Owner and Data Controller
Via Zocco 101
36047 Montegalda (VI)
Owner contact email: firstname.lastname@example.org
we wish to inform you that, according to Par. 13 of Italian Code on Privacy (Legislative Decree 196/2003) and Par. 13 of Regulation (EU) 2016/679, the processing of your personal details will occur through fairness and transparency, for legal purposes and protecting your privacy and your rights. The processing of personal data takes place, under the authority of the data controller, by persons specifically appointed, authorized and instructed to processing in accordance with Article 30 of the Privacy Code and Articles 28 and 29 of the Privacy Regulation, using manual tools , computerized or telematic, with logic strictly related to the purposes and in any case in such a way as to guarantee the confidentiality and security of personal data. Personal data will be stored for a fixed period based on criteria based on the nature and duration of the Charge and on the needs of protection of the Client’s interests.
The processing will also be carried out through computerised systems for the following purposes:
- Fulfilment of the obligation deriving from Par. 109 of Royal Decree 18/6/1931 n. 773, requiring that we register and communicate our guests’ personal details to the Police;
- To comply with the administrative, accounting and fiscal obligations in force;
- To complete our reception duties for messages and phone calls on your behalf;
- To speed up registration procedures in case of future stays at our agriturismo;
- To send you our promotional and up-dating messages about our tariffs and special offers.
In addition, we wish to inform you that the contribution of these details as foreseen in point 1 and 2 is mandatory and that any refusal on your part to reply will make it impossible for us to accept you as a guest in our agriturismo. Nevertheless, if you wish to allow the processing of your personal details as foreseen in points 3, 4 and 5, you will have to give us your authorization. Such authorization can be cancelled at a later stage and you will be able to oppose the processing of such details. For any further information or to assert your rights, recognized by Par. 7 of the Privacy Code (Legislative Decree 196/2003) and by Par. 15 and following of Regulation (EU) 2016/679, please contact the Manager in charge of the processing.
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, phone number and email address.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics and Contacting the User.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contact form (Ninja Forms)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name, last name and phone number.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
- Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
- Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
- Data Subject
The natural person to whom the Personal Data refers.
- Data Processor (or Data Supervisor)
- Data Controller (or Owner)
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, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
- This Application
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
- European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
- Legal information
Pursuant to current legislation on the protection of personal data (EU Regulation No. 679 of 2016), we wish to inform you that the processing of your personal data is carried out fairly and transparently, for lawful purposes and protecting your privacy and your rights.
Processing is also carried out with the aid of computerised means for the following purposes:
1. to acquire and confirm your booking of accommodation and ancillary services, and to provide the services requested. Since this processing is necessary for the definition of the contractual agreement and for its subsequent implementation, the provision of data is mandatory. If you refuse to provide us with your personal data, we will not be able to confirm your booking or provide you with the requested services. Processing will cease after your departure, but some of your personal data may or must continue to be processed for the purposes and in the manner indicated in the following points;
2. to fulfil the obligation provided for by the “Testo unico delle leggi di pubblica sicurezza” (article 109 R.D. 18.6.1931 n. 773) which requires us to communicate to the Police Headquarters, for the purposes of public safety, the personal details of the customers accommodated in accordance with the procedures established by the Ministry of the Interior (Decree of 7 January 2013). The provision of data is compulsory, and in case of refusal to provide them we will not be able to accommodate you in our facility. The data acquired for this purpose are not stored by us;
3. to fulfil current administrative, accounting and fiscal obligations. For these purposes, the data is processed without the need to obtain your consent. The data are processed by us and by our employees, and are communicated externally only in fulfilment of legal obligations. In the event that you refuse to provide us with the data necessary for the above-mentioned purposes, we will not be able to provide you with the requested services. The data collected for these purposes will be stored by us for the period of time prescribed by the respective regulations (10 years, and even longer in the case of tax inspections);
4. to speed up registration procedures in the event of your subsequent stays at our facility. For this purpose, after having obtained your consent at the time of your arrival at our facility, which may be revoked at any time, your data will be stored and will be used when you are our guest again for the purposes referred to in the previous points;
5. to send you our promotional messages and updates on our rates and offers. For this purpose, after obtaining your optional consent, your data will be stored and will not be disclosed to third parties. You may withdraw your consent at any time;
We would also like to inform you that the European Regulation grants you certain rights, including the right of access and rectification, or cancellation or restriction or opposition to processing, as well as the right to data portability, if and to the extent applicable (Articles 15 to 22 of EU Regulation No. 679 of 2016). You may also lodge a complaint with the supervisory authority, in accordance with the procedures provided for in the applicable legislation.
For any further information, and to enforce the rights granted to you by the European Regulation, you may contact:
Agriturismo Fattoria Grimana
Licia and Riccardo Lotto
Par. 15 and following of Regulation (EU) 2016/679:
Right to access your personal details and other rights
- The concerned person is entitled to obtain a confirmation that his/her personal details are – or are not being processed – even though these details have not been registered yet, and to obtain their communication in intelligible form.
- The concerned person is entitled to obtain information about:
· The origin of personal details;
· The purposes and modes of the processing;
· The logic applied in case the processing is carried out through computerized systems;
· The personal details of the Manager, of the persons in charge and of the representative designated as per Par. 5, Art. 2;
· The parties or categories to whom the personal details may be communicated or that may gain knowledge as designated representatives inside the State borders, persons in charge or appointees.
- The concerned person is entitled to obtain:
· The updating, the amendment, or, if so required, the integration of the details;
· The cancellation, the transformation into anonymous form or the stoppage of the detail processing in case it infringes the law, including those which do not require filing with respect to the purposes for which such details were collected and subsequently processed;
· A declaration that the persons to whom the details have been notified or sent out have been made aware of the operations indicated at point a) and b) concerning their contents, except in the case such notification results impossible or requires the use of means that are clearly disproportioned with respect to the protection of the right.
- The concerned person is entitled to partly o entirely oppose:
a) The processing of his/her personal details for legitimate reasons, even though they are pertinent with the purpose of the collection and propose a claim to the Supervisory Authority for the protection of personal data in the cases provided by the Privacy Regulations;
b) The processing of his/her personal details required for purposes of business information or dispatching advertising or other direct sales material or for the completion of market research or interactive business communication.
What are cookies?
Cookies are small files that help the user to improve their search and / or navigation within the site. While browsing, the browser used (internet explorer, google chrome, safari, etc.) stores small text files, namely cookies, which may contain information relating to the user, such as preferences, tastes, interests.
What type of cookies exist and what type of cookies are generated by browsing our site?
There are mainly two types of cookies:
- Transient (or session), which keep the information for the time necessary for web browsing and which are deleted once the browser is exited or the computer is turned off
- Persistent, which store and maintain information on the computer until the cookie itself is deleted and which allow the automatic retrieval of previously entered information
Browsing the site can generate various types of cookies:
- Anonymous analysis cookies
- Site performance cookies
- Third party cookies
The site uses the data collected with cookies in order to offer the user the best possible browsing experience (“Site performance cookies”).
The cookies generated by browsing are used exclusively for statistical purposes (“Anonymous analysis cookies”), not allowing the identification of individuals in particular.
Our site does not use profiling or advertising cookies
These cookies are necessary to create user profiles in order to send advertising messages in line with the preferences expressed by the user within the pages of the site.
How to disable cookies?
The user may at any time disable and / or block the cookies on their browser or from this site by activating the option relating to the procedure for removing cookies on the browser or device in use. Once the sending of cookies has been deactivated and / or blocked, the site can be navigated normally, although there may be slowdowns in loading the pages.
For any other information on how to manage and disable cookies, depending on the browser used, you can consult the following links:
Specifically, cookies are collected for the following purposes and using the following services:
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data collected: Cookies and Usage Data.