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Privacy Policy

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 F. Caracciolo, 11 – 80122 Napoli.

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.

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.

COOKIES & JAVASCRIPT TECHNOLOGIES
In this website we are applied cookies technologies for different purposes, including computer technology authentication or to monitor sessions, and to store specific technical information regarding the users that access the server of Register.it Spa (www.register.it), the hotel website service providers.

Description of the cookie mechanisms adopted:
• Cookie implanted in the user/contracting party’s terminal directly (that will not be used for other purposes) such as session cookies used for on-line booking on the website, authentication or customisation cookies (for example, the choice of the browsing language); these cookies remain active only for the duration of the session.
• Cookie used to statistically analyse accesses/site visits (the so-called “analytic” cookie) that are used for statistical purposes, and to collect aggregate information with the possibility of tracing back to the identification of the individual user personal computer. In these cases, since current legislation requires that, when using analytic cookie, the user is given clear and adequate instructions to easily oppose implementation of such (including any mechanisms to make the cookies anonymous), we give instructions on how to disable installed cookies below. The duration of analytic technical cookie is averagely of 30 minutes.

“Third-party” cookies
Third-party cookies are code parts set by a website different than the website you are currently browsing.

This involves the transmission of cookies from third parties. In this website is carried out the google analytics technology for statistical monitoring of the website visits. This technology use a tracking code that sets first party cookies and javascript files lingering on each visitor’s computer. In addition to transmitting information to a Google server, these cookies store information such as whether the visitor has been to the site before (new or returning visitor), the timestamp of the current visit, and the referrer site or campaign that directed the visitor to the page.

The privacy policies availables on the websites described above. Visitors in any case can turn off the advertising features of Google Analytics on this site by installing the Add-off for your browser downloadable from this LINK.

Here is the list of cookies on this website

NAME: CONSENT
DOMAIN: .google.com
EXPIRE/MAX-AGE: 2038-02-01T07:59:59.426Z
SIZE: 19

NAME: NID
DOMAIN: .gstatic.com
EXPIRE/MAX-AGE:  2018-10-02T21:08:32.126Z
SIZE: 135
HTTP ✓

NAME: NID
DOMAIN:  .google.com
EXPIRE/MAX-AGE: 2018-12-29T13:00:34.064Z
SIZE: 135
HTTP ✓

NAME: _ga
DOMAIN:  .robertonaldicollection.com
EXPIRE/MAX-AGE: 2020-07-01T13:43:17.000Z
SIZE: 29

NAME: _gid
DOMAIN: .robertonaldicollection.com
EXPIRE/MAX-AGE: 2018-07-03T13:43:17.000Z
SIZE: 31

NAME: _hjIncludedInSample
DOMAIN: www.robertonaldicollection.com
EXPIRE/MAX-AGE: 1969-12-31T23:59:59.000Z
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DOMAIN: www.robertonaldicollection.com
EXPIRE/MAX-AGE: 2026-05-29T07:33:14.601Z
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DOMAIN:  www.robertonaldicollection.com
EXPIRE/MAX-AGE: 2026-05-29T07:33:14.564Z
SIZE: 23

NAME: wfvt_354039743
DOMAIN:  www.robertonaldicollection.com
EXPIRE/MAX-AGE: 2018-07-02T14:13:19.181Z
SIZE: 27
HTTP ✓

NAME: wordfence_verifiedHuman
DOMAIN:  www.robertonaldicollection.com
EXPIRE/MAX-AGE: 2018-07-03T13:43:19.181Z
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Cookie Name
: Google Analytics https://support.google.com/analytics/answer/6004245?hl=it
Purpose: STATISTIC
Google Analytics is a Google analysis tool that helps website and app owners to understand how visitors interact with their website content (pages viewed, browsing time, etc.) by providing useful statistics to optimize and improve browsing the website without identifying the browser
Expire Data
_utma 2 years
_utmt 10 minutes
_utmb 30 minutes
_utmc until the end of the session
_utmz 6 months
_utmv 2 years

Cookie Name: Google Adwords  https://support.google.com/adwords/answer/2407785?hl=it
Purpose: PROFILATION
It favors the search on Google services offered by the hotel without collecting or monitoring information that can personally identify a user
Expire Data: 30 days

How to modify settings on the cookies
Most browsers allow to clear cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored.
Therefore, to remove cookies we encourage you to follow the instructions on the pages of the most used internet browsers:

Chrome: https://support.google.com/chrome/answer/95647?hl=it
Fire fox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
Microsoft Edge: https://privacy.microsoft.com/it-IT/windows-10-microsoft-edge-and-privacy
Safari: http://support.apple.com/kb/HT1677?viewlocale=it_IT

Nevertheless, if you block or erase cookies, it may not be possible to reset previously specified preferences or customised settings, and our capacity to customize the user experience will be limited.
More google analytics privacy policies availables on http://www.google.com/policies/technologies/ads/

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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