INFORMATION NOTE ON PRIVACY, ASSIGNMENT OF RIGHTS ON CONTRIBUTIONS AND CONSENT OF USE OF THE IMAGE
Processing of personal data
Navigation on the Site / APP and / or access to certain sections of the Website / APP or the Mobile Application (hereafter “APP”) and / or any requests for information or services from users of the Site / APP may involve the processing of personal data by Hotel Ristorante La Torretta srl, as Data Controller, which will be in compliance with Legislative Decree no. 196/2003 “Code regarding the protection of personal data” (hereinafter the “Code”) .
This information is intended to allow users browsing our site to know, even before accessing the various sections of the Site / APP, how Hotel Restaurant La Torretta srl treats the personal data of users and will still need to user sees it before he gives his / her personal data when registering on the Website / APP.
After the information is provided the terms and conditions to which users can consent to the assignment of rights on the images, the comments, the effect phrases associated with the subject matter of the Site / APP, the material, the contents and any other information designed by users and published on the Site / APP (“Contributions”) and give consent to the use of the image that the user may have conferred.
Purpose of the treatment
According to the needs from time to time manifested by the user who accesses the various sections of the Site / APP (and except for special rules and information for individual transactions involving the provision of specific personal data, published from time to time on the Site / APP), The following are the purposes of the processing of personal data, ie those directly conferred by users through the completion of online forms, or through the use of social networks (see the following section “Nature and methods of providing Personal Data of users “) or those acquired automatically through navigation (see the following section” Categories of Personal Data being processed “) (hereinafter,” Personal Data “):
- a) provide and manage the various services offered; as well as allowing registration on the Site / APP, which is necessary for access to particular sections of the Website / APP itself and to provide and manage the various services offered;
- b) allow users to publish the Contributions directly on the Site / APP, or on sites managed independently by third parties with whom eventually Hotel Ristorante La Torretta srl has reached agreements in this sense, such as, but not limited to, social networks such as Facebook, Twitter, etc. (hereinafter “Social Network”); the publication of the Contributions may also take place together with a pseudonym (“nickname”) chosen by the user during registration on the Site / APP, and possibly to the image associated with the user by their nickname for which: i) the user will be solely responsible for any choice that would prejudice third-party interests; ii) the user is not required to use personal data that allows third parties other than Hotel Ristorante La Torretta srl to identify him / her, but the user, through Hotel Ristorante La Torretta srl, may also disclose his / her personal data if he / she entered them nickname, as well as the photo you may have associated with your profile.
- c) subject to the user’s consent and until revocation of the same, carry out marketing activities such as the sending of promotional and advertising material of Hotel Ristorante La Torretta srl, also by e-mail, mms and sms;
- e) respond to users’ requests in relation to the activity of Hotel Ristorante La Torretta srl, to advertising, or to the Website / APP (“Contact Us” section of the Website / APP);
- f) prior consent of the user, and until revocation of the same, perform comparison and combination, for profiling purposes, of personal data of the same user present in different databases of, or in use at Hotel Ristorante La Torretta srl
Registration of users on the Site / APP is not required for the provision of some services offered by Hotel Ristorante La Torretta srl (eg, those referred to in paragraph e)). However, in order to avoid any requests from users regarding these services, they will be invited to provide personal data, which will be processed only for the relative purposes and for the time strictly necessary.
Method of treatment
Personal Data will be processed by means of collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.
Personal Data will be processed in a mainly automated but also paper format, with logic strictly related to the aforementioned purposes, through the Data Base, the electronic platforms managed by Hotel Ristorante La Torretta srl or by third parties appointed for this purpose (eg Mailchimp , etc); for the updated list contact the owner at the e-mail address indicated below) and / or integrated systems of an IT nature and / or websites or the APP owned or used by Hotel Ristorante La Torretta srl
The Owner has taken a variety of security measures to protect you against the risk of loss, misuse or alteration of your data. In particular: has adopted the measures set out in Articles. 32 – 34 of the Privacy Code; uses password encryption technology with MD5 algorithm and protected data transmission protocols known as HTTPS. Furthermore, keep your data, in encrypted form, on Server sites in the European territory (at Aruba webfarm and / or Iltuohosting and / or Vhosting and / or Shellrent) or, in the case of electronic platforms such as Google, could be transferred to the USA. Servers are subject to a back-up and disaster recovery system.
Place of treatment
Personal Data are processed mainly at the headquarters of the Data Controller and in the places where the Data Processors are located. For more information, contact the owner.
Time of data processing and storage
The Data Controller will process the Personal Data for a period of time no longer than necessary to achieve the purposes for which the personal data are processed, or for a longer period, for purposes permitted by law, and in any case canceled without undue delay.
When the processing is based on the consent of the User, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or an order of an authority.
The user may at any time cancel his / her account or register with the Site or request the interruption of the treatment or withdraw his consent, according to the methods indicated in the personal profile section on the Website.
Nature and methods of providing Users’ Personal Data
The provision of personal data is optional, but for some personal data the conferment is mandatory (ie necessary for those data whose fields are marked with an asterisk or otherwise marked as mandatory) so that Hotel Ristorante La Torretta srl can meet the needs of the user within the functions of the Website / APP. Failure, partial or incorrect provision of Personal Data marked with an asterisk, as necessary for the execution of the requested service, does not make such execution possible; while failure, partial or incorrect provision of the optional Personal Data does not result in any consequence.
The provision of Personal Data can take place: a) by filling in the appropriate fields in the various sections of the Site / APP; or b) by browsing the Website / APP or using cookies.
Categories of Personal Data processed
In addition to the Personal Data provided directly by users (such as name, surname, postal address, e-mail address, password, age, date of birth, sex, image, profession, marital status, etc.), when connecting to the Website , the computer systems and software procedures used to operate the Website itself provide and / or acquire automatically and indirectly some information that could constitute personal data, the transmission of which is implicit in the use of Internet communication protocols (such as, by exemplary but not exhaustive, the so-called “cookies” (as better specified below), “IP” addresses, domain names of the computers used by users who connect to the Website, the addresses in “Url” notation of the requested resources, the time of request to the server, navigation on the Website / APP).
Cookies are lines of text that act as computer markers sent by a server (in this case, that of this Site) to a user’s device (usually to the Internet browser) when they access a given page of a site web; cookies are automatically stored by the user’s browser and re-transmitted to the server that generated them each time the user accesses the same Internet page. In this way, for example, cookies allow and / or facilitate access to some Internet pages to improve the user’s browsing, that is, they allow the memorization of pages visited and other specific information, such as pages viewed more frequently, connection errors, etc. Therefore, for a facilitated and complete use of this site, it would be advisable for the user to configure his browser in order to accept the receipt of these cookies.
Often browsers are set to automatically accept cookies. However users can change the default configuration, so as to disable or delete cookies (from time to time or once and for all), with the consequence, however, that the optimal use of some areas of the Site could be precluded. You can also check the methods and types of cookies stored on your browser by changing the cookie settings of your browser.
Types and management of cookies used by our Website / APP
Our Website / APP uses the following categories of cookies:
- a) Technical cookies or “technical cookies”:
(i) necessary cookies or “strictly necessary cookies”:
They are necessary for navigation on a Web Site / APP and the use of its functionalities, such as to allow a correct display or access to restricted areas. Therefore, disabling these cookies does not allow these activities.
(ii) Performance cookies or “performance cookies”:
They collect information on the efficiency of the responses of a Website / Web App to the requests of users anonymously, for the sole purpose of improving the functionality of the Website / APP Internet; for example, which pages are most frequently visited by users, and whether there have been errors or delays in the delivery of web pages.
(iii) Function cookies or “functionality cookies”:
They allow the Website / APP to remember the choices made by the user and re-propose them to subsequent accesses in order to provide better and personalized services: for example, they can be used to offer content similar to those previously requested by the user.
- b) Cookies for targeted advertising or “targeting cookies”:
This Website / APP also uses: Pop-up Cookie consent Cookies and Google Maps cookies, social cookies of Facebook.
Pop-up Cookie Consent Cookie
Google Maps Cookies
Facebook social cookies
Disabling (opt-out) for cookies:
By virtue of this distinction, the user may proceed with the disabling and / or cancellation of cookies (“opt-out”) through the relevant settings of their browser and the disabling and / or deletion of individual non-technical cookies by accessing the following sites:
– https://tools.google.com/dlpage/gaoptout?hl=it to disable Google Analytics
– www.youronlinechoices.eu, a website managed by the European Interactive Digital Advertising Alliance (EDAA), for the cancellation of other cookies in the case of users based in the European Union,
http://www.aboutads.info/choices/, for the cancellation of other cookies in the case of users residing in the United States of America. These sites are not managed by the owner, who therefore assumes no responsibility in relation to their respective contents.
How to enable or disable cookies on your browsers:
The user can block the acceptance of cookies by the browser. However, this operation may make it less efficient or prevent access to certain features or pages of the Website / APP.
Below are the methods offered by the main browsers to block the acceptance of browsing cookies:
Internet Explorer: http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-11
Categories of subjects who may be aware of the Users’ Personal Data
Personal Data may be brought to the attention of employees or collaborators of the Data Controller who, operating under the direct authority of the latter, process data and are appointed as internal managers or persons in charge of processing in accordance with art. 29 and 30 of the Code or system administrators and who will receive appropriate operational instructions from the Controller; the same will happen – by the Managers appointed by the Owner – towards the employees or collaborators of the Managers.
Personal Data may also be brought to the attention of External Data Controllers, such as third-party companies or other subjects (for example, subjects entrusted with assistance, communication, marketing, advertising, promotions and sale of products and / or services, advertisers, advertising agencies, IT service providers, site managers, e-platform operators – eg Aruba, Vhosting, Iltuohosting, Shellrent, Mailchimp, partners, lenders, professional firms) that perform outsourcing on behalf of Hotel Ristorante La Torretta srl.
Scope of communication or dissemination of personal data of users
Personal Data will not be disclosed to third parties or disseminated, except in the latter case the hypothesis in which the user has entered personal data in his nickname or has also given his own image.
Extra UE transfer of users’ personal data
Personal Data may be transferred outside the EU (specifically in the USA) to be stored on the servers of the electronic platforms (eg Google, Mailchimp). The transfer is carried out by Hotel Ristorante La Torretta srl, subject to verification of the registration of the Data Processor within the “Privacy Shield” system.
The Sites and the APP do not contain almost any information aimed directly at minors. Minors must not give personal information or data to Hotel Ristorante La Torretta srl without the consent of the exhibitors for parental responsibility over them. Therefore, Hotel Restaurant La Torretta srl invites all those who exercise parental responsibility on minors to inform them about the safe and responsible use of the Internet and the Web and to put in place any procedures indicated from time to time.
Data Controller and Data Processors
The data controller is Angela Bortone, Via Livorno, 1 Bianzè (VC)
As interested parties, users have the rights set forth in art. 7 Italian Privacy Code (see below for a full text of the article): in particular, they have the right to obtain from the Controller confirmation of the existence or not of Personal Data concerning them and their communication in intelligible form; they can also ask to know the origin of the Personal Data; the purposes and methods of processing; they can also obtain the updating, correction or integration of Personal Data. They may also, at any time, revoke their consent, cancel their APP account and / or cease to be registered on the Site, requesting the interruption of processing, cancellation, transformation into anonymous form or blocking of the Personal Data processed. They can oppose, in whole or in part to the processing: a) for legitimate reasons to the processing of personal data concerning them; b) for the purpose of sending advertising material or for carrying out market research or commercial communication. In this regard, they may decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
Users also have the rights referred to in Articles 16-21 European Reg. 2016/679 (Right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right of opposition).
Finally, users can promote complaints to the Guarantor Authority if necessary, or contact the same to request information regarding the exercise of their rights deriving from the 2016/679 European regulation.
“Article 7 Italian Privacy Code – Right to access personal data and other rights”
The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in intelligible form.
The interested party has the right to obtain the indication:
- a) of the origin of personal data;
- b) of the purposes and methods of the processing;
- c) of the logic applied in case of treatment carried out with the aid of electronic instruments;
- d) of the identifying details of the holder, of the responsible and of the designated representative according to article 5, paragraph 2;
- e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents.
The interested party has the right to obtain:
- a) updating, rectification or, when interested, 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) 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 is it proves impossible or involves a use of means manifestly disproportionate to the protected right.
The interested party has the right to object, in whole or in part:
- a) on legitimate grounds, to the processing of personal data concerning him / her, even though they are relevant to the purpose of the collection;
- b) 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.
How to exercise rights and to know the list of data processors
The user may, at any time, exercise the rights referred to in art. 7 of the Code by sending an e-mail or a letter to be sent by ordinary mail to the Data Controller.
The user, moreover, if he has allowed you, can oppose the treatment for the purposes referred to in letter c) made by the e-mail address of the user, by clicking on a special “link” present in each e-mail message e.
Assignment of the rights on the Contributions and consent to the use of the image
By registering with the Website / APP, the user:
- A) declares that: i) any right on the Contributions published on the Site / APP when participating in the Initiative belongs to the user, who remains solely responsible for any damage or action that Hotel Ristorante La Torretta srl may be suffer due to the publication of the Contributions; ii) Contributions published by the user do not contain any material that could hinder their publication, e.g. obscene, racist, defamatory, blasphemous, child pornography and are original, that is, they do not violate intellectual and industrial property rights