Privacy Policy

Privacy Policy

(Articles 13 and 14 of the EU General Regulation on the protection of personal data n. 679/2016)

The European Regulation (EU) 2016/679 (hereinafter the “Regulation”) establishes rules concerning the protection of natural persons about the processing of personal data, as well as rules relating to the free circulation of such data.

In accordance with the principle of transparency provided for by art. 5 of the Regulation, HOTEL BODONI – Via Martiri del Popolo, 27 – 50122 Firenze (FI), in the person of the legal representative, as the holder of the treatment, provides the information requested by the Artt. 13 and 14 of the Regulation.

Hotel Bodoni (hereinafter, for BREVITY, “HB”), as the holder of the treatment, shall inform pursuant to Article 13 of the Regulation that the processing of personal data relating to customers and natural persons who have the representation of the companies for the purposes and in the most detailed manner.

Personal data processing means any transaction or set of transactions, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, even if not recorded in a database, such as collection, Registration, organization, structuring, preservation, processing, selection, blocking, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of Provision, comparison or interconnection, limitation, cancellation or destruction.

The treatment will be carried out in manual way (e.g. collection of paper forms) and electronically or with the help of computerized tools.

According to the rules of the regulation, the treatments carried out by HB will be based on the principles of correctness, lawfulness and transparency and the protection of confidentiality.

In accordance with article 13 of the Regulation, we therefore provide the following information.

  1. About us

Our contacts and other contact details are indicated at the bottom of this privacy statement. Hotel Bodoni di Benedetti Paolo & C. SNC, owner of Hotel Bodoni, is the owner of the processing of personal data processed in accordance with this statement (except for cases where this statement indicates otherwise), written according to Reg. (EU) 679/2016.

  1. Source of personal data being processed.

The personal data subject to treatment may be collected in the framework of HB’s commercial procedures, which also includes the processing of data to be indicated in the form of request for tenders, or during the course of the activities Through on-line procedures, directly with the interested parties, or at a third party.

The personal data that HB usually uses include, but are not limited to:

  1. Name, date and place of birth, personal contact details and qualifications (education, training courses and internships), documents proving identity and any other data;
  2. In some cases, we keep track of correspondence, in case of direct contact from the customer;
  3. Feedback on the service offered by HB (e.g. complaints);
  4. We may also collect data regarding visits to our website, including (but not limited to) IP address, browser, location, national traffic data, location data, and other communications data and on the resources you are accessing. This information will allow us to simplify your visit to our website in the future;
  5. We can also collect information for marketing and analysis purposes, including information on how to respond to e-mails, SMS, phone and other marketing campaigns;
  6. “Sensitive data”, relating, for example, to health status or membership of associations;
  1. Cookie

The use we make of cookies for the processing of personal data is described in our information on cookies, which we invite you to read.

  1. Primary purpose of the treatment.

The personal data you provide will be treated in accordance with the principles of correctness, lawfulness and transparency, protecting your privacy, your rights and in accordance with the corporate privacy policy. The company also undertakes to deal with its data in compliance with the principle of “minimization”, i.e. acquiring and treating data as limited as necessary to the following purposes:

  1. For the management and execution of pre-contractual and contractual obligations;
  2. For the insertion into own personal and business data systems;
  3. To implement the relationship established, including related or ancillary activities or the provision of related services required by the customer;
  4. For everything related to the organization and management of the hotel service and the reception of customers;
  5. For relations – both at home and internationally – with the supervisory bodies;
  6. For the management of receipts/payments;
  7. To fulfil the obligations laid down in the civil and/or fiscal laws;
  8. For the management of the HB website;
  9. For HB’s publications and for the management of information reports and communications with customers;
  10. To receive communications, newsletters, informative material, satisfaction recognition, promotional, commercial and advertising material or related events and initiatives, market research or other sample searches and direct sales, Via Automated mail, Sms (Short Message Service) or other means, as well as through telephone calls via operator and paper Mail.

The law provides that there is a justification indicated in the same legislation for the treatment of your data in our possession.

The treatment by our personal data for all these purposes is based on reasons of treatment such as the execution of a contract in which the person concerned is one of the parties, necessary treatment in order to comply with the requirements Legal and regulatory and/or necessary treatment in HB’s legitimate interests in exercising its fundamental rights and those of its staff to manage an activity, so that it does not unduly penalize its interests or rights and freedoms Fundamental. Where the processing of the data is necessary for the legitimate interests of HB, we guarantee that it is carried out in such a way that our legitimate interests have priority over any individual’s interests.

We have the right to treat personal data for reasons other than those of law only in the face of its consent (further motivation of treatment).

  1. Communication and dissemination of personal data for the pursuit of the purpose of the treatment.

In all the cases described above, for the pursuit of the primary purposes, HB may communicate personal data outside the following third parties, to whom the communication is necessary to fulfil the obligations relating to the completion procedure. of the service and/or by virtue of statutory regulations, regulations, standards, directives, etc.

In this context, personal data may be communicated by HB to the following subjects:

  1. Objects carrying out data processing and/or keeping of accounts and consequent fulfilments on behalf of HB;
  2. Companies that carry out the management and maintenance of electronic communications equipment (including the website) and the related consequent fulfilments on behalf of HB;
  3. To the judicial and police authorities or other public administrations for the fulfilment of regulatory obligations;
  4. HB Consultants in charge of the carrying out of legal and/or fiscal activities;
  5. All natural and legal persons in cases where the communication is necessary for the primary purposes of the treatment;
  6. Commercial Consultants and/or partners;
  7. With our advertisers and advertising channels requesting data to select and deliver relevant advertisements to you and other stakeholders. We do not disclose information about identifiable people to our advertisers, but we will provide them with aggregate information about our users. We can also make use of this aggregate information to help advertisers reach the target audience. We can make use of the personal data that we have obtained to enable us to meet the needs of our advertisers, showing their advertisements to that reference audience, notwithstanding the section of this information dedicated to cookies;
  8. With service providers of analytics and search engines) that assist us in improving and optimizing our site, notwithstanding the section dedicated to cookies of this informative.

With reference to art. 13 of the Regulation and the indication of the subjects or categories of persons who may become acquainted with the personal data in the capacity of persons responsible or appointee, the following list shall be provided:

  • Internal workers
  • HB’s internal consultants in charge of administrative and secretarial fulfilments,
  • Technical and Commercial Consultants
  • Legal Advisers/tributaries
  1. Other disclosures we can make

We may disclose your personal data to other third parties:

  1. If we sell or buy companies or assets, in which case-subject to the terms of this privacy statement-we may disclose your personal data to the potential seller or purchaser of such companies or assets. In this case it will be given information to all interested parties.
  2. If we, or substantially all of our assets, are acquired by a third party, in which case the personal data we possess relating to our customers will constitute one of the assets transferred. In this case it will be given information to all interested parties.
  3. If we are obliged to disclose or share your personal data in order to observe statutory obligations or to enforce or enforce our terms and other agreements with you; or in order to protect the rights, property or safety of Hotel Bodoni, our clients or other parties. These include the exchange of information with other companies and organizations in order to avoid fraud and reduce the risk of redevelopment.
  1. Legal basis of the processing of personal data we have done.

The legal basis for the processing of your personal data is as follows:

  1. If, in order to be authorized, it is necessary to obtain your consent to the treatment beforehand (e.g. marketing and advertising), we will get and merge on your consent with respect to the treatment in subject (see below HOW to revoke Consent at all times).
  2. Otherwise, we will treat your personal data where necessary:
  1. For the execution of a contract of which you are a party or in order to carry out measures at your request before concluding such a contract;
  2. To observe an obligation of law to which we are subjected; Or for the purposes of the legitimate interests of us (or others) pursued, provided that this happens only in cases where its interests or fundamental rights and freedoms-which require the protection of personal data-do not prevail over such legitimate interests ( Most of the cases in which we treat your personal data in relation to a relationship with the person you work for will fall into this category).
  1. Methods of Treatment

The processing of your personal data will be carried out by means of paper and computer tools in compliance with the provisions concerning the protection of personal data and, in particular, of the appropriate technical and organizational measures referred to in art. 32.1 of the regulation, and with the observance of any precautionary measures guaranteeing its integrity, confidentiality and availability.

  1. Secondary purposes of the processing of personal data with a promotional, advertising and marketing nature in a broad sense.

The personal data collected in the procedure of concluding the contract may also be treated by HB, both in paper mode (e.g. compilation of forms and similar paper subsequent use electronically) that with Automated/informatics, for commercial promotion purposes, advertising communication, solicitation of purchasing behavior, market research, surveys (including telephone, online or via forms), other research samples of Marketing in a broad sense (including prize events, games and competitions), hereinafter referred to collectively as “treatment for Marketing purposes”. By conferring consent to treatment for Marketing purposes the customer specifically takes note of such promotional, commercial and marketing purposes in the sense of the treatment (including management and administrative activities and expressly authorizes HB to carry out such treatment in accordance with art. 6, paragraph 1, point (a) of the Regulation.

According to the general measure of the privacy guarantor of 15 May 2013 entitled “Consent to the processing of personal data for the purpose of” direct marketing “through traditional and automated contact tools,” specifically refers the customer’s attention to the fact that:

    1. The consent provided for the dispatch of commercial and promotional communications (i.e. through the use of electronic mail, fax, SMS, automatic systems without operator intervention and similar, including electronic platforms and other means Telematics) will imply the receipt of such communications, not only through these automated contact modalities, but also through traditional modalities, such as paper mail or operator calls;
    2. The right to oppose the customer to the processing of his personal data for the purpose of “direct marketing” through the above mentioned automated contact modalities, will extend in any case to the traditional ones and, even in this case, remains save the Possibility of exercising this right in part, both in respect of certain means and in relation to certain treatments;
    3. It remains the possibility for the customer who does not intend to give consent in the terms mentioned above, to express the eventual willingness to receive communications for the above Marketing purposes exclusively through traditional ways of contact , where provided: this will can be exercised free of charge by sending a simple e-mail to the address hotelbodonifirenze@virgilio.it .

For the purposes of the principle of fulfilment of the privacy obligations for the proprietor in compliance with the principles of simplification of the same fulfilments and pursuant to the aforementioned general measure of the privacy guarantor of 15 May 2013, HB informs the customer that the Specific consent formula available on the basis of the procedure for the collection of consent from time to time will be Unitarian and comprehensive and will refer to all possible means of marketing treatment, notwithstanding the possibility for the customer to Notify by email to the address hotelbodonifirenze@virgilio.it A different will regarding the use of certain means and not of others for the reception, after consent, of the marketing communications. In addition, for the purpose of the principle of fulfilment of the privacy obligations for the right holder in accordance with the principles of simplification of the same fulfilments, HB informs the customer that the specific consent formula will be unitary and overall and will also Reference to all the different and possible marketing purposes explained here (without multiplying the formulas of consent for each marketing BOM pursued by the holder), notwithstanding the possibility for the customer to notify by email At the address hotelbodonifirenze@virgilio.it A different selective will as to the consent or denial of consent for individual marketing purposes.

To proceed to the treatment for Marketing purposes it is mandatory to acquire a specific consent, separate, express, documented, preventive and completely optional.

Consequently, where the customer decides to give the specific consent by means of a special form, he must be informed and aware that the purposes of the treatment pursued are of specific commercial, advertising, Promotional and marketing in a broad sense. In view of absolute transparency, HB informs the customer that the data will be collected and subsequently processed based on a specific consent provision:

    1. To send advertising and informative material (e.g. newsletters), promotional or otherwise commercial;
    2. To carry out direct sales or placement activities of HB products or services;
    3. to send commercial information; To carry out interactive commercial communications also within the meaning of article 58 of Legislative Decree 206/2005 (c. “Consumer Code”) through the use of e-mail;
    4. To develop studies and market research;
    5. To send unsolicited commercial communications within the meaning of article 9 of the Legislative Decree of 9 April 2003 No 70 transposing the so-called e-commerce Directive 2000/31/EEC, which provides that unsolicited commercial communications They should be immediately and unequivocally identifiable as such and contain an indication that the recipient of the messages may oppose the receipt of such communications in the future.

Therefore, by providing the optional consent, the customer specifically acknowledges and authorizes such additional, possible secondary treatments.

In any case, even where the customer has consented to authorize HB to pursue all the purposes mentioned in paragraphs 1 to 5 above, it will still be free at any time to withdraw it, without formality sending a clear Communication to that effect to the e-mail hotelbodonifirenze@virgilio.it.Following receipt of this request, HB will proceed promptly to remove and erase data from the databases used for the treatment for Marketing purposes and to inform for the same purposes of cancellation any third parties to which the Data have been communicated. The simple receipt of the cancellation request will be automatically as confirmation of cancellation.

It is specifically and separately informed, as required by art. 21 of the regulation that if the personal data are processed for direct marketing purposes, the customer has the right to oppose at any time the processing of the personal data concerning it carried out for such purposes and that if the person concerned Oppose Treatment for direct marketing purposes, personal data will no longer be subject to treatment for such purposes.

I. 1 communication and dissemination of personal data for the pursuit of secondary purposes of treatment with a promotional, advertising and marketing nature in the broad sense.

For the same purposes as in the numbers 1 to 5 of the preceding paragraph, HB informs the customer that the data may also be communicated to third parties trading partners. The consent to the treatment for Marketing purposes – where lent of the customer – does not cover also the different and further marketing treatment represented by the communication to third parties of the data for the same purposes. To carry out such communication outside it is mandatory to acquire from the customer a further, separate, additional, documented, express and completely optional informed consent.

As in fact clarified in the general measure of the guarantor of 4 July 2013 bearing the guidelines of contrast to spam:

    1. Concerning the communication to third parties for marketing purposes in general, the communication or transfer to third parties of personal data for marketing purposes cannot be based on the acquisition of a single and generic consensus on the part of the persons concerned for such Purpose
    2. The holder of the treatment wishing to collect the personal data of the persons concerned also to communicate them (or give them) to third parties for their promotional purposes must in advance release to the same a suitable information which also individuals each of the third parties or, Alternatively, indicate the categories (economic or commodity) that belong to them;
    3. The holder must acquire a specific consent for the communication (and/or transfer) to third parties of the personal data for promotional purposes, and separate from that required by the holder to carry out the same promotional activity;
    4. If the person concerned releases the above-mentioned consent for communication to third parties, they may carry out promotional activities with them in the automated manner without having to acquire a new consent for the promotional purpose.

Pursuant to the aforementioned general measure of the guarantor of 4 July 2013, third parties receiving communications of the personal data of the persons concerned for subsequent treatment for Marketing purposes shall be identifiable by reference to the following Market or economic categories: suppliers of electronic communication goods and services, Internet service providers, communication agencies, business partners.

The personal data being processed for Marketing purposes will not be subject to dissemination.

        1. Compulsory or optional consent for the pursuit of secondary purposes of the processing of personal data of a promotional, advertising and marketing nature in a broad sense.

We recall with particular attention the fact that the conferral of personal data to HB and the provision of consent to treatment for Marketing purposes and of the distinct consent to the communication to third parties for the treatment for Marketing purposes for The purposes and the modalities described above are absolutely optional and optional (and in any case revocable without formalities even after the performance) and the non-conferral will not have any consequences other than the impossibility for HB and for Any third party to proceed to the marketing treatments mentioned.

In the event of denial of marketing consent there will be no interference and/or consequence on the contractual or other relationship and whose processing of personal data falls within the primary purposes of the treatment referred to in paragraphs B and C of this information Privacy.

Only with reference to the use of the e-mail indicated by the customer at the time of the establishment of the report, it is advised that it will be possible for HB to send information and advertising material only if it relates exclusively to products and/or services Similar to those for which the customer originally gave a marketing consent. It remains in such a particular hypothesis firm the right of the customer to oppose at any time to the treatment (notifying its will to the e-mail hotelbodonifirenze@virgilio.it) at the time of the reception. This opposition will not produce any consequence on the contractual relationship.

        1. Transfer of personal data

The data controller does not transfer personal information to third countries or to international organizations.

It is in any case understood that the holder, if necessary, will have the right to move the servers also extra-EU. In this case, the holder shall ensure that the transfer of the extra-EU data will be in conformity with the applicable legal provisions, subject to the stipulations of the standard contractual clauses laid down by the European Commission.

  1. Data retention times and other information.

The data will be kept for the time defined by the reference regulations, which are specified below in accordance with art. 13, paragraph 2 (a) of the regulation: ten years for documents and related data of a civil, accounting and fiscal nature as provided for in the laws in force.

With reference instead to the personal data subject of treatment for Marketing or treatment purposes for profiling purposes, the same will be kept in accordance with the principle of proportionality and in any case until it has been pursued the The purpose of the treatment or until-if previously-does not intervene the revocation of the specific consent by the customer.

        1. Owner and responsible for the treatment.

The owner of the data processing is Albergo Bodoni di Benedetti Paolo & C. Snc, with headquarters in Florence (FI) – Via Martiri del Popolo 27, Cap 50122.

The extremes that allow you to quickly contact HB and communicate directly and effectively with the same, including the e-mail address, are:

Phone + 39 055-240741

hotelbodonifirenze@virgilio.it

        1. Exercise of rights by the Party concerned.

For the purposes of articles 15 to 21 of the Regulation, customers shall be informed that:

  1. Have the right to ask HB, as the holder of the treatment, for access to personal data, the correction or cancellation thereof or the limitation of the treatment concerned or to oppose their treatment, in the cases envisaged;
  2. The right to portability of data, that is the right to receive in a structured format, of common use and readable by automatic device, the personal data they refer;
  3. Have the right to propose as a natural person a complaint to the guarantor for the protection of personal data, following the procedures and indications published on the official website of the Authority on www.garanteprivacy.it;
  4. Any corrections or cancellations or limitations of the processing carried out at the request of the person concerned – unless this proves impossible or involves disproportionate effort – will be communicated by HB to each of the recipients to whom they have been sent Your personal information. HB may communicate to the person concerned those recipients if the person concerned so requests.

The exercise of rights is not subject to any form constraint and is free of charge.

The addresses for the exercise of rights are:

  1. Via Martiri del Popolo, 27 – 50122 Florence (FI)
  2. hotelbodonifirenze@virgilio.it

 

        1. Date of this statement

The last update of this statement was on 18 April 2019.