This privacy statement is drawn up on the basis of multiple legislative systems, including art. 13 and 14 of Regulation (EU) 2016/679. In compliance with the new GDPR regulation, we provide below information on the processing of personal data of users who interact with our Internet site starting from www.embassypero.com.
1. Data controller
The Data Controller of personal data relating to Users of the Site is
Hotel Embassy s.r.l. – Via Giovanni XXIII 15 a Pero (MI). – firstname.lastname@example.org
2. Type of data collected
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this site.
Unless otherwise specified, all the data requested by this site are mandatory. If the User refuses to communicate them, it may be impossible for this site to provide the Service. In cases where this Site indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which data are mandatory, are encouraged to contact the owner.
The User assumes the responsibility of the Personal Data of third parties obtained, published or shared through this Site and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.
3. Mode and place of processing of collected data
Method of treatment
The Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Site (administrative, commercial, marketing, legal, system administrators) or external subjects (as suppliers of third party technical services, postal couriers, may have access to the Data) hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.
Legal basis of the processing
The Holder processes Personal Data relating to the User in the event one of the following conditions exists:
- the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation regarding the protection of Personal Data;
- the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
- the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
- the processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Holder;
- the processing is necessary for the pursuit of the legitimate interest of the owner or third parties.
In any case, it is always possible to ask the Owner to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.
The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, contact the owner.
The User’s Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the processing site, the User can refer to the section concerning the processing of Personal Data.
You have the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization of public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.
If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the opening dates.
The Data are processed and stored for the time required by the purposes for which they were collected.
- Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of the contract is completed.
- Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is met. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Data Controller.
When the processing is based on the consent of the User, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or an order of an authority.
At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
4. Purposes of collected data processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Hosting and Backend Infrastructure, SPAM Protection, Tag Management, Displaying content from external platforms , Interaction with social networks and external platforms and Position-based interactions.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.
5. Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Hosting and backend infrastructure
This type of service has the function of hosting data and files that allow this site to function, allow distribution and provide a ready-to-use infrastructure to provide specific features of this site.
Some of these services work through geographically dispersed servers in different locations, making it difficult to determine the exact location where Personal Data is stored.
Aruba Hosting is a hosting service provided by Aruba S.p.A.
Interaction with social networks and external platforms
This type of service allows interaction with social networks, or with other external platforms, directly from the pages of this site.
The interactions and information acquired from this Site are in any case subject to the User’s privacy settings relating to any social network.
If an interaction service with social networks is installed, it is possible that, even if the Users do not use the service, the same collect traffic data relating to the pages in which it is installed.
Bookingexpert booking widget
The reservation service is provided by Next Team srl through the site https://be.bookingexpert.it/
Personal Data collected: Cookies and Usage Data.
Non-continuous geolocation (this site)
this Site may collect, use and share data relating to the geographical location of the User, in order to provide services based on the position itself.
Most browsers and devices provide default tools to deny geographic tracking. If the User has expressly authorized this possibility, this Site can receive information on its actual geographical position.
The geographical location of the User occurs in a non-continuous manner, upon specific request of the User or when the User does not indicate in the appropriate field the place in which it is located and allows the application to automatically detect the position.
Personal Data collected: geographic position.
This type of service analyzes the traffic of this Site, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and contents recognized as SPAM.
Google reCAPTCHA (Google Inc.)
Personal Data collected: Cookies, Usage Data
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses Personal Information collected for the purpose of evaluating the use of this Site, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualise and personalize the advertisements of its advertising network.
6. User Rights
Users may exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
- withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
- oppose the processing of your data. The User can object to the processing of his Data when it occurs on a legal basis other than consent. Further details on the right of opposition are indicated in the section below.
- accedere ai propri Dati. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
- verify and request rectification. The User can verify the correctness of his Data and request its updating or correction.
- obtain treatment limitation. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose other than their conservation.
- obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
- receive your data or have it transferred to another holder. You have the right to receive your data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain the transfer without hindrance to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
- propose a complaint. The User can lodge a complaint with the competent personal data protection authority or act in court.
Details on the right of opposition
When Personal Data is processed in the public interest, in the exercise of public authority to which the Holder is invested or to pursue a legitimate interest of the Owner, Users have the right to oppose the processing for reasons related to their particular situation.
Users are reminded that, if their data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Owner deals with data for direct marketing purposes, Users can refer to the respective sections of this document.
How to exercise the rights
To exercise the rights of the User, Users can direct a request to the contact details of the Owner indicated in this document. The requests are deposited free of charge and processed by the Owner as soon as possible, in any case within a month.
8. More information on treatment
Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this Site or related Services by the User.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.
System logs and maintenance
For needs related to operation and maintenance, this Site and any third party services used by it may collect system logs, that is, files that record the interactions and that may also contain Personal Data, such as the User IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time to the Data Controller using the contact details.
Response to “Do Not Track” requests
this site does not support “Do Not Track” requests.
To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.
If the modifications concern treatments whose legal basis is consent, the Controller will collect the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
It constitutes personal data any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a physical person identified or identifiable.
This information is collected automatically through this Site (also from third party applications integrated into this Site), including: IP addresses or domain names of the computers used by the User that connects to this Site, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (good order, error, etc.) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, to the parameters related to the operating system and the IT environment of the User.
The individual who uses this Site that, unless otherwise specified, coincides with the interested party.
The natural person to whom the Personal Data refers.
Data Processor (or Manager)
Data Controller (or Holder)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures related to the operation and use of this Site. The Data Controller, unless otherwise specified, is the owner of this Website.
The hardware or software tool through which the Personal Data of Users are collected and processed.
The Service provided by this Site as defined in the relevant terms (if any) on this site / application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document shall be extended to all current member states of the European Union and the European Economic Area.
Small portion of data stored in the User’s device.