Hotel Savoy – S.I.S.A. srl protects the confidentiality of personal data and guarantees its necessary protection against any event that may put it at risk of violation. As provided for by European Union Regulation No. 679/2016 (hereinafter “GDPR”) and Article 13 in particular, please find below the information required by law relating to the processing of your personal data.
pursuant to Article 13 of (EU) Regulation No. 679/2016 (“GDPR”)
1 - Who we are and what data we process (Article 13, paragraph 1 (a), Article 15 (b) GDPR)
Hotel Savoy – S.I.S.A. srl, represented pro tempore with registered offices at Via Ludovisi, 15 Roma Italy, acts as the Data Controller and can be reached at email@example.com and collects and/or receives information relating to you, such as:
First name, last name, physical address, nationality, residential province and city, landline telephone number and/or cell number, fax, tax ID number, email address(es)
IBAN and banking/postal account information (except for Credit Card number)
Internet traffic data
Logs, originating IP address
Hotel Savoy – S.I.S.A. srl does not require you to supply so-called “private” data, that is, according to the provisions of the GDPR (Art. 9), personal data that identifies race or ethnicity, political opinions, religion or philosophy, or any union affiliation, nor any genetic or biometric information used to uniquely identify a physical person, data associated with health or one’s sex life, or sexual orientation. In the event the services requested from Hotel Savoy – S.I.S.A. srl require the processing of this data, you will first receive specific notification with a request for your consent.
2 - Why we need your data (Art. 13, paragraph 1 GDPR)
The data is used by the Data Controller to fulfil the registration request and for the supply contract on the preselected Service and/or Product purchase, to manage and execute the contact requests forwarded by you, offer assistance, fulfil legal and regulatory obligations demanded of the Data Controller in accordance with the activities performed. In no case will Hotel Savoy resell any of your personal information to third parties nor use it for any purpose not stated.
In particular, your data will be processed for:
a – registration and contact information, and/or informational materials
Your personal data is processed to implement preliminary actions and those following a registration request, to manage information and contact requests, and/or to send informational materials, the hotel service surveys (not obliged to compile), as well as to satisfy any and all other obligations arising herewith.
The legal basis for this processing is to provide the services relating to a request for registration, information and contact, and/or the sending of informational materials, and to comply with legal requirements.
b – administering the contractual relationship
Your personal data is processed to implement preliminary actions and those following the acquisition of a Service and/or a Product, handling of any complain and/or notifications to the support service and performance of the support itself, fraud prevention, as well as fulfilment of any and all other requirements arising from the contract.
The legal basis for this processing is to provide the services relating to the contractual relationship and to comply with legal requirements.
c – promotional activities on Services/Products that are similar to those you have got (Clause 47 GDPR)
The Data Controller, even without your explicit consent, may use the contact information you provided for direct sales of its own Services/Products, limited to those Services/Products that are similar to the ones included in the sale, unless you specifically refuse (firstname.lastname@example.org).
d –business promotional activities on Services/Products that are different from the ones you purchased
Your personal data may also be processed for business promotional purposes, for market research studies involving the Services/Products that the Data Controller offers, but only if you have authorized this processing and have not opposed it.
This processing may occur by the following automated methods:
– telephone contact
and may occur:
a) if you have not withdrawn your consent for the use of your data;
b) if processing is done through contact with a telephone operator, and you are not registered on the not to call registry as outlined in Presidential Decree No. 178/2010;
The legal basis for this processing is the consent you initially granted for the processing itself, which you may freely withdraw at any time.
e – digital security
The Data Controller, in line with the provisions of Clause 49 of the GDPR and through its providers (third parties and/or recipients), processes your personal data involving traffic only to the extent strictly necessary and proportional to guarantee security of the networks and the information. This means the capacity of a network or information system to block, at a given level of security, any unforeseen events or illegal or malicious acts that would compromise the availability, authenticity, integrity and confidentiality of the personal data stored or transmitted. The Data Controller will immediately notify you if there is any risk of violation of your data, except for any obligations noted in the provisions of Art. 33 GDPR associated with notifications of personal data violations.
The legal basis for this processing is to comply with legal requirements and the legitimate interests of the Data Controller in undertaking processing for the purpose of protecting corporate assets and the security of the Hotel Savoy’s offices and systems.
f – profiling
Your personal data may also be processed for profiling purposes (such as analysing the transmitted data and the pre-selected Services/Products, suggesting advertising messages and/or business offers in line with user selections) exclusively when you have given explicit and informed consent.
The legal basis for this processing is the consent you initially granted for the processing itself, which you may freely withdraw at any time.
g – fraud prevention (Clause 47 and Art. 22 GDPR)
Your personal data, except for private data (Art. 9 GDPR) or legal information (Art. 10 GDPR) will be processed to allow controls for monitoring purposes and prevention of fraudulent payments. This processing will be done by software systems that run automated checks and will be carried out prior to negotiating Services/Products;
a negative result on these checks will render the transaction impossible; you can, in any case, express your opinion, obtain an explanation or dispute the decision by outlining your reasons to the Customer Support Department or to the contact email@example.com;
personal data collected only for anti-fraud purposes, which differs from the data needed for the proper performance of the service requested, shall be immediately deleted upon termination of the verification phase.
h – protection of minors
The Services/Products offered by the Controller are reserved for those entities legally able, based on national regulations, to satisfy contractual obligations. The Controller, to prevent illegal access to its own services, implements preventive measures to protect its own interests, such as checking tax identification numbers or, when necessary for specific Services/Products, the accuracy of the identification data on the identification documents issued by the applicable authorities.
3 - Communication to third parties and categories of recipients (Article 13, paragraph 1 GDPR)
Your personal data is communicated mainly to third parties and/or recipients whose activity is necessary to perform the activities relating to the contract established, and to meet certain legal requirements, such as:
Fulfilment of administrative and accounting requirements as well as those connected with the contractual services
Third party providers
Performance of services (assistance, maintenance, delivery/shipping of products, performance of additional services, providers of networks and electronic communication services) associated with the requested service
External professionals/consultants and consulting firms
Fulfilment of legal requirements, exercising rights, protecting contractual rights, credit recovery
Financial Administration, Public Agencies, Legal Authorities, Supervisory and Oversight Authorities
Fulfilment of legal requirements, protection of rights; lists and registries held by Public Authorities or similar agencies based on specific regulations relating to the contractual service
Formally mandated subjects or those with recognized legal rights
Legal representatives, administrators, guardians, etc.
* The Controller requires its own third-party providers and Data Processors to adhere to security measures that are equal to those adopted for you by restricting the Data Processor’s scope of action to processing directly related to the requested service.
The Controller will not transfer your personal data to countries where the GDPR is not applicable (countries outside the EU) except where specifically indicated otherwise, in which case you will be notified first, and if necessary asked for your consent.
The legal basis for this processing is fulfilment of the services outlined in the established contract, compliance with legal obligations, and the legitimate interests of Hotel Savoy – S.I.S.A. srl. to perform the processing necessary for these purposes.
4 - What happens when you do not provide your identification information as needed to perform the requested service? (Article 13, paragraph 2 (e) GDPR)
The collection and processing of your personal data is necessary to fulfil the wi-fi service requests as well as to perform the Service. Should you fail to provide your personal data as expressly required within the order form or the registration form, the Data Controller will not be able to carry out the processing associated with managing the requested services and/or the contract and the Services/Products associated with them, nor fulfil the operations dependent on them.
5 - What happens when you do not provide the consent for processing personal data for the business promotion activities on Services/Products that are different from those purchased?
When you do not give your consent to the processing of your personal data for these purposes, the processing will not be implemented for these specific purposes, but it will not affect the performance of the requested services or those for which you have already given your consent, if requested. In the event you have given consent and later withdraw it or oppose the processing for business promotional activities, your data will no longer be processed for these activities, although this will not create negative effects or consequences for you or the services requested.
6 - How we process your data (Article 32, GDPR)
The Controller makes use of appropriate security measures to preserve the confidentiality, integrity and availability of your personal data, and requires the same security measures from third party providers and the Processors
7 - How long is your data stored? (Article 13, paragraph 2 (a) GDPR)
Unless you explicitly express your own desire to remove it, your personal data will be stored until required for the due purposes for which it was collected. In particular, the data will be stored for the entire duration of your registration and in any case for no longer than a maximum period of 12 (twelve) months of inactivity, that is, within this time period, there have been no Services and/or Products purchased using this registration.
For data provided to the Controller for the purposes of business promotion for services other than those you have already purchased, for which you initially gave consent, it will be stored for 24 months, except when such consent is withdrawn (firstname.lastname@example.org).
For data provided to the Controller for the purposes of profiling, it will be stored for 12 months, again except when consent has been withdrawn. It is also important to add that, should the user forward to Hotel Savoy – S.I.S.A. srl personal data that has not been requested or that is unnecessary for the purposes of performing the services requested, or for the performance of services strictly connected thereto, Hotel Savoy – S.I.S.A. srl cannot be considered controller of this data and will proceed to delete it as soon as possible.
For data provided from our SMP loyalty program, prenoting on www.savoy.it you will automatically be part of SMP, it will be stored for 60 months from the last purchased service, except when such consent is withdrawn (email@example.com).
Regardless of your determination to remove the data, your personal information will be, in any case, stored according to the terms outlined in current law and/or national regulations, for the exclusive purpose of guaranteeing specific requirements, applicable to certain Services (for example, but not limited to, WI-FI Service). Furthermore, personal data will in any case be stored to comply with obligations (e.g. tax and accounting purposes) which may continue even after termination of the contract (Art. 2220 Civil Code); for these purposes, the Controller shall retain only the data necessary to complete these activities. For those cases where the rights arising from the contract and/or registration are used in the courts, your personal data, exclusively required for these purposes, shall be processed for the time necessary to complete them.
8 - What are your rights? (Articles 15 – 20 GDPR)
You have the right to obtain the following from the Data Controller:
confirmation on whether your personal data is being processed and if so, to obtain access to your personal data and the following information:
- the purposes of the processing;
- the categories of personal data in question;
- the recipients or categories of recipients that have received or will receive your personal data, in particular if these recipients are in third party countries or are international organizations;
- when possible, the anticipated storage period of your personal data or, if not possible, the criteria used to determine this period;
- whether you have the right to ask the Data Controller to correct or delete your personal data or the limits on processing your personal data or to oppose the processing of the data;
- the right to lodge a complaint with a supervisory authority;
- in the event the data is not collected from you, all of the information available regarding its origin;
- whether there is an automated decision process, including profiling, and, at least in these cases, significant information on the logic used, as well as the importance and consequences to you for this processing.
- the suitable guarantees provided by the third-party country (outside EU) or international organization to protect any transferred data;
the right to obtain a copy of the personal data processed, again given that this right does not affect the rights and freedoms of others; for extra copies requested by you, the Data Controller may assign a reasonable fee based on administrative costs.
the right to edit any of your incorrect personal data from the Data Controller without unjustified delay d)the right to have your personal data deleted by the Data Controller without unjustified delay, if there are the reasons outlined in the GDPR, Article 17, including, for example, if the data is no longer needed for processing or if the data is considered illegal, and again, if there are no conditions outlined by law; and in any case, if the processing is not justified by another equally legitimate reason;
the right to obtain limits on the processing from the Data Controller, in those cases outlined in Art. 18 of the GDPR, for example where you have disputed the correctness, for the period necessary for the Data Controller to verify the data’s accuracy. You must be notified, within an appropriate time, even when the suspension period has passed or the cause of limiting the processing has been eliminated, and therefore the limitation itself has been withdrawn;
the right to obtain information from the Data Controller on the recipients who have received the requests for any corrections or deletions or limits on the processing implemented, except when this is impossible or would create a disproportionate effort.
the right to receive your personal data in a structured format, commonly used and readable by automatic devices as well as the right to forward this data to another Data Controller without obstruction from the original Data Controller, in those cases outlined by Art. 20 of the GDPR, and the right to obtain direct forwarding of your personal data from one Data Controller to another, if technically feasible. For further information and to send your request, contact the Data Controller at firstname.lastname@example.org. To guarantee that the rights noted above are exercised by you and not by unauthorized third parties, the Data Controller may require you to provide other information necessary for this purpose.
For further information and to send your request, contact the Data Controller at email@example.com. To guarantee that the rights noted above are exercised by you and not by unauthorized third parties, the Data Controller may require you to provide other information necessary for this purpose.
9 - How and when can you oppose the processing of your personal data? (Art. 21 GDPR)
For reasons associated with your particular situation, you may at any time oppose the processing of your own personal data if it is based on legitimate reasons or if it is done for business promotional activities, by sending a request to the Data Controller at firstname.lastname@example.org. You have the right to have your own personal data deleted if the Data Controller has no legitimate reason prevailing over such request, and in any case, where you have opposed the processing for business promotional activities.
Who can you lodge a complaint with? (Art. 15 GDPR)
Without prejudice to any other ongoing administrative or judicial action, you may lodge a complaint with the applicable supervisory authority of the Italian territory (Italian Personal Data Protection Authority), that is, with the agency that performs its duties and exercises its rights within the member country where the GDPR violation occurred.
The Data Controller has nominated a Data Protection Officer (DPO) who can be contacted for any information or requests at email@example.com