Privacy

Information notice on the processing of personal data pursuant to Article 13 of Legislative Decree 196/2003 and Articles 13 and 14 of Regulation (EU) 2016/679

We would like to inform you that Legislative Decree no. 196 of 30 June 2003 ("Personal Data Protection Code" or "Privacy Code") and Regulation (EU) 2016/679 provide for and guarantee the right to the protection of personal data processed by third parties, on the principle that everyone has the right to the protection of the personal data concerning them and to have such data processed in compliance with fundamental rights and freedoms and with the dignity of the data subject, with particular regard to confidentiality and personal identity.

For the purposes of this notice, the Privacy Code and the European Regulation, the following definitions apply:

1. form" means the interface of a website or application that allows the client user to enter and send to the web server one or more pieces of data freely typed in by the user; it is also referred to as a web form;
2. "processing" means any operation or set of operations, whether or not performed by automated means, applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
3. "personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person;
4. "identification data" means personal data that allow the direct identification of the data subject on the basis of the above criteria;
5. "sensitive data" means personal data revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade-union nature, as well as personal data revealing health status and sex life;
6. "data controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
7. "data processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller;
8. "persons in charge of processing" means the natural persons authorised by the data controller or the data processor to carry out processing operations;
9. "data subject" means the identified or identifiable natural person to whom the personal data relate;
10. "communication" means disclosing personal data to one or more identified parties other than the data subject, the controller's representative in the territory of the State, the data processor and the persons in charge of processing, in any form, including by making them available or allowing them to be consulted;
11. "dissemination" means disclosing personal data to unidentified parties, in any form, including by making them available or allowing them to be consulted;
12. "anonymous data" means data which, originally or following processing, cannot be associated with an identified or identifiable data subject;
13. "blocking" means the retention of personal data with temporary suspension of any other processing operation;
14. "database" means any organised set of personal data, divided into one or more units located at one or more sites;
15. "Garante" means the Italian Data Protection Authority referred to in Article 153, established by Law no. 675 of 31 December 1996;
16. "minimum security measures" means the set of technical, IT, organisational, logistical and procedural security measures that constitute the minimum level of protection required in relation to the risks set out in Article 31 of the Privacy Code;

In accordance with Article 5 of Regulation 2016/679, the processing of the data you provide to us will be based on the principles of lawfulness, fairness and transparency and will be carried out in compliance with the principle of necessity, by configuring our information systems and software so as to minimise the use of personal and identification data and to exclude their processing whenever the purposes pursued in individual cases can be achieved through anonymous data or through appropriate methods that allow you to be identified only when necessary.

Data Controller
Villa Oriana Relais Srl
Via Rubinacci 1
80067 Sorrento (NA) – Italy
VAT no.: 05681681218
Registered with the Chamber of Commerce (CCIAA) of Naples
REA no.: NA-769822
Share capital: € 207,000.00
PEC (certified email): villaoriana@pec.it

Information collected by the website http://www.corteguelfa.com and therefore by Villa Oriana Relais Srl
While browsing the website http://www.corteguelfa.com you will be given the opportunity to contact Villa Oriana Relais Srl, including by non-electronic means.

With regard to the information that may be requested from you or that you may provide spontaneously, please note that providing your data may in some cases be optional and in others mandatory; in the latter case, refusal to provide such data may mean that the relationship cannot be performed, or can be performed only in part.

Processing may also involve personal data which, in some countries, fall within the category of "sensitive data" as defined above, in which case Villa Oriana Relais Srl will adopt all the precautions and requirements laid down by the Privacy Code.

Below we list the contact methods through which the website http://www.corteguelfa.com may collect your personal information, or through which you may contact Villa Oriana Relais Srl by providing your personal data yourself. Such information may be acquired directly by the website http://www.corteguelfa.com through services set up and managed directly by Villa Oriana Relais Srl, or acquired through third-party services. For each contact method, detailed information is provided below on who acquires your information, the purposes for which it is collected, the legal basis for the processing and, where data are transferred to third parties, the categories of third parties to whom they will be transferred.

Contact methods offered by the website through which users may provide their personal information:
Telephone, fax, email and postal addresses
Service provider/manager
The service is provided and managed directly by this Application.
Purposes of personal data collection
The service collects personal data for the following purposes:
Responding to your requests.
Legal basis for processing
The legal basis for the processing, pursuant to Article 6 of Regulation (EU) 2016/679, is the consent you have given to the processing of your personal data for one or more specific purposes.
Transfer of collected data to third parties
The data collected by this service will not be transferred to third parties.
Description of the service
While browsing the website you may find our telephone and fax numbers, email and postal addresses so that you can get in touch with us.

Contacts & Location
Service provider/manager
The service is provided and managed directly by this Application.
Purposes of personal data collection
The service collects personal data for the following purposes:
Preparing quotes, responding to requests for information.
Legal basis for processing
The legal basis for the processing, pursuant to Article 6 of Regulation (EU) 2016/679, is the consent you have given to the processing of your personal data for one or more specific purposes.
Transfer of collected data to third parties
The data collected by this service will be transferred to the following categories of third parties:
Collaborators.
Description of the service
Through this form, users can request further information about the services offered.

During any contact with Villa Oriana Relais Srl, you may be asked to provide information useful for continuing our relationship through "free" request fields (submitting forms, sending emails and other types of contact). In this specific case, you are free to send us additional information, which will always be processed in accordance with the applicable data protection provisions.

Please note that in some cases, without the information we may request, we will not be able to offer our services in whole or in part.

How Villa Oriana Relais Srl stores and when it transfers your personal information

All the data you provide to us during or through browsing the website http://www.corteguelfa.com will be processed, subject to your express consent to the entire processing or to one or more operations thereof, by the data controller, by the data processors (if appointed by the data controller) and/or by the persons in charge of processing appointed by the data controller and/or by the data processors. Any sensitive data you provide may be processed only with your written consent, in compliance with the conditions and limits established by the Privacy Code, as well as by law and regulations.

All operations carried out on the data you provide will be performed with the utmost care and attention and will be appropriate to protect your confidentiality. Processing operations will include collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, as well as any combination of two or more of these activities.

The data you provide will be processed manually and/or automatically, on paper and/or digital media (using electronic means owned by us and/or provided by third parties). They will be kept with appropriate technical, IT, organisational, logistical and procedural security measures, ensuring at least the minimum level of protection required in relation to the risks pursuant to Article 31 of the Privacy Code and Article 5 of the Regulation, and in any case in accordance with the principles of:

1. lawfulness, fairness and transparency towards the data subject;
2. purpose limitation (data will be collected for specified, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes);
3. data minimisation (the data collected will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed);
4. accuracy (data will be kept up to date and promptly rectified where necessary);
5. storage limitation (data will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed);
6. integrity and confidentiality.

We will only process data that are strictly relevant, complete and not excessive in relation to the purposes connected with the services offered for which they are collected or subsequently processed, and will keep them in a form that allows your identification for no longer than is necessary for the purposes for which they are collected or subsequently processed.

Over time, the security measures implemented by Villa Oriana Relais Srl may be adapted in light of the regulations applicable at the time and of technical developments in the sector and/or in data storage and archiving technologies.

The data processor(s) and the persons and entities in charge of processing appointed by Villa Oriana Relais Srl will be adequately trained, with particular attention to the applicable rules and to the adoption of minimum security measures, with the sole aim of ensuring the confidentiality and security of the data. Under no circumstances will personal data be disclosed to third parties without your prior consent.

The personal information you provide through the website http://www.corteguelfa.com is sent to and may be stored on servers located both within the European Union and elsewhere.

Any personal information you provide through the use of the website http://www.corteguelfa.com may be communicated by us to any other companies of the Villa Oriana Relais Srl group and/or to the third parties mentioned in the cases described below.

Possible communication of your data to third parties
All the data processing operations described in this privacy notice may require the information collected by Villa Oriana Relais Srl to be shared with any of our affiliated companies, including those based abroad, and with our partners, suppliers (e.g. banks, couriers, logistics companies), consultants, any joint ventures and any future owner of the website or of our business, in the context of providing the services you have requested.

We may communicate your personal data to other companies in connection with any type of possible or actual reorganisation, merger, sale, assignment, transfer or other arrangement concerning all or part of our business, assets and shares/quotas.

We may also use the services of other companies or individuals to perform actions and functions on our behalf, including, for example, providing services, sending correspondence, providing marketing assistance, analysing data, providing customer support, and for accounting, financial, commercial, administrative, invoicing, legal and tax purposes, etc. In order to carry out the activities entrusted to them, such individuals or companies may process your personal information as data processors appointed by us or as independent data controllers. We will disclose to such companies or individuals only the personal information that is strictly necessary for the specific performance of their functions.

Upon specific request, we may cooperate with any court, tribunal, administrative authority, police authority or other similar authority in any investigation or proceeding that may concern you or relate to your use of the website http://www.corteguelfa.com.

Such cooperation may involve disclosing personal information concerning you to the authorities, upon their explicit request.

Although our company adopts suitable measures to protect the personal information and any sensitive data that you provide, have provided or will provide while using the website http://www.corteguelfa.com, no transmission over the internet can ever be guaranteed, by definition, to be 100% secure.

Please therefore always bear in mind that it is not possible, and we may therefore not be able, to guarantee the absolute security of any personal information you transfer to us over the internet through the website http://www.corteguelfa.com or by email.

Plugins and Widgets
The website http://www.corteguelfa.com, owned by Villa Oriana Relais Srl, may use plugins provided by third parties.

When you visit a page of our website containing one or more of these elements, your browser will display content (text and/or images) sent and/or determined by the owner of the plugin. These plugins may also install cookies (third-party cookies).

Our website is therefore not responsible for such content; please refer to the privacy policy of the plugin owner.

Our website may use social plugins from the following social networks, by way of example and without limitation: facebook.com ("Facebook"), plus.google.com ("Google+"), the micro-blogging service twitter.com ("Twitter"), etc. In the future, other plugins from other websites and/or social networks may be added to the pages of our website.

Your rights pursuant to Articles 12 and 13–22 of Regulation (EU) 2016/679 and Article 7 of Legislative Decree 196/2003
For any questions, comments or requests for clarification regarding the privacy policy of Villa Oriana Relais Srl or this notice, if you wish to exercise your privacy rights or any other rights relating to your personal data, or if you have any other questions or requests, please contact us using the contact details shown on the website or the following details:

Villa Oriana Relais Srl
Via Rubinacci 1
80067 Sorrento (NA) – Italy
VAT no.: 05681681218
Registered with the Chamber of Commerce (CCIAA) of Naples
REA no.: NA-769822
Share capital: € 207,000.00
PEC (certified email): villaoriana@pec.it

We are happy to meet your requests; however, we cannot always delete information relating to past interactions and any past transactions and/or bookings.

It is important and necessary that you are informed of the following rights provided for by Article 7 of Legislative Decree 196/2003 and Articles 15–22 of Regulation (EU) 2016/679:

1. the right to obtain confirmation as to whether or not personal data concerning you are being processed, and to have such data communicated to you in an intelligible form;
2. the right to be informed of the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipients to whom the personal data have been disclosed, the period for which the personal data will be stored or the criteria used to determine that period, the existence of the right to request rectification or erasure of the data or restriction of processing, the right to lodge a complaint with a supervisory authority, and the existence of automated decision-making together with meaningful information about the logic involved;
3. the right to obtain, without undue delay, the updating, rectification or, where you have an interest, integration of the data; taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement;
4. the right to obtain the erasure, anonymisation or blocking of data processed unlawfully, including data whose retention is not necessary for the purposes for which they were collected or subsequently processed; and certification that such operations have been brought to the attention, also as regards their content, of those to whom the data were communicated or disseminated, unless this proves impossible or involves a manifestly disproportionate effort compared with the right being protected;
5. the right to obtain restriction of processing where you contest the accuracy of the personal data (for the period necessary to verify their accuracy), where the processing is unlawful, or where the data are needed for the establishment, exercise or defence of legal claims;
6. the right to receive the personal data concerning you in a structured, commonly used and machine-readable format, without hindrance from Villa Oriana Relais Srl, where the processing is based on your consent and carried out by automated means;
7. the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning you, including profiling, carried out for the purpose of sending advertising material or direct selling, or for market research or commercial communication.

You also have the right and duty, at any time, to update any outdated or incorrect personal data we hold about you by visiting the dedicated area, where available, accessible once logged into your account. If you would like a copy of your personal data, wish to inform us of any inaccuracy or error in the information we hold about you, wish to exercise your rights, or have any questions about our personal data protection and privacy notice, please contact us.

Requests addressed to the data controller or data processor may also be sent by registered letter, fax or email, unless the Garante adopts a different system with reference to new technological solutions. In any case, the rights referred to in Article 7(1) and (2) of the Privacy Code may also be exercised by means of an oral request, in which case the request will be briefly recorded by the data subject or the data processor.

Third-party websites and hyperlinks
Our website http://www.corteguelfa.com may contain hyperlinks and/or advertisements to other websites not owned or controlled by Villa Oriana Relais Srl.

Please note that this Privacy Notice applies solely to the personal information we collect through our website, and we cannot be held responsible in any way for personal information collected, stored and used by third parties through their websites.

Villa Oriana Relais Srl recommends that you read the privacy policy of every website you visit.

Minors
By providing your personal data, you guarantee, and we assume, that you are at least 18 years of age. Villa Oriana Relais Srl does not intend to collect any personal data from individuals under the age of eighteen. Where necessary, we will specifically instruct children not to submit their data through our websites and/or take reasonable measures to ensure parental/guardian control over such submission.

Parents/guardians should be aware that our privacy notice and policy will govern the use of personal data, but information voluntarily given by minors – or by others – in comments or similar may be used by third parties to generate unsolicited correspondence.

We invite all parents/guardians to teach their children to use their personal data safely and responsibly when browsing the internet, exercising whatever supervision they deem appropriate, to the extent and in the manner they consider suitable.

In the event of a data breach
In the event of a personal data breach, Villa Oriana Relais Srl will notify the breach to the Italian Data Protection Authority (Garante per la protezione dei dati personali) pursuant to Article 33 of Regulation (EU) 2016/679, without undue delay and, where feasible, within 72 hours of becoming aware of it. Such notification will be made in all cases, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, Villa Oriana Relais Srl, as data controller, will communicate the breach to you without undue delay.

Changes to our privacy notice
Since automatic control mechanisms are not yet free from errors and malfunctions, we reserve the right to make, without prior notice, any changes to this privacy notice that we deem necessary or that are required by law or by any other regulatory source. You should check this privacy notice regularly, as you will be deemed to have accepted any changes and updates if you continue to use the website after they have been published.