Privacy notice pursuant to article 13 of regulation (EU) 2016/679
and of D. Lgs 101/18 on the protection of personal data and on the processing and free movement of such data
Romeo Alberghi s.r.l., in its capacity as Data Controller, provides you with complete information as per art. 13 and art. 14 of Regulation (EU) 2016/679 (hereinafter Regulation) and in accordance with the articles from 15 to 22, and art. 34 in relation to the processing of personal data in a lawfully, fairly, and transparent manner. Personal data are easy to access, written in a clear and understandable language, particularly in case of information destinated to children (under the age of 18 y.o.).
Romeo Alberghi affords all the rights to guests and stakeholders pursuing to the articles from 15 to 22, providing information concerning the advancement of your request. Romeo Alberghi will respond to your request in a reasonable timeframe, and in any event in less than 30 days. Any inability to reply or delays on the part of the data controller will be justified.
ROMEO ALBERGHI s.r.l.
NAPOLI, CENTRO DIREZIONALE ISOLA E/4 - 80143
Reg. no: 07822410630
phone: 081 60 41 200
email: [email protected]
The personal data provided are processed also with the aid of information technology for the following purposes:
- to achieve and confirm any hotel stays, reservations and to provide any other services offered;
- Persuant to arts 6. Lett. a, b, c, d, e, f, and arts 9. Par 1, 2 lett. a, b, c, d, e, f, g, h, i, j, par 3 of G.D.P.R. for the following purposes:
- Signing and mangement of contracts;
- Administrative management;
- Legal obligations;
- In order to fulfill the obligation proposed by “Unique Text of Public Security Laws” (art.109 R.D. 18.6.1931 no.773) requiring us to communicate to Police Headquarters, for public security reason, our guests’ identity according with the Ministry of Interior settled arrangement (7th of January 2013 decree). The acquired data for these purposes are not kept by us, with the exception of your given consent to keep them;
- Legitimate interest of the Data Controller;
- In order to fulfill the administrative, accounting and fiscal requirements;
- In order to carry out the receiving function of messages and telephone calls, email; to send you promotional messages, updates about our rates and special offers. Eventually, for advertising and others kind of marketing activities in accordance with the provisions of “considerando n.47 of Regulation EU 679/2016);
- In order to protect people, the property and the corporate asset a CCTV system is placed in some areas inside the hotel, specified by special signs.
Data will be processed as it follows:
- Personal data are processed in a in automated and/or manual form, or collected through other entities (such as: OTAs, booking channels, travel agencies, institutions, associations, organizations who others entities who organize events or stays in hotel) complying with the principles of lawfulness, fairness, transparency, purpose and retention limitation, data minimisation, accuracy, integrity and confidentiality;
- Personal data are collected according to the purposes described and justified on the legal basis, your personal will be retained as long as it is necessary to fulfil the obligations undertaken. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time;
- your personal information is accurate, complete, and up-to-date;
- maintaining the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.
Personal data will be processed in strict compliance with legal requirements, in accordance with principles of lawfulness and ethics and without breaching your rights to privacy. Personal data will be legally processed for:
- Issue consent;
- Contractual and pre-contractual obligations;
- Legal obligations;
- Legitimate interest of Romeo Alberghi
Romeo Alberghi is able to give evidence of what above said through the data processing register for GDPR compliance.
Your data may be transferred to and processed by other entities for the fulfillment of precontractual, contractual or statutory obligations, or on the grounds of legitimate interest. Categories of recipients may therefore include:
- People in charge of data processing
- Data Processors
- System administrators
- Legal advisers
- Insurance companies
- Internet and email service provider companies
- Public authority
- Police forces (Questura di Napoli)
- Institutions, associations, organizations, business or individuals who organize events or stays at the hotel.
All the above data collected are not publicly disseminated nor transferred to non-UE countries.
Your data will be stored for the time strictly necessary for the performance of the activities related to the purposes set out in this statement. In particular, the storage times will be:
- 10 years (as envisaged by Italian Civil Law art. 2220 Civil Code);
- No more than 1 year for data concerning access to and use of ICT resources;
- No more than 3 years from last check- out /registration for personal data, special data, stay- related data, personal references, identification papers signature, purchasing record and marketing data for sending promotional email about special offers, unless otherwise specified by the data subject;
- No more than 24 H for security camera images, salvo festivi o altri casi di chiusura dell’esercizio, e comunque non oltre una settimana.
- No more than 1 year for the storage of CVs (any format).
- No more than 3 years for the storage of the successful candidates’ interview forms.
We may transfer personal data to our service providers and professional advisors, public and governmental authorities, Romeo Alberghi’s affiliates or third parties in connection with Romeo Alberghi’s operation of its business.
In all cases, longer storage periods will apply if required by specific regulations in the sector. Personal data will be stored until the end of the expiration period envisaged by law for the protection of rights relating to the contractual relationship, unless otherwise specified by the subjects.
Via a specific written communication, sent by certified email or registered letter with return receipt to Romeo Alberghi’s address, you have:
- Right of access to data (art. 15, GDPR)
To obtain from Romeo Alberghi confirmations as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and specific information detailed in art. 15 of the GDPR.
- Right of rectification (art. 16, GDPR)
To obtain from Romeo Alberghi, without undue delay, the rectification of inaccurate personal data concerning you, depending on the purposes of the processing, you also have the right to the supplementation of incomplete personal data, also by providing an additional statement.
- Right to erasure (art. 17, GDPR)
To obtain from Romeo Alberghi the erasure of personal data concerning you without undue delay, and Romeo Alberghi has the obligation to erase your personal data without undue delay, unless there are grounds impeding the exercise of the above right.
- Right to restriction of processing (art. 18, GDPR)
To obtain the restriction of processing of your personal data when possible, or to withdraw consent given previously. The withdraw of consent is without prejudice to the lawfulness of the processing prior to the withdrawal.
- Notification obligation regarding rectification or erasure of personal data or restriction of processing (art. 19, GDPR)
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
- Right to the portability of the data (art. 20, GDPR)
If the processing is based on consent or on a contract, and is undertaken by automated means, you have the right to receive the personal data concerning you, which you have the right to receive the personal data concerning you, which you have provided to the controller, in a structure, commonly used and machine- readable format and to transmit them to another data controller, or have them transferred by the controller itself, if technically feasible.
- Right to object (art. 21, GDPR)
The right to object, on grounds relating to your situation at any time to processing of personal data concerning you which is based on the legitimate interest of Romeo Alberghi or your consent, including profiling, unless Romeo Alberghi demonstrates compelling legitimate grounds for the processing which override your rights.
- Automated individual decision-making, including profiling (art.22, GDPR)
The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. All what is said shall not apply if the decision:
- is based on your explicit consent;
- is necessary for entering into, or performance of, a contract between the data subject and a data controller.
- The right to lodge a complaint with a supervisory authority (art. 77, GDPR)
Without prejudice to any other administrative or judicial remedy, if you consider that the processing of personal data relating to you infringes these regulations, you may lodge a complaint with the Supervisory Authority, and exercise all your rights under current legislation in general (www.garanteprivacy.it).
Romeo Alberghi S.R.L.
All texts, photographs, film clips, graphics, tables, images, information and software of this website are protected pursuant to the laws on copyright, patents and intellectual property.
The brands, denominations and companies mentioned on this site belong to their respective owners or holders and may be protected by patents and/or copyright granted or registered by the relevant authorities; therefore, they may be downloaded or used only for personal and not commercial use; nothing, not even in part, may be reproduced, modified or resold for profit.
The objects, products, programmes and routines which may be present and downloaded, such as, for example, technical documentation, commercial documentation, software, etc., are available solely on the conditions indicated on the website.
The documentation reported on the website originating from third parties, has no legal value and it is necessary to refer to the original text for the purposes of verifying its contents.
USE OF THE WEBSITE
Romeo Alberghi s.r.l. cannot be considered responsible for damage of any kind caused directly or indirectly by accessing the site, by the use of the interactive instruments, by the inability or impossibility of accessing the site, or by the use of the information contained on it. Quotes are allowed by way of reporting or review, only if accompanied by indication of the source and its URL: www.romeohotel.it
Romeo Alberghi s.r.l. reserves the right to change the content of the site and its legal notes at any time and without prior notice.
Romeo Alberghi s.r.l. is not responsible for information obtained by accessing sites which may be reached through hyperlinks, nor can it guarantee that a document available online reproduces the official text to the letter.
Processing of any personal data received via electronic mail or electronic templates, also at the time of registration, complies with the provisions of current Italian privacy regulations (Italian Legislative Decree no. 196 of 30 June 2003 – “Personal Data Protection Code”).
Following consultation of this site, data relating to identified or identifiable persons may be processed. The proprietor of their processing is the company:
Romeo Alberghi Srl – Via Giovanni Porzio 4 Centro Direzionale is. E/4 80143 Naples – Italy, in the person delegated for this purpose by the legal representative pro tempore, who is domiciled for the office at the headquarters of the Company.
The data supplied may be subject to processing consisting of their collection, recording, organisation, storage and adaption, alteration, selection, retrieval, consultation, use, alignment, blocking, disclosure, erasure and destruction, or of a combination of two or more of such operations. The processing concerned will in any case take place for requirements connected with the service requested. It will take place manually or in an automated manner and, in any case, using tools able to assure security and privacy, in compliance with and based on adoption of the regulatory security measures in force at any given time.
The data will not be transferred to third parties and will be used exclusively for communications relating to the site and its contents and for any dispatch of information on topics relating to site contents.
Pursuant to Article 7 of Italian Legislative Decree 196/2003, the parties to whom personal data refer can at all times exercise their right to access such data and exercise the rights provided for in the article mentioned, i.e. confirmation or otherwise of the personal data’s existence, availability to the parties concerned of data in an understandable form, their erasure, transformation into anonymous form or the blocking of any data processed in breach of legislation, updating, and rectification or, if appropriate, addition to the data concerned. The parties can also oppose processing for legitimate reasons. All requests should be sent to: [email protected].
Anything received at the e-mail address indicated above (requests, suggestions, ideas, information, materials, etc.) will not be considered confidential information or data. It must not violate the rights of others and must contain valid, truthful information that does not harm others’ rights. In any case, no responsibility whatsoever can be attributed to the company for the content of messages.
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