Privacy Policy

GUIDELINES AS PER ART. 13 AND 14 - EU REGULATION 2016/679

Data subjects

Website users

Personal data processing

Hereby are described the website's management procedures www.palazzonovello.it, whose owner is Itaca Srl. These guidelines are drafted in accordance with art. 13 of the regulation 2016/679 of the european parliament and the council of 27 April 2016 on the protection of natural persons with regard to processing of personal data. These guidelines are drafted for Hotel Palazzo Novello website and not for other websites that user may access to through their link.

Data controller

Following the consultation of this website, data referring to identified or identifiable persons can be processed.
Data controller: Hotel Palazzo Novello - Via Tito Speri, 17 - 25018 - Montichiari - email: info@palazzonovello.it, Business name: Itaca Srl legally registered in Via Tito Speri, 17 25018 Montichiari (Bs).

Place of data and recipient processing

The processing relating to the web services of this website take place in ITALY at server farms "Server Farm DATA4 GROUP Via Monzoro, 101-105 - 20007 Cornaredo (MI), said parties are suppliers of Titanka! (primary processor) Spa with registered office in Strada degli Angariari, 46 47891 Falciano RSM, which carries out website maintenance and management operations.

Type of data processed

Purposes and lawful basis

Data storage period

The data storage period is defined by requested service's purposes and for a further period of 36 months. Should the requested information be part of an online transaction, such data shall be stored for economic or fiscal accounting purposes for a period of 10 years. As regards technical data managed by the website, such as cookies, the storage period is defined according to the cookies technical characteristics as specified in the table "List of cookie". The storage period of personal data will be automatically extended for a further period of 36 months whenever a new consent to the processing of personal data is given and/or every time users access the services provided by entering their own log-in credentials (e.g. Login personal account).

Optionality of data provision

With the exception of what has been specified regarding browsing data, the user is free to supply to Hotel Palazzo Novello the personal data requested to benefit from the services provided through the website. Failure to provide data relating to the fields marked by the asterisk (mandatory) will result in the impossibility to access such services.

Processing procedures and safety

The processing of personal data occurrs via information systems designed to guarantee data safety and privacy in compliance with the appropriate safety measures pursuant to art. 32 GDPR, via safe communication protocols with SSL encryption algorithms.
Your personal data will be processed in accordance with the aforementioned laws and privacy obligations in effect. Good practices are defined by the Italian Data Protection Authority issued provision "Guidelines on Marketing and against Spam - July 4, 2013" (published on the Official Gazette no 174 on July 26 2013), Guidelines on Personal Data Processing for online Profiling - March 19 2015 and Guidelines on Automated individual decision-making and Profiling for the purposes of the EU Regulation 2016/679.

Data transfer to non-EU countries and guarantees of adequacy

The service provider in charge of hosting, maintenance and management services for the Hotel Palazzo Novello website is Titanka!, a web agency located in San Marino, a non-EU country that has accepted the European framework on personal data processing by adopting the December 21, 2018 law no 171 that guarantees compliance with the GDPR regulations. While waiting for the adequacy assessment procedures to be initiated by the European Commission, data processing is allowed if the data subject has signed a contract or a pre-contractual agreement or has expressed consent to the data transfer after being informed of the risks involved in the procedure (art. 49 GDPR - derogations involved in specific situations). Further data transfers to non-EU countries may occur when using Facebook, Google and other social networks or when turning to service providers located in the US. Such data processing is guaranteed under the "Privacy shield" agreements, signed by individual companies.

Recipients

To carry out business activities and to provide support in organising and maintaining said activities, some of the data might be transferred or reported to recipients. Recipients are divided in the following categories: Third parties, processors and sub-processors and authorised personnel under the authority of the controller or the processor.

Third Parties

Natural and legal people, public authorities, services and other entities that do not include the data subject, the data controller or the data processor and sub-processors. In case data processing should concern administrative or accounting purposes, legal obligations, customer management and contracts, the data can be transferred to:

• Companies managing traditional and electronic postal services;
  
• Companies registering domain names;
  
• Other subjects, if data transfer is necessary for the fulfilment of the aforementioned purposes or legal obligations.
  

Data processors and sub-processors

Natural or legal people, public authorities, services and other entities that processes personal data on behalf of the data controller - Titanka! as primary data processor working with other sub-processors operating as service providers in the fields of technological facilities, connectivity and hosting services, such as Semplify LLC, located in San Marino. Semplify LLC is also working with sub-processor for service provision: Server Farm DATA4 GROUP Via Monzoro, 101-105 - 20007 Cornaredo (MI), Italy, where the data are located. Other possible IT service providers necessary to carry out service provision operations may be located in the US and operating under the "Privacy shield" adequacy agreement.

Inside our company

Your data will be processed solely by personnel explicitly authorised by the data controller, assuring use of suitable instruction, training, privacy agreement observation by the following categories:
-Company management.

Data publishing

Your data will not be published in any way.

Rights of data subjects

Data subject (subjects which the data are referring to) can in any moment exercise the rights stated in the Regulation through a dedicated personal area. It is possible to access said area by requesting the link via the dedicated procedure in the footnote of this information note. A further procedure for the exercise of the Regulation rights, in case the user subscribed to the newsletter, can be used via the dedicated link appearing in the footnote of the email received. Specifically, users will be entitled to enforce rights pursuant to art. 15 through art. 23, and in particular: 1.Erasure of all data. 2.rectification/alteration 3.Restriction. 4.Portability. 5.Right to object to automated decision-making (profiling). If needed, report any other request in the note field. The data subjects, should the requirements be met, have the right to issue a claim to the Data Protection Authority in accordance with the necessary procedures. For further information and to exercise these rights recognised by the European regulation you can address the data controller following the aforementioned references.

Data subjects' right exercise

The requests can also be sent using the following contacts:
Data controller: Hotel Palazzo Novello - Via Tito Speri, 17 - 25018 - Montichiari - email: info@palazzonovello.it, Business name: Itaca Srl legally registered in Via Tito Speri, 17 25018 Montichiari (Bs).

Extended information note on the use of cookies

Extended information note on the use of cookies and pursuant to the measure of the Privacy Authority n. 229/2014, for those interacting with the web services of Hotel Palazzo Novello, accessible from the internet addresses www.palazzonovello.it. The website of Hotel Palazzo Novello uses cookies and similar technologies to guarantee the correct functioning of procedures and enhance user's experiences in online applications. This document provides detailed information on the use of cookies and similar technologies, on how they are used by Hotel Palazzo Novello and how to manage them.

Definitions

Cookies are small text strings that websites visited by users sent to their terminal (usually the browser), where they are memorized to be eventually resent to the same website when the same user will visit the website again. Cookies are stored based on the user's preference by the single browser on a specific used device (computer, tablet, smartphone).

Cookie types

Based on the characteristics and use, cookies can be distinguished in different categories:

Length of cookie

Some cookies (session cookies) remain active only until the browser is closed or the log-out command executed. Other cookies "survive" the closing of the browser and are available even in the user's later sessions. These cookies are called persistent and their duration is established by the browser at the time of their creation. Navigation through the website pages www.palazzonovello.it, users can interact with all the websites managed by third parties that can create or modify profiling or persistent cookies. The temporary storage of every single cookie can be viewed in the table "list of cookies".  

Management of cookie

The user can decide whether to accept or reject cookies via the browser settings. The total or partial deactivation of cookies may affect website functionalities but it will not prevent the navigation. The setting can be specifically defined for every website and web-based application. The following are the web resources which illustrate how to proceed for every main browswer: Chrome, Firefox, Internet Explorer, Opera, Safari. 

List of cookie

Google Analytics

www.palazzonovello.it can include elements transmitted by Google Analytics, a web traffic analytical provider supplied by Google Inc. ("Google"). These are third-party cookies used to collect and analyze information on users' behaviours anonymously on the website of Hotel Palazzo Novello by visiting users. These cookies are used to store non-personal information. Google Analytics protects the privacy of its data. For further information, click the following link: https://support.google.com/analytics/answer/6004245. The user can selectively deactivate the action of Google Analytics by installing on its own browser the opt-out component supplied by da Google: https://tools.google.com/dlpage/gaoptout.

Third-party profiling cookies

The website www.palazzonovello.it may use third-party profiling cookies. These cookies are used to trace the web navigation of users and create profiles on their tastes, habits, choices, etc. Through these cookies, advertising messages matching the preferences shown by users themselves during navigation can be trasnmitted to the user's email. Said cookies can exchange information and trace the navigation of users who subscribed to one of the available services. For further details or to deny consent to third-party cookies it is possible to click on the link in the following table. 

List of third-party cookies

Google Tag Manager (Google Ireland)	read the information	denies consent
Google AdWords (Google Ireland)	read the information	denies consent
DoubleClick (Google Ireland)	read the information	denies consent
Facebook	read the information	denies consent
Twitter	read the information	denies consent