POLICY PRIVACY
San Lorenzo SPA with registered office in Corso Magenta, 65 - 20123 Milan (MI) (hereinafter, "San Lorenzo") as Data Controller, informs you, pursuant to art. 13 of EU Regulation 2016/679 (hereinafter, "GDPR"), which will process user data (hereinafter "User" and / or "Users") collected through the website www.atellaniapartments.com (of hereinafter, also the "Site") in the manner and for the following purposes.
1. Type of data processed by San Lorenzo through the Site.
San Lorenzo processes the following types of personal data (hereinafter, "Data") provided by Users of the Site when visiting the website and / or registering for the newsletter:
a. Data obtained during the navigation of a User on the Site. The computer systems, cookie technology and software procedures used for the operation of the Site www.atellaniapartments.com acquire, during their normal operation, some data whose transmission is implicit in the use of the Internet. The data collected for statistical purposes (Browser, resolution, etc.) are used by the Google statistics system: "Google Analitycs". This is information which by its very nature could, through processing and association with data held by third parties, allow browsing Users to be identified. This category of data includes, for example, the pages visited by the Users within the same, the domain names and the addresses of the websites from which the User has accessed (through referrals) to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server, and other parameters relating to the type of browser (eg Internet Explorer, Firefox), operating system (eg Macintosh, Windows) and the User's computer environment. These data are collected through functional cookies that do not have profiling purposes. For more information on navigation data, Users are invited to consult the Cookie Policy of the Site. These data are used only to obtain anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after the ‘processing.
b. Personal data provided by Users. Most of the pages and contents of the Site are accessible by the unregistered User (hereinafter "the Unregistered User") without the need for his identification for the purpose of consultation. Therefore, access and consultation of the Site does not require any registration, except in relation to the booking of rooms and in relation to the so-called "reserved areas". In this case, the User is registered and provides San Lorenzo with the following identification data: name, surname, country, e-mail, no. by phone, arrival at the facility credit card details. On this occasion, the User assumes the title of "Registered User". c. Personal data provided by Registered Users. The Registered User who makes an online reservation is issued a reservation code and a pin code that allow him to access the Reserved Area of the Site to check the status of his reservation.
2. Purpose of the treatment
a. The data provided by the Registered User and the Unregistered User will be processed without the prior consent of the User pursuant to art. 6 lett. b) GDPR, for the following Service purposes:
i. for the management and processing of statistical surveys on the use of the Site;
ii. to carry out the maintenance and technical assistance necessary to ensure the correct functioning of the Site and the services connected to it;
iii. to improve the quality and structure of the Site, as well as to create new services, functionality and / or features of the same;
iv. to process any contact request sent by the User by email, eg. to obtain clarifications on the services offered through the site;
v. acquire and confirm the booking of accommodation services and ancillary services, including particular needs and / or preferences of the User;
vi. to fulfill legal or regulatory obligations. Article 109 of the R.D. n. 773/1931 ("Consolidated Law on Public Security") provides that the accommodation facilities register and report to the Police Headquarters and the details of the customers accommodated in the manner established by the Ministry of the Interior and the provisions of Article 7, Legislative Decree n. 322/1989, National Statistical Program (PSN) and of the Lombardy Region for the provisions of Article 38 paragraph 8 of the Regional Law 27/2015;
vii. fulfill current administrative, accounting and tax obligations, including electronic invoicing;
viii. perform the function of receiving messages and telephone calls addressed to the User during his stay;
ix. allow San Lorenzo to exercise its rights in court and repress unlawful conduct.
b. The data provided by the Registered User will be processed, subject to consent pursuant to art. 6 lett. a) GDPR, for the following purposes:
allow the Registered User to send commercial communications by e-mail on products, initiatives and / or services offered by San Lorenzo and / or newsletters containing information on offers relating to temporary accommodation. It should be noted that if the Users have already registered on the atellaniapartments.com site by giving their consent, San Lorenzo may send commercial communications relating to services similar to those that the Customer Users have already used, in compliance with all the provisions of the law. and applicable guidelines, unless they disagree, which may be expressed at any time by clicking on the appropriate link at the bottom of the aforementioned commercial communications and / or newsletters.
3.Nature of the provision of data.
The provision of data by the User is mandatory for the purposes of the Service referred to in point 2.a of the previous paragraph.
The provision of data by the Registered User is optional and optional for the purposes referred to in point 2.b of the previous paragraph (and in any case the consent can be revoked without formalities even after the performance). Any refusal to provide such data may make it impossible to receive communications relating to the commercial offers of San Lorenzo.
4. Processing and Storage Methods.
a. The processing of User data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and in particular: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, access, use, interconnection, blocking, communication, cancellation and destruction of data.
b. Users' data are processed with automated and non-automated tools, only for the time strictly necessary to achieve the purposes for which they were collected and, in any case, no later than 10 years from their collection for the purposes of the Service referred to in par. 2.a, no later than 3 years from their collection for the commercial purposes referred to in point 2.b.
c. User data will be processed by persons authorized to carry out the tasks referred to in point 2.a, constantly identified, appropriately trained and made aware of the security obligations provided for by the GDPR as well as prepared by San Lorenzo.
5. Access to data
The data may be made accessible exclusively for the aforementioned purposes to the following subjects:
• employees and collaborators of San Lorenzo in their capacity as persons authorized for processing;
third-party companies or other persons appointed as Managers or autonomous Owners, by way of example, associations or professional firms that provide assistance and consultancy services and activities, with particular reference to (i) Nexteam s.r.l., with registered office in Via San Francesco d'Assisi, 33 - 66100 Chieti (CH) agency in charge of the development of the site and the booking platform, also responsible for data security and (ii) KosmoSol S.r.l. Strada delle Castelline, 42 / D - 43019 Soragna (Parma) 02300720345, a company that offers the PMS cloud management service Nexi Payments S.p.A., with registered office in Corso Sempione 55, 20149 Milan (MI), which provides its own platform to pay for the Service, to (iv) MadBit Entertainment S.r.l. a socio unico Via Gerolamo Zanchi 22 / C, 24126 - Bergamo (BG) which provides the electronic invoicing and electronic storage service of these tax documents.
6. Communication of data
Without the express consent of the User (pursuant to Article 6, letter b) and c) of the GDPR), San Lorenzo may communicate the User's data for the purposes of the Service referred to in art. 2.a and 2.b to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom communication is mandatory by law for the accomplishment of the aforementioned purposes, as independent data controllers. User data will not be disclosed.
7. Data transfer
The personal data provided by the registered User to allow the sending of commercial communications through automated services including e-mails on products, initiatives and / or services offered by San Lorenzo and / or newsletters containing commercial offers from the Atellani Apartments, are processed electronically through the use of the Mail Chimp provider; the related privacy information can be consulted on the website www. https://mailchimp.com/ legal/privacy. In this context, the data will be processed and stored within the European Union or in the United States. Mail Chimp offers a service compliant with the Privacy Shield.
8. Third Party Websites
It should be noted from now on that, should the Site contain links that refer to the websites of third parties, San Lorenzo cannot exercise any control over the content of such websites nor does it have any access to the personal data of the users who visit them.
The owners of the aforementioned websites will therefore remain the sole and exclusive owners and managers of the processing of the personal data of their users, remaining, San Lorenzo extraneous to this activity as well as to any liability, prejudice, cost, which may derive from its failure or incorrect execution.
We therefore recommend that you carefully read the related privacy policies and terms of use of these websites, before providing or consenting to the processing of your personal data.
9. Withdrawal of consent and opposition
If the User has given consent for a treatment aimed at pursuing the purposes mentioned in the previous par. 2.a and 2.b, you will in any case remain free to revoke it at any time, by sending a clear communication to this effect without any formalities to the e-mail: info@atellaniapartments.com. Following receipt of this opt-out request, San Lorenzo will promptly proceed with the removal and cancellation of the data and inform any third parties to whom the data have been communicated for the same cancellation purposes. The simple receipt of the cancellation request will automatically be valid as confirmation of cancellation. We inform you specifically and separately, as required by art. 21 of the GDPR that the User has the right to object at any time to the processing of personal data concerning him carried out for these purposes and that if the interested party objects to the processing for direct marketing purposes, the personal data can no longer be object of treatment for these purposes.
11. Existence of an automated decision-making process, including profiling
The Data Controller does not adopt any automated decision-making process, including profiling, referred to in Article 22, paragraphs 1 and 4, of the GDPR.
The complete and updated list of Managers and persons in charge of processing is kept at the San Lorenzo office and may be requested in the manner referred to in the previous par. 10.
13. Information updates
This Notice will be subject to periodic updates which will be highlighted on the Site.
14. Date of last modification
This information was updated on 22 April 2022.
DATA CONTROLLER
San Lorenzo SPA
Corso Magenta, 65 - 20123 Milan (MI)
VAT number: 03409680158
Tax code: 03409680158
REA: 835112
Share capital: € 2.097.349,00
Website:www.atellaniapartments.com
E-mail: info@atellaniapartments.com
PEC: sanlorenzo@legalmail.it
Telephone: +39 375 528 9922
