PRE-STAY PRIVACY POLICY
Articles 13-14 EU Regulation no. 679 of 27 April 2016
"General Data Protection Regulation"
Dear User,
Lungarno Alberghi S.r.l., in its capacity as Data Controller, hereby informs you, pursuant to Articles 13 and 14 of EU Regulation No. 679 of 27 April 2016, the “General Data Protection Regulation” (hereinafter the “Regulation” or “GDPR”) that, following completion of the questionnaire, it may become aware of information relating to you.
CATEGORIES OF PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING
We will process your personal data for the following purposes:
a) Your personal details, contact information, data relating to your stay, and information about your tastes and preferences will be processed to provide you with a high-quality, personalised service and make your stay an even better experience. Please note that, with the exception of the information described above, you are not required to provide any other special categories of personal data (data capable of revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, or personal data capable of revealing health status or sex life);
b) Your personal details and e-mail address will also be processed to send you promotional communications by email regarding our services and offers;
c) If you choose to subscribe to our newsletter, we will also process information relating to the opening of communications sent by Lungarno Alberghi, collected through a tracking pixel embedded in the communications. This information may include e-mail opens, clicks on links contained in messages, and interest shown in specific content or initiatives. Such data are collected to measure the effectiveness of marketing campaigns and improve the relevance of the content offered. Please note that consent to tracking may be withdrawn separately from consent to receive the newsletter, without interrupting the delivery of such communications.
LEGAL BASIS FOR PROCESSING, NATURE OF DATA PROVISION AND DATA RETENTION PERIOD
For the purposes referred to in point (a), the legal basis is the performance of a contract to which you are a party or the implementation of pre-contractual measures taken at your request. The legal basis also includes the Data Controller’s legitimate interest in providing you with a high-quality hotel service and streamlining the process of collecting data relating to your tastes and preferences, so that such information is already available upon your arrival at the property. If you refuse to provide this information, Lungarno Alberghi S.r.l. will be unable to offer you a personalised, high-end service. Personal identification data will be retained for the period required under applicable tax and accounting legislation. Data relating to your tastes and preferences will be retained for the duration of your stay.
For the purposes referred to in points (b) and (c), the legal basis is your consent. You are free to decide whether or not to consent to receiving our newsletters; however, failure to provide your consent will make it impossible for you to receive our promotional and informational communications. Please note that you may withdraw your consent at any time and as easily as you originally gave it. In particular, you may choose to withdraw your consent to receiving our newsletter or to withdraw your consent solely to the tracking of communications while continuing to receive them. To exercise these rights, you may use the relevant function in the footer of our emails or write to: privacy@lungarnocollection.com. Finally, please note that, unless your consent is withdrawn earlier, your data will be retained for a maximum period of 4 years from your last interaction with the newsletter. If you decide to withdraw your consent to the tracking pixel while continuing to receive the newsletter, your personal data will be processed until you request to be removed from our mailing lists.
RECIPENTS OF PERSONAL DATA
Your personal data will be processed by authorised personnel who have received appropriate training and operate under the authority and responsibility of the Data Controller. Certain information may be disclosed to the following parties:
Companies providing IT system support and maintenance services;
Providers of software and platforms for registering and completing questionnaires designed to collect information relevant to guests’ stay at the property;
Third parties or companies providing services necessary for the purposes outlined above, including communication and email services.
Only the data strictly necessary to perform the relevant functions will be disclosed to the recipients listed above. A detailed list of these parties is available at the registered office of the Data Controller and will be provided upon request by writing to the following e-mail address: privacy@lungarnocollection.com
YOUR RIGHTS
Please be advised that, with regard to your personal data, you may exercise at any time the rights provided for under Chapter III of the Regulation. In particular, you have the right to request from the Data Controller access to your personal data, their rectification or erasure, the completion of incomplete data, and the restriction of processing. You also have the right to receive your data in a structured, commonly used and machine-readable format; to withdraw any consent previously given; to object, in whole or in part, to the processing of your data; and to exercise any other rights granted to you under applicable law. You may exercise your rights by writing to the contact details provided below.
Furthermore, pursuant to Article 77 of the GDPR, you have the right to lodge a complaint with the Supervisory Authority if you believe that the processing of your personal data infringes the aforementioned Regulation.
CONTACT DETAILS OF THE DATA CONTROLLER AND DATA PROTECTION OFFICER (DPO)
The Data Controller is: Lungarno Alberghi S.r.l., with legal office in VIA TORNABUONI 2 - 50123 – (FI) E-mail address: privacy@lungarnocollection.com
The Data Protection Officer (DPO) can be contacted at the following e-mail address: dpo@lungarnocollection.com
