Privacy policy of choruslife.com

1. WHO IS THE DATA CONTROLLER?

Chorus Life S.p.A., with registered office in Viale Vittorio Emanuele II, 10/M, 24121 - Bergamo, Company Registration No. - Tax No. - VAT No. 02162710160, REA No. 267795 and Costim Real Estate S.r.l. with registered office in Viale Vittorio Emanuele II, 10/L, Bergamo, Company Registration No. - Tax No. - VAT No. 04867620165, REA No. 495217, are joint data controllers (“ChorusLife” or “Data Controller”) of the personal data of the users (“Users”) who access the choruslife.com website (“Website”) and use the services provided. In accordance with the provisions of Regulation (EU) 2016/679 (“Regulation”), ChorusLife provides Users with the following information. For the processing operations related to the table reservation service at the restaurants “L'Angolo con Vista” and "L'Angolino Bistrot & Lounge Bar", in addition to the aforementioned joint controllers, ChorusRooftop S.r.l., with registered office in Via Moretti, 34, Bergamo, Company Registration No. - Tax No. - VAT No. 04791820162, is also joint data controller (therefore, limited to such processing, it also falls under the definition of “ChorusLife” or “Data Controller,” as indicated above). For the processing operations related to the table booking service at the “GNAM”, in addition to the aforementioned joint controllers, Chorusfood s.r.l., with registered office in Via Moretti, 34, Bergamo, Company Registration No. – Tax No. – VAT No. 04910420167, REA No. 498414, is also joint data controller (therefore, limited to such processing, it also falls under the definition of “ChorusLife” or “Data Controller”, as indicated above). For the processing operations related to the car park booking service, in addition to the aforementioned joint controllers, Chorus Parking S.r.l., with registered office in Via Moretti, 34, Bergamo, Company Registration No. – Tax No. – VAT No. 04779030164, is also joint data controller (therefore, limited to such processing, it also falls under the definition of “ChorusLife” or “Data Controller”, as indicated above). For the processing operations related to the communications relating to the Arena, in addition to the aforementioned joint controllers, Chorus Life Arena S.r.l., with registered office in Via Moretti, 34, Company Registration No. – Tax No. – VAT No. 04779020165, is also joint data controller (therefore, limited to such processing, it also falls within the definition of “ChorusLife” or “Data Controller”, as indicated above). To this end, the joint controllers have concluded a joint controllership agreement to govern the management of Users' data within the Website, direct marketing and profiling activities for sending commercial communications, as well as the exercise of the rights provided for in the Regulation, the essential content of which may be made available to the User, at the latter's request.

2. FOR WHAT PURPOSES ARE THE DATA PROCESSED?

Personal data collected through the Website and/or otherwise communicated by the User are processed for the following purposes:

1. enabling ChorusLife to fulfil its obligations under the law;
2. enabling the User to access the Website and use the services available therein. Registration is required for certain services (e.g. apartment configurator or table reservation at certain restaurants), whilst it is not required for other services;
3. following a request from the User, contacting him/her by email or telephone in order to provide a personalised service for the configuration and booking of a residence in the ChorusLife smart district;
4. allowing ChorusLife, at the request of the User through a specific contact form or other means, to contact the User in order to respond to the User’s requests;
5. allowing ChorusLife to contact Users for commercial purposes as part of ChorusLife experience and for market research and surveys via e mail and other communication methods (e.g. SMS, direct messaging, telephone, in-app notifications, etc.);
6. allowing ChorusLife to evaluate the User's tastes, preferences, interests and habits to personalise the commercial communications referred to in the previous point.

In addition, in the event of any corporate events (sale of the company or business units), due diligence or in the event of the defence of a right in court and in connection with the related prodromal activities, ChorusLife may proceed with further processing in connection with corporate operations or judicial events.

3. WHAT DATA ARE PROCESSED?

When the User navigates on the Website, the User’s usage data are collected (including, among others, the IP address, user name, navigation data such as the pages visited and the time spent on them, session duration) and, if the User fills in one of the forms (including the registration form) that is available on the Website, some identification data are also collected, including the User’s name and surname, e-mail address and/or phone number and any personal data voluntarily entered by the User in the contact form (this applies also in various booking forms, for example, details relating to a vehicle when booking a parking space). For commercial purposes, where consent has been given by the User, the User’s e-mail address is also processed for sending commercial communications. If the User decides to respond to the surveys referred to in letter D at paragraph 2 above, ChorusLife will also processes the information included in the relevant answers.

4. ON WHAT BASIS ARE DATA PROCESSED?

The processing of personal data for the purpose referred to in point A of paragraph 2 is based on legal obligations to which ChorusLife is subject. The processing of personal data for the purposes referred to in point B and point C of paragraph 2 (use of the Website and enjoyment of its services) is carried out on the basis of an agreement with the User and/or the execution of precontractual measures. The processing of personal data for the purposes referred to in point D of paragraph 2 (contacting the User following the completion of a contact form) is carried out on the basis of the legitimate interest of the Data Controller in following up the User’s requests. The provision of personal data by the User for the purposes referred to in paragraph 2, letters E and F (sending commercial communications and their personalisation) is optional and ChorusLife may process personal data for these purposes only with the User's consent. If the User does not intend to consent to the processing of his or her personal data for these purposes, the Data Controller will not be able to send the User commercial communications or personalise them. Any consent given by the User for one or more of the purposes referred to in the above paragraph may be withdrawn at any time. Failure to provide such consent will have no consequence on the provision of the services of the Data Controller within the scope of the purposes referred to in paragraph 2, letter B. The User’s personal data may also be processed on the basis of the legitimate interest of ChorusLife in carrying out operations of a corporate nature or in the management/exercise of its rights, for example in the context of possible corporate events (sale of the company or business units), due diligence, in the event of the defence of a right in court and in relation to related prodromal activities.

5. HOW ARE DATA PROCESSED? 

In relation to the aforementioned purposes, the data will be processed mainly with the aid of electronic systems and, to a residual extent, on paper, but in all cases with systems that guarantee security and confidentiality.

6. TO WHOM ARE THE DATA COMMUNICATED?

The personal data collected through the Website and/or otherwise communicated by the User will be processed by subjects which are authorized to process the data within ChorusLife and may be communicated solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects: IT service providers (e.g. the provider of the table reservation service for the restaurant, developers and consultants of ChorusLife, for example, in the IT, legal, tax and fiscal fields; group companies such as, by way of example but not limited to Costim S.r.l. and Elmet S.r.l. Where required by law, the data may also be disclosed to competent judicial authorities, public administrations and supervisory and control authorities. The User’s personal data will not be disseminated. With reference to the personal data communicated to them, subjects belonging to the above categories may operate, depending on the case, as data processors (and in this case they will receive appropriate instructions from ChorusLife) or as autonomous data controllers. In the latter case, personal data will be communicated only with the express consent of the data subjects, except in cases where communication is compulsory or necessary by law or for the pursuit of purposes for which the data subject’s consent is not required by law.

7. IS DATA TRANSFERRED ABROAD?

ChorusLife might transfer the User’s personal data to third countries. Transfers of data outside the European Economic Area are subject to a special regime under the Regulation, and are only made to countries that ensure an adequate level of protection of personal data, on the basis of an adequacy decision by the European Commission or where adequate safeguards have been adopted (including the standard contractual clauses laid down by the European Commission), provided that the data subjects have enforceable rights and effective remedies.

8. HOW LONG WILL MY PERSONAL DATA BE STORED?

The personal data collected will be stored in accordance with the provisions of the relevant legislation for a period of time not exceeding that necessary to achieve the purposes for which they are processed. The criteria for determining the period of retention of personal data shall take into account the period of permitted processing and the applicable rules on the limitation of rights and legitimate interests where they form the legal basis of the processing. For example, in the event of termination of the account, the Data Controller shall have the right to retain the User's information to comply with obligations provided by law, where applicable (e.g. of a fiscal nature), as well as to protect the Data Controller in the event of any exercise of rights by the User until the termination of the applicable prescription term (ten years). With reference to the commercial purposes, personal data will be processed until consent is withdrawn provided that ChorusLife will adopt procedures to make the User aware of his/her rights, including the right to manage (and therefore also withdraw) his/her consents. In any case, if there is no interaction between the User and the Data Controller for a period of 24 months the processing will stop. In such circumstances, in the absence of further legal grounds (for example, the User registration management), the data will be deleted or anonymised. With regard to personalising the Chorus Life experience, ChorusLife will use the information for a period of 12 months from the time it is collected, without prejudice to the User's right to withdraw his/her consent at any time. At the end of the retention period, the data will be deleted, anonymised or aggregated in such a way that the User cannot be identified.

9. WHAT ARE THE DATA SUBJECT’S RIGHTS? 

Users may contact ChorusLife, at any time and free of charge to:  

• obtain confirmation as to whether or not their personal data are being processed and, if so, to obtain access to the information referred to in Article 15 of the Regulation, as well as a copy of the personal data being processed;

 

• obtain the rectification of inaccurate personal data concerning them, or, taking into account the purposes of the processing, the integration of incomplete personal data;

 

• obtain the erasure of their personal data in the presence of one of the grounds referred to in Article 17 of the Regulation;

 

• obtain the restriction of the processing of their personal data in the event of one of the cases referred to in Article 18 of the Regulation;

 

• object to the processing of their personal data on grounds relating to their particular position, where applicable, pursuant to Article 21 of the Regulation;

 

• receive the personal data concerning them in a structured, commonly used and machine-readable format and transmit such data to another data controller without hindrance from the Data Controller, if technically possible, in the cases and within the limits set out in Article 20 of the Regulation, where applicable.

In addition, Users have the right to withdraw their consent to the processing of their personal data (where given), at any time, without prejudice to the lawfulness of the processing based on the consent given before withdrawal. If consent is withdrawn, the Data Controller will follow up as soon as possible, however, on a technical level it may take up to 24 hours before the User's action is updated on the Data Controller's systems. Requests to exercise the above rights should be sent by e-mail to info@choruslife.com or to the Data Protection Officer at dpo@choruslife.com. Pursuant to the Regulation, ChorusLife is not authorised to charge costs for complying with one or more of the requests set out in this paragraph, unless they are manifestly unfounded or excessive, and in particular are repetitive in nature. In cases where the User requests more than one copy of his or her personal data or in cases of excessive or unfounded requests, ChorusLife may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) refuse to comply with the request. In these eventualities, ChorusLife will inform the User of the costs before processing the request. ChorusLife may request additional information prior to processing requests if it needs to verify the identity of the individual making the request. The exercise of the same rights may, in any case, be delayed, limited or excluded by reasoned notice given without delay to the User, unless the notice would jeopardize the purpose of the limitation, for the time and to the extent that this constitutes a necessary and proportionate measure, taking into account the fundamental rights and legitimate interests of the User, in order to safeguard any interests in the conduct of a defensive investigation or the exercise of a right in court (and related prodromal activities). In such cases, the rights of the data subject may also be exercised by lodging a complaint to the Garante per la protezione dei dati personali. Without prejudice to any other administrative or jurisdictional action, the User also has the right to lodge a complaint to the Garante per la protezione dei dati personali if he/she considers that the processing concerning him/her is carried out in breach of the General Data Protection Regulation. Further information is available on the website http://www. garanteprivacy.it. ChorusLife, in any event, invites the User to make contact directly through the channels indicated above, before approaching to the Supervisory Authority, in order to resolve amicably and in the shortest possible time any dispute regarding the protection of personal data. 13/07/2026