Privacy policy

This application is used by the hotel or accommodation facility (referred to in the following as Data Controller or Data Owner, as an automated reservation processing tool. This Application collects some Personal Data from its Users, processes and stores the data for later use on behalf of the Data Controller itself. Hereafter follow the relevant information regarding Privacy and Data Treatment in compliance with the EU General Data Protection Regulation (GDPR).

1.     Definitions

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, directly or indirectly, by reference to any other information, including a personal identification number.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor on Behalf (or Data Processor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

Usage Data

Information collected automatically from this Application, or from any third party service used by this Application, which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

This Application

The hardware or software tool comprising the present reservation service by which the Personal Data of the User is collected and processed on behalf of the Data Controller.

Cookie

Small piece of data stored in the User's device.

2.     Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: First Name, Last Name, Phone number, Address, Country, State, Province, Email address and ZIP/Postal code, Reservation Information (such as room type, rate plan, extras, amount, etc.), Cookie and Usage data.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User, or collected automatically when using this Application.
Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless otherwise stated, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.
Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

3.     Methods of processing the Data

Methods of Processing

The Data Controller by means of the Data Processor processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Means of Processing

The Data is processed via the Internet using encrypted https protocol, stored in GDPR compliant server infrastructure by the Data Processor and transmitted to the Data Controller via the Internet using encrypted https protocol. The data is that managed in Data operating offices and in any other places where the parties involved with the processing by the Controller are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

4.     The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its Accommodation services, as well as for the following purposes: Analytics, Interaction with external social networks and platforms, Access to third party services' accounts, Advertising, Contacting the User, Displaying content from external platforms, Handling payments, Infrastructure monitoring, Registration and authentication and Remarketing.

The Personal Data used for each purpose is outlined in the specific sections of this document.

5.     Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookie and Usage data.

Place of processing: USA – Privacy Policy – Opt Out

Google AdWords conversion tracking (Google Inc.)

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Application.

Personal Data collected: Cookie and Usage data.

Place of processing: USA – Privacy Policy

Contacting the User

Contact form (This Application)

By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: Address, Country, Email address, Fax number, First Name, Last Name, Phone number, Province, State and ZIP/Postal code.

Phone contact (This Application)

Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.

Personal Data collected: Phone number.

Displaying content from external platforms

These services allow you to view content hosted on external platforms directly from the pages of this Application and interact with them.
If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data collected: Cookie and Usage data.

Place of processing: USA – Privacy Policy

Handling PCI DSS card tokenization and payments

Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

Receptio (SysPay Ltd)

Receptio is a tokenization service provided by SysPay Ltd., which allows Credit Cards to be processed and stored from start to end in a PCI DSS Level 1 environment.

Personal Data collected: Credit Card data - namely Card Holder, Number, Expiry date, and CVV.

Place of Processing: Malta - Privacy Policy

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments using their PayPal credentials.

Personal Data collected: Various types of Data as specified in the privacy policy of the service.

Privacy Policy

Infrastructure

The server infrastructure including, virtual servers, VPN, cloud monitoring services, back-up, storage and system administration is managed by fully qualified GDPR compliant partners.

4Ward S.r.l.

Awarded Microsoft Partner for many years in a row, provides private Cloud Services, Virtual Machines and Storage, and System Administration Services via it’s branch company Pegasus S.r.l.

Place of Processing: Italy - Privacy Policy

6.     Cookie Policy

This Application uses Cookies. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.

7.     Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System Logs and Maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.
To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller and Data Processor reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

The Data Controller is responsible for this privacy policy.

8.     Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application.