Privacy Policy

Privacy policy of choruslife.com and choruslifeliving.com

1. WHO IS THE DATA CONTROLLER?

Chorus Life S.p.A., with registered office at viale Vittorio Emanuele II, 10/M, 24121 – Bergamo, Companies Register – Tax ID/VAT no. 02162710160, Bergamo REA no. 26779, and Costim Real Estate s.r.l., with registered office at viale Vittorio Emanuele II, 10/L, Bergamo, Bergamo Companies Register, Tax ID and VAT no. 04867620165, Bergamo REA no. 495217 — are joint data controllers (“ChorusLife” or “Data Controller”) of the personal data of users (“Users”) who access the choruslife.com website (“Site”) and use the services available therein. In accordance with the provisions of Regulation (EU) 2016/679 (“Regulation”), ChorusLife provides Users with the following information.

For the processing related to the table booking service at the restaurants “L’Angolo con Vista” and “L’Angolino Bistrot & Lounge Bar“, in addition to the joint controllers above, ChorusRooftop S.r.l., with registered office at via Madonna della Neve, 27, Bergamo, Bergamo Companies Register, Tax ID and VAT no. 04791820162, is also a joint controller (therefore, limited to this processing, it is also included within the definition of “ChorusLife” or “Data Controller” as indicated above).

For the processing related to the table booking service at the “GNAM” restaurant, in addition to the joint controllers above, Chorusfood s.r.l., with registered office at via Moretti, 34, Bergamo, Bergamo Companies Register, Tax ID and VAT no. 04910420167, Bergamo REA 498414, is also a joint controller (therefore, limited to this processing, it is also included within the definition of “ChorusLife” or “Data Controller” as indicated above).

For the processing related to the parking reservation service, in addition to the joint controllers above, Chorus Parking S.r.l., with registered office at via Madonna della Neve, 27, Bergamo, Bergamo Companies Register, Tax ID and VAT no. 04779030164, is also a joint controller (therefore, limited to this processing, it is also included within the definition of “ChorusLife” or “Data Controller” as indicated above).

For the processing related to Arena communications, in addition to the joint controllers above, Chorus Life Arena S.r.l., with registered office at via Madonna della Neve, 27, Bergamo Companies Register, Tax ID and VAT no. 04779020165, is also a joint controller (therefore, limited to this processing, it is also included within the definition of “ChorusLife” or “Data Controller” as indicated above).

To this end, the joint controllers have entered into a joint controllership agreement governing the management of Users’ data within the Site, the direct marketing and profiling activities for sending commercial communications, and the exercise of the rights provided for by the Regulation, the essential content of which may be made available to the user upon their request.

2. FOR WHICH PURPOSES IS THE DATA PROCESSED?

Personal data collected through the Site and/or otherwise communicated by the User are processed in order to:
A. allow ChorusLife to comply with its legal obligations;
B. allow the User to access the Site and use the services available there. For some services, registration is required (e.g. apartment configurator or table booking at certain restaurants), while for others it is not necessary;
C. upon the User’s request, contact the User by email or phone in order to provide a personalised service for the configuration and reservation of a residence in the ChorusLife smart district;
D. allow ChorusLife, upon the User’s request, through a specific contact form or other methods, to contact the User to respond to the User’s requests;
E. allow ChorusLife to contact Users for commercial purposes within the Chorus Life experience, as well as for market research and surveys via email and other communication tools (e.g. SMS, direct messaging, telephone, in-app notifications, etc.);
F. allow ChorusLife to assess the User’s tastes, preferences, interests and habits in order to personalise the commercial communications referred to in the previous point.

Furthermore, in case of corporate events (sale of the company or business branches), due diligence, or in case of defence of a right in legal proceedings and in relation to the related preparatory activities, ChorusLife may carry out further processing operations connected to corporate transactions or judicial events.

3. WHICH DATA ARE PROCESSED?

When the User browses the Site, their usage data is collected (which includes, among others, the IP address, the user agent, browsing data such as pages visited and time spent on them, the duration of sessions) and, if the User fills in any form (including the registration form), some identifying data is also collected including first and last name, email address and/or phone number, and any personal data freely entered by the User in the contact form (these indications also apply with reference to the various reservation forms, for example data related to a vehicle in case of parking reservation). For commercial purposes, where consent has been given by the User, the User’s email address is also processed for sending commercial communications (where provided, additional contact data is also processed). If the User decides to respond to the surveys referred to in letter D of paragraph 2 above, ChorusLife will also process the information included in the relevant answers.

4. ON WHICH BASIS ARE THE DATA PROCESSED?

The processing of personal data for the purpose referred to in letter 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 letter B and letter C of paragraph 2 (use of the Site and enjoyment of related services) is carried out on the basis of a contract with the User and/or the performance of pre-contractual measures. The processing of personal data for the purpose referred to in letter D of paragraph 2 (contacting the user following the completion of a contact form) is carried out on the basis of the Data Controller’s legitimate interest in following up on 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 of commercial communications and their personalisation) is optional, and ChorusLife may process personal data for these purposes only with the prior consent of the User. If the User does not wish to consent to the processing of their 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 can be revoked at any time. Failure to grant such consent will have no consequence on the provision of the Data Controller’s services under the purposes referred to in paragraph 2, letter B.
The User’s personal data may also be processed on the basis of Chorus Life’s legitimate interest in carrying out corporate transactions or managing/exercising its own rights, for example in the context of any corporate events (sale of the company or business branches), due diligence, in case of defence of a right in legal proceedings and in relation to the related preparatory activities.

5. HOW IS THE DATA PROCESSED?

In relation to the above-mentioned purposes, data processing will take place mainly through the use of electronic tools and, to a residual extent, through paper-based support, but in any case with tools suitable to guarantee security and confidentiality.

6. TO WHOM IS THE DATA COMMUNICATED?

Personal data collected through the Site and/or otherwise communicated by the User will be processed by persons authorised to process data within ChorusLife and may be communicated solely and exclusively for the indicated purposes and where necessary, to the following categories of subjects: IT service providers (such as providers of services for restaurant table reservations); developers and consultants of ChorusLife, for example in IT, legal, tax and fiscal fields; group companies such as, by way of example and not exhaustively, General Contracting Services s.r.l. and Elmet S.r.l.

Where required by law, the data may also be communicated to the 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, the subjects belonging to the categories listed above may operate, as the case may be, as data processors (and in that case will receive appropriate instructions from ChorusLife) or as distinct data controllers. In the latter case, personal data will be communicated only with the express consent of the data subjects, except in cases where the communication is required or necessary by law, or for the pursuit of purposes for which the law does not require the data subject’s consent.

7. IS THE DATA TRANSFERRED ABROAD?

ChorusLife may transfer the User’s personal data to third countries. Data transfers outside the European Economic Area are subject to a special regime under the Regulation, and are only carried out 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 appropriate safeguards have been adopted (including the standard contractual clauses approved by the European Commission), provided that data subjects have enforceable rights and effective remedies.

8. FOR HOW LONG WILL MY PERSONAL DATA BE RETAINED?

The personal data collected will be stored in accordance with the legislation in force for a period of time not exceeding that necessary to achieve the purposes for which they are processed.
The criteria for determining the retention period of personal data take into account the permitted processing period and the applicable laws on the limitation of rights and legitimate interests where they constitute the legal basis of the processing. For example, in case of account closure, the Data Controller will have the right to retain information related to the User in order to comply with legal obligations, where applicable (e.g. of a tax nature), as well as to protect itself in case of any exercise of rights by the User until the end of the applicable limitation period (ten years).
With reference to commercial purposes, personal data will be processed until any revocation of consent, it being understood that ChorusLife will adopt procedures to make the User aware of their rights, including the right to manage (and therefore also revoke) their consents. In any case, in the absence of interaction between the User and the Data Controller for a period of 24 months, the processing in question will be discontinued. In such circumstances, in the absence of further legal bases (for example management of the User’s registration), the data will be deleted or anonymised.
In relation to the personalisation of the Chorus Life experience, ChorusLife will use the information for a period of 12 months from its collection, without prejudice to the User’s right to revoke their consent at any time. Upon expiry of the retention period, the data will be deleted, anonymised or aggregated in such a way as not to allow the User to 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 processing of their personal data is taking place and, in such case, obtain access to the information referred to in art. 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 art. 17 of the Regulation;
• obtain the restriction of processing of their personal data, where one of the cases referred to in art. 18 of the Regulation applies;
• object to the processing of their personal data for reasons connected with their particular situation, where applicable, pursuant to art. 21 of the GDPR;
• receive in a structured, commonly used and machine-readable format the personal data concerning them, as well as transmit such data to another controller without hindrance from the Data Controller, where technically possible, in the cases and within the limits referred to in art. 20 of the Regulation, where applicable.

In addition, Users have the right to revoke their consent to the processing of their personal data (where given), at any time, without prejudice to the lawfulness of processing based on the consent given prior to revocation. In case of revocation of consent, the Data Controller undertakes to follow it 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.

The relevant requests to exercise the rights indicated above must be sent by email to the address info@choruslife.com or to the Data Protection Officer at dpo@choruslife.com.
Under the Regulation, ChorusLife is not authorised to charge fees to fulfil one or more of the requests listed in this paragraph, unless they are manifestly unfounded or excessive, and in particular of a repetitive nature. In cases where the User requests more than one copy of their personal data, or in case of excessive or unfounded requests, ChorusLife may (i) charge a reasonable expense contribution, taking into account the administrative costs incurred to process the request, or (ii) refuse to fulfil the request. In these cases, ChorusLife will inform the User of the costs before processing the request.
ChorusLife may request further information before processing the requests, should it need to verify the identity of the natural person who submitted them.

The exercise of these rights may, in any case, be delayed, limited or excluded by motivated communication made without delay to the User, unless the communication could compromise the purpose of the limitation, for the time and within the limits in which this constitutes a necessary and proportionate measure, taking into account the fundamental rights and legitimate interests of the User, in order to safeguard any interest in the conduct of a defensive investigation or the exercise of a right in court (and the related preparatory activities). In such cases, the rights of the data subject may also be exercised by appealing to the Italian Data Protection Authority.
Without prejudice to any other administrative or judicial remedy, the User also has the right to lodge a complaint with the Italian Data Protection Authority, if they believe that the processing concerning them is carried out in violation of the General Data Protection Regulation. Further information is available on the website http://www.garanteprivacy.it.
ChorusLife invites the User, in any case, to make direct contact through the channels indicated above before turning to the Supervisory Authority, so as to amicably and as quickly as possible resolve any dispute regarding the protection of personal data.

06/05/2026