PRIVACY POLICY
Residenze del Garda Srl, hereinafter referred to as the Company, has developed this Privacy Policy to describe how the website www.kairosgardahotel.it is managed, with reference to the processing of personal data of users/visitors who consult it.
This is a disclosure made pursuant to Articles 13 and 14 of EU Regulation 2016/679 (Code regarding the processing of personal data) - to those who connect to the Company's website and use the related web services from the address www.kairosgardahotel.it. This policy is provided only for the aforementioned site and not for other websites that may be consulted by the user through specific links.
This privacy policy constitutes an integral part of our site and the services we offer. Access to and use of the site as well as the purchase of products on the site are based on the assumption that this Privacy Policy has been read and understood. If you do not agree with this Privacy Policy, we kindly ask you not to use our site.
The website www.kairosgardahotel.it is owned by the Company and is managed entirely by it.
TABLE OF CONTENTS
Data Controller
Personal Data Processed
Navigation Data
Special Categories of Personal Data
Data Provided Voluntarily by the Data Subject
Purposes of Processing
Legal Basis and Mandatory or Optional Nature of Processing
Recipients of Personal Data
Transfers of Personal Data
Retention of Personal Data
Rights of the Data Subject
Changes
1. Data Controller
The data controller for the processing carried out through the Site is Residenze del Garda Srl as defined above. For any information regarding the processing of personal data by the controller, including the list of data processors, you can write to the following address: info@residenzedelgarda.it.
2. Personal Data Processed
Following navigation of the Site, we inform you that the controller will process personal data which may consist of an identifier such as name, an identification number, an online identifier, a postal address, an email address, a telephone number (landline and/or mobile) or one or more characteristic elements of your physical, physiological, mental, economic, cultural, or social identity suitable for making the data subject identified or identifiable (hereinafter only "Personal Data").
The Personal Data processed through the Site are the following:
a. Navigation Data
The IT systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical cybercrimes against the site or third parties: with the exception of this eventuality, the data collected by the site are currently removed within a short period of time.
b. Special Categories of Personal Data
When using our Site (or sending via email) for an application, you may provide your Personal Data falling within the special categories of Personal Data referred to in Article 9 of the Regulation, literally "[...] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as [...] genetic data, biometric data intended to uniquely identify a physical person, data concerning health or a person's sex life or sexual orientation". We invite you not to publish such data unless strictly necessary. Indeed, we remind you that in the event of the transmission of special categories of Personal Data, but in the absence of a specific manifestation of consent to process such data (an eventuality which in any case obviously allows you to send a curriculum vitae), the controller cannot be held responsible in any way, nor can it receive any complaints, as in this case the processing will be permitted as it concerns data made manifestly public by the data subject, in accordance with Article 9(1)(e) of the Regulation. We still specify the importance, as already noted above, of expressing explicit consent to the processing of special categories of Personal Data, should you decide to share such information.
We also inform you that, for selection purposes, the controller may analyze professional social profiles freely available on the Internet (e.g., LinkedIn).
c. Data Provided Voluntarily by the Data Subject
When using certain Services on the Site (e.g., the request/contact/booking form), the processing of Personal Data of third parties sent by you to the controller may occur. In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you grant the broadest indemnity against any complaint, claim, request for compensation for damages from processing, etc. that may reach the controller from third parties whose Personal Data has been processed through your use of the Site's functions in violation of the applicable data protection regulations. In any case, should you provide or otherwise process Personal Data of third parties when using the Site, you guarantee from now on - assuming all related responsibility - that this particular case of processing is based on an appropriate legal basis pursuant to Article 6 of the Regulation which legitimizes the processing of the information in question.
3. Purposes of Processing
The processing we intend to carry out, with your specific consent where necessary, has the following purposes:
a. to allow the provision of the Services requested by you;
b. to respond to requests for assistance, information, or bookings;
c. to analyze CVs and contact candidates who have submitted their application;
d. to fulfill any legal, accounting, and fiscal obligations.
e. marketing purposes: the data provided may be processed, with explicit and specific consent, for sending promotional and marketing communications, including newsletters and market research, through automated tools (sms, mms, email, push notifications) and non-automated tools (paper mail, phone calls with an operator). The legal basis for the processing of your data for these purposes is Article 6, paragraph 1, letter a) of the Regulation. Direct marketing processing is optional and depends on your free choice; therefore, failure to provide your consent for this purpose will not prejudice the use of the services.
4. Legal Basis and Mandatory or Optional Nature of Processing
Pursuant to Article 7 of the Code regarding the processing of personal data, data subjects have the right at any time to obtain confirmation of the existence or non-existence of such data and to know its content and origin, verify its accuracy, or request its integration, updating, or rectification. Pursuant to the same article, they have the right to request the cancellation, transformation into anonymous form, or blocking of data processed in violation of the law, as well as to object, in any case, for legitimate reasons, to their processing. Requests should be sent by writing to or contacting the data controller at the following address: info@residenzedelgarda.it.
5. Recipients of Personal Data
Your Personal Data may be shared, for the purposes referred to in section 3 above, with:
a. subjects who typically act as data processors, namely:
a1) individuals, companies, or professional firms that provide assistance and advice to the controller in accounting, administrative, legal, tax, financial, debt collection, marketing, and communication matters relating to the provision of the Services;
a2) subjects with whom it is necessary to interact for the provision of the Services (e.g., hosting providers);
a3) or subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks); (collectively "Recipients");
b. subjects, bodies, or authorities to whom it is mandatory to communicate your personal data by virtue of legal provisions or orders from authorities;
c. persons authorized by the controller to process Personal Data necessary to carry out activities strictly related to the provision of the Services or to the other purposes referred to in section 3 above, who have committed to confidentiality or have an adequate legal obligation of confidentiality (e.g., the controller's employees).
6. Transfers of Personal Data
Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. The controller ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulation. Indeed, the transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission, or on another suitable legal basis. More information is available from the controller by writing to the following address: info@residenzedelgarda.it.
7. Retention of Data
Personal Data processed for the purposes referred to in the section "Purposes of Processing" will be kept for the time strictly necessary to achieve those same purposes. In any case, as this is processing carried out for the provision of Services, the controller will process the Personal Data until the time permitted by Italian law to protect its interests (Article 2946 of the Italian Civil Code and subsequent articles). Regarding CVs submitted through the Site or via email as per section 3.c, the Personal Data will be kept for a period deemed appropriate in relation to the purpose for which the data is acquired.
Personal Data processed for the purposes referred to in section 3.d will be kept for the time required by the specific applicable legal obligation or rule.
Personal Data processed for the purposes referred to in section 3.e will instead be kept until the data subject's consent is revoked, or, in the absence of such revocation, for a maximum period deemed appropriate.
More information regarding the data retention period and the criteria used to determine this period can be requested by writing to the controller at the following address: info@residenzedelgarda.it.
8. Rights of the Data Subject
Pursuant to Articles 15 and subsequent articles of the Regulation, you have the right to ask the controller, at any time, for access to your Personal Data, its rectification or erasure, or to object to its processing, you have the right to request the restriction of processing in the cases provided for by Article 18 of the Regulation, as well as to obtain your data in a structured, commonly used and machine-readable format, in the cases provided for by Article 20 of the Regulation.
Requests should be addressed in writing to the controller at the following address: info@residenzedelgarda.it.
In any case, you always have the right to lodge a complaint with the competent supervisory authority (Guarantor for the Protection of Personal Data), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.
9. Changes
The Company may modify or simply update, in whole or in part, this Privacy Policy. Any modification or update to the Privacy Policy will be available to all users in the Privacy section of the site as soon as the updates are active and will be binding as soon as they are published on the site in this section. If the User does not intend to accept these changes, they may stop using our site. Continued use of our website and our products and services following the publication of the aforementioned changes and/or updates will constitute acceptance of the changes and acknowledgment of the binding nature of the new terms and conditions.
