This document describes how the site www.hotelsantavittoria.com (“Site”) is managed, with reference to the processing of personal data belonging to the users (“User/Users”) consulting it. It is an information notice issued in accordance with article 13 of the Italian Legislative Decree no. 196/2003 (“Privacy Code”) and articles 13 of the EU Regulation no. 679/2016 (“GDPR”), for anyone who visits the Site and/or interacts with Castello di Santa Vittoria S.r.l. services available through the Site.
1. Data controller
The data controller is Castello di Santa Vittoria S.r.l. with registered office in Via Cagna, 4 – 12069 Santa Vittoria d’Alba (Cn) P.IVA P.I./CF. 02755670045 e-mail address firstname.lastname@example.org (“Data Controller or Castello di Santa Vittoria”).
2. Types of data processed
2.1 Browsing data
During normal use, the electronic systems and software procedures enabling this Site to operate, acquire certain personal data; transmission of same is implicit in the use of internet communication protocols.
This information is not being collected in order to be associated to well-identified data subjects, but its nature, by means of processing and associations with data held by third parties, could make the users identification possible.
The category of data could be listed as follow: (i) IP addresses or domain names of computers used by users connecting to the Site, (ii) addresses in URI (uniform resource identifier) notation for resources requested, (iii) the time of request, (iv) the method used to submit the request to the server, (v) the dimension of the file obtained in response, (vi) the numerical code indicating the status of the response given by the server (success, error etc) and (vii) other parameters regarding the user’s operating system and the IT environment.
This data is used only to glean anonymous statistical information on the use of the Site and to check that it operates correctly and this data is deleted immediately after processing.
2.3 Data provided on volountary basis
The data controller processes the following data supplied by the User: email, name, surname, telephone number. Users are responsible for any Personal Data of third parties obtained, published or shared through Castello di Santa Vittoria and confirm that they have the third party’s consent to provide the Data to the Owner. The Users declare to be the age thus freeing the data controller from any liability.
3. Purposes of the processing and voluntary or obligatory nature of providing the data
The personal data of the Users are processed by the Data Controller in order to:
- pursue, in accordance with article 6(1) let. f) of GDPR, an its own legitimate interests consisting in ensuring network and information security, i.e. the ability of a network or an information system to resist, at a given level of confidence, accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services offered by, or accessible via, those networks and systems;
- allow the User to ask for information by using the “Contact us” form page and the data processor to send the feedback required;
- contact the User and sending messages, newsletter, letters containing marketing information related to services and products offered by Castello di Santa Vittoria after the User has given its free and specific consent in accordance with the article 23 and 130 of the Privacy Code and article 7 of GDPR;
- to exercise of the rights of the Data Controller, for example the right of defence;
- to fulfil the legal obligations provided by the law, a regulation or community norm or to any order from the competent Supervisor Authority.
Castello di Santa Vittoria can send marketing information related to products and similar to those that User has already used, unless the User deny his consent as indicated in the art. 130 paragraph 4 of the Privacy Code.
4. Consequences of any refusal to respond
Except as provided for the browsing data which are necessary to allow the Users to correctly use the Site and for the cookie, the users are free to provide their personal data in order to ask for a Data Controller reply. The refusal to allow their data to be processed would make impossible for Users to obtain any reply.
5. Method of processing
The personal data is processed through computerized, automated manual systems for such period of time that is necessary to achieve the purposes for which the data is collected.
The personal data, moreover, is processed only by those subjects appointed to carry out such fulfilments, currently identified and duly educated on the constraints provided by the applicable law, as well as by adopting specific security measures aimed to ensure the protection of Your confidentiality and to avoid the loss of data, any unauthorized accesses to the data and any data processing which may be qualified as unlawful or not in compliance with the abovementioned purposes.
6. Communication of personal data
In any case, it remains understood that the Data Controller retains the right to communicate the Users personal data to the companies in charge for carrying out specific services within its activity and/or, in general, in its favor, that will operate as independent data controllers or processors, as well as the right to communicate and/or to distribute the User personal data that, in compliance with the applicable law, the police, the judicial authority, the information and security agencies or other public subjects might ask for purposes related to defense or State security or to preventing, detecting or suppressing crimes.
Your data are not subject to dissemination.
7. Transfer of personal data
The Data storage and processing take place in on servers within the European Union. It is understood that, the Data Controller, if necessary, will have the right to move the location of servers in Italy and / or European Union and / or non-EU countries. In such a case, the Data Controller shall ensure that the transfer of Data in non-EU countries will take place in accordance with applicable law by stipulating, where necessary, agreements ensuring an adequate level of protection and / or adopting the standard contractual clauses as provided by the European Commission.
8. Data subject’s rights
Pursuant to article 7 of the Privacy Code and articles 15 et seq. of GDPR, the User has the right to obtain:
- confirmation of whether or not there is personal data concerning him/her, even if such data has not been registered yet, is entitled to receive notice of such data in a form that is legible and to access to such data;
- a copy of Your personal data;
- rectification of Your personal data, if they are incorrect;
- erasure of Your personal data;
- restriction of Your personal data processing;
- in a structured, commonly used and machine-readable format, personal data You have provided to the Data Controller or You have created;
- the indication of:
- the source of personal data;
- the categories of personal data processed;
- the purposes and manner of data processing;
- the reasoning applied in the event of processing undertaken with the aid of electronic systems;
- details allowing identification of data controllers and data processors;
- the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period;
- individuals or entities or categories of individuals or entities to whom personal data may be communicated or who may gain knowledge thereof in their capacity as designated representative in Italy, data processors or persons in charge of the processing;
- updating, rectification, and, when requested, integration of the data;
- anonymization or blocking of data that have been processed unlawfully, including data which it is not necessary to preserve in respect of the purposes for which the data is collected or subsequently processed;
- The data subject, moreover, shall have the right to object, either wholly or partially:
- on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
- to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication survey.
In order to exercise the aforementioned rights, it is necessary to write to the Data Controller e-mail address, as it is indicated at the previous paragraph 1, specifying “Privacy ” as object.
Finally, we inform You that if You believe that your rights have been infringed by the Data Controller and/or by a third party, you have the right of lodging a complaint with a Italian Data Protection authority (“Garante Privacy”) and/or with another competent authority provided by GDPR.
9. Data retention
The processing will last only for such period of time that is necessary for achieving the purposes mentioned at the previous paragraph 3. The Data Controller will then store Your personal data only in compliance with the legal obligations provided by the applicable laws, for administrative purposes and/or to claim or to defend an own right in the case in which a litigation or a pre-litigation procedure arise.
The User can always request that the Data controller suspend any use of the Data or remove the Data.
If the User considers that its rights have been infringed by the Data Controller, has the right to lodge a complaint with the Italian Supervisory Authority or any other supervisor authority in the European Union by following the procedure provided by this link: https://www.garanteprivacy.it/en/home_en/.