Dear Guest,
Hotel Royal srl (VAT: 02397220647), located at Via Posta Vecchia, 1 – 83030 Pietradefusi (AV) ITALY, as the Data Controller, informs you about the use of your personal data provided and/or related to you for booking and staying at our hotel.
The Data Controller informs you, pursuant to Articles 13/14 of EU Regulation 2016/679, that your personal data provided or related to you will be processed in compliance with the legal provisions.
According to the regulations, the processing of your personal data (personal details, residence information, contact data, email, phone number, preference data, booking details, stay-related data, browsing data, etc.) will be conducted in accordance with principles of fairness, legality, transparency, and protection of privacy.
Personal data are processed using both manual and automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, unlawful or incorrect use, and unauthorized access.
Processing is also carried out with the aid of computer systems for the following purposes:
With your explicit authorization, the personal data (as per Article 4(1) of EU Regulation 2016/679) you provide or related to you during the booking and/or stay may be processed for the following additional purposes:
A) Direct marketing activities through the sending of promotional materials via postal mail, email, SMS/MMS, mobile applications, or other digital communication channels.
B) Customer profiling activities aimed at improving the offerings of goods and services by Hotel Royal srl (customer profiling).
Please note that the aforementioned processing activities may be used to understand your consumption choices in order to make Hotel Royal srl’s commercial policies and services more effective. Consequently, you may receive targeted discounts, offers, or promotions based on your preferences and consumption.
Providing data for the purposes outlined in points A) and B) is voluntary and optional. Therefore, all hotel services can still be provided even if you choose not to authorize the processing for these purposes.
The legal basis for the processing is your explicit consent, given by checking the appropriate boxes and completing the procedure double opt-in your personal data, as defined in Article 4(1) of EU Regulation 2016/679, provided or related to you, will be processed in compliance with legal requirements for a period deemed appropriate for achieving the purposes indicated in this point, considering the balance between the legitimate interests of the Data Controller and the rights and freedoms of the customer as the data subject. Your data will be processed according to the timelines specified by legal provisions or, in the absence of specific regulations, as long as necessary for marketing and profiling activities. The Data Controller ensures that data processing will not continue indefinitely.
We emphasize that you have the right to withdraw your consent at any time for the activities described in this section 2) by sending a simple informal written communication to the contact details of the Data Controller specified later in this notice. According to the law, any processing carried out before the withdrawal of consent remains valid.
Regardless of the data subject’s decision to remove them, personal data will be retained to fulfill obligations (e.g., fiscal and accounting) that remain even after the termination of the contract (Article 2220 of the Italian Civil Code). For these purposes, the Data Controller will only retain the data necessary to comply with such obligations.
Exceptions are made in cases where it is necessary to assert rights arising from the contract and/or registration, in which case the personal data of the data subject, limited to what is necessary for these purposes, will be processed for the time required to pursue such rights.
The Data Controller does not transfer personal data to countries outside the EU where the GDPR does not apply, unless specifically indicated otherwise. In such cases, if necessary, consent will be requested.
We would also like to inform you that providing your data for the processing activities mentioned in points 1, 2, and 3 is mandatory. If you refuse to provide this data, we will not be able to accommodate you at our hotel. If you wish for the processing described in points 4, 5, and 6 to be carried out, you will need to provide your consent. However, consent can be withdrawn later by opposing the processing activities.
Below, we provide you with additional information and clarifications regarding the specified processing activities:
– The personal data you provide or that is related to you may be subject to partially or fully automated processing, which may be carried out using paper, electronic, and/or magnetic supports.
– Personal data will not be disseminated but may be communicated to or accessed by specifically trained operators within the Data Controller's organization and/or external parties who collaborate with the company as data processors or independent data controllers. Examples include, but are not limited to:
– We inform you that the Data Controller has appointed external data processors who may have IT systems located in countries outside the European Union, and therefore data may be processed in those countries. However, we specify that personal data will only be processed in third countries that have received an adequacy decision from the European Commission and provide appropriate security guarantees for data processing. For any clarification and requests, you may contact the Data Protection Officer at the details provided below.
– We also inform you that you have the right to request from the Data Controller access to your personal data, as well as its correction, deletion, or restriction of processing. You also have the right to object to the processing of personal data and to exercise the right to data portability. The rights mentioned in this paragraph can be exercised as provided by Articles 15, 16, 17, 18, 20, and 21 of Regulation (EU) 2016/679, which are reproduced for your convenience along with this notice. All rights may be exercised with the Data Controller, and you also have the right to file a complaint with the national data protection authority.
This notice integrates and completes elements already known to the data subject
Article 15 - Right of access by the data subject The interested party has the right to obtain from the data controller confirmation as to whether or not personal data concerning him or her are being processed and, in this case, to obtain access to the personal data and the following information: a) the purposes of the treatment; b) the categories of personal data in question; c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients are from third countries or international organisations; d) when possible, the expected retention period of personal data or, if this is not possible, the criteria used to determine this period; e) the existence of the right of the interested party to ask the data controller to rectify or delete personal data or to limit the processing of personal data concerning him or to oppose their processing; f) the right to lodge a complaint with a supervisory authority; g) if the data are not collected from the interested party, all available information on their origin; h) the existence of an automated decision-making process, including profiling referred to in Article 22, paragraphs 1 and 4, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the interested party. 2. If personal data are transferred to a third country or to an international organisation, the interested party has the right to be informed of the existence of adequate guarantees pursuant to Article 46 relating to the transfer. 3. The data controller provides a copy of the personal data being processed. In case of further copies requested by the interested party, the data controller may charge a reasonable fee based on administrative costs. If the interested party submits the request by electronic means, and unless the interested party indicates otherwise, the information is provided in a commonly used electronic format. 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 has the right to obtain from the data controller the rectification of inaccurate personal data concerning them without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the completion of incomplete personal data, including by providing a supplementary statement.
Article 17 Right to Erasure ("Right to be Forgotten") The data subject has the right to obtain from the data controller the erasure of personal data concerning them without undue delay, and the data controller is obliged to erase personal data without undue delay if one of the following reasons 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 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 data controller is subject.
Article 20 Right to Data Portability 1. The interested party has the right to receive the personal data concerning him or her provided to a data controller in a structured, commonly used and machine-readable format and has the right to transmit such data to another data controller without impediments on the part of the data controller to whom it was provided if: a) the processing is based on consent pursuant to Article 6, paragraph 1, letter a), or Article 9, paragraph 2, letter a), or on a contract within the meaning of Article 6(1)(b); and b) the processing is carried out by automated means. 2. When exercising their rights relating to data portability pursuant to paragraph 1, the interested party has the right to obtain the direct transmission of personal data from one data controller to another, if technically feasible. 3. The exercise of the right referred to in paragraph 1 of this article is without prejudice to Article 17. This right does not apply to processing necessary for the execution of a task of public interest or connected to the exercise of public powers referred to the data controller is vested. 4. The right referred to in paragraph 1 must not adversely affect the rights and freedoms of others.
Article 21 Right to Object 1. L'interessato ha il diritto di opporsi in qualsiasi momento, per motivi connessi alla sua situazione particolare, al trattamento dei dati personali che lo riguardano ai sensi dell'articolo 6, paragrafo 1, lettere e) o f), compresa la profilazione sulla base di tali disposizioni. Il titolare del trattamento si astiene dal trattare ulteriormente i dati personali salvo che egli dimostri l'esistenza di motivi legittimi cogenti per procedere al trattamento che prevalgono sugli interessi, sui diritti e sulle libertà dell'interessato oppure per l'accertamento, l'esercizio o la difesa di un diritto in sede giudiziaria. 2. Qualora i dati personali siano trattati per finalità di marketing diretto, l'interessato ha il diritto di opporsi in qualsiasi momento al trattamento dei dati personali che lo riguardano effettuato per tali finalità, compresa la profilazione nella misura in cui sia connessa a tale finalità di marketing diretto. 3. Qualora l'interessato si opponga al trattamento per finalità di marketing diretto, i dati personali non sono più oggetto di trattamento per tali finalità. 4.5.2016 IT Gazzetta ufficiale dell'Unione europea L 119/45 4. Il diritto di cui ai paragrafi 1 e 2 è esplicitamente portato all'attenzione dell'interessato ed è presentato chiaramente e separatamente da qualsiasi altra informazione al più tardi al momento della prima comunicazione con l'interessato. 5. Nel contesto dell'utilizzo di servizi della società dell'informazione e fatta salva la direttiva 2002/58/CE, l'interessato può esercitare il proprio diritto di opposizione con mezzi automatizzati che utilizzano specifiche tecniche. 6. Qualora i dati personali siano trattati a fini di ricerca scientifica o storica o a fini statistici a norma dell'articolo 89, paragrafo 1, l'interessato, per motivi connessi alla sua situazione particolare, ha il diritto di opporsi al trattamento di dati personali che lo riguarda, salvo se il trattamento è necessario per l'esecuzione di un compito di interesse pubblico.
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