The Cookies Placed through our Website
We use the following cookies.
- Strictly necessary cookies. These first party cookies are essential in order to enable you to move around our website and use its features. Without these cookies, services you have asked for cannot be provided. They are deleted when you close the browser.
- Performance cookies. These first party cookies collect information about how visitors use our website and apps. They allow us to recognise and count the number of visitors, see how visitors move around the website when they are using it and identify the regions that they are visiting from.
- Functionality cookies. These first party cookies allow our website to remember choices you make such as your user language and provide more personal features.
- Analytics. We may use third party analytics services such as Google Analytics and others. Your IP address and other information will be collected by automated means to evaluate your use of the website, compile reports on website activity, identify user patterns and provide related services. These providers may retain and use aggregated data collected from our users in connection with their own business, including in order to improve their products and services. For more information about how Google Analytics uses your information please click here. In addition, authentication and tracking logs will be used to compile user statistics.
- Targeting or advertising cookies. These cookies allow us to deliver ads more relevant to you, your interests and demographic profile, and to measure the effectiveness of advertising campaigns. They remember that you have visited our website, the length of your visit, the ads you viewed and other information in your “utilisation profile”. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion. As a result, you may see our ads on other websites which participate in advertising networks administered by third-party vendors, such as Google AdWords, Bing Ads, Yandex, Facebook, and others.
- Social Media cookies. These cookies allow you to easily use your social media such as Facebook, Twitter, Instagram and others. These are persistent cookies which will be kept on your device until their expiration or earlier manual deletion. If you use these functionalities, the plug-in and its content are loaded directly from the social media provider’s servers and included in the website by your browser. If you log into your respective social media account at the time you interact with the social media plug-ins on our website, the social media provider will connect this information with your social media user profile. We cannot influence which personal data the social media provider will collect about you. For more information, please see the privacy notices of Facebook, Twitter, Instagram and others.
We may combine information from cookies and other technologies with other information about you.
We assume that you are happy for us to place cookies on your device. In some cases, when you arrive on our website a pop-up message will appear asking for your consent to place advertising cookies on your device. In order to provide your consent, please click ‘Ok’. Once your consent has been provided, this message will not appear again when you revisit.
- How do we use your information?
We may process your information in accordance with the law as required in order to:
– respond to and process your queries, comments, complaints and requests;
– process your reservations or cancellations, deliver the services, products or content requested by you, manage and administer your user account, send you service communications;
– provide you with a customised and premium service including customer service before, during and after your travel and/or event. For these purposes, we may create a profile about you including information from our Management System, which will also enable us to increase our communication relevance;
– display content on our websites and apps, such as stories, product reviews, comments and photos, provided by you;
– handle job application that you may make to us, carry out profiling for recruitment purposes and use recruitment tools that allow us to assess our applicants’ suitability for specific roles;
– enable our suppliers and service providers to carry out certain functions on our behalf, including the hosting of our websites, verification, technical, logistical or other functions;
– send you personalised marketing communications and newsletters through our marketing channels, and serve personalised ads to your devices, subject to your consent or otherwise as permitted by law;
– communicate with you about, and administer your participation in, special events, programs, surveys, contests and other offers or promotions;
– administer our business including financial operations, credit checks and debt recoveries;
– carry out data analysis, statistical research, and trend analysis in relation to user activity, demographic information, guest profiles, user comments or other contributions to develop and improve our websites, products and services and to ensure the effectiveness of our business efforts;
– comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law. We also record information to comply with financial reporting requirements, including those imposed by auditors and government regulators. We may also collect certain information as required by local laws (e.g. passport number to speed up check-in procedures at hotels, to register to events or for special visits, including name of partner and kids.
The legal basis for our processing of your personal data for the purposes described above will typically include:
- processing necessary to fulfil a contract, such as our terms and conditions or reservation terms, that we have in place with you, such as the processing for the purposes set out in above paragraphs;
- processing necessary for our or a third party’s legitimate interests, which is carried out on the basis of our legitimate interests to ensure that our website, services and content are competitive and provided efficiently, without delays and in an user-friendly and personalised manner taking into account user feedback, data and profiles, to ensure the security of our business and information of our users, and to ensure the proper and efficient administration of our business, unless consent is required for any such processing under applicable law;
- your consent, where such consent is required under applicable law;
- processing necessary for compliance with a legal obligation to which we are subject; and
- other applicable legal grounds for processing from time to time.
Your right to opt-out
If you would like us to stop sending you marketing communications you may use the opt-out link in our marketing communication or send an e-mail titled “unsubscribe” to firstname.lastname@example.org. Please note your enquiries will be received during Italian office hours and we will aim to respond as soon as reasonably possible.
If you, or another user of your device, wish to withdraw your cookies consent at any time, you have the ability to accept or decline cookies by modifying your browser setting. If you choose to decline cookies, you may not be able to fully experience the features of our website, content and services.
Disclosure of your information
We may disclose your information in accordance with the law for the purposes listed above to third parties including:
- the public where you have included information in our blogs, forums and discussion groups;
- our outsourced suppliers, service providers, consultants, databases, incident response or business continuity providers; our analytics and customer relationship management partners; our marketing, communications and advertising partners;
- the payer, such as your employer who pays on your behalf and receives your billing information;
- legal entities, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company or new owner;
- public authorities where we are required by law to do so; and
- any other third party where you have provided your consent.
- Is my information transferred overseas?
We may transfer your information outside of the country in which it was collected for the purposes and to the parties set out above. Our Management System is located in Italy.
Security of your information
We endeavour to protect your information through the measures set out below. Unfortunately, we cannot always guarantee complete security. Unauthorised entry or use, hardware or software failures, events outside our control and other factors, may compromise the security of your information. Nevertheless, we will comply with our obligation to implement appropriate technical and organisational measures to ensure a level of security of personal data appropriate to safeguard against the risks of a personal data breach.
We store client information in a secure location, be it a database, Management System, marketing and research database or a filing cabinet. Furthermore, we take steps to ensure that only designated individuals have access to this information. Credit card information is transmitted and stored in encrypted format and only unencrypted when required for taking payments or guaranteeing future stays. Access to unencrypted credit card details is restricted to designated individuals as per PCI DSS industry best practise.
It is important to note that e-mail communications are not secure. There is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by e-mail. We recommend that you do not include any confidential information (i.e. credit card information) when using email. For your protection, our email responses to you will not include any confidential information.
How long is my information retained?
Your personal data will be retained for as long as is necessary for the purposes listed above or as required by applicable law. If you are located in the European Economic Area or in the UK, you may contact us about further detail about our data retention periods in relation to your personal data.
We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful reason to do so.
Information about children
This section is for parents, guardians and children under the age of 16.
If you are under 16, please ask your parent or guardian before using any of our services including our website, as not directly intended for children.
We will ask parents and guardians for information about their children such as name and age when this is needed to deliver services.
Where European data protection laws apply and you are a data subject whose personal data are processed by us, you may have certain rights in relation to your personal data, as further described below. In such circumstances, you may exercise your rights by emailing us to email@example.com or by calling us at +39.0670453905
- Right to make subject access request (SAR). Data subjects may request in writing copies of their personal data. Where possible, we will enable our users to access their information.
- Compliance with SARs is subject to certain limitations and exemptions and the rights of other individuals. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and payment, where applicable. We will endeavour to respond to any SARs as prescribed by law.
- Right to rectification. Data subjects may request that we rectify any inaccurate or incomplete personal data.
- Right to withdraw consent. Data subjects may at any time withdraw their consent to the processing of their personal data carried out by us on the basis of their previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your personal data is essential.
- Right to object to processing including profiling. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse the data subject’s request. We will comply with each valid opt-out request in relation to marketing communications without delay.
- Restriction. Data subjects may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
- Right to erasure. Data subjects may request that we erase personal data about them and we will comply, unless there is a lawful reason for not doing so.
- Right to data portability. In certain circumstances, data subjects may request the controller to provide a copy of their personal data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. To the extent this applies to our services, we will comply with such transfer request. Please note that a transfer to another provider does not imply the erasure of personal data.
- Right to lodge a complaint with the supervisory authority. We suggest that data subjects contact us about any questions or complaints in relation to how we process their personal data. However, each data subject has the right to contact the relevant European supervisory authority directly.