Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). Effective from booking hotel stays and/or booking bicycles for excursions.

FOREWORD

This notice takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree no. 196 of 30 June 2003). The document has also been drawn up in accordance with the Privacy Guarantor’s Guidelines (especially the Guidelines for combating spam issued by the Privacy Guarantor on 4 July 2013).

Data Controller: Hotel Liliana, with registered office in Varigotti (SV), Strada degli Ulivi, 53, Tel. +39 019.69.80.42, Fax. +39 019.91.13.07053, Email mail@lilianahotel.it, registered with the Savona Chamber of Commerce.

Site to which this privacy policy refers: https://www.lilianahotel.it (Site).

The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you may send any request for information directly to the Data Controller.

INFORMAZIONI GENERALI

Il presente documento descrive come il Titolare del Trattamento tratta i Suoi dati personali conferiti sul Sito.

Di seguito vengono descritti i principali trattamenti dei Suoi dati personali. Viene in particolare spiegata la base giuridica del trattamento, se il conferimento è obbligatorio e le conseguenze del mancato conferimento di dati personali. Per descrivere al meglio i Suoi diritti, qualora necessario, abbiamo specificato se e quando un determinato trattamento di dati personali non viene effettuato.Sul Sito Lei ha la possibilità di inserire dati personali di terzi soggetti. In questo caso Lei garantisce di aver ottenuto il consenso d parte di questi soggetti all’inserimento di questi dati personali. Pertanto, Lei si impegna a manlevare e tenere indenne il Titolare del Trattamento da qualsiasi responsabilità.

Registration on the Site

The information and data requested in the event of registration will be used to allow you both to access the reserved area of the Site and to take advantage of the online services offered by the Data Controller to registered users. The legal basis of the processing is the Data Controller’s need to execute pre-contractual measures taken at the request of the data subject. The provision of data is optional. However, your refusal to provide the data will make it impossible for you to register on the Site.

Purchases on the Site

Your personal data will be processed to allow you to make purchases on the Site. In the case of an online purchase order, to allow the conclusion of the purchase contract and the correct execution of the operations connected to the same (and, if necessary according to sector regulations, to fulfil tax obligations). The legal basis of the processing is the obligation of the Data Controller to perform the contract with the data subject or to fulfil legal obligations. Irrespective of the above (and therefore of your consent), the Data Controller may process your data for the purpose of so-called ‘soft-spam’, governed by Article 130 of the Privacy Code. This means that limited to the email you provide in the context of a purchase through the Site, the Data Controller will process the email in order to allow a direct offer from similar products/services, unless you object to such processing in the manner set out in this Policy. The legal basis for the processing is the legitimate interest of the Data Controller in sending this type of communication. This legitimate interest may be considered equivalent to the interest of the data subject in receiving ‘soft-spam’ communications.

The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication.

Responding to your requests

Your data will be processed to respond to your requests for information. Providing it is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user’s interest in receiving replies to communications sent to the Data Controller.

Generic marketing

Subject to your consent, the Data Controller may process the personal data you provide in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis for this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, and will also make it impossible for the Data Controller to conduct market surveys, including those aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to the e-mail address you provide on the Site.

Profiling

The Data Controller does not carry out “profiling” with your personal data. Therefore, it will not send you advertising material and/or newsletters regarding its own products or those of third parties of your specific interest.

Data transfer

The Data Controller does not pass on your personal data to third parties.

Geolocation

The Site does not implement geolocation tools for the user’s IP address.

Curriculum Vitae

It is not possible to send CVs via the Site. Your data will therefore not be processed for these purposes.

Appointment booking

Third party appointment booking systems are not active on the Site. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts listed above.

Disclosure of personal data

Within the scope of its ordinary activities, the Controller may communicate your personal data to certain categories of persons. In Article 2 you will find a list of the persons to whom the Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not disclosed to third parties.

The ‘communication’ of personal data to third parties is different from the ‘transfer’ (regulated in the preceding point). In fact, in communication, the third party to whom the data is transmitted may only use it for the specific purposes described in the relationship with the Data Controller. In the transfer, on the other hand, the third party becomes the autonomous Data Controller. Moreover, in order to transfer your personal data to a third party, your consent is always required.

Notwithstanding the foregoing, it is understood that the Data Controller may still use your personal data in order to properly fulfil its obligations under applicable laws.

SPECIFIC PRIVACY POLICY

Art. 1 Processing modalities

1.1 The processing of your personal data will be mainly carried out with the aid of electronic or automated means, according to the methods and with the instruments suitable to guarantee security and confidentiality in compliance with the GDPR.

1.2 The information acquired and the manner in which it is processed will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.

1.3 The Site does not process “special data”. Particular data are those which may reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade-unionist character, state of health and sexual life.

1.4 No judicial data are processed through the Site.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are set out below:

• The Data Controller may communicate your personal data to all those entities (including public authorities) that have access to your personal data by virtue of regulatory or administrative measures.
• Your personal data may also be communicated to all those public and/or private entities, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labour Offices, etc.), if the communication is necessary or functional to the correct fulfilment of the obligations arising from the law.
• The Data Controller makes use of employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
• In its ordinary business of managing the Site, the Data Controller makes use of companies, consultants or professionals in charge of installing, maintaining, updating and, in general, managing the hardware and software of the Data Controller or which the latter uses for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
• In order to send its communications, the Data Controller makes use of external companies in charge of sending these types of communications (CRM platforms). Your personal data (in particular your email) may therefore be communicated to these companies.
• The Data Controller does not use external companies to provide the customer care service.
• Buyers’ personal data are not disclosed to couriers or forwarding agents.

The Data Controller reserves the right to amend the above-mentioned list on the basis of its ordinary operations. Therefore, you are invited to regularly access this notice to check to which entities the Controller discloses your personal data.

Art. 3 Storage of personal data

3.1 This article describes how long the Data Controller reserves the right to store your personal data.

• Your personal data will only be stored for as long as is necessary to ensure the proper provision of the services offered through the Site.
• For marketing purposes, personal data will be stored until consent is revoked. For inactive users, personal data will be deleted one year after the sending of any last viewed email.
• For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to prove that the contract has been properly executed.
• For customer care purposes, the data will be deleted once the service is completed.

3.2 Without prejudice to Article 3.1, the Data Controller may retain your personal data for as long as required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR. If the transfer of your personal data takes place to a country outside the EU and for which the European Commission has issued an adequacy opinion, the transfer is in any case considered safe from a regulatory point of view. This Article 4.1 indicates the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy finding.

• You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a country with these characteristics.

4.2 Notwithstanding Article 4.1, your data may also be transferred to countries outside the EU and for which the European Commission has not issued an adequacy finding. You are therefore invited to regularly review this Article 4.2 to find out to which of these countries your data may be transferred. In order to enable the proper functioning of the Site, your personal data may be transferred to the U.S.. In these cases, the Data Controller will take all appropriate contractual measures to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on 4 June 2021.

4.3 In this article, the Data Controller indicates the countries in which it may specifically conduct its business. This may imply the application of the legislation of the country in question, together with that of the GDPR.

• At the user’s request, the Data Controller will apply to the processing of personal data the legislation that may be more favourable under the user’s national law.

Article 5. Rights of the Data Subject

Pursuant to Art. 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:

• to request from the Data Controller access to your personal data and the rectification or erasure of such data or the restriction of processing concerning you or to object to its processing, as well as the right to data portability
• withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to withdrawal
• file a complaint with a supervisory authority (e.g. the Data Protection Authority).

The above rights may be exercised by making a request to the contacts indicated in the Preamble without formalities.

Art. 6. Amendments and Miscellaneous

The Data Controller reserves the right to make changes to this information notice at any time, giving suitable publicity to users of the Site and guaranteeing in all cases adequate and similar protection of personal data. In order to view any changes, you are invited to consult this policy on a regular basis. In the event of substantial changes to this privacy policy, the Data Controller may also give notice thereof by email.