INFORMATION ON THE PROCESSING OF PERSONAL DATA of the users visiting the websites of Villa Passalacqua pursuant to art. 13 GDPR 679/2016
This page contains a description of the policies for managing the website in regard to processing the personal data of the users who visit the site and their privacy. This information is provided pursuant to article 13 of GDPR 679/2016 – Laws concerning the Protection of Personal Data and the individuals who interact with the web services of Villa Passalacqua, which is accessible by telematics means through the following web address:
which corresponds to the home page of the official website of Villa Passalacqua. This informative note is provided only for the aforementioned website and not for other websites eventually accessed by the user through links.
Following access to this website, data pertaining to persons that are identified or identifiable may be processed. The “Data Controller” of the personal data collected following a visit to our website or any other data used for providing our services is Meta Spa, Viale Masia, 34 - 22100 Como.
PLACE WHERE DATA IS PROCESSED
Data processing pertaining to the web services of this website [(physically hosted by Microsoft Azure (https://azure.microsoft.com/) by our web service provider partner “Positioner” (https://www.positioner.com)] is carried out at the aforementioned headquarters and said data is processed only by the technical personnel in charge of processing of the Data Processing Office, or by eventual persons in charge of processing who are entrusted to process occasional maintenance operations.
The personal data obtained from the users who submit purchase requests or through informative material (informative notes, newsletters, registration, etc) is used only to carry out the services or assistance requested and is not transmitted to third parties, except in the following possible cases:
- Business partners of Meta Spa, Villa Passalacqua, to whom Meta Spa transmits the data exclusively in order to avoid on-line reservations, including Preferred Hotel Group (https://preferredhotels.com) by the SynXis reservation system (https://www.sabre.com) - and Ovosodo Srl, our web & communication agency (www.ovosodo.net);
- Persons, companies or professional offices who lend assistance and consulting services to Meta Spa, Villa Passalacqua concerning accounting, administrative, legal, financial and tax matters;
- Subjects who are authorized to have access to the data by law or through requests by the authorities.
CATEGORIES OF PROCESSED DATA
The information systems and software procedures relied upon to operate this web site acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols.
Such information is not collected in order to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties.
This data category includes IP addresses, and/or the domain names of the computers used by any user connecting with this web site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment.
These data are only used to extract anonymous statistical information on website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the website; except for this circumstance, any data on web contacts is currently retained for no longer than seven days.
Data voluntarily provided by the user
Sending e-mail messages to the addresses mentioned on this website, which is done on the basis of a freely chosen, explicit, and voluntary option, entails acquisition of the sender's address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s).
Data will be retained only for registration request to send the newsletters or special offers and will not be disclosed to anyone. The personal information regarding the individual who visited the website is not collected or used. The visitors remain anonymous. The only exception to this rule concerns the information for personal identification needed to fulfill the reservation contractual obligations on behalf of the user.
In the event of reservations made through the website, the user must provide his name, address, telephone number and information regarding the payment manners and credit card used. Meta Spa will use said information only to process the reservations and to send specific information, which is relevant to the confirmation of said, such as a receipt, the reservation code and the conditions. The information provided will not be used for marketing purposes and will not be sold, transmitted, given by contract or sent to third parties an any way, with the exception of our provider of on-line reservation services, Preferred Hotel Group, by his Synxis web tool, to whom elaboration of the reservations is entrusted to, only for online reservations purposes.
In any event, the administrator of the website guarantees the use of scrupulous procedures in order to protect the navigational data and the use of particular precautions to protect the data pertaining to the credit card, which is provided during on-line reservations.
Site visitors can register for our newsletter service. By registering, the user's e-mail address will automatically be included in a list of contacts to which e-mail messages will be sent. The newsletter will be containing periodic updates with commercial and promotional information relating to initiatives, events or promotions of the data controller.
To subscribe to the newsletter, you can use the registration forms on the site by entering your name and e-mail address. The information supplied with the registration form will be only used to sending our newsletter via e-mail and will not be disclosed to third parties. The newsletters will be sent through the MAGNEWS platform (https://www.magnews.it/) owned by " DIENNEA S.R.L." acting as data processor.
PERIOD FOR DATA RETENTION - CRITERIA USED
According to the provisions set forth in art. 5 par. 1 lett. e) of the Regulation (EU) 2016/679, collected personal data shall be kept in a form which permits identification of data subjects for a period not exceeding the purposes for which the personal data were collected and subsequently processed.
Data retention periods depend on the purposes of the processing:
- purposes related to technical navigation data for the correct functioning of the website: retention only for the related session, after which the data are deleted;
- purpose of reply to info request/services supply request (up to 12 months for contact requests; 10 years for administrative / accounting / financial documentation relating to the provision of a service);
- newsletter, marketing or promotional communications in general (up to 24 months -until withdrawal of consent)
- purpose of administrative / accounting / financial management: 10 years as as required by law for the conservation of administrative / accounting / financial documentation.
TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES
Personal data is not transferred to non-EU third countries, except for any cases described above where the controller provide appropriate safeguards. For transfers to the USA or others extra EU countries, in the absence of an adequacy decision pursuant to Article 45(3), or of appropriate safeguards pursuant to Article 46, it takes place on the basis:
- Reservation Data - Preferred Hotels - the transfer is necessary for the performance of a contract between the data subject and the controller, or the implementation of pre-contractual measures taken at the data subject's request, pursuant to art. 491, b) GDPR.
OPTIONAL DATA PROVISION
Subject to the specifications made with regard to navigation data, users are free to provide the personal data listed in the request forms of Villa Passalacqua or referred to in contacting Villa Passalacqua in order to make on-line purchasing or to request delivery of information materials and other communications. Failure to provide such data may entail the failure to be provided with the items requested.
Personal data is processed with automated means for no longer than is necessary to achieve the purposes for which it has been collected. Specific security measures are implemented to prevent the data from being lost, used unlawfully and/or inappropriately, and accessed without authorisation. There is no provision for an automated decision-making process for the processing of personal data.
DATA SUBJECTS' RIGHTS
The data Controller is Meta Spa, Villa Passalacqua. The Data Protection Officer is Mr. Massimo Bruno. You may contact them at any time to exercise your rights as provided for in Chapter III GDPR 679/2016, in particular, the right to obtain confirmation as to whether or not personal data concerning you exist and the logic applied to the processing, the right to ask for their integration, the right to object to their processing on legitimate ground, and the right to request rectification, updating, erasure (right to be forgotten) or blocking of data that have been processed unlawfully, the right to obtain a copy of the personal data being processed as well as the right to data portability, also by sending a written request to the Controller.
RIGHT TO LODGE A COMPLAINT
If a data subject considers that the processing of personal data relating to him or her infringes the Regulation, he or she has the right to lodge a complaint with the Garante pursuant to Article 77 of the Regulation, or else to bring a judicial proceeding pursuant to Article 79 of the Regulation.