{"id":3,"date":"2022-09-22T13:47:02","date_gmt":"2022-09-22T13:47:02","guid":{"rendered":"https:\/\/castellotorreinpietra.it\/wordpress\/?page_id=3"},"modified":"2023-03-20T10:19:28","modified_gmt":"2023-03-20T10:19:28","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/castellotorreinpietra.it\/en\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"
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Dear Guest,<\/p>\n

Hotel Royal srl (VAT: 02397220647), located at Via Posta Vecchia, 1 \u2013 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.<\/p>\n

Treatment methods<\/strong><\/h4>\n

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.<\/p>\n

Processing is also carried out with the aid of computer systems for the following purposes:<\/p>\n

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  1. Reservation and Stay Purposes<\/strong>: Personal data provided or related to you during the reservation and\/or stay will be processed for delivering the requested hotel services.
    The legal basis for this processing is the necessity to fulfill contractual and\/or pre-contractual obligations under Article 6(1)(b) of EU Regulation 2016\/679, as well as to comply with legal obligations under Article 6(1)(c) of the same Regulation. Providing these personal data is essential for the provision of hotel services; failure to provide them may prevent the Data Controller from delivering the requested services. The personal data will be processed for the time necessary to fulfill contractual and\/or legal obligations.<\/li>\n
  2. Compliance with Public Security Obligations: To comply with the \"Consolidated Public Security Laws\"<\/strong> Compliance with Public Security Obligations: To comply with the \"Consolidated Public Security Laws\" (Article 109 of R.D. 18.6.1931 n. 773), we are required to report guest details to the Police Headquarters for public security purposes, according to the procedures established by the Ministry of the Interior (Decree 7 January 2013). Providing these data is mandatory and does not require consent; refusal to provide them will result in the inability to accommodate you. Data collected for this purpose will be stored for a maximum of 10 years to allow for fiscal and judicial verification by the competent authorities.<\/li>\n
  3. Administrative, Accounting, and Fiscal Obligations:<\/strong> To meet current administrative, accounting, and fiscal obligations. Processing for these purposes is carried out without requiring consent. Data are processed by us and our external partners and are communicated to third parties only in compliance with legal obligations. Refusal to provide necessary data will prevent us from providing the requested services. Data for these purposes are retained for the time required by relevant regulations (10 years, or longer in case of tax audits).<\/li>\n
  4. To streamline the registration procedures for any future stays at our facility.<\/strong> For this purpose, with your revocable consent given at any time, your data will be retained until you request its deletion and will be used during future stays at our facility for the purposes mentioned above.<\/li>\n
  5. To handle the reception of messages and phone calls addressed to you during your stay.<\/strong> For this purpose, your consent is required. You may revoke your consent at any time. However, processing will cease upon your departure.<\/li>\n
  6. For the protection of individuals, property, and company assets through a video surveillance system in certain areas of the facility, identifiable by appropriate signage.<\/strong> Consent is not required for this processing.<\/em>, this is because it serves our legitimate interest in protecting individuals and property from potential threats, theft, robbery, damage, vandalism, as well as for fire prevention and workplace safety. Recorded images are retained for no more than one week and are not shared with third parties, except in response to specific investigative requests from judicial or law enforcement authorities.<\/li>\n
  7. to manage surveys and\/or evaluations related to the quality of services provided by Hotel Royal srl and\/or the perception of its image as a company. This processing does not require consent as it is based on the legitimate interest of the Data Controller<\/em><\/li>\n
  8. Profiling and marketing purposes (optional)<\/strong><\/li>\n<\/ol>\n

    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).<\/p>\n

    Please note that the aforementioned processing activities may be used to understand your consumption choices in order to make Hotel Royal srl\u2019s 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.<\/p>\n

    The legal basis for the processing is your explicit consent, given by checking the appropriate boxes and completing the procedure double opt-in<\/em> 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.<\/p>\n

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    1. In the case of registration and\/or access through third-party accounts, Hotel Royal srl may process and access certain profile information from the corresponding social network solely for internal administrative processes and\/or the purposes mentioned above.<\/em><\/li>\n
    2. If it is necessary to process the User\u2019s data to fulfill a legal obligation or to execute the contractual relationship between Hotel Royal srl and the user, the processing will be lawful as it is required to meet these purposes.<\/em><\/li>\n<\/ol>\n

      Regardless of the data subject\u2019s 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.<\/p>\n

      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.<\/p>\n

      Below, we provide you with additional information and clarifications regarding the specified processing activities:<\/p>\n

      \u2013 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.
      \u2013 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:<\/p>\n

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      1. \u2013 Companies, firms, and\/or independent professionals for the processing and management of personal data;<\/li>\n
      2. \u2013 Companies, firms, and\/or independent professionals for consulting and\/or management activities in technical, corporate, and IT fields;<\/li>\n
      3. other parties to whom communication may be necessary for the proper and complete execution of the contractual relationship and\/or to fulfill legal obligations and\/or to pursue the specified purposes.<\/li>\n<\/ol>\n

        \u2013 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.<\/em><\/p>\n

        \u2013 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.<\/p>\n