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Privacy

INFORMATION ON THE PROCESSING OF PERSONAL DATA
of the users visiting the websites of Hotel Parco dei Principi
Pursuant to Article 13 of the Italian Lgs. Decree 196/03 and EU Regulation 2016/679

This page contains a description of the policies for managing the website in regard to processing the personal data of the users who visit the site and their privacy. This information is provided to individuals who interact with the web services of Hotel Parco dei Principi, which is accessible by telematics means through the following web address:

www.parcodeiprincipi.com and https://www.robertonaldicollection.com/parco-dei-principi/it/

which corresponds to the home page of the official website of dell’Hotel Parco dei Principi di Via G. Frescobaldi, 5 – 00198 Rome.

This informative note is provided only for the aforementioned website and not for other websites eventually accessed by the user through links.

THE “CONTROLLER”
Following access to this website, data pertaining to persons that are identified or identifiable may be processed. The “Data Controller” of the personal data collected following a visit to our website or any other data used for providing our services is ICEM Spa, Via Posillipo n°9 Palazzo Donn’Anna Napoli (NA) – 80123 – Italy.

PLACE WHERE DATA IS PROCESSED
Data processing pertaining to the web services of this website (physically hosted by Register.it SpA (“www.register.it“) at the Data Center of Reading (UK)) is carried out at the aforementioned headquarters and said data is processed only by the technical personnel in charge of processing of the data processing office, or by eventual persons in charge of processing who are entrusted to process occasional maintenance operations.

The personal data obtained from the users who submit hotel reservation requests or through informative material (informative notes, newsletters, registration, etc) is used only to carry out the services or assistance requested and is not transmitted to third parties, except in the following possible cases:

• Business partners of ICEM Spa, or representative chains such as Roberto Naldi Collection (https://www.robertonaldicollection.com) to whom ICEM Spa transmits the data exclusively in order to avoid on-line reservations;
• Persons, companies or professional offices who lend assistance and consulting services to ICEM Spa, concerning accounting, administrative, legal, financial and tax matters;
• Subjects who are authorized to have access to the data by law or through requests by the authorities;
• Personal Data can be shared within the hotels of “Roberto Naldi Collection” or controlling companies located in the world, including companies located in a country that is not a member of the European, in accordance with Chapter V of the GDPR 679/2016, with a view to supplying specific services requested.

The credit card data used for booking will be automatically unavailable at the end of the stay.

CATEGORIES OF PROCESSED DATA

Navigational data
The information systems and software procedures relied upon to operate this web site acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols.

Such information is not collected in order to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties.

This data category includes IP addresses and/or the domain names of the computers used by any user connecting with this web site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user’s operating system and computer environment.

These data are only used to extract anonymous statistical information on website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the website; except for this circumstance, any data on web contacts is currently retained for no longer than seven days.

Data voluntarily provided by the user
Sending e-mail messages to the addresses mentioned on this website, which is done on the basis of a freely chosen, explicit, and voluntary option, entails acquisition of the sender’s address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s).

Data will be retained only for registration request to send the newsletters or special offers and will not be disclosed to anyone.
The personal information regarding the individual who visited the website is not collected or used. The visitors remain anonymous. The only exception to this rule concerns the information for personal identification needed to fulfill the contractual obligations of reservations on behalf of the user.

Reservations
In the event of reservations made through the website, the user must provide his name, address, telephone number and information regarding the payment manners and credit card used. ICEM Spa will use said information only to process the reservations and to send specific information, which is relevant to the confirmation of said, such as a receipt, the reservation code and the conditions.

The information provided will not be used for marketing purposes and will not be sold, transmitted, given by contract or sent to third parties an any way, with the exception of our provider of on-line reservation services, Leading Hotels and Blastness only for online reservations purposes.

In any event, the administrator of the website guarantees the use of scrupulous procedures in order to protect the navigational data and the use of particular precautions to protect the data pertaining to the credit card, which is provided during on-line reservations.

Newsletter
According to article 13 GDPR 679/2016, we kindly inform you that our archives and systems include e-mail addresses that have been collected from individuals who directly provided their personal data to receive our newsletter. These addresses are used by us in compliance with the wishes of those data subjects to receive e-mail communications from our company. The data will be processed only by our authorized persons in charge of processing and will be processed until withdrawal of consent.
If you want to remove your e-mail address from our archives and systems, please click on the “Unsubscribe” link at the bottom of this communication. You can, at any time, request for your rights according to Chapter III GDPR 679/2016. The request should be sent to Data Controller ICEM Spa – Parco dei Principi by the e-mail address: privacy@robertonaldicollection.com. Furthermore, it is possible to exercise the right to lodge a complaint to the Privacy Supervisor Authority according to Artt. 77 and ss Chapter VIII GDPR.

Personal Data Processing Collected From Curriculum Vitae
ICEM Spa accept Personal Curriculum Vitae of possible candidates both on paper and in an electronic format. Providing spontaneous and voluntary of the Curriculum Vitae data will be considered as implicitly informed consent by the data subjects for personal data processing contained, only following the purposes related to the selection of potential candidates.

The data processed for the purpose of selection of candidates are personal useful to search for the particular profile. In general, the nature of the data is normal, except in some cases where you may indicate any sensitive data necessary to identify the specific requirements of the regulations, such as specifying a particular protected class, the suitability for certain jobs and / or start-ups required, within the limits set by the law;

The provision of data relating to the selection of candidates is required. Any refusal to provide such data makes it impossible to perform an orderly selection and the possible recruitment. The data in question will not be disclosed to anyone.

General Rules for providing the CV
Any CV received spontaneously, replying to a job advertisement, will be stored directly by authorized person in charge of the processing in accordance with the safety guidelines of personal data adopted in compliance with the security measures ex Chapter IV, 2) of the GDPR. These will be printed only on the occasion of a meeting and a conversation with the data subject. After the interview, if the candidate is not selected, the CV will be retained for a maximum of 2 years and after will be deleted and / or destroyed.

To send Curriculum Vitae use only the following addresses: ICEM Spa, Human Resource Dpt. Via G. Frescobaldi, 5 – 00198 Roma, by e-mail address: fp.hr@robertonaldicollection.com.

PERIOD FOR DATA RETENTION – CRITERIA USED
According to the provisions set forth in art. 5 par. 1 lett. e) of the Regulation (EU) 2016/679, collected personal data shall be retained in a form which permits identification of data subjects for a period not exceeding the purposes for which the personal data were collected and subsequently processed.

Data retention periods depend on the purposes of the processing:
• purposes related to technical navigation data for the correct functioning of the website: retention only for the related session, after which the data are deleted;
• purpose of reply to info request/services supply request (up to 12 months for contact requests ; 10 years for administrative / accounting / financial documentation relating to the provision of a service);
• data collection for staff recruitment (up to 24 months);
• newsletter, marketing or promotional communications in general (until withdrawal of consent);
• purpose of di administrative / accounting / financial management: 10 years as as required by law for the conservation of administrative / accounting / financial documentation.

OPTIONAL DATA PROVISION
Subject to the specifications made with regard to navigation data, users are free to provide the personal data listed in the request forms of Hotel Parco dei Principi or referred to in contacting the ICEM Spa in order to provide CV, to make on-line reservations or to request delivery of information materials and other communications. Failure to provide such data may entail the failure to be provided with the items requested.

PROCESSING ARRANGEMENTS
Personal data is processed with automated means for no longer than is necessary to achieve the purposes for which it has been collected. Specific security measures are implemented to prevent the data from being lost, used unlawfully and/or inappropriately, and accessed without authorisation.

DATA SUBJECTS’ RIGHTS
Data subjects are entitled to obtain confirmation of the existence of personal data concerning them and be informed of their contents and origin, verify their accuracy, or else request that such data be supplemented, updated or rectified (as provided for in Section 7 of Law 196/03 and Chapter III GDPR 679/2016), in particular, the right to obtain confirmation as to whether or not personal data concerning they exist and the logic applied to the processing, the right to ask for their integration, the right to object to their processing on legitimate ground, and the right to request rectification, updating, erasure (right to be forgotten) or blocking of data that have been processed unlawfully, the right to obtain a copy of the personal data being processed as well as the right to data portability, also by sending a written request to the following e-mail address: (privacy@parcodeiprincipi.com).

RIGHT TO LODGE A COMPLAINT
If a data subject considers that the processing of personal data relating to him or her as performed via this website infringes the Regulation, he or she has the right to lodge a complaint with the Garante pursuant to Article 77 of the Regulation, or else to bring a judicial proceeding against the Supervisory Authority pursuant to Article 79 of the Regulation.

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