INFORMATION ON PERSONAL DATA PROCESSING
Pursuant to Articles 13/14 of Regulation (EU) 2016/679 “General Data Protection Regulation” Dear Guest,
DeG Professional Srl. (VAT/Tax ID 17343551002), with its registered office at Viale Regina Margherita, 176, 00918, Rome, ITALY, as the Data Controller, informs you about the use of personal data provided by you and/or relating to you for the booking and stay at the Villa Tower Inn hotel in Pisa.**
The Data Controller company informs you, pursuant to Articles 13/14 of Regulation (EU) 2016/679, that it will process the personal data provided by you or relating to you in accordance with the legal provisions. According to the regulations, the processing of your personal data (personal details, residence data, contact data, email, mobile phone, data relating to preferences, booking data, data relating to your stay, navigation data, etc.) will be conducted in accordance with the principles of fairness, lawfulness, transparency, and the protection of confidentiality.
1) Purposes of Booking and Stay
We inform you that the personal data provided by you or relating to you during the booking and/or stay will be processed for the provision of the requested hotel services. The legal basis for this processing is represented by the necessity to fulfill contractual and/or pre-contractual obligations pursuant to Article 6(1)(b) of Regulation (EU) 2016/679, as well as the necessity to comply with legal obligations pursuant to Article 6(1)(c) of Regulation (EU) 2016/679. We inform you that the provision of these personal data is essential for the provision of hotel services; in the event of failure to provide the data, the Data Controller company may not be able to fully or partially provide the requested services. Personal data, as defined in Article 4(1) of Regulation (EU) 2016/679, may be processed for the time necessary to fulfill contractual and/or legal obligations.
2) Purposes of Profiling and Marketing (Optional)
With your express authorization, the personal data (as defined in Article 4(1) of Regulation (EU) 2016/679) provided by you or relating to you during the booking and/or stay may be processed for the following additional purposes:
- A) “direct marketing” activities through the sending of advertising/promotional material via ordinary mail; email, SMS/MMS, mobile applications or other digital communication channels.
- B) customer profiling activities aimed at improving the offer of goods and services of the company D e G Professional Srl (customer profiling).
We inform you that the processing mentioned above may be managed to understand your consumption choices in order to make the commercial policies and services of the company more effective. Consequently, you may receive discounts, offers, or promotions tailored to your preferences and consumption habits. The provision of data for the purposes outlined in the previous points A) – B) is free and optional; therefore, all hotel services can still be provided even if you refuse to authorize the processing for the purposes outlined in this point 2). The legal basis for the processing is your explicit consent, given by checking the appropriate clauses and completing the double opt-in procedure. The personal data provided by you or relating to you, as per Article 4(1) of Regulation (EU) 2016/679, will be processed in accordance with the legal provisions for a period appropriate to the fulfillment of the purposes indicated in this point 2), taking into account the principle of balancing the legitimate interests of the data controller with the rights and freedoms of the client as the data subject. Your data will be processed according to the timelines provided by the legal provisions, or in the absence of specific rules, your data will be processed for as long as necessary for the execution of marketing and profiling activities. The data controller company guarantees that the processing of data will not occur indefinitely. We emphasize that you have the right to withdraw your consent for the activities outlined in this point 2) at any time by means of a simple informal written communication to the contact details of the Data Protection Officer specified later in this information notice. In accordance with the law, any processing carried out before the withdrawal remains valid.
Below we provide you with further information and clarifications valid for both the processing specified in point 1) and those specified in point 2):
– The personal data provided by you or relating to you may be subject to partially or fully automated processing that may be carried out using paper, electronic, and/or magnetic media.
– The personal data will not be disclosed but may be communicated or may come to the knowledge of specifically trained operators who are part of the staff of the data controller company and/or external parties who collaborate with the company as data processors or independent data controllers, such as, but not limited to:
– Companies, firms, and/or freelance professionals for data processing and management activities;
– Companies, firms, and/or freelance professionals for consulting and/or management activities in technical, corporate, and IT fields;
– DeG Professional Srl for the provision of goods and/or services and for related activities;
– Other parties to whom communication is necessary for the correct and complete performance of the contractual relationship and/or to fulfill legislative obligations and/or to pursue the specified purposes.
– We inform you that the Data Controller company has appointed external data processors who may have IT systems in countries outside the European Union, and therefore the data may be processed in those countries. However, we specify that personal data will only be processed in third countries that have obtained an adequacy decision from the European Commission and guarantees of security in processing. For any clarification and request, you can contact the Data Protection Officer (DPO) at the contact details specified below.
– We also inform you that it is your right to request from the Data Controller company access to your personal data, rectification, erasure, restriction of processing, and to object to the processing of personal data and exercise the right to data portability. The rights mentioned in this paragraph can be exercised as provided for in Articles 15, 16, 17, 18, 20, 21 of Regulation (EU) 2016/679, which we reproduce for your convenience along with this information notice. All rights can be exercised against the Data Controller company. Additionally, it is your right to lodge a complaint with the supervisory authority provided for by the applicable national law.
– For any clarification and to exercise the rights mentioned above, you can contact the Data Controller (DeG Professional Srl) by reaching the Data Protection Officer (Art. 37 Reg. UE 2016/679) at the privacy office of DeG Professional Srl, Viale Regina Margherita, 176, 00918, Rome, ITALY, or by phone at +39 3356181786, or by email at hotevillatowerinn@gmail.com.
D e G Professional Srl. This notice supplements and completes information already known to the data subject.
EXTRACT FROM REGULATION (EU) 679/2016 Article 15 Right of access by the data subject
1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
f) the right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the data subject, any available information as to their source;
h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
**Article 16 Right to rectification**
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Article 17 Right to erasure (‘right to be forgotten’)
1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based according to Article 6(1)(a), or Article 9(2)(a), and where there is no other legal ground for the processing;
c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
d) the personal data have been unlawfully processed;
e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
a) for exercising the right of freedom of expression and information;
b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) as well as Article 9(3);
d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
e) for the establishment, exercise or defence of legal claims.
significance and the envisaged consequences of such processing for the data subject.
2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
**Article 16 Right to rectification**
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Article 18 Right to restriction of processing 1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: (a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject. 2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. L 119/44 EN Official Journal of the European Union 4.5.2016 3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted. Article 20 Right to data portability 1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: (a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and (b) the processing is carried out by automated means. 2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others. Article 21 Right to object 1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. 4.5.2016 IT Official Journal of the European Union L 119/45 4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Cookies policy
Extended Information on Cookies
Cookies consist of portions of code installed within the browser that assist the Controller in providing the service according to the described purposes. Some of the purposes of installing Cookies may also require the consent of the User.
Technical and Aggregated Statistics Cookies
- Activities strictly necessary for operation:
This Application uses Cookies to save the User’s session and to carry out other activities strictly necessary for its operation.
- Activities for saving preferences and optimization:
This Application uses Cookies to save browsing preferences and optimize the User’s browsing experience. These Cookies include, for example, those used to set the language and currency.
**Other types of Cookies or third-party tools that may be used:** Some of the services listed below collect statistics in aggregate form and may not require the User’s consent or may be managed directly by the Controller – depending on what is described – without the help of third parties. If among the tools indicated below there are services managed by third parties, these could – in addition to what is specified and also without the Controller’s knowledge – perform tracking activities of the User. For detailed information, it is recommended to consult the privacy policies of the listed services. How can I control the installation of Cookies? In addition to what is specified in this document, the User can manage preferences for Cookies directly within their own browser and prevent – for example – third parties from installing them. Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookie that might have saved the consent for the installation of Cookies by this site. It is important to note that, by disabling all Cookies, the functioning of this site may be compromised. The User can find information about how to manage Cookies in their browser at the following addresses: [Google Chrome](https://support.google.com/chrome/answer/95647?hl=en), [Mozilla Firefox](https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences), [Apple Safari](https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac), and [Microsoft Windows Explorer](https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies). In the case of services supplied by third parties, the User can also exercise their right to object to tracking by consulting the privacy policy of the third party, via the opt-out link if explicitly provided, or by contacting the same directly. Notwithstanding the above, the Controller informs the User that they may use Your Online Choices. Through this service, it is possible to manage the tracking preferences of most advertising tools. The Controller, therefore, advises Users to use this resource in addition to the information provided in this document. Given that the installation of Cookies and other tracking systems operated by third parties via the services used within this Application cannot be technically controlled by the Controller, every specific reference to Cookies and tracking systems installed by third parties is to be considered indicative. For complete information, consult the privacy policy of any third-party services listed in this document. Given the objective complexity linked to the identification of technologies based on Cookies and their very close integration with the operation of the web, the User is invited to contact the Controller should they wish to receive any further information regarding the use of Cookies and any uses of the same – for example by third parties – made through this site.
Further Information on Processing
Defense in Court
The User’s Personal Data may be used for the defense by the Controller in court or in the stages leading to possible legal action, in cases of abuse in the use of the same or related services by the User. The User declares to be aware that the Controller may be required to disclose the Data at the request of the public authorities.
Specific Information
Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific services, or the collection and processing of Personal Data.
System Logs and Maintenance
For operational and maintenance needs, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
For more information regarding the processing of Personal Data, Users may contact the Data Controller at any time using the contact information provided. This Application does not support “Do Not Track” requests. To determine if any third-party services used support them, please consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time, notifying Users on this page. Therefore, please consult this page frequently, taking the date of the last modification indicated at the bottom as a reference. In the event of non-acceptance of the changes made to this privacy policy, the User is required to cease the use of this Application and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to the Personal Data collected up to that time.
**Update 01.02.2024**
