INFORMATION TO DATA SUBJECTS REGARDING THIS WEBSITE
This page contains a description of the policies for managing the website in regard to processing the personal data of the users who visit the site and their privacy. This information is provided pursuant to article 13 of Italian and European Privacy Code, Legislative Decree no. 196/2003 and GDPR 679/2016 – Laws concerning the Protection of Personal Data and the individuals who interact with the web services of Hotel Borgo San Felice, which is accessible by telematics means through the following web address:
which corresponds to the home page of the official website of Hotel Borgo San Felice, Loc. San Felice, 53019 Castelnuovo Berardenga (SI).
This informative note is provided only for the aforementioned website and not for other websites eventually accessed by the user through links.
This informative note is also in conformance with Recommendation no. 2/2001 that the European Authorities for protection of personal data, united with the Group instituted by article 29 of European Directive no. 95/46/CE, adopted on May 17, 2001 in order to identify a few minimum requisites for processing the on-line collection of personal data, and in particular, the manners, times and nature of the information that the data controller must provide the user when they access the web page, regardless of the purpose of the access.
THE “DATA CONTROLLER”
Following access to this website, data pertaining to persons that are identified or identifiable may be processed. The “Data Controller” of the personal data collected following a visit to our website or any other data used for providing our services is Borgo San Felice Srl, Mr. Danilo Guerrini, Loc. San Felice, 53019 Castelnuovo Berardenga (SI). The General Data Processor Coordinator for data processing is Mr. Massimo Bruno, who can be contacted at firstname.lastname@example.org
PLACE WHERE DATA IS PROCESSED
The processing operations related to the web-based services that are made available via this website [physically "hosted" by Blastness S.R.L., Galleria del Corso,2 - 20122 - Milano (www.blastness.com)]
are carried out at the aforementioned office of the Data Processing Office exclusively by technical staff in charge of said processing, or else by persons tasked with such maintenance activities as may be necessary from time to time.
The personal data obtained from the users who submit hotel reservation requests or through informative material (informative notes, newsletters, registration, etc) is used only to carry out the services or assistance requested and is not transmitted to third parties, except in the following possible cases:
• Business partners of Borgo San Felice Srl, to whom Borgo San Felice transmits the data exclusively in order to avoid on-line reservations, among which Blastness S.R.L. and Relais & Châteaux;
• Persons, companies or professional offices who lend assistance and consulting services to Hotel Borgo San Felice concerning accounting, administrative, legal, financial and tax matters;
• Subjects who are authorized to have access to the data by law or through requests by the authorities;
CATEGORIES OF PROCESSED DATA
The information systems and software procedures relied upon to operate this web site acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties.
This data category includes IP addresses and/or the domain names of the computers used by any user connecting with this web site, the URI (Uniform Resource Identifier
) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment.
These data are only used to extract anonymous statistical information on website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the website; except for this circumstance, any data on web contacts is currently retained for no longer than seven days.
Data voluntarily provided by the user
Sending e-mail messages to the addresses mentioned on this website, which is done on the basis of a freely chosen, explicit, and voluntary option, entails acquisition of the sender's address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s). Data will be retained only for enrollment request for any marketing or specific to send the newsletters or special offers and will not be disclosed to anyone. Data will be stored only for any markings on specific requests or to send you newsletters or special offers and will not be disclosed to anyone.
The personal information regarding the individual who visited the website is not collected or used. The visitors remain anonymous. The only exception to this rule concerns the information for personal identification needed to fulfill the contractual obligations of reservations on behalf of the user.
In the event of reservations made through the website, the user must provide his name, address, telephone number and information regarding the payment manners and credit card used. Borgo San Felice Srl will use said information only to process the reservations and to send specific information, which is relevant to the confirmation of said, such as a receipt, the reservation code and the conditions.
The information provided will not be used for marketing purposes and will not be sold, transmitted, given by contract or sent to third parties an any way, with the exception of our provider of on-line reservation services, Blastness S.R.L., Galleria del Corso,2 - 20122 - Milano (www.blastness.com
) and Relais & Châteaux Entreprise, 58-60, Rue de Prony - 75017 Paris – France (www.relaischateaux.com
), to whom elaboration of the reservations is entrusted to, only for online reservations purposes.
In any event, the administrator of the website guarantees the use of scrupulous procedures in order to protect the navigational data and the use of particular precautions to protect the data pertaining to the credit card, which is provided during on-line reservations.
Personal Data Processing Collected From Curriculum Vitae
The Borgo San Felice Srl accept Personal Curriculum Vitae of possible candidates via e-mail in PDF format. Providing spontaneous and voluntary of the Curriculum Vitae data will be considered as implicitly informed consent by the data subjects for personal data processing contained, only following the purposes related to the selection of potential candidates.
The data processed for the purpose of selection of candidates are personal useful to search for the particular profile. In general, the nature of the data is normal, except in some cases where you may indicate any sensitive data necessary to identify the specific requirements of the regulations, such as specifying a particular protected classes, the suitability for certain jobs and / or start-ups required. These particular data will be processed with explicit consent of the data subject to the processing of such personal data for one or more specific purposes;
The provision of data relating to the selection of candidates is required. Any refusal to provide such data makes it impossible to perform an orderly selection and the possible recruitment. The data in question will not be disclosed to anyone.
General Rules for providing the CV
Any CV received spontaneously, replying to a job advertisement, will be stored directly by person in charge of the processing in accordance with the safety guidelines of personal data adopted in compliance with the minimum security measures ex Annex "B " of the Code. These will be printed only on the occasion of a meeting and a conversation with the data subject. After the interview, if the candidate is not selected, the CV will be deleted and / or destroyed.
In all other cases, after a short period of time and after the talks and after the trial period (60 days) CVs will be deleted from the PC and, if printed, they will be destroyed.
The Curriculum Vitae considered interesting will be subject to protection and in any case eliminated within three years of collection.
To send Curriculum Vitae use the following addresses:
• Human Resources Dpt, Borgo San Felice Srl, Loc. San Felice, 53019 Castelnuovo Berardenga (SI)
• E-mail: email@example.com
PERIOD FOR DATA RETENTION - CRITERIA USED
According to the provisions set forth in art. 5 par. 1 lett. e) of the Regulation (EU) 2016/679, collected personal data shall be kept in a form which permits identification of data subjects for a period not exceeding the purposes for which the personal data were collected and subsequently processed.
Data retention periods depend on the purposes of the processing:
• purposes related to technical navigation data for the correct functioning of the website: retention only for the related session, after which the data are deleted;
• purpose of reply to info request/services supply request (up to 12 months for contact requests ; 10 years for administrative / accounting / financial documentation relating to the provision of a service);
• data collection for staff recruitment (up to 36 months);
• newsletter, marketing or promotional communications in general (until withdrawal of consent);
• purpose of administrative / accounting / financial management: 10 years as as required by law for the conservation of administrative / accounting / financial documentation.
None of the user’s personal data is purposely acquired by the website. The only monitoring activities is carried out by the google analytics technology for statistical monitoring of the website visits.
The data will be shared with the website google.com and third parties’ websites, only for statistical purposes processing of the visits. The privacy policies availables on the websites described above. Visitors in any case can turn off the advertising features of Google Analytics on this site by installing the Add-off for your browser downloadable from this LINK
OPTIONAL DATA PROVISION
Subject to the specifications made with regard to navigation data, users are free to provide the personal data listed in the request forms of Borgo San Felice or referred to in contacting the hotel in order to provide CV, to make on-line reservations or to request delivery of information materials and other communications. Failure to provide such data may entail the failure to be provided with the items requested.
Personal data is processed with automated means for no longer than is necessary to achieve the purposes for which it has been collected. Specific security measures are implemented to prevent the data from being lost, used unlawfully and/or inappropriately, and accessed without authorisation.
RIGHTS OF THE INTERESTED PARTY
You may contact the Data Controller at any time to exercise your rights as provided for in Section 7 of Law 196/03 and Chapter III GDPR 679/2016, in particular, the right to obtain confirmation as to whether or not personal data concerning him exist and the logic applied to the processing, the right to ask for their integration, the right to object to their processing on legitimate ground, and the right to request rectification, updating, erasure (right to be forgotten) or blocking of data that have been processed unlawfully, the right to obtain a copy of the personal data being processed as well as theright to data portability to another controller.
The requests should be sent to:
• Borgo San Felice Srl, Loc. San Felice, 53019 Castelnuovo Berardenga (SI), or at email address (firstname.lastname@example.org
). The Data Protection Officer DPO e-mail contact is: email@example.com
RIGHT TO LODGE A COMPLAINT
If a data subject considers that the processing of personal data relating to him or her as performed via this website infringes the Regulation, he or she has the right to lodge a complaint with the Garante pursuant to Article 77 of the Regulation, or else to bring a judicial proceeding against the Garante pursuant to Article 79 of the Regulation.
INFORMATION ON THE TREATMENT OF PERSONAL DATA USER SOCIAL MEDIA
Dear Sir/Madam, pursuant to art. 13 of the GDPR we inform you that the processing of personal data, we carried out with the help of electronic means, will be based on principles of correctness, lawfulness and transparency, relevance, not excessive in relation to the purposes for which they are collected and protecting your privacy and your rights.
In particular We can collect information from Social Media Users such as public uploads and posts, including publicly posted photographs. With such assets, we process name, social media username, physical address (if available), email-address (if available), IP address, and geo location (if available).
Borgo San Felice, to which you have submitted content through the brand hashtags, @brand mentions or branded location tags you have included in your social media posts, may use your username or email address to communicate with the data subjects, in addition to using their photo. IP and geo-location are used to filter content by region, country or other local area. Such data is used with data subjects consent only.
The data will be processed for institutional communication of the Borgo San Felice, including through publication in journals and institutional pages in Social Networks. The data collected will not be used for other purposes and will be used until the withdrawal of consent by the data subjects. The processing will be carried out both manually and computerized. At our office data may be known by our persons in charge of processing or by other external parties employees to pursue the above purposes, and will be processed by appropriate procedures to ensure the security and respect of GDPR.
Personal data will not be transferred to third countries outside EU, in compliance with the provisions of chapter V of GDPR. For use and publication on social media, by taking vision of this policy, the data subject accepts terms and conditions and privacy policies of use and publication of personal data from the social networks that can be find on various internet sites, and for the processing of which Borgo San Felice declines all responsibility.
The Data Controller is Borgo San Felice Srl, Mr. Danilo Guerrini, Loc. San Felice, 53019 Castelnuovo Berardenga (SI). You may contact the Data Controller at any time to exercise your rights as provided for in Chapter III of GDPR, in particular, the right to obtain confirmation as to whether or not personal data concerning him exist and the logic applied to the processing, the right to ask for their integration, the right to object to their processing on legitimate ground, and the right to request rectification, updating, erasure (right to be forgotten) or blocking of data that have been processed unlawfully, the right to obtain a copy of the personal data being processed as well as theright to data portability to another controller at the above address or by email address (firstname.lastname@example.org
). The Data Protection Officer DPO e-mail contact is: email@example.com
If a data subject considers that the processing of personal data relating to him or her as performed via this website infringes the Regulation, he or she has the right to lodge a complaint with the Garante pursuant to Article 77 and ss CHAPTER VIII of the Regulation. More information available at https://www.borgosanfelice.it/en/privacy.html