PRIVACY POLICY

INFORMATION* ON THE PROCESSING OF PERSONAL DATA in accordance with Articles 13/14 EU Regulation 2016/679 “General Data Protection Regulation”

Dear guest,
the company Lefay Resorts S.r.l. (VAT no.: 027860980) with registered office in S. Felice del Benaco (BS) ITALY, Via Santigaro 4, head of the group of the same name, as Data Controller, wishes to provide to you information on the use of your personal data that you provided and/or is referable to you at the point of booking and stay at the hotel premises of the group.
Pursuant to Articles 13/14 EU Regulation 2016/679, the data controller company wishes to inform you that it will handle personal data provided by you or referable to you in accordance with the provisions set out by the law.
The regulation states that the processing of your personal data (personal details, place of residence, contact details, email, mobile, data relating to preferences, information relating to the booking, to your stay, navigation data etc.) will be characterised by principles of accuracy, permissibility, transparency and privacy protection.

1) Purposes – booking and stay

Personal data provided by you (former Article 4(1) of EU Regulation 2016/679) or referable to you at the point of booking and/or stay will be processed in order to assign hotel and spa services as requested.
The legal basis for this processing resides in the requirement to meet contractual and/or pre-contractual obligations in accordance with Article 6(1) (b) of EU Regulation 2016/679 and the need to conform to legal obligations contained in Article 6(1) (c) of EU Regulation 2016/679. We would like to inform you that the provision of this personal data is indispensable in order to provide the hotel and Spa services; where the data is not provided, the data controller companies might be unable to provide all or some of the services requested.
Personal data may be processed for as long as necessary in order to meet contractual and/or legal obligations related to these purposes, to the conservation obligations foreseen by the law and the limitations timing specified within Articles 2936 and following of the Italian Civil Code.

2) Profiling and marketing purposes (optional)

Upon your express authorisation, personal data (as per Article 4(1) of EU Regulation 2016/679) provided by you or referable to you at the point of booking and/or stay may be processed for the following additional purposes:
A) direct marketing activity via the sending of publicity/promotional material through the post; email/ sms/mms, mobile applications or other digital communication channels.
B) client profiling activity aimed at improving the supply of goods and services by the Lefay group (client profiling)
Please note that the processing procedures above may be managed to include your consumer preferences to improve the efficiency of the Lefay group’s commercial policies and services; consequently you may receive discounts, offers or targeted promotions on the basis of your preferences and consumption habits.
The provision of data for the purposes described in A) – B) is optional so that all hotel and Spa services can still be supplied, even where you refuse to authorise the processing for the purposes listed in point 2).
The legal basis for the processing is represented by your express consent given by ticking the appropriate clauses and completing the double opt-in procedure. Personal data under Article 4(1) EU Regulation 2016/679 provided by you or relating to you will be processed in compliance with the law for the period of time taken to complete the purposes listed in point 2) with regard to the principle of balancing the legitimate interests of the data controller with the rights and freedoms of the customer who is the data subject. Your data will be processed in accordance with the time frames set out in the legal provisions, or in the absence of specific regulations, your data will be processed for as long as necessary to complete marketing and profiling activities; the data controller company guarantees that the processing of the data will not take place for an indeterminate period of time.
We acknowledge that you are entitled at any time to withdraw your consent to the activities mentioned in point 2) by means of a simple informal written communication sent to the contact details of the data protection officer as specified below in this policy.
In accordance with the law, any data which has been processed before the withdrawal of consent shall be made safe.

Further information and clarifications pertaining to the processing mentioned in point 1) and in point 2) are provided below:

- Personal data provided by you or referable to you may be processed employing partially or fully automated means through the use of hard-copy, electronic, and/or magnetic means.
- Personal data connected to you will not be circulated but may be passed or be brought to the attention of appropriately trained operators who form part of the data controller company and/or external parties collaborating with the companies as data processing officers or independent controllers such as - by way of example, which is not intended to be exhaustive

• Companies, firms and/or contractors engaged to process and manage personal data;
• Companies, firms and/or contractors engaged in consultancy and/or technical, company or ICT management;
• Companies belonging to the Lefay Resorts group supplying goods and/or services and engaged in related activities;
• Other parties to whom it is necessary to pass data for the proper and complete fulfilment of the contractual relationship and/or to meet legal requirements and/or to achieve the specified purposes.

- You are also informed that you are entitled to make a request to the data controller company (Lefay Resorts S.r.l.) for access to your personal data, rectification, deletion, restriction of data processed; you are, moreover, entitled to object to the processing of personal data and to exercise your right to portability. The rights contained in this paragraph may be exercised as provided for by Articles 15, 16, 17, 18, 20, 21 EU Regulation 2016/679 which we have reproduced at the foot of this policy document for your convenience.
All the rights may be exercised in relation to the data controller company; you may also object to the supervisory authority under the national legislation in force.
- For any clarification and to exercise the rights above, you are free to apply to the Data Protection Officer (DPO) in the person of the temporary director of the privacy office of the Lefay Resort group who can be reached at S. Felice del Benaco (BS) ITALY, Via Santigaro 4 or on telephone no. 0365/441711 or via email at marketing@lefayresorts.com.

Lefay Resorts S.r.l.

*This policy document complements and completes information already known to the data subject.

EXTRACT FROM EU REGULATION 679/2016

Article 15 Right of access by the data subject The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, access to the personal data and the following information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such data processing for the data subject. 2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. 3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. 4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.n

Article 16 Right to rectification The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17 Right to erasure (“right to be forgotten”) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 4.5.2016 IT Official Journal of the European Union L 119/43 b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing; c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); d) the personal data have been unlawfully processed; e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1). 2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: a) for exercising the right of freedom of expression and information; b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3); d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or e) for the establishment, exercise or defence of legal claims.

Article 18 Right to restriction of processing 1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject. 2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. L 119/44 IT Official Journal of the European Union 4.5.2016 3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 20 Right to data portability 1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and b) the processing is carried out by automated means. 2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21 Right to object 1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. 4.5.2016 IT Official Journal of the European Union L 119/45 4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Cookies policy

Extended information on Cookies
Cookies consist of portions of code installed in the browser that assist the Owner of the website in providing the service according to the purposes described. Some of the purposes for which the Cookies are installed may also require the User’s consent. If you close the cookie banner by clicking on the “X” at the top of it, the default settings will remain in place and you will be able to continue browsing without cookies or other non-technical tracking tools.

Technical Cookies and Cookies to collect aggregated statistical information
1. Activity strictly necessary for the functioning of the service:
This Application uses Cookies to save the User’s session and to carry out other activities that are strictly necessary for the operation of the same.
2. Activity regarding the saving of preferences and optimisation:
This Application uses Cookies to save browsing preferences and to optimise the User’s browsing experience. Among these Cookies are, for example, those to set the language and the currency.

Other types of Cookies or third-party tools that might use them
Some of the services listed below collect statistics in aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.
If any third-party operated services are listed among the tools below, these may be used to track Users’ browsing habits – in addition to the information specified herein and without the Owner’s knowledge. Please refer to the privacy policy of the listed services for detailed information.

How can I manage the installation of Cookies?
In addition to that specified in this document, the User can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing them. Through the browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that might possibly have saved the consent for the installation of Cookies by this website. It is important to note that by disabling all Cookies, the functioning of this site may be compromised. Users can find information about how to manage Cookies in their browser at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer.
In the case of services provided by third parties, Users can exercise their right to withdraw from the tracking activity by using the information provided in the third party’s privacy policy, by clicking the opt-out link – if provided – or by contacting the third party.
Notwithstanding the foregoing, the Owner informs that Users may take advantage of: Your Online Choices. This service allows Users to manage their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of this resource in addition to the information provided in this document.
As the installation of Cookies and other tracking systems operated by third parties through the services used in this Application cannot be technically controlled by the Owner, every specific reference to Cookies and tracking systems installed by third parties should be considered indicative. In order to acquire complete information, consult the privacy policy of all possible third party services listed in this document.
Due to the objective complexity connected with the identification of Cookie based technologies and their close integration with operation of the web, Users are invited to contact the Owner in order to receive further information regarding the use of Cookies themselves and their possible use – for example, by third parties – carried out through this site.

Further information on processing
Defence in legal claims
The Personal Data of the User may be used by the Controller for defence in legal proceedings, or in the preparatory stages prior to instituting a proceeding, to defend against abuse when using the same or connected services by the User.
The User declares that he/she is aware that the Controller could be asked to disclose the Data at the request of the public authorities.

Specific information
At the request of the User, in addition to the information contained in this privacy policy, this Application could supply to the User additional and contextual information regarding specific services, or the collection and processing of Personal Data.

System and maintenance Log
For needs connected to operation and maintenance, this Application and any third-party services used by the same could collect system Log files, which are files that record interactions and which may also contain Personal Data, such as the IP address of the User.

Information not contained in this policy
Further information regarding the processing of Personal Data may be requested at any moment by the Data Controller using the contact information.
This Application does not support “Do Not Track” requests. To determine whether the services of the third parties it uses support these requests, please read their privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. Therefore, please check this page often, referring to the date of the last modification given at the bottom. If a User objects to any of the changes to the Policy, he/she must cease using this Application and can request that the Data Controller removes his/her Personal Data. Unless stated otherwise, the previous privacy policy shall continue to be applied to all Personal Data collected up to that moment.

Last modification 24 May 2018

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