1. CONTROLLER, CONTACT DETAILS AND PLACE OF PROCESSING
1.1
Controller:
Stabilimento Termale Hotel Terme Leonardo Tria srl. with registered office at 35037 Teolo (PD), via Monteortone No. 46, Tel. 049 9939200, E-mail [email protected]
1.2
Data Protection Officer (DPO): appointed by the Controller is Francesco Renga. He is domiciled at the Controller’s office and can be contacted at: [email protected]
2. PERSONAL DATA AND PURPOSE OF PROCESSING
2.1
In accordance with the provisions of Reg. (EU) 2016/679, Legislative Decree 196/2003 (as amended by Legislative Decree 101/2018), the measures and guidelines of the Data Protection Authority, and data protection legislation in general, this section of the website processes navigation and usage data (and any other information obtained through cookies and similar tools). In particular, with regard to the booking and information request procedure, it processes the user’s personal/identifying data (first name, last name, arrival date and number of nights, etc.), contact details (for example, e-mail address and, during booking, telephone number and address), and, for booking only, payment data.
2.2
The collection of ordinary personal data (name, e-mail, telephone number, address, etc.) may, subject to the user’s specific consent given via the relevant website feature, be used for direct marketing, market research and commercial communications, particularly for sending newsletters or SMS. In the absence of objection, it may also be used for traditional marketing purposes (such as an operator call or sending postal mail to the address provided).
2.3
The collection of ordinary personal data (such as name, last name, contact details, arrival date and number of nights, payment data, etc.) may be necessary to handle a hotel booking. The personal data collected will also be processed to comply with legal obligations or to defend the Controller’s or third parties’ rights in legal proceedings.
2.4
The data entered in the information request form (personal data, contact details, arrival date and number of nights, etc.) are used to respond to e-mail inquiries sent to the Controller and to exercise any data subject rights under privacy law. Once the user contacts the Controller voluntarily, the Controller may process the data provided for these purposes.
3. TYPES AND LEGAL BASES OF PROCESSING
3.1
Processing may be carried out with or without electronic or automated tools, always in compliance with data protection legislation, in particular Article 32 of Reg. (EU) 2016/679, which requires appropriate technical and organizational measures. Processing is performed by the appointed and authorized handlers and/or processors, under the supervision and according to the instructions of the Controller.
3.2
For marketing/promotional purposes, the legal basis for processing is the user’s explicit consent (Art. 6(1)(a) GDPR). For traditional marketing activities, the legal basis is the legitimate interest of the Controller (Art. 6(1)(f) GDPR), taking into account Recital 47.
3.3
For personal data collected/processed in connection with hotel bookings, the legal basis is the performance of pre-contractual and contractual measures at the user’s request (Art. 6(1)(b) GDPR). For compliance with legal obligations, it is Art. 6(1)(c). For the defense of the Controller’s or third parties’ rights in legal proceedings, it is the legitimate interest of the Controller and the right of defense (Art. 6(1)(e) and Art. 9(2)(f) & (g) GDPR).
3.4
For data transmitted via the information request form, the basis is either pre-contractual measures (Art. 6(1)(b)) or, where no such relationship exists, the legitimate interest of the Controller (Art. 6(1)(f)).
4. VOLUNTARY DATA PROVISION
4.1
Providing personal data for marketing or traditional marketing purposes is neither contractually nor legally required but is necessary for these purposes. Refusal or incorrect provision of data will prevent or limit these activities (depending on whether fields are marked as required). The user may withdraw consent or object at any time, and processing will cease immediately.
4.2
Providing personal data for hotel bookings or via the information request form is also voluntary but necessary for pre-contractual and contractual measures. Refusal or incorrect provision of data will prevent or limit these activities.
5. RETENTION PERIOD
5.1
If no deletion or objection is requested, data processed for pre-contractual or service-related purposes will be retained only as long as necessary for service provision and no longer than needed to protect the Controller’s rights. If processed under a contract, data will be retained for 10 years from contract termination. For subsequent related purposes, retention extends for an additional 10 years.
5.2
For marketing and traditional marketing purposes, data will be retained for the duration of the corresponding service unless a withdrawal or deletion is requested.
6. DISCLOSURE AND SHARING
Personal data may be disclosed for these purposes to consultants and independent professionals (e.g., business consultants, law firms), public or private entities when required by law or necessary for contract performance (e.g., providers of administrative software). Data will not be shared publicly.
7. DATA SUBJECT RIGHTS
Regulation (EU) 2016/679 grants data subjects rights to access, rectify, complete, erase, restrict processing, data portability, withdraw consent, and object on legitimate grounds. In case of violations, the data subject may lodge a complaint with the Data Protection Authority. To exercise rights, the data subject may contact the Controller or the Data Protection Officer.
Cookie Policy
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Tria S.r.l. - Hotel Leonardo Da Vinci Terme & Golf cookies and third party cookies
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