Vanna Camp GmbH
Prantach 25
39015
St. Leonhard in Passeier/S. Leonardo i.Passiria
Südtirol Italien / Alto Adige (BZ) Italia
Florian Haller – E-Mail:
florian.haller@vanna.camp
MWSt.-Nr.
03299430219
Zertifizierte PEC-Adresse: vannacamp@pecimprese.it
PRIVACY
POLICY
Cubivan
Pre-Order – Reservation and Deposit Payment
Vanna Camp GmbH · Last updated: 27 August 2026
1. Controller for Data Processing
The controller
responsible for the processing of your personal data within the meaning of
Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”) and the
Codice in materia di protezione dei dati personali (Legislative Decree No.
196/2003, as amended, “Codice Privacy”) is:
Vanna Camp GmbH
Prantach 25, 39015 St. Leonhard in Passeier (BZ), Italy
VAT No.: IT03299430219
PEC: vannacamp@pecimprese.it
represented by its managing director Florian Haller
Hereinafter “we”, “us” or
the “Provider”.
2. Contact for Data Protection Enquiries
For questions regarding
the processing of your personal data and to exercise your rights under Clause
3, you can reach us at florian.haller@vanna.camp. A data protection officer
within the meaning of Article 37 GDPR has not been appointed, as the statutory
requirements for doing so are not met.
3. Your Rights as a Data Subject
Under the GDPR and the
Codice Privacy, you have the following rights:
•
Access
to the personal data we process concerning you (Article 15 GDPR)
•
Rectification
of inaccurate data (Article 16 GDPR)
•
Erasure
of your data (Article 17 GDPR), unless statutory retention obligations preclude
this
•
Restriction
of processing (Article 18 GDPR)
•
Data
portability (Article 20 GDPR)
•
Objection
to processing based on Article 6(1)(f) GDPR (Article 21 GDPR)
•
Lodging
a complaint with a data protection supervisory authority (see Clause 13)
To exercise these rights,
an informal notice to the contact address given in Clause 2 is sufficient. We
will process your request within the statutory deadlines (as a rule, one month,
Article 12(3) GDPR).
4. Data Processing When Visiting Our Website
When you access our
website, our hosting provider automatically collects technical data transmitted
by your browser (server log files): IP address, date and time of access, page
accessed, referrer URL, browser type and version, and operating system. This
data is used for the technical provision of the website and for system security
(Article 6(1)(f) GDPR, legitimate interest in stable and secure operation).
[Please insert the name and registered office of the
hosting provider actually used, as well as the retention period of the log
files; a data processing agreement pursuant to Article 28 GDPR may need to be
concluded with the provider.]
5. Cookies
Our website uses only
technically necessary cookies required for the operation of the website and the
reservation process (Article 6(1)(f) GDPR); no consent is required for these.
6. Data Processing in Connection with the Cubivan
Reservation and Deposit Payment
If you make a reservation
for the Cubivan Pre-Order via our website and pay the deposit under the
Reservation Agreement, we process the following personal data:
•
Name,
address and email address (provided by you in the reservation form)
•
Automatically
assigned reservation number
•
Time
and content of your consent to the Reservation Agreement, the General Terms and
Conditions (GTC), and the Participation Terms, including the separate
confirmation of the clauses set out in § 19 of the Reservation Agreement (see
Clause 8)
•
IP
address and timestamp of the respective consent steps, for evidentiary purposes
•
Amount
and time of the deposit paid
We process this data in
order to conclude and perform the Reservation Agreement with you (Article
6(1)(b) GDPR), to comply with our statutory obligations to demonstrate
effective consent to the aforementioned clauses (Article 6(1)(c) GDPR in
conjunction with Article 1341 of the Codice
Civile), and to fulfil commercial and tax-law retention obligations
(Article 6(1)(c) GDPR).
The following table
summarises the principal purposes of processing:
Purpose
of Processing
Legal
Basis (GDPR)
Retention
Period
Conclusion
and performance of the Reservation Agreement (incl. deposit payment)
Article
6(1)(b)
Duration of
the contractual relationship plus statutory periods (Clause 11)
Evidence of
consent to the Reservation Agreement, GTC and Participation Terms (incl. § 19
clauses)
Article
6(1)(c) in conjunction with Article 1341 of the Codice Civile
Until
expiry of the statutory limitation periods
Processing
of the deposit payment via Stripe
Article
6(1)(b)
Duration of
payment processing plus tax-law periods
Sending
confirmation and transaction emails
Article
6(1)(b)
Until
purpose is fulfilled, then deleted
Fraud and
abuse prevention
Article
6(1)(f)
Max. 12
months after the transaction*
Compliance
with commercial- and tax-law retention obligations
Article
6(1)(c)
10 years
(Article 2220 of the Codice Civile)
*
Indicative figure – please adapt to your actual fraud-prevention practice.
7. Payment Processing via Stripe
We process payment of the
deposit through the payment service provider Stripe. Depending on the
arrangement, the contracting party is Stripe Payments Europe, Limited and/or
Stripe Technology Europe, Limited, both based in Ireland (please refer to your
Stripe agreement or Stripe's current privacy policy for the exact contractual
allocation). In connection with payment processing, we transmit to Stripe:
name, email address, reservation number, and the deposit amount due. You enter
your payment data (e.g., credit card number) directly on the payment page
hosted by Stripe; this data is never stored or viewed by us at any time.
Stripe processes the data
in part as our processor (Article 28 GDPR, on the basis of the Data Processing
Agreement provided by Stripe) and in part as an independent controller in its
own right, for example for fraud prevention and to fulfil its own statutory
obligations (including anti-money-laundering requirements). Further information
on data processing by Stripe can be found in Stripe's privacy policy at
stripe.com/privacy.
8. Confirmation Email and Second Consent
After completing the
first consent step on our website, we automatically send an email to the
address you provided containing a personalised confirmation link. Via this
link, you confirm the Reservation Agreement, the GTC, the Participation Terms,
and the clauses requiring separate approval under § 19 of the Reservation
Agreement a second time before being redirected to the payment page. For this
purpose, we process your email address, the unique, time-limited confirmation
link, and the time and IP address of your confirmation. This processing serves
to demonstrate effective, separate consent within the meaning of Article
1341(2) of the Codice Civile (Article
6(1)(c) GDPR) and to perform the Reservation Agreement (Article 6(1)(b) GDPR).
[insert name of email delivery service] sends the confirmation
email on our behalf, acting as our processor.
9. Disclosure to Other Processors and Service Providers
In addition to Stripe
(Clause 7) and the email delivery service (Clause 8), we may engage further
service providers, in particular for website hosting (Clause 4) [and, where
applicable, accounting software/CRM – please complete]. We have
concluded data processing agreements pursuant to Article 28 GDPR with all
service providers who process personal data on our behalf.
10. Transfer to Third Countries
To the extent that
service providers – in particular Stripe – process data outside the European
Union or the European Economic Area, for example in the United States, we
ensure that an adequate level of data protection is guaranteed, in particular
through the conclusion of EU Standard Contractual Clauses pursuant to Article
46(2)(c) GDPR together with supplementary technical and organisational
measures. A copy of the relevant safeguards may be requested via the contact
address given in Clause 2.
11. Retention Period
We store your personal
data only for as long as is necessary for the respective processing purposes or
as required by statutory retention obligations:
•
Contractual
and accounting records (including the Reservation Agreement and payment
receipts): 10 years pursuant to Article 2220 of the Codice Civile
•
Evidence
of consent (consent log under Clauses 6 and 8): until expiry of the statutory
limitation periods for claims arising from the Reservation Agreement
•
Server
log files under Clause 4: in accordance with the period specified there, unless
security-related reasons require longer retention
Upon expiry of the
respective periods, the data will be deleted or anonymised, unless further
statutory retention obligations preclude this.
12. Data Security
We take appropriate
technical and organisational measures to protect your personal data against
accidental or intentional manipulation, loss, destruction, or access by
unauthorised persons, in particular through encryption of data transmission
(TLS/SSL) and access restrictions. Payment data is processed exclusively by
Stripe in accordance with the PCI-DSS standard.
13. Right to Lodge a Complaint with the Supervisory
Authority
You have the right to
lodge a complaint with a data protection supervisory authority regarding our
processing of your personal data. The competent authority is, in particular:
Garante per la protezione
dei dati personali
Piazza Venezia, 11 – 00187 Rome, Italy
Email: garante@gpdp.it
PEC: protocollo@pec.gpdp.it
Web: www.garanteprivacy.it
Alternatively, you may
contact the supervisory authority of your habitual residence (Article 77 GDPR).
14. Changes to this Privacy Policy
We reserve the right to
amend this Privacy Policy in order to adapt it to changes in the legal
situation or to changes in our services and data processing. The version
published on our website at the time of your visit or your reservation shall
apply.