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Newsletter Policy

INFORMATION

ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679

Interested subjects: Navigators, users of the services and subscribers to the newsletter

“HOTEL BELVEDERE S.A.S. DI PASQUINI MARINA & C. “, in the capacity of Data Controller of your personal data, pursuant to and for the purposes of Regulation (EU) 2016/679 hereinafter referred to as ‘GDPR’, hereby informs you that the aforementioned legislation provides for the protection of data subjects with respect to the processing of personal data and that such processing will be based on principles of correctness, lawfulness, transparency and protection of your privacy and your rights.

To achieve its purposes, relating to the management of the relationship, the Data Controller needs to acquire personal data, such as, by way of example, your name and surname, telephone or mobile number, email address, tax code.

Your personal data will be processed in accordance with the legislative provisions of the aforementioned legislation and the confidentiality obligations provided for therein.

Purpose of processing: Service delivery: Your data will be processed to respond to any requests that can be received from the forms for filling in, and forms available on the website, or from requests received by email.

Legal basis: The legal basis of the processing is of a contractual nature in the terms in which data processing is envisaged in the face of a request for information which is followed by a reply.

Optional purposes:

Marketing – newsletter reception service: in particular, your data will be processed, subject to your free consent, for the receiving  of newsletters, by entering your email address in the appropriate text box containing the relevant information to subscribe to the newsletter, or by selecting / ticking the appropriate box indicating “newsletter subscription” present in a form.

Legal basis: The legal basis of the processing is the consent of the interested party.

Consequences of refusal to the optional purposes: The provision of data is optional for you with regard to the aforementioned purposes, and your refusal to process does not compromise the continuation of the relationship or the adequacy of the treatment itself.

Consequences of failure to communicate: the processing of functional data for the fulfillment of these obligations is necessary for a correct management of the relationship and their conferment is mandatory to implement the purposes indicated above.

The Data Controller also announces that any non-communication, or incorrect communication, of any mandatory information, may cause the Data Controller to be unable to guarantee the adequacy of the processing itself.

Processing methods: The processing is carried out with manual and / or IT and telematic tools, in order to ensure the security, integrity and confidentiality of data in compliance with the physical and logical organizational measures provided by the provisions in force, in order to minimize the risks of destruction or loss, unauthorized access, modification and unauthorized disclosure in compliance with the procedures set out in Articles 6, 32 of the GDPR.

 

Recipients: To carry out certain activities, or to provide support to the operation and organization of the activity, some data may be brought to the attention or communicated to recipients. These subjects are divided into:

Third parties: (communication to: natural or legal persons, public authorities, service or other body that is not the data subject, the data controller, the data processor and the authorized persons responsible for the processing) including:

  • Companies that manage traditional or computerized postal services
  • Any other subjects whose data communication is necessary to achieve the above purposes indicated.

 

Data processors: (the natural or legal person, public authority, service or other body that processes data personal data on behalf of the data controller)

∙ Providers of IT, web, or other services necessary to achieve the purposes necessary for the relationship management.

Within the company structure, your data will be processed only by personnel expressly authorized by the Owner, with assurance of adoption of a confidentiality agreement and, in particular, by the following categories of employees:

  • Administration;
  • Other employees whose treatment is necessary for the correct execution of the relationship;

Dissemination: Your personal data will not be disclosed in any way.

Transfer of data to third countries: The owner does not transfer personal data to countries outside the EU. If there is, the interested parties will be informed in advance, and guarantee measures will be adopted for the transfer towards the recipients, which, depending on the cases, may be: verification of the existence of adequacy decisions for the recipient country by the Commission, signing of standard contractual clauses, verification of adoption of any additional measures in transposition of the 01/2020 EDPB recommendation. Notwithstanding these guarantees, for data processing (in reference to art. 49 of the GDPR), where applicable, the verification of the existence of a contract or measures pre-contractual in favor of the interested party or the consent to the transfer.

Retention period: We inform you that, in compliance with the principles of lawfulness, purpose limitation, data minimization, pursuant to art. 5 of the GDPR, the retention period of your personal data is established for a a period of time not exceeding the achievement of the purposes for which they are collected and processed, if any signed a contract, this retention period may cease with the forfeiture or withdrawal of the contract, the same data may be kept, where applicable, for a further period of time for the purpose of managing any disputes, the legal basis for this storage is the legitimate interest of the data controller. The retention period for data processing relating to marketing is functional to the purposes pursued by the data controller, and in any case not more than 3 years from the last contact, or feedback received.

Data Controller:  the Data Controller, pursuant to legislation, is “HOTEL BELVEDERE S.A.S. DI PASQUINI MARINA & C. “, with legal and operational headquarters in V.le Gramsci 95 – 47838 Riccione (RN), VAT number: 01603580406 in the person of its pro tempore legal representative.

By sending an e-mail to the following address info@belvederericcione.com or a fax to 0541 691394 you can request more information regarding the data provided.

EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22, 23 – Rights of the interested party

  1. The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet recorded, and their communication in an intelligible form.
  2. The interested party has the right to obtain the indication:
  3. of the origin of the personal data;
  4. of the purposes and methods of the processing;
  5. of the logic applied in case of treatment carried out with the aid of electronic instruments;
  6. of the identity of the owner, manager and the representative appointed under article 5, paragraph 2;
  7. of the subjects or categories of subjects to whom the personal data may be communicated or who can become aware of them as designated representative in the State, managers or agents.
  8. The interested party has the right to obtain:
  9. updating, rectification or, when interested, integration of data;
  10. the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently treated;
  11. the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment proves impossible or involves a manifestly disproportionate use of means compared to protected right;
  12. data portability.

 

  1. The interested party has the right to object, in whole or in part:
  2. for legitimate reasons to the processing of personal data concerning him, even if pertinent to the purpose of the collection;
  3. to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

Complaint: The interested parties, having met the conditions, also have the right to lodge a complaint with the Guarantor as authority control according to the established procedures. For any further information, and to assert the rights recognized to you from the European Regulation, you can contact the data controller at the above references.

Consent

Formula for acquiring the consent of the interested party

Your consent to receive the newsletter will be recorded (IP address, email, date and time) by ticking the box underlying the insertion of the email, or following the affixing / clicking in the appropriate box, and together with pressing the “enter” / “ok” button. This consent will be filed to prove the conferment, and allow you to unsubscribe at any time, in addition to all the other rights set out above.