Privacy
Official policy not supplied.
This notice explains how habawaba.com handles personal data of visitors, people who write to the office, and account holders. It follows Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).
Controller
The controller is Waterpolo Development, a non-profit association, legal address Via Marco Polo 25, 81030 Castel Volturno (CE), Italy. Rights requests: office@habawaba.com. Site administration: admin@habawaba.com.
Data the site handles
- Technical navigation data: IP address used to limit contact-form submissions, time, requested page, chosen language.
- Cookie choice, stored in
hb_consentand, as an aggregate record, in an internal log (choice, notice version, date). - Language, in
hb_locale. - Contact form: name, email and message, stored in the administration inbox.
- Account area: name, email, password stored only as a hash, sessions. The
hb_sessioncookie is httpOnly. - If analytics are accepted: first-party events (page view, call-to-action, registration start or submit, video play, locale change, download). The record is event name, path and language. No third-party tracker is used.
- YouTube videos embedded from youtube-nocookie.com. Google may process technical data when a video plays. Links to Instagram, Facebook and YouTube leave this site.
Purposes and legal bases
- Pages, language and account session: contract or steps before a contract, and legitimate interest in a working site (Art. 6.1.b and 6.1.f).
- Replying to a contact message: request of the person (Art. 6.1.b).
- Measuring use of the site: consent (Art. 6.1.a). Events do not run unless analytics are accepted.
- Legal duties if an authority requires them (Art. 6.1.c).
Retention
- Language and consent cookies: up to 12 months.
- Account session: 14 days.
- Contact messages: as long as needed to reply, and not more than 24 months after the thread is closed.
- Consent log and analytics events: 24 months.
- Accounts: until the user asks for deletion or the administration closes the account.
Who can see the data
Data stay on the systems that publish this site and in the HaBaWaBa administration database. Office and technical staff can access them. Data are not sold. A host or email provider processes data only to deliver the service. Videos are served by Google (YouTube). A transfer outside the EEA happens only with an adequacy decision or standard contractual clauses.
Rights
You can ask for access, rectification, erasure, restriction, objection and, where processing is based on consent or a contract and is automated, portability. Account export and deletion are available in the account area. Withdraw analytics consent by deleting the hb_consent cookie and choosing essential cookies only. You may lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it).
Public pages do not need an account. The contact form needs a name, email and message. An account needs an email and a password. The site does not make automated decisions that produce legal effects.


