1 Identity and contact details of the owner and managers
The Data Controller is Hotei Sorrento srl – Villa Manning Relais with legal and operative office in Via Fuorimura 31, 80067 Sorrento (NA) – P. IVA 08664831214
The updated list of data responsibles and data processors is kept at the registered office of the Data Controller.
2 Object of the Treatment
HOTEI SORRENTO SRL – VILLA MANNING RELAIS processes personal data and sensitive, identifying data (hereinafter, “personal data, sensitive data” or even “data“) you have communicated when contracts have been concluded for services provided by HOTEI SORRENTO SRL – VILLA MANNING RELAIS, ie the provision of stay and events at HOTEI SORRENTO SRL – VILLA MANNING RELAIS
the personal data collected are:
- Mailing address
- Telephone number
- Email address
- Credit / debit card number or other payment details
- Financial information in certain circumstances
- Language preference
- Date and place of birth
- Nationality, passport, visa or other identification data issued by the government
- Data regarding family members and partners, such as names and age of children
- Data on the state of health and on special needs such as “allergies and intolerances, disabilities, diseases that require accommodation in dedicated rooms or special menus
3 Purposes of processing and legitimate interests
Your personal data are processed:
- without your express consent (Article 6 letter b), e) GDPR), for the following Service Purposes:
- the data are processed by HOTEI SORRENTO SRL – VILLA MANNING RELAIS as data controller as processing is necessary for the performance of a contract of which the data subject is a party or for the execution of pre-contractual measures required at the request of the data (personal data relating to contracts or pre-contractual activities with customers, suppliers, employee data during hiring or pre-employment):
- fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering);
- exercise the rights of the owner, for example the right to defense in court;
- Only subject to your specific and distinct consent (Article 7 GDPR) provided to the Data Controller, your sensitive personal data may be acquired and processed for the provision of the requested service and within the limits and purposes in the present disclosure defined
We collect personal data in different ways.
- Online Services. We collect Personal Data when you make a reservation, when you purchase goods and services from our Website or from other websites we associate with (eg. Booking), when you send us messages, when you contact us, when you post on social media, when you sign up for a newsletter or participate in surveys, contests or promotional offers.
- Outline visits and offline interactions. We collect personal data when you visit our facilities. We collect personal data even when you participate or participate in promotional events hosted by our structure or when you provide your personal data to promote an event.
- Reservations. We collect Personal Data when you make a telephone booking, when you send us an e-mail or fax, or when you use the online chat service or contact customer service. These communications could be recorded in order to guarantee the quality and training of the personnel.
We use your personal data to provide you with the requested services and in particular:
- to facilitate bookings, make payments, send messages of an administrative nature, send confirmation messages
4 Recipients of personal data and data communication
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B) to employees and collaborators of the Owner also external, in their capacity as persons in charge and / or responsible for processing and / or system administrators;
In the case of personal data of the employee HOTEI SORRENTO SRL – VILLA MANNING RELAIS., the data can be transmitted to the following recipients:
- Tax Adviser for the fulfillment of tax payroll processing matters
- Responsible for the management of his data for the provision of the requested service (acceptance, catering, billing, room service, etc.)
Personal data is stored on servers located within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.
Without the need for an express consent art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers.
5 Method of treatment and retention period
The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, use, interconnection, blocking, communication, cancellation and destruction of data.
Your personal data are subjected to both paper and electronic processing and partly automated.
The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the purposes of the Service requested.
6.Rights of the interested party
In your capacity as an interested party, you have the rights set forth in art. 15 GDPR and precisely the rights of:
- obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
- obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, the managers and the designated representative pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;
- obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right;
- to object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
- Right to rectify personal data in case they are modified and not in compliance with those previously acquired or communicated (Article 16)
- Right to delete data (“right to be forgotten” Article 17). HOTEI SORRENTO SRL – VILLA MANNING RELAIS., if one of the following cases exists, proceeds to delete the data from all the databases and the archives where it is contained:
- personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
- the interested party revokes the consent and if there is no other legal basis for the processing;
- the data subject opposes the processing pursuant to Article 21 (1) and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21 (2);
- personal data have been processed unlawfully;
- personal data must be deleted to fulfill a legal obligation under Union or Member State law to which the controller is subject;
- the personal data have been collected in relation to the information society service offer referred to in Article 8 (1).
- Right to limit processing (Article 18). The interested party has the right to obtain from the data controller the limitation of processing when one of the following hypotheses occurs:
- the interested party disputes the accuracy of personal data for the period necessary for the data controller to verify the accuracy of such personal data;
- the processing is illegal and the interested party opposes the cancellation of personal data and asks instead that its use is limited;
- although the data controller no longer needs it for processing purposes, personal data are necessary for the data subject to verify, exercise or defend a right in court;
- the interested party has opposed the treatment pursuant to Article 21 (1), pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.
- Right to object (Article 21-22): The interested party has the right to object at any time, for reasons connected with his particular situation, to the processing of personal data concerning him / her pursuant to Article 6, paragraph 1, letters e) of), including profiling on the basis of these provisions. HOTEI SORRENTO SRL – VILLA MANNING RELAIS does not submit data to decisions based solely on automated processing.
HOTEI SORRENTO SRL – VILLA MANNING RELAIS notify each interested party of any corrections, limitations or deletions of data.
HOTEI SORRENTO SRL – VILLA MANNING RELAIS abstains from further processing personal data unless there are legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the interested party or for the establishment, exercise or defense of a right in court.
For the data that HOTEI SORRENTO SRL – VILLA MANNING RELAIS trafficking for marketing purposes I the rights of the interested party are expressed in the specific Information on the processing of data for marketing purposes and information to the processing of data for purposes of profiling and aggregation.
7. How to exercise rights
You can exercise your rights at any time by sending: – an e-mail addressed to [email protected]
8. Nature of the provision of data and consequences of refusal to reply
The provision of data for the purposes referred to in art. 2. It is mandatory. In their absence, we can not guarantee the services of the art. 3.A and 3 B
The provision of data for purposes other than what is reported in this statement (eg promotions, publications, advertising, etc.) is optional and managed as defined in the Information on data processing for marketing purposes.