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).
FOREWORD
This disclosure 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 drafted on the basis of the Privacy Guarantor’s Guidelines (especially the Guidelines on Countering Spam issued by the Privacy Guarantor on 4 July 2013).
Data Controller
Hotel Pierre Milano s.r.l.
Via De Amicis, 32 · 20123 Milano
Email: info@cityhotel.it
P.IVA 08109720154
Site to which this privacy policy refers: https://cityhotel.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.
GENERAL INFORMATION
This document describes how the Data Controller processes your personal data provided on the Site.
The main processing of your personal data is described below. In particular, the legal basis of the processing, whether the provision of personal data is obligatory and the consequences of not providing personal data are explained. In order to better describe your rights, we have specified if and when a certain processing of personal data does not take place.
Registration on the Site
The Site does not offer the possibility of registration. Therefore, the Data Controller does not process your personal data for this purpose.
Purchases on the Site
It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose. The Data Controller does not process your data in order to send you ‘reminder’ emails to purchase products and/or services of the Data Controller.
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
The Data Controller will not send you advertising material and/or newsletters relating to its own products or those of third parties.
Profiling
The Data Controller does not carry out ‘profiling’ with your personal data. Therefore, it will not send you advertising material and/or newsletters relating to its own products or those of third parties that are of specific interest to you.
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
Resumes cannot be sent via the Site. Your data will therefore not be processed for these purposes.
Booking appointments
The information and data requested when booking an appointment and/or a service will be used to allow you to make the booking in question with the Data Controller in the manner indicated on the Site. 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 to book an appointment and/or service on the Site.
Communication of personal data
In the ordinary course of its business, 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 are 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, 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 their security and confidentiality in compliance with the GDPR.
1.2 The information acquired and the methods of processing will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure IT 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. Below are the subjects to whom the Data Controller reserves the right to communicate your data:
- The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions.
- Your personal data may also be communicated to all public and/or private subjects, natural and/or legal persons (legal, administrative, and tax consulting firms, Judicial Offices, Chambers of Commerce, Labor Chambers and Offices, etc.), if the communication is necessary or functional for the correct fulfillment of legal obligations.
- The Data Controller employs employees and/or collaborators of any kind. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
- In its ordinary management activity of the Site, the Data Controller uses companies, consultants, or professionals tasked with the installation, maintenance, updating, and, in general, the management of the hardware and software of the Data Controller or that the latter uses to provide its services. Therefore, only for these purposes, your data may also be processed by these subjects.
- The Data Controller does not use CRM platforms (companies that primarily perform the activity of sending automated communications to users). Therefore, your personal data is not communicated to these companies.
- The Data Controller does not use external companies to provide customer care services.
- The personal data of buyers are not communicated to couriers or shippers.
The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this information to check which subjects the Data Controller communicates your personal data to.
Art. 3 Retention of Personal Data
3.1 This article describes how long the Data Controller reserves the right to retain your personal data.
- Your personal data will be retained only for as long as necessary to ensure the correct provision of the services offered through the Site.
- For customer care purposes, the data will be deleted once the assistance service is completed.
3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as modified 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 secure from a regulatory standpoint as it is governed by the GDPR. If the transfer of your personal data takes place to a non-EU country for which the European Commission has issued an adequacy decision, the transfer is considered secure from a regulatory perspective. This Article 4.1 indicates from time to time the countries to which your personal data may be transferred and where the European Commission has issued an adequacy decision.
- The Data Controller may transfer your personal data to the United Kingdom. The European Commission has indeed ruled, with the decision of June 28, 2021, that the United Kingdom offers an adequate level of personal data protection according to the GDPR.
4.2 Without prejudice to what is indicated in Article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not issued an adequacy decision. You are therefore invited to regularly review this Article 4.2 to ascertain in which of these countries your data may be transferred. To allow the proper functionality of the Site, your personal data may be transferred to the USA. In these cases, the Data Controller will adopt all suitable contractual measures to ensure an adequate level of personal data protection, including, among others, the Standard Contractual Clauses approved by the European Commission on June 4, 2021.
4.3 In this article, the Data Controller indicates the countries to which it specifically directs its activity. This circumstance may imply the application of the regulations of the country in question, along with those of the GDPR.
- At the user’s request, the Data Controller will apply the most favorable regulations provided by the national legislation of the user.
Art. 5 Rights of the Data Subject
Pursuant to Article 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:
- request the Data Controller access to your personal data and the rectification or deletion of the same or the restriction of processing concerning you or to object to their processing, as well as the right to data portability.
- withdraw consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal.
- lodge a complaint with a supervisory authority (e.g., the Data Protection Authority).
The above rights may be exercised by making a request informally to the contacts indicated in the Introduction.
Art. 6 Modifications and Miscellaneous
The Data Controller reserves the right to make changes to this information at any time, providing suitable publicity to the users of the Site and ensuring in any case adequate and similar protection of personal data. To review any changes, you are invited to regularly consult this information. In case of substantial changes to this privacy notice, the Data Controller may also communicate it via email.
