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Policy

 

Dear Customer,

At Emy Country House di Roberto De Santis, we have always paid attention to the protection of the personal data of all our Customers. Consequently, we are currently implementing a privacy management system based on the principles introduced by the new Regulation (EU) 2016/679, applicable from 25 May 2018, and the “Privacy Code” (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent.

Your personal data will be processed by Emy Country House di Roberto De Santis, as the Data controller, in a way that is both transparent and relevant and in accordance with the principles of lawfulness, and necessity under the current applicable provisions.

We also inform you that Emy Country House di Roberto De Santis has appointed the Data Processor Officer (DPO), contactable at: vicolake@cottagebeachvico.it

We thank you for your attention and look forward to welcoming you to our hotels.


Emy Country House di Roberto De Santis Team

Customer Information

Customer information under Regulation (EU) 679/2016 and the “Privacy Code” (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent decrees relating to the protection of personal data processing.

In accordance with Article 13 of the Regulation (EU) 679/2016 (Regulation) and the Privacy Code (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent decrees, hereinafter for the sake of brevity, Privacy, Emy Country House di Roberto De Santis S.p.A. (hereinafter “Emy Country House di Roberto De Santis”), as the Data Controller, hereby informs you that your personal data, and your or your underage children's special categories of personal data (Regulation Article 9), if any, provided by you shall be processed in a pertinent and transparent manner, and in compliance with the principles of lawfulness and necessity under the current governing regulations.

Purposes of the processing

The personal data shall be processed for institutional purposes associated with or useful for our Company's business, and therefore to:

a) perform the hotel accommodation service and related transactions, or one or more contractually agreed transactions;
b) comply with legal obligations of a tax, statutory, accounting and administrative nature;
c) meet internal operating and business needs of Emy Country House di Roberto De Santis, with respect to the service provided;
d) process the data of minors (in accordance with the applicable regulations) over whom you exercise parental authority, for the purpose of making reservations and registering at the hotel.
And, subject to your freely given, specific and unambiguous consent:
e) carry out profiling activities through automated or online data processing in order to provide customized promotions based on the choices and habits of the user;
f) supply, by email (newsletter) or conventional mail, information and/or surveys regarding Emy Country House di Roberto De Santis products or services, marketing, advertising and promotional initiatives reserved to Emy Country House di Roberto De Santis customers and implemented by Emy Country House di Roberto De Santis or by subsidiaries, affiliates or other related parties.

Legal basis of the processing
The legal basis of the data processing is the specific contractual relationship established and the freely given, specific and informed consent of the data subject.

Data processing method
The data will be processed with paper-based, electronic or telecommunication means, and with suitable security measures to safeguard the security and confidentiality of your personal data.

Data retention
In observance of the proportionality and necessity principles, the data shall not be retained for longer than is strictly necessary for the purposes stated above, thus for the service offered or compliance with specific laws.

Recipients of personal data
The data collected will be processed exclusively for the purposes stated above and may be communicated to subsidiaries, affiliates or other companies associated with the Emy Country House di Roberto De Santis Group, either in Italy or abroad, exclusively for the management of the services offered to Emy Country House di Roberto De Santis customers. Using adequate security measures put into place by the Data Controller, your data and your child's/children's data may also be communicated to law enforcement agencies and other public and private parties to comply with legal, tax, administrative, financial and similar obligations. The data will not be disseminated in any case.

Mandatory and optional supply of data
Whereas consent is not required for processing personal data preordained to the performance of the contract and fulfillment of the legal obligations referred to in the "Purposes of the processing" section, points a), b) c) and d), please note that:
- the supply of data for the purposes stated in points a), b) c) and d) above is optional, but necessary to perform the customer services, and the lack of consent could result in not allowing the service to be performed;
- the consent to processing for the purposes stated in point e) is freely given and optional, and the data subject may object at any time and in any event to such processing, easily and free of charge, by contacting the Data Controller, even by email, and obtain an immediate reply confirming the termination of such processing; notwithstanding the foregoing, refusal to supply the personal data requested could result in impossibility to be promptly updated on the new services offered by our company and to use some services and benefits reserved to Emy Country House di Roberto De Santis customers.

Rights of the data subject
The data subject may exercise his or her rights with the Data Controller under the Regulation, Article 15 and subsequent articles, i.e. he or she may obtain confirmation as to whether or not personal data concerning him or her are being processed, and obtain their communication in an intelligible form. The data subject shall also have the right to obtain the access, updating, rectification, integration, portability and erasure of the data and to impose limitations on their processing. Moreover, the data subject shall have the right to object, wholly or in part, for legitimate reasons, to the processing of his or her personal data, even if pertinent to the purpose for which it is collected, for the sending of advertising or direct sales materials and for conducting automated market research or business communications, without prejudice to his or her right to lodge a complaint to the supervisory authority. Those rights may be exercised by contacting the Data Controller, which shall provide, upon request, the complete and updated list of the Data Processors.
The requests shall be directed to the Data Controller.

Rights regarding deceased persons
In the hypotheses provided for in Articles 15 to 22 of the Regulation referring to personal data of deceased persons, the rights may be exercised by those who have a direct interest or are acting to protect the data subject in their capacity as authorized representative, or for family reasons deserving protection. The requests shall be directed to the Data Controller.

Protection of the data subject
If the data subject considers that the rights he or she enjoys under the Privacy Code have been violated, he or she may either submit a complaint to the Privacy Authority or lodge an appeal with the judicial authorities.

Data Controller
The Data Controller is Emy Country House di Roberto De Santis S.p.A., whose administrative offices are in Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

I AM STAR Customer Information

Disclosures in accordance with Regulation (EU) 679/2016, Article 13.
The I AM STAR program involves processing your personal data, which Emy Country House di Roberto De Santis carries out in complete observance of the fundamental rights and freedoms of the data subject, particularly with respect to confidentiality, personal identity and the right to personal data protection, for the following purposes:
a) issuance of access codes (user ID and password) for the reserved area of the www.cottagebeachvico.it website, with consequent periodic communication and supply of the benefits (discounts, services, advantages) provided by the program regularly or occasionally, and tailoring of service;
b) communication of other advertising and promotional initiatives reserved exclusively to the members of the program offered by Emy Country House di Roberto De Santis and by associates, related parties, subsidiaries, affiliates and business partners of Emy Country House di Roberto De Santis or by third parties engaged by Emy Country House di Roberto De Santis ;
c) compliance with legal obligations of a tax, statutory, accounting and similar nature.
The data collected will be processed using electronic and paper-based means, in full compliance with the minimum security measures, in accordance with Regulation (EU) 679/2016.
The data collected will be preserved and stored at the offices of Emy Country House di Roberto De Santis. Refusal to provide the personal data requested may result in impossibility to receive the access codes to the reserved Emy Country House di Roberto De Santis area, to use such codes and to use the associated benefits.
The personal data collected shall be processed exclusively for the purposes referred to herein and may be communicated to Emy Country House di Roberto De Santis associates, related parties, subsidiaries and affiliates, to partners of program or to third parties engaged by Emy Country House di Roberto De Santis exclusively for the management of the relevant benefits. Under Regulation (EU) 679/2016, Article 15, you may exercise your rights with the Data Controller at any time, i.e. you may obtain confirmation as to whether or not personal data concerning you are being processed, know the data content and source, verify the accuracy or obtain integration, updating or rectification of the data, pursuant to Regulation (EU) 679/2016, Articles 15 and 16. Under Regulation (EU) 679/2016, Article 17, I AM STAR program members also have the right to obtain the erasure, transformation into an anonymous form or blocking of data processed unlawfully, and to object to personal data processing for legitimate reasons or to object to the personal data processing for purposes of sending advertising or direct sales materials or for conducting market research or business communications, by contacting the Data Controller.

The Data Controller is Emy Country House di Roberto De Santis S.p.A., based in Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

tel. +39 3287236493

Consent under Regulation (EU) 679/2016, Article 7.

Live Chat Service Customer Info

Information for clients of the “Live Chat” service, pursuant to EU Regulation no. 679/2016 and the Italian Data Protection Act (Legislative Decree no. 196/2003), as amended by Legislative Decree no. 101/2018 et seq. regarding the processing and protection of personal data

Pursuant to article 13 of EU Regulation no. 679/2016 (the Regulation) and the Italian Data Protection Act (Legislative Decree no. 196/2003) as amended by Legislative Decree no. 101/2018 et seq. (for the sake of brevity, the Privacy law), Emy Country House di Roberto De Santis (hereinafter “Emy Country House di Roberto De Santis”), in its capacity as the Data Controller, would like to inform you that the personal data you provide will be processed in a way that is pertinent, transparent and compliant with the principles of lawfulness and necessity, in accordance with the relevant measures in force.

Purpose of Processing

In this regard, please note that your personal data (name, surname, e-mail, tel. no.) and the content of the chat will be processed for the following purposes:

  • To respond to requests for information regarding products, services, commercial, advertising and promotional activities provided by Emy Country House di Roberto De Santis or its subsidiaries, affiliates or companies connected therewith.

Legal basis for processing

The legal basis for processing refers to the specific contractual relationship established, to which the data subject is party, or to the carrying out of pre-contractual measures adopted at the request of the data subject (art. 6, para. 1, lett. b) of the Regulation)

Means of data processing

Personal data will be processed using IT or electronic tools and with adequate security measures designed to guarantee the security and confidentiality of your personal data.

Data retention period

In observance of the principles of proportionality and necessity, data will not be stored for any longer than the time strictly necessary to achieve the purposes indicated above

Recipients of the personal data

The data collected will be processed exclusively by physical persons authorised by the Data Controller for the performance of work tasks, and may be transmitted to subsidiaries, affiliates or companies connected with Emy Country House di Roberto De Santis Group, both in Italy and abroad. In observance of the adequate safety measures implemented by the Data Controller, personal data may also be transmitted to public security bodies and other public or private subjects for the purpose of compliance with obligations established by law. Personal data may also be shared with third parties acting, on a contractual basis, in the capacity of data managers, pursuant to art. 28 of the Regulation.

Mandatory and non-mandatory provision of data

Without prejudice to the fact that, with regard to the processing of data necessary for the execution of the contract or for the precontractual measures referred to in the paragraph “Purpose of processing”, it is not necessary to provide consent, please note that it is not mandatory to provide such data, because they are not required to complete the request for information.

Rights of the data subject

Subjects to whom the personal data refer may exercise their rights vis-à-vis the Data Controller, pursuant to article 15 et seq. of the Regulation, i.e. they may obtain confirmation of the existence of their personal data and request the communication thereof in an intelligible form. They are also entitled to obtain access to, updating, rectification, integration and deletion of data or restrictions on their processing. They also have the right to oppose the processing of their personal data, in full or in part, for legitimate reasons, even if said processing is pertinent to the purpose for which they were collected. They have the right to data portability, to file a complaint with the supervisory authority, and to oppose the sending of advertising or direct sales material, or material for market research or commercial communications, by contacting the Data Controller, who can also provide, on request, a complete, updated list of the Data Managers.

Requests must be made to the Data Controller.

Protection of data subjects

If the data subject considers that his or her rights based on the privacy regulations have been infringed, s/he may alternatively file a complaint with the Data Protection Authority or present an appeal to the legal authority.

Data Controller

The Data Controller is Emy Country House di Roberto De Santis Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

 

Live Chat Service Customer Info

Information for clients of the “Live Chat” service, pursuant to EU Regulation no. 679/2016 and the Italian Data Protection Act (Legislative Decree no. 196/2003), as amended by Legislative Decree no. 101/2018 et seq. regarding the processing and protection of personal data

Pursuant to article 13 of EU Regulation no. 679/2016 (the Regulation) and the Italian Data Protection Act (Legislative Decree no. 196/2003) as amended by Legislative Decree no. 101/2018 et seq. (for the sake of brevity, the Privacy law), Emy Country House di Roberto De Santis S.p.A. (hereinafter “Emy Country House di Roberto De Santis”), in its capacity as the Data Controller, would like to inform you that the personal data you provide will be processed in a way that is pertinent, transparent and compliant with the principles of lawfulness and necessity, in accordance with the relevant measures in force.

Purpose of Processing

In this regard, please note that your personal data (name, surname, e-mail, tel. no.) and the content of the chat will be processed for the following purposes:

  • To respond to requests for information regarding products, services, commercial, advertising and promotional activities provided by Emy Country House di Roberto De Santis or its subsidiaries, affiliates or companies connected therewith.

Legal basis for processing

The legal basis for processing refers to the specific contractual relationship established, to which the data subject is party, or to the carrying out of pre-contractual measures adopted at the request of the data subject (art. 6, para. 1, lett. b) of the Regulation)

Means of data processing

Personal data will be processed using IT or electronic tools and with adequate security measures designed to guarantee the security and confidentiality of your personal data.

Data retention period

In observance of the principles of proportionality and necessity, data will not be stored for any longer than the time strictly necessary to achieve the purposes indicated above

Recipients of the personal data

The data collected will be processed exclusively by physical persons authorised by the Data Controller for the performance of work tasks, and may be transmitted to subsidiaries, affiliates or companies connected with Emy Country House di Roberto De Santis Group, both in Italy and abroad. In observance of the adequate safety measures implemented by the Data Controller, personal data may also be transmitted to public security bodies and other public or private subjects for the purpose of compliance with obligations established by law. Personal data may also be shared with third parties acting, on a contractual basis, in the capacity of data managers, pursuant to art. 28 of the Regulation.

Mandatory and non-mandatory provision of data

Without prejudice to the fact that, with regard to the processing of data necessary for the execution of the contract or for the precontractual measures referred to in the paragraph “Purpose of processing”, it is not necessary to provide consent, please note that it is not mandatory to provide such data, because they are not required to complete the request for information.

Rights of the data subject

Subjects to whom the personal data refer may exercise their rights vis-à-vis the Data Controller, pursuant to article 15 et seq. of the Regulation, i.e. they may obtain confirmation of the existence of their personal data and request the communication thereof in an intelligible form. They are also entitled to obtain access to, updating, rectification, integration and deletion of data or restrictions on their processing. They also have the right to oppose the processing of their personal data, in full or in part, for legitimate reasons, even if said processing is pertinent to the purpose for which they were collected. They have the right to data portability, to file a complaint with the supervisory authority, and to oppose the sending of advertising or direct sales material, or material for market research or commercial communications, by contacting the Data Controller, who can also provide, on request, a complete, updated list of the Data Managers.

Requests must be made to the Data Controller.

Protection of data subjects

If the data subject considers that his or her rights based on the privacy regulations have been infringed, s/he may alternatively file a complaint with the Data Protection Authority or present an appeal to the legal authority.

Data Controller

The Data Controller is Emy Country House di Roberto De Santis Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

 

 

Company Operator Info

Information to be provided to Tour Operators and Companies pursuant to article 13 of Regulation (EU) 2016/679 and the “Privacy Code” (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent decrees relating to the protection of personal data processing

In accordance with Article 13 of the Regulation (EU) 679/2016 (Regulation) and the Privacy Code (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent decrees, hereinafter for the sake of brevity, “Privacy”, EMY COUNTRY HOUSE DI ROBERTO DE SANTIS S.p.A., as the Data controller, informs that the Tour Operator’s and Company’s (hereinafter for the sake of brevity “Customer”) personal data will be processed in a way that is both transparent and relevant and in accordance with the principles of lawfulness, and necessity under the current applicable provisions.

Purposes of the processing
Data are collected and processed in order to:
1. fulfil all transactions required by regulatory obligations;
2. carry out the transactions strictly connected and instrumental to the starting of the relationship between Emy Country House di Roberto De Santis and the Customer, including the acquisition of information preliminary to the signing of the contract;
3. manage the relationships related to administrative and accounting activities, orders, shipping, invoicing, services and any disputes;
4. carry out the assessment, where necessary, based on the GDPR EU 2016/679 and the “Privacy Code” (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent decrees; and will be processed in accordance with the principles of correctness, lawfulness, transparency and protection of your confidentiality and your rights.
The contractual, product and service provided, trade and other disputes and promotional purposes cover the processing of the Customer’s data only. The Customer’s data will be processed throughout the entire term of the contracts agreed and also subsequently to fulfil all legal obligations and for future trade purposes.

Means of processing
The treatment of data for the above purposes will take place through both automated, electronic or magnetic and non-automated, paper-based means in accordance with the rules of confidentiality and security provided by the law, the related regulations and internal policies.

Place of data processing
The data are currently processed and stored at the Data controller’s administrative offices in Viale Belfiore 27, 50144, Florence. Furthermore, personal data are processed on behalf of the Data controller, by professionals and/or companies which can provide technical, development, management and administrative/accounting activities.

Mandatory or optional nature of the data provision
Some data are necessary to commence the contractual relationship or to execute it, while other data can be considered as ancillary for those purposes. The provision of data is mandatory only to the extent of the data which are subject to a legislative or contractual obligation.

Consequences of refusing consent to the provision of data
Where the provision of data is required by a regulatory or contractual obligation, any refusal to do so would prevent the Supplier from performing or continuing the contract as it would result in unlawful processing. Where the provision of data is not subject to any regulatory obligation, the refusal to do so would not result in the above consequences, however, it would prevent the performance of ancillary transactions.

Data communication
Without prejudice to the communication and dissemination of data required by regulatory obligations, your personal data may be communicated in Italy and/or abroad to:
• Professionals and consultants, advisory companies, factoring companies, credit institutions, credit collection companies, credit insurance companies, commercial information companies and transport companies;
• Public or private bodies, including as a result of inspections and audits, such as: the tax authorities, the tax police, judicial authorities, the Italian foreign exchange office, the Labour inspectorate, ASL (Italy’s local healthcare authorities), social security institutions, ENASARCO (Italy’s social security institution for agents), the Chamber of commerce, etc.;
• Other Emy Country House di Roberto De Santis companies, including those based abroad;
• Parties with access to your data as per the provisions of the law.

Data retention
The data provided will be stored in our archives in accordance with the following:
▪ with respect to administrative, accounting and order-related activities and the management of quotes and the entire production, support, maintenance, shipping, invoices, services and dispute flows: 10 years as per the article 2220 of the Italian Civil Code, without prejudice to late payment of the fees which justify the extension;
▪ for marketing purposes: 24 months.
The personal data shall be stored for no longer than is necessary for the purposes for which the personal data are processed, in accordance with article 5.e of the Regulation (“Data Retention”).
At Emy Country House di Roberto De Santis’ choice, the Supplier shall delete or return all the personal data after the end of the provision of services relating to processing, and delete existing copies, in accordance with article 28.f, of the Regulation.

Data breach
In the case of a personal data breach, which results in a risk to the rights and freedoms of natural persons, the Data controller shall without undue delay notify the Supervisory Authority, in accordance with article 33 of the Regulation (“Data breach”).

Rights of the data subject
With respect to personal data, the data subject may exercise their rights pursuant to article 15 and following articles of the Regulation within the limits and conditions laid down in the relevant articles. The data subject may revoke any consent to data processing given to Emy Country House di Roberto De Santis S.p.A. at any time, though without prejudice to the mandatory obligations required by the legislation in force when the request for revocation was made, by contacting the Data controller via the contact details below.

Data controller
The Data controller you may contact to exert the rights covered by the above article is Emy Country House di Roberto De Santis S.p.A., with administrative offices in Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

 

 

Suppliers

Information to be provided to suppliers pursuant to article 13 of Regulation (EU) 2016/679 and the Privacy Code (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent decrees relating to the protection of personal data processing.

In accordance with Article 13 of the Regulation (EU) 679/2016 (Regulation) and the Privacy Code (Legislative Decree 196/2003) as amended by Legislative Decree 101/2018 and subsequent decrees, hereinafter for the sake of brevity, Privacy, Emy Country House di Roberto De Santis S.p.A. (hereinafter “Emy Country House di Roberto De Santis”), as the Data controller, informs that the Supplier’s personal data will be processed in a way that is both transparent and relevant and in accordance with the principles of lawfulness, and necessity under the current applicable provisions.

Purposes of the processing

Data are collected and processed in order to:
1. fulfil all transactions required by regulatory obligations;
2. carry out the transactions strictly connected and instrumental to the starting of the relationship between Emy Country House di Roberto De Santis and the Supplier, including the acquisition of information preliminary to the signing of the contract;
3. manage the relationships related to administrative and accounting activities, orders, shipping, invoicing, services and any disputes;
4. carry out the assessment, where necessary, based on ISO 9001:2015 specifications, Legislative decree no. 196/03 and the GDPR EU 2016/679;

and will be processed in accordance with the principles of correctness, lawfulness, transparency and protection of your confidentiality and your rights.
The contractual, product and service purchase, trade and other disputes and promotional purposes cover the processing of the Supplier’s data only. The Supplier’s data will be processed throughout the entire term of the contracts agreed and also subsequently to fulfil all legal obligations and for future trade purposes.

Means of processing
The treatment of data for the above purposes will take place through both automated, electronic or magnetic and non-automated, paper-based means in accordance with the rules of confidentiality and security provided by the law, the related regulations and internal policies.

Place of data processing
The data are currently processed and stored at the Data controller’s administrative office in Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it more, personal data are processed on behalf of the Data controller, by professionals and/or companies which can provide technical, development, management and administrative/accounting activities.

Mandatory or optional nature of the data provision
Some data are necessary to commence the contractual relationship or to execute it, while other data can be considered as ancillary for those purposes. The provision of data is mandatory only to the extent of the data which are subject to a legislative or contractual obligation.

Consequences of refusing consent to the provision of data
Where the provision of data is required by a regulatory or contractual obligation, any refusal to do so would prevent the Supplier from performing or continuing the contract as it would result in unlawful processing. Where the provision of data is not subject to any regulatory obligation, the refusal to do so would not result in the above consequences, however, it would prevent the performance of ancillary transactions.

Data communication
Without prejudice to the communication and dissemination of data required by regulatory obligations, your personal data may be communicated in Italy and/or abroad to:

  • Professionals and consultants, advisory companies, factoring companies, credit institutions, credit collection companies, credit insurance companies, commercial information companies and transport companies;

  • Public or private bodies, including as a result of inspections and audits, such as: the tax authorities, the tax police, judicial authorities, the Italian foreign exchange office, the Labour inspectorate, ASL (Italy’s local healthcare authorities), social security institutions, ENASARCO (Italy’s social security institution for agents), the Chamber of commerce, etc.;

  • Other Emy Country House di Roberto De Santis companies, including those based abroad;

  • Parties with access to your data as per the provisions of the law.

Data retention
The data provided will be stored in our archives in accordance with the following:

  • With respect to administrative, accounting and order-related activities and the management of quotes and the entire production, support, maintenance, shipping, invoices, services and dispute flows: 10 years as per the article 2220 of the Italian Civil Code, without prejudice to late payment of the fees which justify the extension;

  • For marketing purposes: 24 months.

The personal data shall be stored for no longer than is necessary for the purposes for which the personal data are processed, in accordance with article 5.e of the Regulation (“Data Retention”).

At Emy Country House di Roberto De Santis’ choice, the Supplier shall delete or return all the personal data after the end of the provision of services relating to processing, and delete existing copies, in accordance with article 28.f, of the Regulation.

Data breach
In the case of a personal data breach, which results in a risk to the rights and freedoms of natural persons, the Supplier (as the external data processor, where appointed) shall without undue delay notify the Data controller of the personal data breach, in accordance with article 33 of the above Regulation (“Data breach”).

Rights of the data subject
With respect to personal data, the data subject may exercise their rights pursuant to article 15 and following articles of Regulation within the limits and conditions laid down in the relevant articles. The data subject may revoke any consent to data processing given to Emy Country House di Roberto De Santis S.p.A. at any time, though without prejudice to the mandatory obligations required by the legislation in force when the request for revocation was made, by contacting the Data controller via the contact details below.

Data controller
The Data controller you may contact to exert the rights covered by the above article is Emy Country House di Roberto De Santis Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

 

Video Surveillance

Information pursuant to article 13 of Regulation (EU) 2016/679 and article 3.1 of the Measure of the Data protection authority dated 8 April 2010
Pursuant to article 13 of Regulation (EU) 2016/679 (the "Regulation") and article 3.1 of the Measure of the Data protection authority dated 8 April 2010, EMY COUNTRY HOUSE DI ROBERTO DE SANTIS , as the Data controller,

NOTIFIES

that a closed-circuit surveillance system operates at our hotels in accordance with the Measure of the Data protection authority dated 8 April 2010.

Purposes of the processing
The personal data of the data subjects, comprised, specifically, of their images obtained during recording, are collected solely for the following purposes:
a) Safety: protecting the safety of the company's workers and/or collaborators, and of third parties;
b) Protecting company assets: preventing thefts, robberies, damage, assaults and acts of vandalism.

Data are lawfully processed also without the explicit consent of the concerned parties, pursuant to article 6.2.2.1 of the above Measure.

Means of processing
Data are processed electronically in accordance with adequate data security and protection measures and for the above-mentioned purposes.
Specifically, when processing data, the company declares that it complies with the following principles:
- Lawfulness of data processing: data processing through video-surveillance systems is carried out correctly and for specific and legitimate purposes (safety and protection of assets).
- Necessity of data processing: the company undertakes not to use the systems excessively and unnecessarily.
- Proportionality of data processing: the data collected are those strictly necessary to achieve the above-mentioned purposes.

Data dissemination and Communication to third parties
The data in question will not be disseminated and will not be communicated unless specifically requested by the police or the court.

Minimum information
The data subjects are properly informed using panels (simplified information) located in the areas and the premises subject to videosurveillance.

Image retention period
Images are recorded and stored in accordance with article 3.4 of the Measure of the Data protection authority dated 8 April 2010. Specifically, the data obtained will be stored for up to five days. After this time limit, the data will always be deleted by means of overwriting, except when requested by the police or the court or, however, as a result of criminal events, damage to company assets, unauthorised access to the premises by personnel and/or third parties or thefts of company materials and products.

Data controller
The Data Controller is Emy Country House di Roberto De Santis S.p.A., whose administrative offices are in Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

 

Appointment of the Data processor and the person in charge of data processing
The Data controller appointed in writing the Data processor and the person in charge of data processing authorised to access the premises where the control points are located and to use the systems and, where necessary for the purposes to be achieved, to view the images and/or obtain copy thereof in accordance with article 3.3.2 the Measure.

Rights of the data subject
The data subjects have the right, at all times, to obtain confirmation of the existence or non-existence of the data and information on the content and origin, to verify the correctness of the data or to request data integration, erasure or rectification (articles 15 and following of Regulation (EU)).
Furthermore, they have the right to request the correction of any inaccurate personal data or the erasure, the restriction of processing and the portability of the data and to lodge a complaint with a supervisory authority and, in any case, to object such processing, for legitimate reasons (articles 17 and following of the Regulation).

Requests are to be sent to the Data controller.

 

Cookies

NOTE ON EMY COUNTRY HOUSE DI ROBERTO DE SANTIS COOKIE POLICY

Emy Country House di Roberto De Santis.com and the provider of our reservation system, Travelclick, Inc, like most other websites, may store or retrieve information on your browser, mostly in the form of ‘cookies’. This information may refer to users, their preferences or the device used to access the internet (computer, tablet or mobile) and is mainly used to make the website operate in accordance with users’ expectations, offering a more customised browsing experience and storing the choices made earlier.

Below you can find out more about the different cookies we use. If you want, you can prevent the setting of all or some cookies. However, this may comprise the use of the website or the services offered.

Strictly Necessary Cookies
These cookies are necessary for the website to function properly. They enable you to navigate around the site, search for flights and other services, and make bookings.
Without these cookies we could not provide the services that you come to the site for.

Performance Cookies
These cookies allow us to understand how visitors use our site, so we can measure and improve how the site works. For example they help us to know which pages are the most and least popular. They count things like the number of visitors, how long people spend on the site and how they find it. This lets us know where we are doing well, and where we can improve, as well as making sure the pages load quickly and display properly.
All information these cookies collect is anonymous and not tied to any personal information about you. We use services from Google, Adobe and Marin Software to perform these functions.

Cookies
These cookies are used to enable us to provide enhanced functionality, and more personal information and features. This includes being able to watch YouTube videos, providing information about certain destinations, and also allowing you to share content through social networks.

These services are mostly provided by third parties. If you have an account, or use the services of these parties on other websites, then they may be able to know that you have visited our sites. The use of data collected through cookies by those third parties is subject to their own privacy policies; therefore we identify these cookies by the parties setting them.

Targeting/Advertising Cookies
These cookies are used to deliver adverts that are relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.
They are placed by our advertising network partners and help to support our investment in the websites – so we can keep our fares as low as possible. They may also be used to show you relevant advertisements on other websites you visit.
The actual cookies they set can change from one moment to the next – so rather than list them here, we identify the companies themselves.

Opting Out of Cookies
If you have any concerns about our use of cookies, you can take action to prevent them being set, including changing your browser settings to block certain types of cookies.
For detailed information on how to do this, look in your browser’s help information.

Advertising companies also enable you to opt-out of receiving targeted advertising, if you would prefer to do so. This does not stop cookies from being set, but it does stop these companies using and collecting some data.

Below is a list of cookies set by this site:

• PHPSESSID
• __utma
• __utmb
• __utmc
• __utmz
• acs
• clid
• ipinfo
• uvc

Data can be processed using IT, paper, digital, electronic or magnetic tools. The collected data will be kept and stored at Emy Country House di Roberto De Santis Caprarola 01032 loc Procojo snc vicolake@cottagebeachvico.it

. They will be used exclusively for the above-mentioned purposes and may be communicated to associates, related companies or subsidiaries of Emy Country House di Roberto De Santis Group, in Italy and abroad, to manage the benefits reserved to Emy Country House di Roberto De Santis’ customers.

In compliance with the minimum security measures, your data may also be disclosed to the public safety and other public and private entities for the fulfilment of obligations under the law, including tax, administrative, financial and similar laws. In no event will the data be disclosed.
In accordance with the principles of necessity and proportionality, the data will not be stored for periods longer than those necessary to achieve the above purposes and, therefore, the service provided or specific law provisions.

You will be able to exercise your rights towards the Data controller at any time in accordance with article 15 and subsequent articles of Regulation (EU) 679/2016, allowing you to obtain confirmation of your personal data and their communication in intelligible form. You will also have the right to obtain updating, rectification, integration and deletion of data or to restrict processing. Finally, you will have the right to object to, in whole or in part, for legitimate reasons, the processing of personal data, even for the purpose of collecting and sending advertising materials or direct selling or for carrying out market research or commercial communications by contacting the Data controller, with which there is also available, on request, the complete and updated list of Processors.

You will also have the right either to file a complaint with the Privacy Authority or lodge an appeal with the judicial authorities.

The Data controller is Emy Country House di Roberto De Santis - 01032, loc Procojo snc , Tel. + 39 3287236493 - e-mail: vicolake@cottagebeachvico.it