Privacy Policy

Thursday 24 May 2018

Dear Customer,

In accordance with applicable privacy laws (EU Regulations n. 679, 2016), we would like to take this opportunity to inform you that your personal information will be processed in an ethical and transparent manner, only for lawful purposes, and in a manner that safeguards your privacy and your rights.

Processing takes place manually and using IT tools, and is done for the following purposes:

  1. To obtain and confirm your booking of accommodations and other services, and to provide such services as requested. Since this processing is required to define our contractual relationship and to perform under our contract with you, your consent is not required, unless certain “sensitive” information is submitted. Should you refuse to submit your personal information, we will not be able to confirm your booking or provide you with the requested services. Processing shall cease once you check out, although some of your personal information may (or in some instances, has to) continue to be processed for the purposes and in the manner described below;
  2. To comply with our “Public Safety Law” (Article 109 Royal Decree n. 773, 18/6/1931) which requires that we provide identification data of our guests to the police, for purposes of public safety, in the manner established by the Ministry of the Interior (Decree of 7 January 2013). Data submission is mandatory, and does not require your consent. Should you refuse to provide such information, we will not be able to host you in our hotel. Data acquired for such purposes shall not be retained by us, unless you provide consent to their retention as required under point 4, infra ;
  3. To comply with applicable administrative, accounting, and tax regulations. For these purposes, your consent is not required. Personal information is processed by us and our persons in charge of data processing, and is disclosed outside the company only when and if required by law. Should you refuse to submit the required data for the above purposes, we will not be able to provide you with the requested services. Data acquired for such purposes is retained by us for the required statutory period (10 years – or longer, in case of tax audits);
  4. To speed-up check-in on your next visit to our hotel. For such purposes, upon obtaining your consent (which can be revoked at any moment), your information will be retained for a maximum of __10 years__ and will be used the next time you are our guest, for the reasons listed supra;
  5. To allow you to receive messages and telephone calls during your stay. Your consent is required for such purposes. You can revoke your consent at any time. Such processing, where consent is granted, shall end when you check out;
  6. To send you advertising messages and updates on special rates and promotions. For this purpose, upon obtaining your consent, your information shall be retained for a maximum of __10 years__ and will not be disclosed to third parties. You may revoke your consent at any moment;
  7. For purposes of protecting persons, property, and company assets, using a video-surveillance system for some areas of the hotel, which are duly identified by signage. Your consent is not required for such processing because it is conducted pursuant to our legitimate interest to safeguard persons and property against potential violence, theft, robbery, damage, and vandalism. Surveillance is also conducted for purposes of fire prevention and occupational safety and health. Recorded images are erased after 24 hours, except on holidays or other days the business is closed; images are never retained for more than one week. These images are not subject to third-party disclosure, except as required to comply with a specific investigatory demands from a court or the police.

We also would like to inform you that the European Regulation grant you certain rights, including rights of access to, adjustment, erasure, limitation of, or objection to the processing of your data, as well as data portability rights, when and insofar as applicable (Articles 15-22 of the EU Regulations n. 679, 2016). You can also file a complaint with the Data Protection Authority, according to the procedures set forth under applicable regulations.

For any other concern, and to assert your rights under the EU Regulation, please contact:

Data Controller:

TRIA s.r.l.  Francesco Renga Via Monteortone,46 -35037 Teolo [email protected]

Data Processor:

TRIA s.r.l.  Raffael Renga Via Monteortone,46 -35037 Teolo [email protected]

Cookie Policy

Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf uses "cookies" in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information. Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf cookies and third party cookies

Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf may place our cookies on your device via the Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies. We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes. There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”. Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

Other technologies

The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

Uses for Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf cookies

Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf uses cookies for a number of purposes, such as the following:
  • to enable, facilitate and streamline the functioning of the Platform across different webpages and browser sessions.
  • to simplify your access to and use of the Platform and make it more seamless.
  • to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
  • to show you content (which may include advertisements) that is more relevant to you.

Uses for third party cookies

Our partners’ cookies are intended to obtain information to help them provide services to Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf. For example, third party companies and individuals we engage to provide services to us may track your behavior on our Platform to market and advertise Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf listings or services to you on the Platform and third party websites. Third parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or third party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative (https://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (https://www.aboutads.info/choices/). You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager (https://www.google.com/settings/ads/onweb/). Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Platform – it just will not be tailored to your interests. In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.

Disabling Cookies

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website (https://www.adobe.com/) and make changes at the Global Privacy Settings Panel (https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager02.html).

Changes to this Cookie Policy

We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email. It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform.

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