1. What is Personal Data?
2. When and what kind of data are stored and processed, and for what reason?
A. Use of the Website
Whenever you navigate our Website, data about you is collected and processed. We collect the following data:
- Information related to the browser or device you use to access our website
- IP address
- Country you are browsing from
- Other demographics and statistical information
The data is collected through the session cookies (with regard to cookies see also below) we use on our Website. It is anonymised before we use it to build anonymous utilisation profiles, for marketing purposes and to optimise our Website and the services we provide. This data shall not be used in order to identify the visitor of this Website personally.
B. Interacting with us
Every time you interact with us (e.g. booking a property through our Website, by phone or through a third party provider,) we may collect and process the Personal Data you provide to us, which includes:
- Your selected property
- Your selected dates
- Number of people in the reservation (adults and children)
- Age of children and infants
- The rate/special offer selected
- Any option and extra selected
- Your full name
- Your address, including city and country, and your billing address
- Your number of passport and date and place of birth
- Your e-mail address, and mobile number
- Your credit card details or of other method of payments
- Arrival Information
- Any other preferences you signalled to us.
We use this Personal Data to handle your reservation and to establish and fulfil our contract with you. This includes verifying your identity, taking guarantee and/or payment information, and sending you stay-related communication.
We have kept the mandatory required fields to a minimum (the fields with the “ * ” are mandatory ).
C. Newsletter and special offers
If you provide your contact information to us (e.g. when booking a service with us or when signing up for our newsletter via our Website), we may use your e-mail address to send you our newsletters and details of other special offers.
If you sign up for our newsletter via our Website, you are required to provide your email address only. When you sign up for the newsletter via our website, you will receive an email to reconfirm your interest in staying in touch (double opt-in). By providing your email address and subsequent confirmation via the double opt-in, you consent to receive our newsletter. You can revoke your consent and opt out of receiving the newsletter at any time by clicking on the unsubscribe link included in every newsletter.
D. “Contact Us” functionality
You can get in contact with us via our Website by using the “Contact Us” functionality, or by telephone. To contact us you are required to provide the following information:
- Your full name
- Your e-mail address
- Your enquiry
- Recaptcha, to confirm you are an actual person, and not a robot
- Any additional information (e.g. home address or telephone numbers ) is provided voluntarily.
We use your information to reply to your enquiry.
By providing your confirmation via the opt-in, you can consent to receive our newsletter to your e-mail address. You can revoke your consent and opt out of receiving the newsletter at any time by clicking on the unsubscribe link included in every newsletter.
3. Transfer of Personal Data to a third country
We use some international Patners in order to give us our services (such as booking engine or payment engine) . Where information is transferred outside the European Economic Area, we will ensure that appropriate safeguards are implemented. If your Personal Data is transferred to a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a third party’s Binding Corporate Rules.
We use the following categories of cookies on our Website:
Category I: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for such as remembering your login details or data provided for a booking cannot be provided.
Category II: Performance Cookies
These cookies collect information on how people use our website. For example, we use Google Analytics cookies to help us understand how users arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, booking experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
Category III: Functionality Cookies
These cookies remember choices you make such as the country you visit our Website from, language and search parameters such as number of guests, property, time of stay. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant.
IV. Google Analytics
Our Website uses Google Analytics, which is a web analytics service provided by the third party provider Google, Inc. (“Google”). Google Analytics is used for the purpose of evaluating your use of our Website, compiling reports on Website activity and other services relating to Website activity and internet usage. The information generated by the cookie about your use of the Website is usually transmitted to and stored by Google on servers in the United States. This transfer is covered by Google’s Privacy Shield certification and a separate data processing agreement that we have concluded with Google :
https://support.google.com/analytics/answer/6004245?hl=de&ref_topic=2919631 (information on Google Analytics and data privacy).
If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Our cookies will have the file names:
Current versions of web browsers offer enhanced user controls regarding the placement and duration of both first and third-party cookies. Search for “cookies” under your web browser’s “Help” menu for more information on cookie management features available to you. You can enable or disable cookies by modifying the settings in your browser. You can also find out how to do this, and find more information on cookies at www.allaboutcookies.org. However, if you choose to disable cookies in your browser, you may be unable to complete certain activities on our websites or to correctly access certain parts of it. If you would like more information about interest-based advertising, including how to opt-out of these cookies, please visit http://youronlinechoices.eu/.
5. What kind of security measures for the compliance with data protection?
We strive to maintain the appropriate standards of security and we have Partners wich guarantee technical and organisational measures for the protection of your Personal Data in accordance with the current state of the art technologies, especially to protect the data against loss, falsification or access by unauthorised third persons. For the transfer of particularly sensible Personal Data via the internet, such as for example credit card details, we use Partners who exclusively use encrypted transmission routes and we comply with the Payment Card Industry Data Security Standards (PCI DSS) and SSAE16/SOC1 certification which is a set of policies and procedures intended to optimise the security of credit, debit and cash card transactions and protect cardholders against misuse of their personal information. However, the transmission of information via the internet is not completely secure. So, whilst we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website. Any transmission is at your own risk. As far as third parties (i.e. external companies) are rendering data processing services for us, we have committed them to the compliance with our data privacy regulations.
6. Your Rights
In respect of the collection and use of your personal data, you may:
- withdraw your consent at any time for example by unsubscribing from the newsletter under “data protection”
- ask us whether we process Personal Data about you, for which purposes, the categories of Personal Data concerned, to which categories of recipients the information has been disclosed, where possible, the envisaged period for which the personal data will be stored (or, if not possible, the criteria used to determine that period)
- inquire with us about the appropriate safeguards relating to the transfer to a third party
- ask us for a copy of the Personal Data undergoing processing and ask to receive your Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any hindrance from us
- have inaccurate data rectified object against the further processing and request erasure of your Personal Data
If you have any further questions on your personal data which has been stored with us or would like to exercise your rights please refer to the contact details stated below.
7. Retention and deletion of Personal Data
We will retain your personal data only for a limited period of time needed to fulfil the purposes of processing mentioned above. After that time your personal data will be erased. If we process your personal data based on your consent we will retain your personal data for a limited period of time needed to fulfil the purposes of processing it.
Where we enter into a contract with you, we will keep your information for the duration of the contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. The criteria to determine the storage period are statutory and contractual requirements, the nature of our relationship with you, the nature of the data concerned are determined by the Italian Laws, that require us to hold certain information for specific periods.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
8. Contact for questions and/or problems relating to the data protection?
Please contact us at firstname.lastname@example.org