INTRUDUCTION
This privacy policy is referred to the websites clelia.it
cleliaapartments.com (hereinafter, the "Site") and describes the data
processing activities performed by Hotel Clelia sas di Lupi Anna Maria & C
through the Site, which is owned by Hotel Clelia sas di Lupi Anna Maria & C
The Site is managed by Hotel Clelia sas in its role of Data Processor nominated
by the Data Controller, as defined below. Hotel Clelia sas recognizes the
importance of the privacy of its users and is committed to protect it, in accordance
with European Legislation on data protection and the the Italian “Privacy Code”
(Legislative Decree June 30, 2003 n. 196 and further amendments and
integrations).
TYPES OF DATA COLLECTED
If user visits the Site usually no personal data will be collected
or processed, expect for the so named "surfing data", which are data
whose transmission to the Site is necessary to allow the functioning of the
information systems that manage the Site and more generally the use of Internet
communications protocols. Surfing data are for example the computer’s IP
addresses or domain names used to visit the Site together with other parameters
on the relevant operating system. Delfino di Meloni Cristina & C. S.n.c.
does not collect surfing data to associate them with other user’s information
or to identify users. However, by their nature, surfing data may allow the
identification of user by association with other information. Hotel Clelia sas
may use said data to assess possible responsibilities for information crimes against
the Site or realized through the Site. With this exception, Hotel Clelia sas
keeps surfing data only temporarily and according to applicable legislation. As
regards to the use of Cookies, please refer to the section below.
Hotel Clelia sas di Lupi Anna Maria & C. collects and
processes personal data voluntarily provided by user upon interaction with the
Site functionalities and request of the services offered by the Site, for
example when user subscribes to the Site, to the newsletter and purchases Hotel
Clelia sas di Lupi Anna Maria products.
Hotel Clelia sas di Lupi Anna Maria & C may collect
include name, e-mail and phone number. When personal data are collected on the
Site a specific informative statement will be displayed according to Art. 13 of
the Privacy Code. If user provides Hotel Clelia sas with personal data of third
parties (for example the telephone number or e-amil address of a third party)
user shall provide that said communication to Hotel Clelia sas. and its
processing for the purposes specified in the relevant privacy statement are in
compliance with the Privacy Code and applicable legislation, so for example
user may provide third parties’ data only after having duly informed them and
having obtained their consent if necessary.
PURPOSES AND MEANS OF PERSONAL DATA PROCESSING; CONSEQUENCES
IN CASE OF REFUSAL
In addition to the so-called surfing data (please refer to
section 2 above and the paragraph on Cookies, below) Hotel Clelia sas di Lupi
Anna Maria & C. may process the personal data in order to provide the
services requested, such as elaborating and operating the purchase requests and
perform the necessary fulfillments connected to them, including administrative,
accounting tax and legal obligations.
User’s personal data will also be processed by Hotel Clelia
sas di Lupi Anna Maria & C to comply with obligations imposed by laws,
regulations and Community legislation (including money laundering legislation)
and to establish or defend a legal claim of Hotel Clelia sas di Lupi Anna
Maria. Furthermore, personal data may be processed for marketing purposes
(namely to send newsletter, information, promotional material regarding
products, services, promotions and initiatives of Hotel Clelia sas as well as
to invite to events and activities) or for profiling activities (creation of
profiles based on habits and choices of consumers), where the appropriate
consents are provided by the user.
For the purposes described above, the conferment of personal
data of the user is necessary, and any refusal would prevent Hotel Clelia sas.
from performing its contractual obligations and providing services and goods to
the user.
Hotel Clelia sas processes personal data mostly through
electronic and automated means whose procedures and logics are defined
according to the purposes herein specified. Data may also be processed in paper
form. Hotel Clelia sas keeps data only for the time that is necessary to
fulfill specific purposes that are sought from time to time.
EXTENT OF PERSONAL DATA COMMUNICATION AND TRANSFER ABROAD
User personal data will be accessible within Hotel Clelia
sas di Lupi Anna Maria & C. organization on a need-to-know basis by its
personnel as persons charged with data processing operations. User personal
data may be communicated to institutions, authorities, public entities,
professionals, independent consultants, business partners of Hotel Clelia sas.,
notably third parties to which it may revert to in relation to performance of
business, professional and technical services functional to the managing of the
Site and the processing purposes herein specified. User’s personal data may
also be communicated to third parties in case of mergers, acquisitions,
transfer of assets, products or other extraordinary operations and Hotel Clelia
sas companies. These third parties will be provided only with the information
necessary to perform their respective functions; they agree to use the
information received only for the processing purposes above specified, to keep
it confidential and secure and to comply with applicable law. User’s personal
data may further be communicated to whoever is the legitimate addressee under
applicable laws, thus for example in case of judicial processes, request by
competent courts and authorities or other legal obligation, and if Hotel Clelia
sas di Lupi Anna Maria & C in good faith holds the data communication as
necessary to comply with obligations deriving from applicable legislation, to
protect and defend the rights and property of Hotel Clelia sas and the Site. The
third parties receiving data will process them as Controllers, Processors or
persons in charge of processing, as the case may be, for the same purposes
specified in this Privacy Policy and according to applicable privacy laws.
Hotel Clelia sas
where requested by privacy law, will obtain the necessary consents in
order to process the data provided. The data provided will under no
circumstance be processed by third parties for their own promotional and
profiling purposes.
THE DATA CONTROLLER AND THE DATA PROCESSOR
The data Controller is Hotel Clelia sas di Lupi Anna Maria
& C, Corso Italia 23 - 19013 Deiva
Marina - La Spezia – Italia, Tel. +39 0187 82626, e-mail: info@cleliaapartments.com