INFORMATION ON PRIVACY
INFORMATION ON THE PROCESSING OF PERSONAL DATA OF WEBSITE USERS IN ACCORDANCE WITH ART. 13 OF D.LGS. 196/2003 AND ART. 13 OF THE EU REGULATION 679/2016 This document was drawn up pursuant to art. 13 of Legislative Decree 196/2003 (hereinafter, “Privacy Code”) and EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to know our privacy policy, to understand how your personal information is handled when you use our site (www.primaguesthousecollection.com, hereinafter “Site”) and, where appropriate, to give consent to the processing of your personal data expressed and aware. The information and data provided by you or otherwise acquired in the context of the use of the navigation services and access to the reserved area of the Site (hereinafter “Services”), will be processed in compliance with the provisions of the Regulations and the obligations of confidentiality that inspire the activity of Antonio Galati. According to the rules of the Privacy Code and the Regulation, the treatments carried out by Antonio Galati will be based on the principles of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality, as well as the principle of accountability of referred to in art. 5 of the Regulation.
Holder of the treatment
Antonio Galati, with registered office in Lungotevere Michelangelo 9, Vaticano Prati, is constantly committed to protecting the online privacy of its users. We therefore invite you, before communicating any personal data to the Data Controller, to read this information carefully because it contains important information on the protection of your personal data.
Personal data being processed
We inform you that the personal data being processed may consist of an identifier such as your name and surname, company email, company you belong to and the role covered within it, possibly a telephone number and VAT number, an identification number, location data, to an online identifier, depending on the type of services requested. Furthermore, the personal data processed through the Site are the following:
1. Navigation data
The computer systems and software procedures used to operate the Site automatically acquire, in normal operation, some information relating to web browsing whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which by its nature could, through associations and processing with data held by third parties, allow users or navigators to be identified. This category includes information relating to IP addresses, domain names of the computers used by users who connect to the site, addresses in URI (Uniform Resource Identifier) notation of the requested resources, time of the request, the method used to submit the request to the web server, the size of the file obtained in response, numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of this website and to check its correct functioning, to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site or third parties. Specific information is given in the sections of the website set up for particular services, also accessible after registration, where personal data is requested from the site user.
2. Cookie
What are cookies
Browsing this website involves the receipt of cookies, short strings of text that the websites visited send to the user’s browser (i.e. the program used to navigate such as, for example, Chrome, Explorer, Mozilla, etc.) where they are stored before being re-transmitted to the same websites during subsequent visits. While browsing a site, the user may also receive cookies from sites or web servers other than the one they are visiting on their computer (so-called “third-party” cookies). It is possible to distinguish technical cookies, which allow the carrying out of activities strictly related to the functioning of the site and can be used freely, and profiling cookies, used in order to display advertising messages to the user in line with the preferences expressed by the same in the course. navigation and for which it is necessary to acquire the user’s consent. Through this site, the user’s browser can receive technical cookies and third-party profiling cookies.
Technical cookies
In particular, technical navigation cookies are used, in order to memorize navigation preferences and improve navigation on the site, and analytical cookies (specifically Google Analytics provided by Google Inc. – hereinafter “Google”), which collect, in the form anonymous and aggregate, statistical information on how users navigate (for example, number of pages visited and accesses, time spent on the site), useful to understand in which aspects it is possible to improve the website. For more information about the processing of data carried out by Google through the Google Analytics service, the user can visit the web page http://www.google.com/analytics/learn/privacy.html, and view the privacy policy of Google on the web page http://www.google.com/intl/it/policies/privacy/ The use of these cookies does not require the acquisition of the user’s consent, who can still decide to disable their use on their browser. Furthermore, Google Analytics cookies can be specifically rejected using the specific tool provided by Google (v. Https://support.google.com/analytics/answer/181881?hl=it&ref_topic=2919631&vid=1-635775549103353382-1182928194) .
Third party profiling cookies
Through some pages of this website it is also possible to receive third-party profiling cookies in your browser, for example to allow the display of content hosted on external platforms and interact with them (eg YouTube) or connected to the Google AdWords service. (aimed at showing the user, during navigation, advertisements based on the websites previously visited). For this reason, when accessing these pages, a banner is proposed to inform the user and allow him to give his consent to the receipt of these cookies, by closing the banner or clicking on any other element of the page, outside the banner. same. Antonio Galati does not have access to the information collected by third party cookies, which are used in full autonomy by the managers of the aforementioned services. For more information on the methods of processing the data collected by means of these cookies, users are invited to consult the information notes on privacy provided by the parties who make the services in question available. In particular, the third-party cookies used on the site are the following: YouTube: https://www.youtube.com/static?template=privacy_guidelines AdWords: https://support.google.com/adwordspolicy/answer/6008942?hl=it Facebook: https://www.facebook.com/privacy The user can disable the cookies placed by the third parties listed above by clicking on the links indicated. Where there are no links, you can refer to the following site www.youronlinechoices.com/it/ which allows you to manage user preferences regarding cookies.
How to manage cookies within your browser
The user can set their browser in such a way as to be warned of the presence of cookies and decide whether or not to accept a specific cookie or to automatically reject all cookies. Below are the references on how to manage the activation / deactivation of cookies for the main browsers: Google Chrome: https://support.google.com/accounts/answer/61416?hl=it Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie Apple Safari: https://support.apple.com/kb/PH19214?locale=it_IT Opera: http://help.opera.com/Windows/10.00/it/cookies.html Microsoft Internet Explorer e Microsoft Edge: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies If you decide to refuse cookies, it is also possible that some interactive features offered by the Site may not be usable, in whole or in part.
3. Purpose of the treatment
Your personal data will be processed by the Data Controller for the following purposes: 3.1 allow browsing of the Site and the provision of the services made available by the Owner, including the management of the Site’s security; 3.2 fulfill any obligations established by applicable laws, regulations or community legislation, or satisfy requests from authorities; 3.3 for the processing of statistics, without it being possible to trace your identity; 3.4 send newsletters and promotional communications for direct marketing purposes through email, sms, mms, push notifications, fax, paper mail, telephone with operator, whose promoted products may also be from other partner companies; 3.5 for the purpose of carrying out profiling activities, by collecting and analyzing information on the selections and choices made within the Site, in order to send personalized offers on other products and / or services; 3.6 to communicate / transfer personal data to third party companies such as partner companies of the event for sending newsletters and promotional communications for marketing purposes through email, sms, mms, push notifications, fax, paper mail, telephone with operator. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
4. Legal basis and mandatory or optional nature of the processing
The legal basis for the processing of personal data for the purposes referred to in section 3.1 is art. 6.1.b) of the Regulations as the processing is necessary for the provision of services or for the response of the interested party’s requests. The legal basis for the processing of personal data for the purposes referred to in section 3.2 is, instead, art. 6.1.c) of the Regulations (“processing is necessary to fulfill a legal obligation to which the data controller is subject”). The provision of personal data for these purposes is optional, but failure to provide it would make it impossible to activate the requested services. It should be noted, however, that the processing referred to in section 3.3 is not performed on the basis of personal data and, therefore, can be freely carried out by the Data Controller. The legal basis for the processing of personal data for the purposes referred to in sections 3.4, 3.5 and 3.6 is art. 6.1.a) of the Regulation as the treatments are based on consent. The latter is optional and is free to revoke it at any time without any consequence (except for the fact that it will no longer receive marketing communications and / or profiling activities will no longer be carried out). The consents previously granted can be revoked by following the instructions in Paragraph 8 of this information. For the treatments carried out for the purpose of sending direct advertising material or direct sales or for carrying out market research or commercial communications in relation to products or services of the Owner similar to those used by you, Antonio Galati can e-mail addresses pursuant to and within the limits permitted by art. 130, paragraph 4 of the Code and the provision of the Authority for the protection of personal data of 19 June 2008 even in the absence of explicit consent. The legal basis for the processing of your data for this purpose is art. 6, paragraph 1, lett. f) of the Regulations. It remains without prejudice to the possibility of opposing this treatment at any time, initially or on the occasion of subsequent communications, easily and free of charge, also by writing to the addresses indicated in the “Contacts” section of this information, as well as obtaining an immediate response that confirms the interruption of this treatment (Article 15 of the Regulation).
5. Recipients of personal data
Your personal data may be shared, for the purposes referred to in section 3 of this information, with: 5.1. subjects who typically act as data processors pursuant to art. 29 of the Code and 28 of the Regulations, that is, subjects who cooperate with the Data Controller for the pursuit of the aforementioned purposes, including subjects delegated to carry out technical maintenance activities (collectively “Recipients”); the list of data processors who process data can be requested from the Data Controller by writing to the addresses indicated in the “Contacts” section of this information; 5.2. subjects, bodies or authorities to whom it is mandatory to communicate your personal data by virtue of legal provisions or orders of the authorities; 5.3. persons authorized by the Data Controller, pursuant to art. 30 of the Code and 29 of the Regulation, to the processing of personal data necessary to carry out activities strictly related to the provision of services, which are committed to confidentiality or otherwise have an adequate legal obligation of confidentiality. The updated list of subjects who may process your personal data, as data processors, is available by sending a written request to the Data Controller at the addresses indicated in the “Contacts” section of this information.
6. Transfer of personal data
As regards the possible transfer of Data to Third Countries, the Data Controller announces that the processing will take place according to one of the methods permitted by current law, such as the consent of the interested party, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for the free circulation of data (eg EU-USA Privacy Shield) or operating in countries considered safe by the European Commission. It is possible to have more information, on request, from the Data Controller at the contacts indicated above.
7. Data retention
Personal data processed for the purposes referred to in section 3.1 will be kept for the time strictly necessary to achieve those same purposes. In any case, since these are treatments carried out for the provision of services, the Data Controller will keep personal data for the period of time envisaged and permitted by Italian law to protect its interests (Article 2946 of the Italian Civil Code and subsequent amendments). Personal data processed for the purposes referred to in section 3.2 will be kept until the time required by the specific obligation or applicable law. Further information regarding the data retention period and the criteria used to determine this period can be requested by sending a written request to the Data Controller at the addresses indicated in the “Contacts” section of this information. In any case, the possibility is reserved for the Data Controller to keep your personal data for the period of time envisaged and permitted by Italian law to protect their interests (Article 2947 of the Italian Civil Code).
8. Rights of interested parties
Pursuant to articles 7 of the Code and 15 et seq. of the Regulations, you have the right to ask Antonio Galati at any time to access your personal data, correct or delete them or to oppose their processing, request the limitation of processing in the cases provided for by art. 18 of the Regulation, as well as to obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation. Requests must be sent in writing to the Data Controller at the addresses indicated in the “Contacts” section of this information. In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your personal data is contrary to the legislation in force.
9. Changes
The Owner reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. The Data Controller therefore invites you to regularly visit this section to become aware of the most recent and updated version of this information in order to be always updated on the data collected and on the use made by Antonio Galati.
10. Contacts
To exercise the above rights or for any other request, you can write to the Data Controller at the physical address indicated above or through the dedicated contact, info@primaguesthousecollection.com preferably by inserting in the subject of the communication the words “Request to exercise privacy rights”.