1. What data do we process?
Pursuant to Art. 13 of the European General Data Protection Regulation, we process the following data:
- personal data (surname, name, address, e-mail, telephone number, fax number, date of birth) as well as your language and the license plate of your vehicle
- the data shown in your passport or identity card
- data relative to the method of payment or otherwise connected with your payments (e.g. bank coordinates, details of credit card)
- date of arrival and length of stay, as well as any personal preferences associated with your stay
2. What is your data processed for?
We collect and use your personal data in order to answer to requests for information and emails and to be able to provide our services as desired and to allow easy access to our website.
The data provided will be processed for the following purposes:
- Memorization of the data for the purpose of future bookings and requests
- For the implementation of pre-contractual and contractual requirements relative to the guest’s visit (booking, period of stay, departure etc.)
- Forwarding of communications and telephone calls directly to the guest
- Management of fitness and wellness centres
- Forwarding of information, special offers and new features offered by the hotel by e-mail, ordinary mail, and other means of communication concerning the hotel, the local area and any local events etc. The consent to the data processing referring to the sending of information, offers and news about the hotel and its surroundings is given on a voluntary basis. In case of no longer interest you can inform us any time. In absence of requested data we can’t deliver any offer or news.
- For compliance with legal obligations
- For further information on the topic “what are your data processed for” see also point “Data collection” on our website
Your personal data will be processed in accordance with the contract and with current legislation, as set forth in the provisions of EU Regulation 679/2016 (GDPR). Consent for the processing of personal data included in special categories is given on a voluntary basis.
Should you refuse to release basic data, travel document data and bank data, it will not be possible to fulfil the contractual obligations and accommodate you at our establishment. We do not apply profiling and automated decisions.
3. Legal ground for data processing
- Legal ground for the processing of your data:
- compliance with obligations and pre-contractual and contractual requirements
- your consent
- compliance with legal and judicial obligations
- legitimate interests (e.g. for improvements to our client service and our contacts with the clients – also regarding direct advertising – or video surveillance intended to protect persons and property from possible aggression, theft, robbery, damage and vandalism, as well as for fire protection and safety in the workplace). (For each purpose whose legal ground comprises legitimate interest, the nature of such legitimate interest must be specified).
4. To whom do we pass personal information?
We take the protection of your personal rights very seriously and assure you that we will not sell or rent your data to other providers.
(Subjects = Persons, companies or office communities)
- Subjects with witch a cooperation is necessary to provide our services (e.g. our host provider
- Subjects hired for the technical maintenance of our hard- and software.
- Subject who assist and advise us on administrative, accounting, tax, legal, financial, marketing and communication issues, relating to the provision of services.
- Subjects, authorities or other entities to which your personal information is required due to obligatory requirements.
- Persons authorized by the controller to process personal data, required for activities related to the provision of services. They are committed to confidentiality or have a responsible legal obligation to maintain confidentiality (e.g. employees of the controller)
- You can find more info about “when and to whom do we pass personal information” under the main issue “Data acquisition on our web site”.
5. Storage of personal data
The duration of the conservation of the data is calculated on the basis of the obligations for the conservation of the data and the requirements contemplated by the law. If your personal data are processed in order to comply with a legal requirement or a contractual obligation, they will be kept only for the time that is strictly necessary for their processing. If the data are processed with your consent, they will be kept until that consent is revoked.
6. Data acquisition on our web site
The following gives a simple overview of what happens to your personal information when you visit our website.
How do we collect your data?
Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form on our website or on other portals.
Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.
6.1. Contact form
Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1)(a) DSGVO. You have the right to withdraw your consent at any time simply contacting us per e-mail. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
6.2. SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar.
If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
6.3. Server log files
The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
These data will not be combined with data from other sources.
The basis for data processing is Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest to ensure an optimized service provided free of technical errors. Therefore server log files have to be stored.
6.4. Encrypted payments on this website
If you enter into a contract which requires you to send us your payment information (e.g. account number for direct debits), we will require this data to process your payment.
Payment transactions using common means of payment (Visa/MasterCard, direct debit) are only made via encrypted SSL or TLS connections. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon in your browser line is visible.
In the case of encrypted communication, any payment details you submit to us cannot be read by third parties.
6.5. Analytics and third-party tools
When visiting our website, statistical analyses may be made of your surfing behavior. This happens primarily using cookies and analytics. The analysis of your surfing behavior is usually anonymous, i.e. we will not be able to identify you from this data.
You can object to this analysis. We will inform you below about how to exercise your options in this regard:
If you choose to disable cookies, you may lose some features and functionality and some contents of our website may not be displayed or may not function correctly.
1a. What are cookies?
According to their function, cookies are divided in following categories:
Third Party Cookies:
- Technical and analytics cookies: According to Italian privacy legislation following types of cookies are considered “technical cookies” and can be used without the explicit consent of the user:
- Navigation cookies: Navigation cookies are necessary to make the website work properly and to make users’ experience easier and faster. They also make it possible to access secure areas of the website and to register i.e. to newsletters.
- Function cookies: These cookies make it possible for specific features of the site to function, in order to make the website and your online experience more user-friendly.
- Analytics cookies: These cookies monitor website usage statistics without personally identifying individual visitors. These cookies help us understand how visitors interact with our websites by providing information about the areas visited, the time spent on the website, etc. These cookies don’t identify you as an individual. All data is collected and aggregated anonymously.
To get more information about these cookies, see the links below.
YouTube, Google Analytics, Google Maps, Google Plus
Online behavioural advertising (also known as interest-based advertising) is a way of serving advertisements on the websites you visit and making them more relevant to you and your interests. This happens thanks to profiling cookies. The information contained in a cookie is used to track a user’s activity when visiting pages online.
The information collected and used for this type of advertising is not personal, in that it does not identify you – the user – in the real world. No personal information, such as your name, address or email address, is used. Data about your browsing activity is collected and analysed anonymously.
Profiling cookies remain stored on users’ device for a longer time.
Users can opt out behavioural advertising permanently by disabling interest-based advertising by Google here: https://www.google.com/settings/ads/onweb/
Detailed information and links about profiling and remarketing cookies are available on the official website or the European Interactive Digital Advertising Alliance: www.youronlinechoices.eu
2a. What types of cookies do we use?
that are necessary to show the pages correctly, to make the features of the website function properly and to access secure areas. Use this tool to check which cookies are set and used by our sites: www.cookie-checker.com
According to the current Italian legislation, not all types of cookies require a specific and express consent to be used. In the case of technical cookies express consent is not required, as the legislation recognises that technical cookies are indispensable for a website to work in a correct way.
According to the Italian Privacy Agency, analytics cookies are to be considered as technical cookies used to collect anonymous data about website usage statistics. Analytics cookies help us improve our website and offers; thanks to them we can monitor which types of content, what links and features users enjoy most, for instance.
For our statistics we use the “Google Analytics” tool by Google Inc.
The main cookie used by Google Analytics is the ‘__ga’ cookie.
For more detailed information about “Google Analytics” read on for “c) Google Analytics”
Third party cookies and services
Our website uses following third party services:
Google Maps, Google Analytics, Google reCAPTCHA, if required Google Adwords, YouTube
Currently our website DOES NOT use profiling cookies.
Click-Through-Link-Technology in our Newsletter Manager
In some of our newsletters we use the so-called “click-through URL” that allows you to open specific pages of our website. Each click on one link in the newsletter is tracked and collected by the newsletter software. This helps us to know what contents of the newsletter were interesting for you and what were not, so that in future we can improve our email communication with you. If you do not want to track this information, simply avoid to click on the text and graphic links in our newsletter.
3a. How can I control or disable cookies?
In your browser you can disable cookies or delete the ones that have already been saved. By disabling cookies, some contents or features of our site may not function properly or may not be shown correctly.
Learn how to block, disable or delete cookies in the browser you use:
Google Analytics opt-out browser add-on:
If you want to prevent your data from being stored and used by Google Analytics, you can click on this link:
deactivate Google Analytics for this web site
Third party cookies:
You can disable or delete each of them separately. On the site of the European Interactive Digital Advertising Alliance you find detailed instructions: www.youronlinechoices.eu
b) Google Maps
This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.
Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/
c) Google Analytics
This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en
Outsourced data processing
We have entered into an agreement with Google for the outsourcing of our data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
d) Google AdWords and Google Conversion Tracking
This website uses Google AdWords. AdWords is an online advertising program from Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States (“Google”).
As part of Google AdWords, we use so-called conversion tracking. When you click on an ad served by Google, a conversion tracking cookie is set. Cookies are small text files that your internet browser stores on your computer. These cookies expire after 30 days and are not used for personal identification of the user. Should the user visit certain pages of the website and the cookie has not yet expired, Google and the website can tell that the user clicked on the ad and proceeded to that page.
Each Google AdWords advertiser has a different cookie. Thus, cookies cannot be tracked using the website of an AdWords advertiser. The information obtained using the conversion cookie is used to create conversion statistics for the AdWords advertisers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, advertisers do not obtain any information that can be used to personally identify users. If you do not want to participate in tracking, you can opt-out of this by easily disabling the Google Conversion Tracking cookie by changing your browser settings. In doing so, you will not be included in the conversion tracking statistics.
Conversion cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
g) Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).
reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.
The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.
Data processing is based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam.
f) Newsletter data
If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) DSGVO. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established, thus informing YouTube about which of our pages you have visited.
Furthermore, Youtube can store cookies on your device. With the help of these cookies, Youtube can receive information about visitors of our website. This information will u. a. used to capture video statistics, improve user-friendliness, and prevent attempted fraud. The cookies remain on your device until you delete them.
If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy
7. What rights do you have regarding your data?
Right of access by the data subject: In accordance with art. 15 of the GDPR, you are entitled to be informed of the personal data processed, their provenance, nature, possible forwarding to third parties (in such case identifying the same) and their utilization.
Right of rectification and erasure: In accordance with art. 16 of the GDPR, you may at any time require the rectification or completion of your personal data. Similarly, in accordance with art. 17 of the GDPR, you are entitled to require the erasure of the data. In the presence of published data, you also enjoy the “right to be forgotten”, i.e. to request that the measures necessary to erase all the links, copies, replications and similar.
Right to object: You may at any time exercise your right to object as described in art. 21 of the GDPR and modify or entirely revoke your consent for the future.
Right of restriction (or blocking) of processing: In accordance with art. 18 of the GDPR, you may require the restriction of the processing of your personal data. The relevant data may be processed only subject to specific prior consent, i.e. their processing will be effectively limited.
Right to data portability: In accordance with art. 20 of the GDPR, you are entitled to request and receive the personal data provided by yourself in a structured, commonly used and machine-readable format, and you have the right to require their transmission to another controller.
In accordance with art. 77 of the GDPR, you have the right to lodge a complaint with the supervisory authority.
8. Characteristics of consent
Your personal data will be processed in accordance with the contract and with current legislation, as set forth in the provisions of EU Regulation 679/2016 (GDPR).
Consent for the processing of personal data included in special categories is given on a voluntary basis. In the absence of such consent, the personal data cannot be processed for any future bookings.
Consent for the processing of personal data as regards the forwarding of information, special offers and new features offered by the hotel, too, is voluntary. If the personal data are not provided, then offers and other information shall not be supplied.
The person responsible reserves the right to change or update the content in whole or in part, also due to changes in applicable legislation.