Privacy Policy
Last updated: 5 October 2026
This notice is provided under Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and Italian Legislative Decree 196/2003 as amended, to visitors of themanhattan.it and to anyone enquiring about The Manhattan residences (Viale Giacinto Martinelli 13, Riccione, Italy).
1. Data controller
New Eden S.r.l.
Registered office: Viale Tiberio 11, 47921 Rimini (RN), Italy
Tax code / VAT no.: IT04692650403
E-mail: info@theneweden.it
Certified e-mail (PEC): neweden.srl@legalmail.it
2. Data we process
- Enquiry form data (“Enquiry” popup / Contact page): name, e-mail address, phone number, apartment of interest, your message, and your confirmation that you have read this notice.
- Data you give us when contacting us directly by e-mail, phone or WhatsApp: your contact details and the content of the communication.
- Browsing data: our systems and hosting provider record technical data such as IP address, date and time, page requested, browser and operating system (server logs), needed for the site to work securely.
- Cookies and similar tools: technical cookies and, only with your consent, Google Analytics 4 analytics cookies and Google Maps content. See the Cookie Policy.
3. Purposes and legal bases
- Answering your enquiries about the residences and arranging contacts, viewings and negotiations: pre-contractual steps taken at your request (Art. 6(1)(b) GDPR).
- Operation and security of the site, prevention of abuse and spam: our legitimate interest (Art. 6(1)(f)).
- Website usage statistics with Google Analytics 4 and loading Google Maps: only with your consent (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code), which you can withdraw at any time.
- Legal obligations and defence of legal claims: legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)).
Providing form data is optional, but without your name and e-mail we cannot reply. We do not use your data for automated decision-making or profiling and we do not pass it to third parties for marketing.
4. Recipients
- Sales agent: enquiries sent through the form are e-mailed to the real-estate agent Federica Gigio (Coldwell Banker Italy network, federica.gigio@cbitaly.it), who will contact you and handle the sale, with a copy to the controller (info@theneweden.it). The agent processes the data for real-estate brokerage purposes .
- Technical providers acting as processors: Hostinger International Ltd (website hosting and sending of form e-mails), the controller’s e-mail provider, Google Ireland Ltd (Google Analytics 4 and Google Maps, only with consent).
- Authorities and others where disclosure is required by law.
5. Third-party services
- Google Analytics 4 (Google Ireland Ltd): enabled only after you consent via the cookie banner (Google Consent Mode v2, default “denied”). Google Signals and ad personalisation are disabled; GA4 does not log or store IP addresses. Data may be transferred to Google LLC in the United States, which participates in the EU-U.S. Data Privacy Framework.
- Google Maps: the interactive map on the Location page loads only if you consent to “external content” or click “Load map”; at that point your browser connects to Google servers.
- Google Fonts: the site uses fonts served by Google; to download them your browser sends your IP address to Google. Google states it does not use this data for profiling.
- WhatsApp (WhatsApp Ireland Ltd / Meta): the WhatsApp button opens a chat with the agent’s number (+39 389 028 9998). WhatsApp’s own privacy policy applies; your messages will be handled by the agent to answer your enquiry.
- Language flags: flag icons are loaded from flagcdn.com, which receives your browser’s IP address.
6. Retention
- Enquiries and related communications: as long as needed to handle the enquiry and any negotiation, and no longer than 24 months after the last contact, unless a contract follows or the law requires otherwise.
- Google Analytics 4 data: for the retention period set in the GA4 property (maximum 14 months).
- Technical server logs: for the period set by the hosting provider for security purposes.
- Your cookie choice: 6 months, after which you will be asked again.
7. Your rights
You may at any time exercise your rights under Articles 15-22 GDPR: access, rectification, erasure, restriction, portability, objection to processing based on legitimate interest, and withdrawal of consent (without affecting earlier lawful processing). Write to info@theneweden.it. You can change your cookie choices at any time via Cookie preferences.
You also have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it).
8. Changes
This notice may be updated; the date of the latest update is shown at the top.