INFORMATION PROVIDED PURSUANT TO AND FOR THE PURPOSES OF ART. 13 OF THE ITALIAN CODE ON THE PROTECTION OF PERSONAL DATA ADOPTED WITH LEGISLATIVE DECREE OF 30 JUNE 2003, No. 196
GHP SRL (hereinafter “the Company”), pursuant to and for the purposes of art. 13 of the Italian Code on the protection of personal data adopted with legislative decree no. 196 of 30 June 2003 (hereinafter “the Code”) on regulations for the safeguard of the personal data of all subjects, with regard to the personal data it intends to process, supplies users interested in using the email information service (hereinafter “the interested parties”) with the following information.
- Purposes and characteristics of personal data processing
Personal data collected will be processed and stored by the Company for the following purposes:
a. Purposes connected and instrumental to the sell of hotel accommodation and/or tourist services requested to the Company and the provision of all accessory and/or complementary services;
b. Purposes connected and instrumental to checking the quality of all services provided by the Company, including customer service;
c. Purposes connected and instrumental to commercial information and promotion with regard to the development of new services, available products and/or opportunities to benefit from special conditions, also through third party companies, owned or not owned by the Company’s Hotel Group, as well as to communicating to third party companies specializing in commercial information and promotion and to verifying the interested party’s degree of satisfaction with the services supplied by the Company. Processing connected to these purposes requires the consent of the interested parties, which, if denied will prevent them from receiving any information or advertising material and from participating in marketing activities or surveys on the degree of satisfaction with the services provided.
Modes of data processing
With regard to the purposes listed above, personal data processing by the company is carried out via manual, computer and telematic instruments, organized according to logics correlated to the declared purposes themselves, and in any case in such a way as to guarantee the safety and confidentiality of the processed data. The storage of personal data takes place via electronic and computer instruments and via specific paper archives.
- Categories of subjects to whom personal data may be communicated or who may have access to it as persons responsible for or in charge of processing
3.1. The personal data collected may, without the interested party’s specific consent, in fulfilment of the obligations provided for in legal or regulatory provisions or in European Union norms, be communicated to Subjects recognised by these norms.
3.2. The personal data collected may also be communicated to categories of subjects who carry out activities connected and instrumental to the supply of services listed on the site and to the execution of the Company’s activities, or who are acquainted to these subjects as persons commissioned by the Company to process personal data. These categories may consist of, for example and not exhaustively, subjects who carry out hosting services and subjects responsible for the storage of personal data from documents or other material supplied and originated by the site Users themselves.
3.3. The personal data may be communicated to third party Companies, specialised in promotion, marketing and service quality surveys, who have commercial agreements with the Company.
If the interested party denies consent to communicating personal data to the aforementioned subjects, in some cases it may be impossible for the Company to supply the commercial services requested.
3.4. Certain categories of subjects, being in charge of the data processing, may have access to the interested parties’ personal data in order to fulfil their tasks. In particular, the Company has commissioned, or may commission, its employees, consultants or partners, with the processing of personal
data. Subjects designated by the Company as responsible for the data processing may, with regard to carrying out their specific tasks, also have access to the personal data.
3.5. The personal data may also be communicated to companies controlled by and/or connected to, or belonging in any way to the same group as the Company.
3.6. The Company does not circulate the personal data it processes.
The interested parties may at any time request the Company to supply the precise identity, corporate name or denomination of the subjects the Company communicates their personal data to.
- Rights of the interested parties
Art. 7 of the Code confers to the interested parties specific rights, including the right to obtain from the Holder the confirmation of the existence or not of the personal data concerning them and having them made available in an intelligible form; to be informed on the origins of the data and on the logic and purposes the data processing is based on; to request the deletion, transformation into anonymous form or blockage of any data processed in violation of the law, as well as the updating, correction, or integration of the data; to oppose, for legitimate reasons, the processing of the data itself.
The rights referred to in this paragraph may be exercised with an informal request to the Holder or the subject responsible, also by a third party, and sent to the Company’s registered office by registered letter, fax or email. Concerning the exercise of rights under art. 7, paragraphs 1 and 2, of the Code, the request may also be transmitted orally.
For each request regarding the existence or not of personal data regarding them, interested parties may be asked, if the existence of the data is not confirmed, to pay a contribution towards costs, in any case not higher than the costs actually encountered, according to the conditions and within the limits established by the Privacy Authority.
- Holder and Party Responsible for the Data Processing
The Holder of the collected and processed personal data is GHP SRL, in the person of the pro tempore legal representative, with registered office and operational headquarters in Via Giordano Bruno 28 - 47921, Rimini, Telephone n. +39 0541 24215/6, Fax n. +39 0541 27842, e-mail firstname.lastname@example.org.
The regularly updated list containing the identification data of the party responsible for personal data processing is viewable at the Company’s operational headquarters.
Having read and understood the information provided by GHP SRL and having taken note of its content, I hereby declare that I am informed on:
- the purposes and modes of the personal data processing as specified above;
- the compulsory nature of the disclosure of the data, as stated in point 1. a);
- the subjects data may be communicated and circulated to, as subjects who may have access to the data insofar as they are involved in the processing itself as part of their functions;
- my rights according to art. 7 of the Code;
- the holder of the data and the parties responsible for its processing.
In consideration of the above, under art. 23 and art. 25 of the Code, I give my consent to the collection, processing and communication of my personal data in relation to and instrumental to the supply of Services and the carrying out of my requests. Under articles 23 and 25 of the Code, I give my consent to the collection, processing and communication of my personal data for the purposes of information and commercial promotion, as well as to the communication of the same data to companies specialised in commercial promotion and to companies controlled by and/or linked to the Holder of the processed data, aware that the manifestation of consent to the processing of the data for these ends is not compulsory, but that a denial of consent may prevent certain services from being performed, or, in any case, prevent them from being performed at an optimal level.