using clear and plain language.

In any case, all our customers/users can contact each of the companies indiscriminately to exercise their rights. In principle, customers will receive feedback from the person against whom they are asserting their rights.

  1. What data do we process?

The categories of personal data that the joint controllers can collect and process during navigation on the Site and the purchase phase of a product are the following different types of personal data concerning you, including:

  • We process the following data when you browse our site: User's name and surname; User's e-mail address; telephone contact; User's IP address.
  • We process the data necessary to allow you to proceed with the purchase on the Site or to deliver to you some products purchased from others: your identification data (such as name and surname), your contact data (such as email address and telephone number), the shipping address and the billing address, the payment data (such as the payment method used, the holder, the number of the card used), the data relating to the product purchased.
  1. Why your data is processed and on what legal basis

The data will be processed for the following purposes:

  1. to complete the purchase of the products offered on our site. When you proceed with the purchase we ask you for the personal data necessary for the payment, the shipment of the product, the possible management of the return and the prevention and repression of fraud and abusive behavior if you choose to pay by credit or debit card.

Legal basis: the condition that makes the processing lawful is constituted by the execution of the contract to which you are a party.

  1. To fulfill legal obligations (e.g. invoicing) arising from the execution of the contract referred to in the preceding point.

Legal basis: the condition that makes the processing lawful is the fulfillment of a legal obligation.

  1. To send the newsletter to the User, upon registration;

Legal basis: the condition that makes the processing lawful is constituted by your free, specific, informed and unequivocal consent.

  1. Management of the reserved area of ​​the site with provision of related services (always subject to registration of the User.

Legal basis: the condition that makes the processing lawful is constituted by the execution of the contract to which you are a party.

  1. Nature of the provision of data and consequences of any refusal

Providing the information requested for the purposes indicated in points 4.a) and 4.d) is mandatory to fulfill the contractual obligations. You are free to provide them, but any refusal to provide them will make it impossible for Keepup Società Benefit srl or PromoTurismoFVG to execute the contract or to correctly carry out all the obligations required by current legislation.
Providing the information requested for the purposes indicated in points 4.b) is mandatory to fulfill contractual obligations. In the event of stipulation of the contract, you are obliged to provide this data; any refusal to provide them will determine the impossibility for Keepup Società Benefit srl to execute the contract or to correctly carry out all the obligations required by current legislation.
Providing the information requested for the purposes indicated in points 4.c) is mandatory Optional. You are free to provide them and to express - or not - your consent to their processing, but any refusal to provide them or to express consent will determine the impossibility for Keepup Società Benefit srl or PromoTurismoFVG to register you for the newsletter service and to send them to you.

  1. Who will process your data

Your personal data may be processed by the Joint Controllers' personnel, appropriately trained and authorised to process data, or by third parties who provide instrumental services to the Joint Controllers, who typically act as data controllers, such as customer service companies, companies specialising in market research and data processing, physical stores or as "independent data controllers" (for example, couriers and freight forwarders, banking operators, freelancers or legal or tax consultancy and assistance companies).

Furthermore, your personal data may be communicated to third parties when the communication is required by applicable laws and regulations with respect to legitimate third party recipients of communications, such as authorities and public bodies that process your data as independent controllers for their respective institutional purposes.

  1. Transfer of data outside the EU

Data will never be transferred to third countries that do not comply with the conditions set out in articles 45 et seq. of EU Reg. 2016/679 and, in particular, the Data Privacy Framework and the related program.

  1. How long is your data kept?

We retain your personal data for a limited period of time, strictly related to the purpose for which they were collected and in compliance with applicable legal or regulatory obligations. At the end of the established retention period, your personal data will be deleted or otherwise rendered anonymous in an irreversible way, unless the Parties are required to retain the data for a further period to comply with legal or regulatory obligations or to exercise or defend a right in court.

The retention period varies depending on the purpose of the processing, in particular:

  • data collected for the execution of the purchase contract: until the conclusion of the administrative-accounting formalities. The data related to invoicing will be kept for ten years from the date of invoicing;
  • payment data: until the payment is certified and the related administrative-accounting formalities are completed following the expiry of the right of withdrawal and the terms applied for contesting the payment;
  • in the event of a judicial or administrative dispute, your data will be retained for the period necessary for the protection in court of a right by Keepup Società Benefit srl or by PromoTurismoFVG (for the treatments under their respective jurisdiction) or by a third party or within the limits imposed by the judicial or administrative authority;
  • the data relating to the sending of newsletters will be retained by PromoTurismoFVG until the purpose is achieved or, if this occurs earlier, until you revoke your consent.
  • The data relating to the management of the reserved area of ​​the site and the provision of related services by PromoTurismoFVG will be retained until the provision of the related service and in compliance with the retention terms established by current legislation.
  1. What are your rights?

You may contact the Joint Data Controllers or the Data Protection Officer of the PromoTurismoFVG company at any time, at the contact details specified in paragraph 1, to exercise your rights recognised by the GDPR and, in particular:

  • know whether or not personal data concerning you are being processed and, where that is the case, to obtain access to and a copy of such personal data (right of access);
  • rectification of your personal data, that is, to obtain the correction, modification or updating of any inaccurate or no longer correct data, as well as to obtain the integration of incomplete personal data, also by providing an additional declaration (right of rectification);
  • request the deletion of your personal data when, in particular, 1) they are no longer necessary for the purposes for which they were collected or processed, or 2) they have been processed unlawfully, or 3) they must be deleted to comply with a legal obligation, or, finally, 4) you have objected to their processing (see right to object below) and there is no prevailing legitimate reason that allows the owner to proceed with the processing anyway (right to erasure or right to be forgotten);
  • obtain the limitation of the processing of your personal data, that is, that the owner retains such data without being able to use them, except for your possible requests and the exceptions provided by law. This right can be exercised only when:

- you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;

- the data processing is unlawful and you request the limitation of their use, rather than their deletion;

- even if the owner no longer needs them for the purposes of processing, the personal data are necessary for you to ascertain, exercise or defend a right in court

- you have objected to the processing pending verification of whether the legitimate reasons of the owner prevail over those of the interested party (right to limitation);

  • request your data or transfer it to a person other than the owner (right to data portability).
  • lodge a complaint with one of the supervisory authorities responsible for compliance with the rules on personal data protection, if you believe that the processing of your personal data has been carried out unlawfully. In Italy, the complaint can be lodged with the Garante per la Protezione dei Dati Personali.
  1. Changes to the Privacy Policy

The features, functionalities and services offered by the Site may undergo changes in the future, consequently, this Privacy Policy may undergo modifications and additions over time. You are therefore invited to periodically check its contents. You will be duly notified of any significant modifications made to this Privacy Policy.