Privacy Policy

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We inform you,
pursuant to the art. 13 of the GDPR n. 2016/679 (hereinafter, “GDPR”), that in case of collection of personal data concerning you, such processing will be based on the principles of correctness, lawfulness, transparency and protection of your privacy and your rights;
a) our organisation, as a legal person, has the dual role of data controller and data controller;
b) the data controller and the data processor (see contact details on the last page); having carried out the appropriate assessments internally, they have not designated the data protection manager, as, pursuant to art. 37 paragraph 1 of the GDPR n. 2016/679 is not covered by the obligation.

Your data will be processed
c/i) pursuant to art. 6 letter b) and c), for purposes relating to the execution of a contract or the execution of pre-contractual measures and to fulfill the legal obligations to which the data controller is subject; for example, data processing necessary for the management of requests, estimates and bookings, fulfillment of all contractual, accounting and tax obligations, management of payments including by credit cards, POS and advanced online services managed by the respective credit institutions or agencies and litigation management; furthermore, for all obligations established by law; for example, regulations, community and local regulations or orders from the authorities, registration and communications given to the authorities and management of any disputes; in addition to this, for the pursuit of the legitimate interest of the data controller or third parties under the conditions established by the GDPR;
c/ii) pursuant to art. 7, subject to your freely expressed consent, for other service and marketing purposes; for example; data processing necessary for sending promotional offers on our services and other events, updating rates, other quotes provided as well as greetings and holiday communications; to carry out additional services such as external communication of data relating to your stay for the exclusive purpose of allowing the function of receiving objects, messages and telephone calls addressed to you;
for the processing of particular categories of personal data in order to offer a better level of hospitality; for example, food intolerances, allergies or other particular data;
for the processing of advanced online services; for example, signing up for our management program to use your email address to send your bill, receipt or invoice, to manage loyalty scores and other similar services;
c/iii) pursuant to art. 7, subject to your freely expressed consent, for further purposes; for example; data processing necessary to LOGIN to our public WIFI/LAN network to surf the internet;
as well as data processing necessary during the use of our institutional website whose transmission is implicit in the use of internet communication protocols, such data are not collected to be associated with identified interests, but by their very nature could, through processing and associations with data held by third parties, allow users to be identified; for example, this category of data includes the IP addresses or names of the devices used by users who connect to the site, the URI notation addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server response and other parameters relating to the operating system and the user’s information environment;
the aforementioned data can be used for the sole purpose of obtaining anonymous statistical information on the use of the public WIFI/LAN network and the institutional website; for example, to check the correct functioning of our IT infrastructure and improve the service;
Likewise, the data could be used by the competent authorities, for example, to ascertain responsibility in the event of hypothetical computer crimes or damage to our WIFI network, LAN, our IT system and our institutional website.
d) pursuant to art. 6 paragraph 1 letter f), taking into account the reasonable expectations of the parties, for the purposes of legitimate interests pursued by the data controller or by third parties; for example; data for the purposes of fraud prevention (attendance monitoring, entry register, biometric data, video surveillance images…) and direct marketing purposes.

The recipients and categories of recipients of your data are
e) natural or legal persons, public authorities, collaborators such as employees, professionals, service providers, bodies and associations.

Your personal data may be transferred to a third country or to an international organisation
f) due to the foregoing, your data in addition to being processed in paper format in the internal archives of our organization or with third parties; they are mostly processed and stored in electronic format on our mass storage inside our structure or within the European Union through hosting, server and cloud services. In any case, it is understood that the owner, if necessary, will have the right to move the hosting, server and cloud servers also to non-EU areas; Likewise, the owner hereby ensures that the transfer of data to non-EU areas will take place in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided for by the European Commission. The processing of your data is correct and transparent, carried out through the operations of collection, recording, organisation, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper and electronic and/or automated processing. They may be processed, only for the purposes referred to in c/i, c/ii, c/iii and d above, also by employees and collaborators of the owner or other entities based in Italy and other European countries, by third-party companies or other subjects; for example, by way of example, credit institutions, professional firms, insurance companies for the provision of insurance services, IT and telephone service providers or other entities that provide services/products on behalf of the Data Controller, in their capacity as external managers of the treatment. If personal data are not obtained from the interested party, the data controller, in application of the art. 14 of the GDPR, will provide every specific circumstance within one month; otherwise, this information applies to you. The retention period of your data is defined a) as long as necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the purposes referred to in previous points c/i and for no more than 2 years from collection of the data for the purposes referred to in previous points c/ii, c/iii and d. As an interested party, by sending a registered letter or an email to the data controller at, you can assert the following rights. b) right of access, referred to in art. 15 of the GDPR, to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to obtain access to the personal data and information; if you request further copies of data, the owner and data controller reserves the right to charge you a reasonable fee based on administrative costs; right of rectification, pursuant to art. 16 of the GDPR, to obtain the rectification of inaccurate personal data concerning you without unjustified delay; right to cancellation, pursuant to art. 17 of the GDPR, to obtain the cancellation of personal data concerning you without unjustified delay; right to limit processing, pursuant to art. 18 of the GDPR, to obtain the limitation of processing; right to data portability, pursuant to art. 20 of the GDPR, to receive in a structured format the personal data concerning you provided to a data controller and to transmit such data to another data controller without impediments; right of opposition, pursuant to art. 21 of the GDPR, to object at any time to the processing of personal data concerning you pursuant to art. 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions. c) right to revoke consent, for the cases provided for by the GDPR, at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation; d) right to lodge a complaint with a supervisory authority, in ITALY the Privacy Guarantor PIAZZA DI MONTE CITORIO n. 121 00186 ROME email e) Nature of the provision of data and consequences of refusal to respond The provision of data for the purposes referred to in the previous point c/i is mandatory, equally, taking into account the purposes of legitimate pursuits referred to in the previous point d, the provision must be consented to; in their absence, our organization cannot guarantee the provision of services and the satisfaction of your expectations. Without the need for express consent, the processing of such data can be carried out by the Authorities, by the insurance company for the provision of insurance services, by professional firms also for the management of disputes, as well as by those subjects to whom communication is mandatory. by law for the fulfillment of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers. Your information will not be disseminated. The provision of data for the purposes of c

The previous c/ii and c/iii is optional. Taking into account the reasonable expectations of the parties for the purposes. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the services offered and use the internet connections via our WIFI network /public LAN as well as a series of advanced services present on our institutional website. However, you will continue to be entitled to the services referred to in the previous c/i
f) You have the right not to be subjected to a decision based solely on automated processing
referred to in the previous points c/ii and c/iii, including profiling that produces legal effects concerning you or that significantly affects your person in a similar way. Therefore, the interested party can decide to receive only communications via traditional methods or only automated communications or neither of the two types of communication.

date 06/17/2024

Contact details of the Data Controller