PRIVACY POLICY
Esperia S.r.l. – Hotel Esperia (hereinafter referred to as Hotel Esperia) headquartered in Via Val Cismon, 1 – 16167 Genova, telephone: 010321777, e-mail info@hotelesperia.it (hereinafter referred to as Hotel Esperia) in accordance with the EU Regulation 679/2016 – General Data Protection (GDPR), acknowledges the importance of personal data protection and recognises it as one of the main goals of its activities.
We kindly request you to carefully read this privacy policy (“Privacy Policy”) before disclosing personal data, as it contains important information regarding the protection of personal data and the security measures taken in order to ensure confidentiality in full compliance with GDPR requirements. Furthermore, this privacy policy: only applies to the website http://www. hotelesperia.it / (“Website”), not to other websites to which we may provide links; is provided as a statement pursuant to Art. 13 of GDPR for users who interact with the Website; complies with Recommendation 2/2001 on certain minimum requirements for collecting personal data on-line in the European Union adopted by the Article 29 Working Party on May, 17, 2001.
Hotel Esperia hereby informs you that the processing of your personal data will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality. Your personal data will be processed in accordance with the provisions of GDPR and with confidentiality obligations. Your personal data will be processed using paper and automated and electronic tools.
CONTENTS
Here is the table of contents of this privacy policy, so that you can easily find information on the processing of your personal data.
1. DATA CONTROLLER
2. PERSONAL DATA SUBJECT TO PROCESSING
a. Navigation data
b. Data provided voluntarily
c. Cookies and similar technologies
3. PURPOSES, LEGAL BASIS AND MANDATORY OR DISCRETIONARY NATURE OF PROCESSING
4. RECIPIENTS
5. DATA TRANSFERS
6. DATA RETENTION
7. DATA SUBJECT’S RIGHTS
8. CHANGES TO THIS POLICY
1. DATA CONTROLLER
The Data Controller of the Website is Esperia S.r.l. – Hotel Esperia, as defined above. For information on how Hotel Esperia processes personal data, e.g. the list of processors, please contact Hotel Esperia via email at info@hotelesperia.it or call +39 (0) 10321777.
2. PERSONAL DATA SUBJECT TO PROCESSING
“Personal Data” means any information relating to an identified or identifiable natural person in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity, etc.
Personal data collected through the Website are:
a. Navigation data
The computer systems used to operate the Website need to acquire some Personal Data, the transmission of which is implicit in the use of Internet communication protocols. While such data are not collected for the purpose of identifying you, they may imply, for their very nature, identification through processes and associations with data owned by third parties. This category of data includes: IP addresses, domain names of the device used to connect with the Website, addresses of the resources requested in URI (Uniform Resource Identifier) notation, the time of request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to your operating system and computer environment.
These data are used only to obtain anonymous statistical information on the use of the Website and to check its correct functioning; furthermore, to allow the correct provision of the functions requested by you, given the system architecture used, they will be cancelled after 7 days for safety reasons and to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Website or third parties.
b. Data provided voluntarily
Through the Website you can voluntarily provide Personal Data such as name, surname, address, telephone, e-mail, for instance by sending an e-mail to Hotel Esperia. Moreover, in order to book a room, you may also voluntarily provide the Hotel with necessary credit card details to pay or guarantee the booking. Payment administration services allow this Website to process payments by credit card or other payment instruments. The data collected for the payment are acquired directly by the operator of the payment service (PayPal) without being processed by this Website or by the Data Controller. PayPal is a payment service provided by PayPal Inc., which allows users to pay online.
Hotel Esperia will process the abovementioned data in accordance with the GDPR and will assume that they refer to you or to third parties who have expressly authorised you to disclose them on the basis of a specific legal basis that justifies the processing of these data. With respect to these assumptions you are an independent Data Controller, which implies that you assume all legal obligations and responsibilities. In this sense you grant the widest possible indemnity with respect to any dispute, claim, request for compensation for damages resulting from processing, etc., that may be sent to Hotel Esperia by third parties whose Personal Data were processed by the Website in breach of the GDPR.
c. Cookies and similar technologies
Hotel Esperia collects Personal Data through the use of Cookies. For more information on the use of cookies and similar technologies, please click here.
3. PURPOSES, LEGAL BASIS AND MANDATORY OR DISCRETIONARY NATURE OF PROCESSING
The Personal Data provided through the Website will be processed by Hotel Esperia for the following purposes:
a) reply to a contact request by e-mail sent through the Website in order to receive information, etc.;
b) statistical research/analysis of aggregated or anonymous data, therefore without the possibility of identifying the user, as they are intended to measure the Website operations, traffic and to assess its usability and interest;
c) fulfilment of a legal obligation to which Hotel Esperia is subject;
d) need to ascertain, exercise or defend a right in Court or any time legal authorities perform their jurisdictional functions;
e) booking/payment of a room.
The legal basis of the processing of Personal Data for the purposes in point a) is the provision of a service to reply to a request which does not require consent under GDPR.
The purposes in point b) do not require the processing of Personal Data; the purposes in point c) are related to the fulfilment of a legal obligation; the purposes in point d) imply lawful processing of Personal Data under GDPR as, once Personal Data are disclosed, processing is necessary in order to fulfil a legal obligation Hotel Esperia is subject to; the purposes in point e) are necessary to fulfil a contract the subject is a party to or to fulfil pre-contractual measures adopted upon subject’s request.
Providing Personal data for the purposes listed above is voluntarily, but any failure to provide them could make it impossible to reply to your requests or confirm booking or fulfil legal obligations Hotel Esperia is subject to.
4. RECIPIENTS
For the purposes listed in point 3 your Personal Data may be shared with:
a. subjects whose intervention is necessary to provide the services of the Website - including, by way of example, keeping it online - and which usually act as processors on behalf of Hotel Esperia;
b. people Hotel Esperia authorises to process Personal Data who are committed to the respect of their confidentiality or are subject to legal confidentiality requirements; (ex. Hotel Esperia’s employees and workers);
c. Courts in the exercise of their functions when required by the GDPR.
5. DATA TRANSFERS
Your Personal Data are located on servers within the European Union. It is intended that the Data Controller, if necessary, has the right to move the servers outside the European Union. In this case the Data Controller ensures, as of now, that the transfer of data outside the EU will take place in accordance with applicable legal provisions or, alternatively, will be based on a decision as to whether the transfer is appropriate or on the stipulation of the standard contractual clauses provided by the European Commission. For more information, please contact the Data Controller.
Your data are not subject to dissemination.
6. DATA RETENTION
Hotel Esperia will process your Personal Data for the time strictly necessary to fulfil the purposes listed in point 3. By way of example, Hotel Esperia will process Personal Data to reply to contact request for the time necessary to provide you with the requested information. Without prejudice to the above Hotel Esperia will process your Personal Data within the limits of the applicable Italian law to protect its interests (Art. 2947(1)(3) of the Italian Civil Code). For more information on Personal Data retention periods and on the criteria to establish them please contact Hotel Esperia.
7. DATA SUBJECT’S RIGHTS
In your capacity as a Data Subject you have rights as per Articles 15-21 of the EU Regulation, i.e.: right of access, rectification, cancellation (“right to be forgotten”), right of limitation of processing, right to data portability, right of opposition.
To exercise your rights, please contact the Data Controller, Esperia S.r.l. – Hotel Esperia (hereinafter referred to as Hotel Esperia) headquartered in Via Val Cismon, 1 – 16167 Genova, telephone 010321777, e-mail info@hotelesperia.it.
Furthermore you have the right to submit a complaint to the competent control authority (the Italian Data Protection Authority, Garante per la Protezione dei Dati Personali) in accordance with Art. 77 of the EU Regulation or to take legal actions. (Art. 79 of the Regulation).
8. CHANGES TO THIS POLICY
This Privacy Policy has been in force since May 2018. Hotel Esperia reserves the right to modify or simply update the contents of this statement, completely or partially, also in the event of changes in the GDPR. Hotel Esperia kindly invites you to consult this section regularly in order to know the most updated version of the Privacy Policy and be aware of how Hotel Esperia collects and uses Personal Data.
