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PRIVACY POLICY

Last updated: October 13, 2026

This Privacy Policy explains how Umberto Reale processes personal data through palazzocapparucci.com, in accordance with the GDPR (EU) 2016/679 and applicable Italian law.

1. Data Controller

Umberto Reale
Via Paccarone 12, Fermo (FM), 63900, Italy
Phone: (+39) 378 4716780
Email: palazzocapparucci@gmail.com

2. Personal Data

  • Identity and contact data provided by users;
  • Information relating to requests and bookings;
  • Fiscal data required by law;
  • Technical and browsing data, including IP address, browser and pages visited;
  • Cookie preferences.

Bookings may be made through the external booking engine Xenion. Data entered into that service may also be processed by Xenion under its own privacy notice and arrangements with the Controller.

3. Purposes and legal bases

  • Managing requests, bookings and services: performance of a contract or pre-contractual steps;
  • Complying with tax, accounting and legal obligations: legal obligation;
  • Responding to user requests: pre-contractual steps or legitimate interest;
  • Protecting the website, preventing fraud and improving functionality: legitimate interest;
  • Analytics and non-essential cookies: user consent, where required.

The website does not operate a regular newsletter. Promotional communications will be sent only where there is a valid legal basis and, where required, prior consent.

4. Retention

Personal data is retained for as long as necessary for the stated purposes and, where applicable, for the periods required by tax and legal obligations. Data collected through cookies and analytics tools is retained according to the periods stated in the Cookie Policy and by the relevant providers.

5. Recipients

Data may be disclosed to public authorities where required by law, IT and hosting providers, payment providers and the Xenion booking engine, only as necessary to provide the services. These parties operate according to their applicable roles and agreements.

6. International transfers

Some providers, including hosting, analytics, payment or booking-engine providers, may process data outside the European Economic Area. Where this occurs, the transfer will rely on a GDPR-approved mechanism, such as an adequacy decision or Standard Contractual Clauses, where applicable.

7. Your rights

You may request access, rectification, erasure, restriction, data portability and object to processing where provided by the GDPR. You may also withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.

To exercise your rights: palazzocapparucci@gmail.com. You may also lodge a complaint with the Italian Data Protection Authority.

8. Minors

The service may sometimes be used by people under 18, but it is not specifically directed at children. We do not knowingly collect children’s data without an appropriate legal basis and, where necessary, the involvement of a parent or guardian.

9. Cookies

We use essential cookies and, only with consent where required, functional, analytics and third-party cookies. For details and preference management, please see the Cookie Policy.

10. Security and changes

We take reasonable measures to protect personal data, but no system can guarantee absolute security. We may update this Privacy Policy by publishing the latest version on this page.

11. Contact

Umberto Reale — Via Paccarone 12, Fermo (FM), 63900, Italy — (+39) 378 4716780 — palazzocapparucci@gmail.com