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RAPHAEL - Singer & Songwriter » Privacy policy

Privacy policy

This is the privacy notice / policy of In this document, “we”, “our”, or “us” refers to 

This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

It tells you about your privacy rights and how the law protects you. We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information. We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.

Our policy complies with Italian law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.



What personal data are being processed?

  • Basic contact details (name, surname, telephone number, e-mail address);
  • Information about using our web pages (clicks on links, time spent), and response information to our emails (if the message has been opened, to which links you clicked);

The legal basis for the processing of personal data

We may process your personal data on the following legal bases:

  • when necessary for the fulfillment of our legal obligations (e.g. issuing invoices for the service provided);
  • when the processing of your personal data is necessary for the conclusion and fulfillment of a contract that you have concluded with us or because you wanted from us an offer;
  • when you gave a consent for the processing of your personal data for the specific purpose of the processing, whereby you are always entitled to withdraw the consent (e.g., for personalized information of our offer based on profiling);
  • when we have a legitimate interest in processing your personal data (for example: when we send you an e-mail in case you write us an e-mail on our web page).

The purposes of the processing of personal data

We may use your personal information for one or more of the purposes:

  • communicating with you regarding the provision of our services and responding to your inquiries;
  • the conclusion of the contract and the fulfillment of the obligations arising from the concluded contract;
  • commercial communications (sending e-mail, ordinary mail and SMS messages);
  • commercial communications on the basis of tailored or individualized offers and messages, the creation of user profiles or classification into groups, each of which can receive commercial communications with different content. When creating profiles, we monitor individuals’ activity (such as the time that an individual spends on a particular content what content interests him in and an opening of e-mails) and the frequency and value of past purchases;
  • to enforce any legal claims and to resolve disputes;

How long do we keep your personal data and what happens to them afterwards

  • We keep basic personal data all the time, as long as you have the status of our registered user on our web pages, you are subscribers to our newsletters, …
  • We keep your personal data which are processed on the basis of your consent permanently or until you withdraw this consent given by you.
  • We keep data on invoices issued for 10 years from the issue.
  • We will keep the data necessary for concluding and fulfilling the contract between you and us, for 5 years from the completion of the contract (delivery of goods).

After the expiry date, your personal information is effectively erased or anonymized, which means that we process them in such a way that they can no longer be associated with you or attributed to you

Voluntariness of providing the data and consequences of not providing

The provision of personal data is voluntary. You are not obliged to provide personal data to us, but if you do not provide them, you can not receive certain services or conclude contracts with us. Which data are such that their non-provision entail the stated consequences, we will indicate each time we obtain personal data from you.

Who has access to your personal data

We do not transfer your personal data and allow third parties (outside of us) to get acquainted with them, except for those who have a written contract with us, on the basis of which they perform certain tasks related to the processing of data and are obliged to comply with the legislation regarding the processing and protection of personal data (so-called Contractual processors). Contractual processors to whom we provide personal information are:

  • marketing service providers;
  • Contractual processors may process personal data only in the accordance with our instructions and may not process personal data for their own purposes. They are obliged, together with their employees, to protect the confidentiality of your personal data.
  • Contractual processors of personal data do not transfer to third countries (outside the Member States of European Economic Area – those are EU Member States and Iceland, Norway and Liechtenstein).

What kind of rights do you have regarding personal data, how can you withdraw consent for processing, and what are the consequences of withdrawal

You have the following rights regarding your personal data:
– to request from us at any time:

  • confirmation, if we process your personal data;
  • access to personal data and the following information: processing purposes; types of personal data; users or categories of users to whom personal data have been or will be disclosed, in particular users in third countries or international organisations; the planned retention period of personal data or, if that is not possible, the criteria used to determine that period; the existence of automated decision-making, including the profiling and the reasons for it, as well as the importance and estimated consequences of such processing for you;
  • one (free of charge) copy of your personal data in the format you specify yourself (if the request is provided by electronic means of communication and you do not request otherwise, the copy shall be provided in electronic form); for additional copies you request, we can charge a reasonable fee, taking into account the costs;
  • correction of inaccurate personal data;
  • processing restrictions when:
    • dispute the accuracy of personal data, for a period that allows us to verify the accuracy of personal data;
    • the processing is illegal and you are against the deletion of your personal data, and request a restriction on their use instead;
    • we do not need personal data for processing purposes anymore, but you need them for establishment, exercise, or defence of legal claims;
  • deletion of all personal data (right to forget), if the conditions set out in Article 17 of the General Data Protection Regulation are fulfilled, and in particular when you withdraw the consent for the processing of personal data;
  • the printout of personal data in a structured, widely used and machine-readable form, with the right to forward this information to another controller, without hindering you;
  • ceasing the use of personal data for direct marketing purposes, including the creation of profiles;
  • that you are not subject to a decision based solely on automated processing, including the creation of profiles if the conditions under Article 22 of the General Data Protection Regulation are met.

– the right to file an appeal against us with the Information Commissioner if you believe that the processing of your personal data violates the General Data Protection Regulation.

Procedure for exercising rights

You may address your requests regarding the exercise of rights in relation to personal data in writing to any contact listed at the top of this document under
The Controller of the personal data and contact details.

For the purposes of reliable identification in the case of the exercise of rights in connection with personal data, we may require additional information from you, and we may only refuse to act if we prove that we can not reliably identify you.

At your request by which you exercise your rights in relation to personal data, we must respond without undue delay, and no later than one month after receiving your request.

More about GDPR regulation

What is GDPR?
GDPR is the acronym for General Data Protection Regulation, which establishes new rules concerning the protection of personal data (from this point forward: General Regulation).
Where do I get the official text of the General Regulation? Here (click).