Policy Privacy
​ With this information notice, the *** (P.IVA ***), in the person of the legal representative Andoni Gil Ortis (CF ***), with registered office in Via Traiana 7, Civitavecchia, Rome (00053) (hereinafter, also the “Owner” or the “Company”) (whose references are indicated in the “Contact” section on the site), intends to describe to you the methods of management of the website www.lifestyleandsuites. it (hereinafter, the “Site”) with reference to the processing of personal data or other data that may belong to special categories, pursuant to Article 9 of the GDPR (hereinafter, the “Data”) of the users who consult it, in accordance with Article 13 of Legislative Decree 30.6.2003 No. 196 (hereinafter, the “Privacy Code”) and Articles 13 and 14 of EU Regulation No. 2016/679.
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1. OWNER AND OBJECT OF THE TREATMENT
This is an information notice provided in accordance with current national and international laws to those who navigate on the Site, regardless of the mode and tool used.
Following authorization for processing, the Owner will process the Data transmitted in accordance with the provisions of the Regulations and current national legislation, including any measures of the Supervisory Authority (i.e. Guarantor for the Protection of Personal Data) where applicable.
The Controller is committed to protecting the privacy of all users of the Site and invites all users to read the Privacy Policy outlined below.
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2. METHODS AND PURPOSES IN PROCESSING AND USE
2.1. The purposes of Data processing are made known to the data subjects from the moment of collection.
The processing will be carried out by the Data Controller in the performance of its commercial and economic activity.
2.2. Any new and different processing of Data will be activated only after the notification of a new information to users and data subjects to obtain their specific consent, where required.
2.3. In any case, Personal Data are not communicated to third parties or disseminated without the prior consent of the interested party, except in the cases expressly indicated by art. 24 of Legislative Decree n.196/03.
The Privacy protocols and standards used by the Company for the protection of personal data, are based on the following principles:
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2.3.1. RESPONSIBILITIES IN PROCESSING AND USE
The Processing of Data is managed over time by managers identified within the corporate organization.
2.3.2. TRANSPARENCY IN PROCESSING AND USE
The Data are collected and processed in accordance with the principles expressed in the Privacy Policy adopted by the Data Controller, set out in this disclosure. At the time of the eventual conferment of data, the interested party is provided with a brief but complete information notice, in accordance with the provisions of current privacy legislation (formerly art. 13 of Legislative Decree no. 196/03).
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2.3.3. RELEVANCE IN COLLECTION
Data are collected and processed lawfully and fairly. They are recorded only for specified, explicit and legitimate purposes, are relevant and do not exceed the purposes of processing.
2.3.4. PRINCIPLE OF VERIFIABILITY
The Data collected are updated, organized and stored in such a way that all interested parties are given the opportunity to know what Data have been collected and recorded, to check their quality and request any correction, integration, deletion for violation of the law, or to exercise all the rights referred to in Article 8 of this policy, through the methods provided for in Article 10 of this policy.
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2.3.5. SECURITY PRINCIPLE AND MEASURES TAKEN
2.3.5.1. The Data collected and processed are protected by technologies suitable to protect the Data against any unlawful disclosure or alteration and by technical and computer security measures that are intended to minimize the risks of destruction, loss (including accidental), or access by unauthorized parties.
2.3.5.2. These measures are periodically checked and updated according to technical progress, the nature of the data and the specific characteristics of the processing.
2.3.5.3. Third parties that perform support activities of any kind for the provision of services by the Company, in relation to which they perform personal data processing operations, are designated as Data Processors and are required to comply with the security and confidentiality measures of the processing.
2.3.5.4. The identity of third parties shall be disclosed and made known to users and data subjects.
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3. TYPE OF DATA AND MANNER OF PROCESSING
3.1. While browsing the Site, professional and personal interests of users may be detected. This information, however, is collected for the sole and exclusive purpose of providing the services requested and possibly to control the quality of those offered. In general, the data may be:
(a) Data voluntarily provided by users: The Data collected and processed on the Site are necessary for the provision of the services provided by the same. Consequently, in case of failure to provide the same, the services requiring their use cannot be provided.
Without the express consent of the interested parties to the use of e-mail, landline or cell phone for purposes of advertising information, direct sales or interactive commercial communication, these tools will not be used for such purposes.
Specific disclosures will be made in the sections of the Site that may be prepared for the provision of Data.
In case of voluntary sending by the interested parties of e-mails to the addresses of the Owner and indicated in the Site, the same will acquire the sender's address and any other information that may be contained in the message. This Data will be used for the sole purpose of performing the services or services requested.
b) Navigation Data: The Site's automated procedures acquire certain Data, the transmission of which is implicit in the use of Internet communication protocols.
Although this information is not intended to be associated with identified users, by its nature, if associated with other data held by third parties (e.g. internet service providers), it could allow the identification of users (e.g. IP addresses, domain names of the PCs used by users connecting to the Site, URL addresses of the requested resources, time of the request, numeric code relating to the status of the response given by the server).
This Data is used for anonymous statistical purposes only about the use of the Site and its proper functioning.
The Owner or the designated managers keep the trace of the connections made for a limited period according to the law, in order to respond to any request from the judicial authority legitimately entitled to request it to ascertain responsibility in case of computer crimes.
(c) Data entered in forms on the Site: in addition to what is specified in point b) of this article, users may freely give or not give their Data through registration forms for services.
On the forms some Data may be indicated as mandatory. In that case, those Data must be understood as necessary for the provision of the requested services. On the contrary, in case of non-provision, those services cannot be provided.
At the time of each conferment of data, the interested parties will be provided with a summary information regarding the purposes and methods of processing, the mandatory or optional nature of the conferment, the consequences of failure to confer, the subjects or categories to which the Data may be communicated, etc. Users will, therefore, be able to express their consent in an informed, free and express form.
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4. COOKIE POLICY.
4.1. The Site makes use of cookies. Cookies are portions of code (small files) installed within a browser that enable the efficient operation of the Site, improving its performance by providing personal information to the Owner for various purposes (eg. statistical, advertising).
Cookies are important to personalize each user's browsing experience and by storing their preferences (e.g. language, currency) make subsequent accesses faster.
Some of the purposes of installing temporary markers may, however, require users' consent. By way of information, the main categories of cookies are:
(a) technical and aggregate statistics cookies
Technical cookies have the function of allowing the performance of activities strictly related to the operation of a web space. The technical cookies used by the Owner can be divided into the following subcategories:
i. navigation cookies, which allow to save users' browsing preferences and optimize the browsing experience;
ii. analytics cookies, which acquire statistical information regarding users' browsing patterns. This information is processed in aggregate and anonymous form;
iii. functionality cookies - including third-party cookies, which activate specific features of the Site and are necessary for the provision of services.
Such cookies do not require users' prior consent for their installation and use.
Other types of cookies or third-party tools that may make use of them
Some of the services listed below may not require users' consent and may be managed directly by the Owner, without the need for third parties. Should services operated by third parties be among these tools, they could possibly perform user tracking activities, even without the knowledge of the Owner.
Facebook Remarketing
Data collected: Cookies and Usage data;
Facebook Conversion Monitoring
data collected: Cookies and Usage Data;
Google Analitycs
data collected: Cookies and Usage Data;
Google Fonts
data collected: Usage Data and those specified by the service's privacy policy;
Google Maps
data collected: Cookies and Usage Data;
Youtube
data collected: Cookies and Usage Data.
Controlling the installation of cookies
In addition to what is stated in this policy, data subjects can manage any preference regarding cookies through their browser, preventing, for example, installation by third parties.
By disabling all cookies, the operation of the Site may be impaired.
You can find information on how to manage cookies in your browser in the appropriate privacy policy sections of Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer.
You can disable cookies through the configurations of your respective browsers:
Chrome: https://support.google.com/chrome/answer/95647?hl=it;
Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie;
Internet Explorer: http://windows.microsoft.com/it-it/windows7/how-to-manage-cookies-in-internet-explorer-9;
Opera: http://help.opera.com/Windows/10.00/it/cookies.html;
Safari: http://support.apple.com/kb/HT1677?viewlocale=it_IT.
The Owner informs that the User can make use of Your Online Choices, through which it is possible to manage the tracking preferences of most advertising tools.
The Owner strongly advises interested parties and users of the Site to use this resource in addition to the information provided in this policy.
For any other technical information related to cookies, in addition to the information provided in this policy, please refer to:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/2142939.
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5. DATA STORAGE METHODS
The Data will be retained in compliance with the GDPR or the applicable legislation for their protection, for as long as necessary to fulfill the purposes set forth in this notice.
in the case of a contractual relationship, only Personal Data functional for the fulfillment of civil and tax obligations will be kept for the duration of the contractual relationship.
10 years for specific civil obligations such as the retention of invoices or relevant business documentation.
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6. ACCESS TO DATA
6.1. The Data processed by the Data Controller may be accessible to employees and collaborators of the Data Controller in their capacity as persons in charge and/or internal data processors and/or information systems managers. Access to the data by these individuals will take place only if the processing is necessary for the performance of their duties by performing only those operations necessary for the performance of such duties.
6.2. the Data Controller provides for the protection of user information against unauthorized access, unlawful processing, accidental loss, destruction, and damage, and retains such information for the period of time strictly necessary to pursue the purposes for which the data were collected.
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7. COMMUNICATION OF DATA
7.1. Without the need for express consent (ex art. 24 lett. a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate the Data upon notification of the Supervisory Bodies (such as IVASS) or of the Judicial Authorities, as well as to those subjects to whom the communication is compulsory by law in order to comply with legal obligations, or to assert or defend a right in court. These subjects will process the data in their capacity as autonomous data controllers. The Data will not be disseminated, unless the requested service requires it.
7.2. If necessary, in relation to particular services or products requested, the Data may also be communicated to third parties who perform, in their capacity as autonomous data controllers, functions closely related and instrumental to the provision of services, since without such communication, these services and products could not be provided.
7.3. Outside of the above, the Data Controller does not transfer personal data to countries outside the EU or to international organizations.
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8. TRANSFER OF DATA
8.1. Personal data are stored on the company's internal server located at the operational headquarters in Piazza della Repubblica 14/E - Turin, within the European Union.
8.2. It is in any case understood that the Data Controller, should it become necessary, will have the right to move the servers also outside the EU. In this case, the Controller assures as of now that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.
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9. RIGHTS OF THE INTERESTED PARTIES
9.1. The data subject has the rights under Art. 7 Privacy Code and Art. 15 GDPR, namely to obtain:
i. confirmation about the existence or not of personal data concerning him/her, even if not yet registered, and their communication in intelligible form;
ii. an indication of:
(a) the origin of the personal data;
b) of the purposes and methods of processing;
c) the logic applied in case of processing carried out with the aid of electronic instruments;
d) of the identification details of the data controller, data processors and the designated representative pursuant to Art. 5, paragraph 2 Privacy Code and Art. 3, paragraph 1, GDPR;
e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, managers or appointees;
iii.
a) the updating, rectification or, when interested, the integration of data;
b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
to oppose:
iv. in whole or in part:
a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator by e-mail and/or through traditional marketing methods by telephone and/or paper mail. It should be noted that the data subject's right to object, set forth in point b) above for direct marketing purposes through automated modalities extends to traditional ones and that, in any case, the possibility for the data subject to exercise the right to object even partially remains unaffected. Therefore, the data subject may decide to receive only communications by traditional means or only automated communications or neither type of communication.
Ove applicabili, ha altresì i diritti di cui agli artt. 15-21 GDPR (Diritto di rettifica, diritto all’oblio, diritto di limitazione di trattamento, diritto alla portabilità dei dati, diritto di opposizione), nonché il diritto di reclamo all’Autorità Garante.
9.2. Ove consentito dalla legge, l’utente potrà avere il diritto di ottenere una copia dei Dati in nostro possesso.
9.3. Prima di rispondere ad ogni specifica richiesta, potrebbero essere richieste all’Utente informazioni opzionali, quali:
(i) verification of identity;
(ii) additional details necessary to best respond to the request.
9.4. Holder will provide individual responses within an appropriate time period and, in any event, within the time period required by law. If you wish to exercise this right, you should contact us through the contact details provided in Articles 11 and 13 of the Policy.
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10. METHODS OF EXERCISING RIGHTS
Users and data subjects may at any time exercise their rights under EU Regulation 2016/679 by sending:
a registered letter with return receipt to Via Traiana 7, Civitavecchia, Rome (00053)
a communication by e-mail to the e-mail address: privacy@lifestyleandsuites.it
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11. OWNER, MANAGER AND APPOINTEES
The data controller is the Data Controller, indicated in the epigraph in this information notice.
The updated list of data processors and persons in charge of the processing is kept at the registered office of the Data Controller and can be known through a special request made in the manner indicated above.
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12. CONTACTS
Processing related to the web services of the above website takes place at the registered office of the Owner, located at Via Traiana 7, Civitavecchia, Rome (00053).
Any comments, questions or requests regarding the Holder's use of the User's information should be forwarded to the e-mail address: privacy@lifestyleandsuites.it
Pursuant to art.11 of this privacy policy, the Data may be processed by persons appointed as data processors both internally and externally, as well as by data processors in charge of the management of the requested service and will be communicated or disseminated to third parties within the limits and for the purposes provided for in the policy.
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13. FUTURE CHANGES TO THE PRIVACY POLICY
The possible entry into force of new industry regulations, as well as the constant review and updating of services to users, may result in the need to vary these arrangements. It is therefore possible that the privacy policy will undergo further changes over time and we therefore invite Data Subjects to periodically consult the online privacy policy section of the Site.
To this end, the policy presents at the bottom the date it was updated.
Policy updated as of April 10, 2018.