Privacy & Cookie Policy

This privacy policy is referred to the websites (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). 

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. 

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. 

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 is Hotel Clelia sas di Lupi Anna Maria & C, Corso Italia 23  - 19013 Deiva Marina - La Spezia – Italia, Tel. +39 0187 82626, e-mail: