Privacy Policy — Italian Beach Club App
Last updated: 30 April 2026
This Privacy Policy describes how the Italian Beach Club mobile application (the “App”) processes users’ personal data, in accordance with Regulation (EU) 2016/679 (“GDPR”) and Italian Legislative Decree 196/2003 as amended.
The App is the mobile version of the website www.italianbeach.club and allows users to browse editorial content about Italian beach clubs and to receive notifications about new content, including notifications based on the user’s location.
1. Data Controller
The Data Controller is:
SolAmare di Tiziana Di Masi
Via Augusto Righi 9, 40128 Bologna (BO), Italy
Italian VAT: 04358541201
2. Categories of data processed
The App does not require registration or the creation of a user account. Data processing is limited to what is strictly necessary to operate each individual feature.
2.1 Anonymous identifier for push notifications
When the user consents to receive push notifications, the device is assigned an anonymous identifier (subscription ID / player ID) generated by OneSignal. The identifier is not linked to a name, email, phone number or any other directly identifying information, but it still qualifies as a unique device identifier under Article 4(1) GDPR.
2.2 Geolocation data (GPS)
If the user enables location services, the App accesses the device’s precise location (GPS) in real time for the sole purpose of delivering notifications relevant to the user’s current area (e.g. new content related to nearby beach clubs). The location is not stored as a tracking history: it is used on a momentary basis to assess the geographic relevance of notifications.
2.3 Technical system data
For the App to function correctly, minimal technical data may be processed (operating system version, device model, language, time zone), used solely to ensure compatibility and proper rendering of content.
3. Purposes and legal bases
| Purpose | Data processed | Legal basis (GDPR) |
|---|---|---|
| Sending push notifications about new content | Anonymous device ID | Consent (Art. 6(1)(a)), provided both via the operating system permission and within the App |
| Geographic personalisation of notifications | Real-time GPS location | Consent (Art. 6(1)(a)) |
| Technical functioning of the App | Technical system data | Performance of the service requested by the user (Art. 6(1)(b)) |
4. Recipients and processors
Data may be processed by the following providers, appointed as Processors under Article 28 GDPR:
- OneSignal Inc. (USA) — delivery of push notifications. OneSignal receives the anonymous device identifier. Extra-EU transfers are based on the Standard Contractual Clauses (SCCs) approved by the European Commission.
- Supabase (backend service, European Union region) — storage of editorial content and technical references required for the App to function. No extra-EU transfer.
Data is not sold or transferred to third parties for marketing purposes.
5. Extra-EU transfers
The only extra-EU transfer concerns OneSignal Inc., based in the United States. The transfer is governed by the Standard Contractual Clauses (SCCs) under EU Decision 2021/914 and by additional technical and organisational measures.
6. Retention periods
- OneSignal anonymous ID: kept for as long as the user keeps notifications enabled; automatically deleted when the App is uninstalled or notification consent is revoked at the operating system level.
- Location data: not retained; evaluated in real time and immediately discarded.
- Technical data: processed only for the duration of the session.
7. Your rights
You may exercise at any time the rights granted by Articles 15-22 GDPR, including:
- access to your data;
- rectification and erasure;
- restriction of, and objection to, processing;
- withdrawal of consent (with effect from the moment of withdrawal);
- data portability (where applicable).
To exercise these rights, please write to guidabeachclubitalia@gmail.com.
You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or with the supervisory authority in your country of residence.
How to withdraw consent
- Push notifications: can be disabled from the operating system settings (iOS/Android) or from the App’s Profile menu.
- Geolocation: can be disabled from the operating system settings.
8. Minors
The App targets a general audience and is not specifically directed at children. Use of the App is permitted from the age of 14. Users under that age require consent from the holder of parental responsibility.
9. Security
Appropriate technical and organisational measures are in place to protect data from unauthorised access, loss or alteration, including encryption in transit (HTTPS/TLS) and access controls on backend systems.
10. Changes to this policy
This Privacy Policy may be updated from time to time. Material changes will be communicated through the App or published on www.italianbeach.club. The date of the last update is shown at the top of this document.
11. Contact
For any question regarding the processing of personal data: