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Newsletter Privacy Policy

Pursuant to Art. no. 13 of the EUROPEAN REGULATION No. 679/2016

Dear Interested,

PRINCIPE HOTEL MANAGEMENT srl as Data Controller pursuant to art. no. 13 of the European Regulation n. 679/2016 "General Data Protection Regulation (GDPR)" (hereinafter EU Regulation), laying down provisions on the processing of personal data, intends to inform you regarding the processing of your personal data.

The law provides that anyone who processes personal data is required to inform the interested party in relation to the data processed and the elements qualifying the processing, which must in any case take place in a lawful, correct and transparent manner, as well as protect confidentiality and guarantee rights of the interested party.

It should be noted that by data processing we mean any operation or set of operations concerning the collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, destruction of data itself.

1.Data controller

The Data Controller is PRINCIPE HOTEL MANAGEMENT srl, with registered office in V.le Ammiraglio Morin 67 – 55042 Forte dei Marmi (LU), Tax Code and VAT number 06611040962, who can be contacted at the following numbers: telephone +39 0584 783636, e-mail: vascellari@principefortedeimarmi.com (hereinafter "Data Controller" or "Data Controller").

2. Nature of the data processed, purpose and legal basis of the processing

Nature of the data processed. In relation to the purposes of the processing indicated below, we inform you that only "common personal data" will be processed such as, for example:

 

  • company contact personal data (name, surname, denomination, email);
  • etc.

 

Purpose of the treatment. Your personal data will be processed for the following purposes:

  1. to respond to your request to register for our newsletter: by voluntarily completing the appropriate form found in this newsletter area;
  2. comply with legal obligations;
  3. marketing: to send you advertising material, direct sales, carrying out market research and commercial and promotional communications;

 

Legal basis of the treatment. Personal data, for the purposes referred to in points 2A and 2B, will be processed lawfully to fulfill pre-contractual and contractual obligations between us and the user (Article 6, paragraph 1 letter b), to fulfill our legal obligations (Article 6 paragraph 1 letter c).

Your personal data, for the purposes referred to in point 2C of this information, may be processed lawfully only with your consent (art. 6. parag.1 letter a EU Regulation), specific, separate, expressed, documented, preventive and of the all optional.

The consent you have given may be revoked at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation (Article 7, paragraph 3 of the EU Regulation)

Furthermore, the interested party is informed that, pursuant to art. 21 of the EU Regulation, the interested party has the right to object at any time to the processing of personal data concerning him carried out for direct marketing purposes (including profiling) and that, if the interested party opposes the treatment, the data personal data can no longer be processed for these purposes.

 

Clarification: following the principle of maximum transparency towards the interested party distinctive of our Company, we wish to inform you that if you decide to give consent to point 2C (marketing), you must be informed in advance and aware that the purposes of the processing pursued are specific commercial, advertising, promotional and marketing nature in the broadest sense, such as:

 

  1. send advertising and information material (e.g. Newsletter), of a promotional nature;
  2. send commercial information by paper, automated or electronic means and, in particular, by ordinary mail or e-mail, telephone (e.g. calls, WhatsApp messages, SMS, MMS), fax and any other IT channel (e.g. websites web, mobile apps);
  3. forward invitations to events, demonstrations and meetings of an informative and promotional nature;
  4. send updates on promotional initiatives or on technical innovations, for services, training or assistance and/or detection of the degree of satisfaction with quality.

3. Recipients of the data and methods of treatment

The processing of your personal data will be based on principles of correctness, lawfulness and transparency and may be carried out using paper and electronic means both by the staff of the writing Company, authorized/in charge of processing personal data, and by external subjects called to carry out specific assignments, on behalf of the Data Controller, as Data Processors, pursuant to art. 28 EU Regulation, subject to our letter of assignment which imposes the duty of confidentiality and security of the processing of personal data, and the adoption of suitable security measures to prevent data loss, illicit and incorrect use, and unauthorized access , in compliance with current provisions on the protection of personal data.

 

For the sake of brevity, the detailed list of these figures is available at the headquarters of the Data Controller and is at your disposal.

 

Your personal data will not be disclosed and will not be transferred to third countries or international organizations, will not be disclosed to third parties except for legal or contractual obligations

4. Data retention times

Your personal data will be kept for a period of time not exceeding the achievement of the purposes for which they are processed, in compliance with the principle of limitation of conservation established by the EU Regulation and/or for the time necessary for legal and contractual obligations or until the revocation of the specific consent by the interested party intervenes and, therefore

 

- with reference to the purposes indicated in points 2A-2B, the data will be kept for a time not exceeding the achievement of the purposes for which they are processed and/or for the time strictly necessary for the fulfillment of legal and contractual obligations;

- with reference to the purposes indicated in point 2C, the data processed for Marketing purposes will be kept no later than 24 months from collection.

 

To guarantee the retention times declared, it is envisaged that a periodic check is carried out on an annual basis on the data processed and on the possibility of being able to cancel them if they are no longer necessary for the intended purposes.

5. Consequences of failure to communicate data

The personal data referred to in points 2A-2B of this information are necessary, without such data it would be impossible for us to proceed with the registration (creation of your personal account), fulfill the contractual and legal obligations.

 

The personal data, however, referred to in point 2C are optional, the refusal to provide them will not entail any consequences and will not affect your request to proceed with the registration as well as to fulfill the contractual and legal obligations. You can therefore decide not to provide any data or to subsequently deny at any time the possibility of processing data already provided.

6. Rights of the interested party

In your capacity as an interested party, you have the rights referred to in articles from n. 15 to no. 22 of the EU Regulation listed below and precisely has the right to:

 

- obtain confirmation of the existence and processing of personal data concerning him and in this case, obtain access to his data (so-called right of access);

- obtain information about the purposes of the processing, the categories of data in question, the recipients or categories of recipients to whom the data have been or will be communicated, in particular if recipients from third countries or international organizations, the data retention period expected or the criteria used to determine that period; and if the data are not collected from the interested party, obtain all available information on their origin;

- obtain the rectification of data concerning him (so-called right of rectification)

- obtain the cancellation of data concerning him (so-called right to be forgotten);

- obtain the limitations of the treatment (so-called right of limitation of treatment);

- obtain data portability, i.e. receive them from a data controller in a structured format, commonly used and readable by an automatic device and transmit them to another data controller without impediments (so-called right to data portability);

- oppose the processing at any time (so-called right of opposition). We specifically inform you, as required by art. 21 of the EU Regulation, that if personal data are processed for direct marketing purposes (including profiling), the interested party has the right to object at any time to the processing of personal data concerning him carried out for these purposes and that if the If the interested party opposes the processing for direct marketing purposes, the personal data can no longer be processed for these purposes;

- be made aware (with the possibility of objecting) of the existence of an automated decision-making process relating to natural persons, including profiling;

- revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation;

- lodge a complaint with a supervisory authority (Guarantor for the Protection of Personal Data).

 

It should be noted that there may be conditions or limitations to the rights of the interested party. It is therefore not certain that, for example, you have the right to data portability in all cases, this depends on the specific circumstances of the processing activity.

 

Another example: if you decide to oppose the processing of data, the Data Controller has the right to evaluate your request, which may not be accepted in the event of the existence of binding legitimate reasons for proceeding with the processing which prevail over your interests, rights and freedom.

7. Methods of exercising rights

Without any formalities, you can exercise your rights clearly and explicitly at any time by sending:

 

- a registered letter with return receipt to the writer;

- an email to vascellari@principefortedeimarmi.com 

Or by contacting the Data Controller directly on the number: +39 0584 783636.

8. Minors

What is offered by the Data Controller and object of the existing relationship with you does not provide for the intentional acquisition of personal information relating to minors. In the event that information on minors is involuntarily recorded, the Data Controller will cancel it in a timely manner, upon request or notification by the interested party.

9. D.P.O. (R.P.D.) – Persons in charge / Authorized - Data processors

Below we provide you with some information that you need to bring to your knowledge, not only to comply with legal obligations, but also because transparency and fairness towards the interested parties is a fundamental part of our activity.

D.P.O. (Data Protection Officer) – R.P.D. (Data Protection Officer). You may also contact the Data Protection Officer for information and to forward requests regarding your data or to report disservices or any problems encountered. The Data Controller has appointed Mr. Nicola Ghinello as Data Protection Officer who can be contacted at the following address: e-mail: nicola.ghinello@dpo-rpd.com 

 

Appointees/Authorised. The updated list of persons in charge/Authorised for processing is kept at the headquarters of the Data Controller.

 

Responsible for the treatment. For the sake of brevity, the detailed list of these figures is available at our office.

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