Information provided pursuant to Legislative Decree 196/2003 and Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 (GDPR). and subsequent amendments of the Privacy Guarantor.
Dear user, we would like to inform you that E.T.G. Srl collects the data referring to these, acquired through the sites www.tritonetophouse.com / www.piazzadispagnacomfortrooms.com or even verbally, directly or through third parties, qualified as “personal data” by Legislative Decree no. 196/2003 and EU Regulation 2016/679. This legislation provides that those who process personal data are required to inform the data subject about which data are processed and about certain elements qualifying the processing, which must always be carried out correctly, legally and transparently, protecting their privacy and your rights. Therefore, in accordance with EU Regulation 2016/679, we provide you with the following information:
1. Data Controller
The data controller is E.T.G. Enif Tourism Group srl – VAT number: 12255101003 Via Francesco Crispi, 10 – 00187 ROME
2. Purpose of the processing
The processing will also be carried out with the aid of computerized means for the following
a) to fulfill the obligation set out in Article 109 of the R.D. 18.6.1931 n. 773, which requires us to communicate to the Police Headquarters the details of the clients staying;
b) to fulfill current administrative, accounting and tax obligations;
c) to carry out the function of receiving messages and phone calls addressed to her;
d) to speed up the registration procedures in the event of your subsequent stays at our hotel. For this purpose your data will be kept for a maximum period of 6 months;
e) to send you our promotional messages and updates on the rates and offers made.
We also wish to inform you that the provision of your data for the treatments referred to in points a) and b) is obligatory, and in case of refusal to supply them we will not be able to host it in our facility. The data is collected to provide a service, for the execution of a contract, to respond to a request or following a spontaneous user transfer. The provision is optional. Failure to provide the data referred to in points a) and b) will prevent or limit the provision of the service or the execution of the contract with the interested party.
Personal data will also be used for the following purposes:
• Sending technical, commercial, informational communications, catalogs, price lists, samples
• Promotional activities
• Market research and quality control
If you wish the treatments referred to in points c), d), e) to be carried out, you must give us your consent. The consent may in any case be subsequently withdrawn by opposing the treatments. For any further information, and to enforce the rights recognized to you by Article 7 of the Privacy Code (Legislative Decree 196/2003), you may contact the Data Controller. In addition, navigation data is collected anonymously regarding IP address, date and time of access, URL requested. These data are collected for statistical purposes, to check the correct functioning of the services, for security reasons and to comply with the regulations in force. This data is not transmitted to third parties.
3. Lawfulness of the processing
The purpose of the processing is based on the execution of the pre-contractual measures or contractual obligations:
• Management of customer relations regarding:
• accounting ;
• Management of our pre-sales service;
• Management of outstanding payments and disputes;
• Management of partner hotels and business organizations.
4. Collection of personal data
“Personal Data” means information that identifies you personally or allows you to identify a person. We collect your Personal Data in the manner prescribed by law, such as:
• First name
• Mailing address
• Telephone number
• Email address
• Credit / debit card number or other payment details
• Financial information in certain circumstances
• Language preference
• Date and place of birth
• Nationality, passport, visa or other identification data issued by the government
5. Recipients of personal data
Personal data may be disclosed to third parties for the purpose of processing.
Personal data is stored for an unlimited period of time, at the discretion of the Data Controller. They are however kept, where applicable, for the minimum period provided for by the law. System access / log tracks are kept for a minimum of 6 months.
7. Rights of the interested party
As an interested party you can exercise your following rights towards us:
a) obtain confirmation of the existence of personal data concerning you, even if not yet recorded, and the communication in intelligible form of the same data and their origin, as well as the purposes and methods of processing and the logic applied in case of processing carried out with electronic instruments;
b) obtain the deletion, transformation into anonymous form or blocking of data which does not need to be kept for the purposes for which the data was collected and processed;
c) obtain the updating, rectification and integration of their data;
d) object, in whole or in part, for legitimate reasons, to the processing of data concerning you, even if pertinent to the purpose of the collection. We also remind you that in any case you are always entitled to lodge a complaint with the Italian supervisory authority, or the Guarantor for the protection of personal data.
8. Right to cancellation «right to oblivion»
1. The interested party has the right to obtain from the data controller the deletion of personal data concerning him without undue delay and the data controller has the obligation to delete personal data without unjustified delay, if one of the following reasons exists:
a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws the consent on which the processing is based in accordance with Article 6, paragraph 1, letter a), or Article 9, paragraph 2, letter a), and if there is no other legal basis for the processing ;
c) the data subject opposes the processing pursuant to Article 21, paragraph 1, and there is no legitimate prevailing reason to proceed with the processing, or he opposes the processing pursuant to Article 21, paragraph 2;
d) personal data have been unlawfully processed;
e) personal data must be deleted in order to fulfill a legal obligation established by the law of the Union or of the Member State to which the data controller is subject;
f) personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1. 2.
The data controller, if he has made personal data public and is obliged, pursuant to paragraph 1, to delete them, taking into account the available technology and the implementation costs, takes reasonable measures, including technical, to inform the data controllers who are processing by processing the personal data of the data subject’s request to cancel any link, copy or reproduction of his personal data. 3. Paragraphs 1 and 2 do not apply to the extent that processing is necessary:
a) for the exercise of the right to freedom of expression and information;
b) for the fulfillment of a legal obligation that requires the treatment foreseen by the law of the Union or of the Member State to which the holder of the treatment is subject or for the execution of a task carried out in the public interest or in the exercise of public authority of which the data controller is invested;
c) for reasons of public interest in the field of public health in accordance with Article 9 (2) (h) and (i) and Article 9 (3);
d) for archiving purposes in the public interest, for scientific or historical research or for statistical purposes in accordance with Article 89, paragraph 1, to the extent that the right referred to in paragraph 1 risks rendering impossible or seriously affecting the achievement of the objectives of such treatment; or e) for the ascertainment, the exercise or the defense of a right in court “), which specifies the scope, the conditions and the limitations.7. Supervisory authority
The interested party has the right to lodge a complaint with the supervisory authority: Guarantor for the Protection of Personal Data www.garanteprivacy.it
9. Treatment processes
Personal data is subjected to automated processes, such as profiling for statistical purposes but is anonymized. The processing of customer or guest data acquired by the accommodation facility is aimed at confirming a reservation of accommodation services and ancillary services, and to provide the services requested (general information and contact details, fiscal code and / or VAT number, credit card details and debt provided as guarantee and / or balance, list of services and products requested and purchased, date of arrival and departure, etc.). These treatments are necessary for the definition of the contractual agreement and for its subsequent implementation, and therefore it is necessary to inform the client that his consent is not required (except in the case in which particular, so-called sensitive data are given). In case of refusal to provide personal data, all or some services cannot be provided. It is necessary to inform the customer that the processing will cease at his departure, by destroying the paper registration media. For the accounting part, your personal data must continue to be processed.
10. Purpose of use
Personal data will not be processed for purposes other than those for which they were collected. The data collected will be used for accommodation purposes and are: name, surname, gender, date and place of birth, citizenship, type and document number as well as place of issue, date of arrival and days of stay. For purposes of loyalty – Only the data necessary to attribute the advantages connected to the use of the card can be processed, that is: personal details of the card holder; data relating to the volume of overall expenditure progressively realized, if necessary for the attribution of the same advantages and only for the time strictly necessary. Any conservation of detailed data relating to the particular types of goods or services purchased, or advantages achieved (points, prizes, bonuses, etc.) is not considered necessary for the sole purpose of customer loyalty; in particular cases where the preservation is lawful, the principle of proportionality will be respected. The purpose of the use is to protect two different assets: the right to privacy of people, that is the protection of those data pertaining to the intimate sphere of the person, whose dissemination, although not constituting a real offense to the honor or to the decorum, however, is not of public or social utility; the right to personal identity, in order to avoid that a specific person is attributed acts or behaviors that, although not detrimental to dignity, honor or decorum, are not true correspondents. Pursuant to the Privacy Code, if the processing operations, carried out with the aid of electronic tools, are aimed at analyzing the preferences and consumption choices of the interested parties, notification will be made to the Guarantor
Cookies are small text files that the sites visited by users send to their terminals, where they are stored before being re-transmitted to the same sites on the next visit. Instead, the so-called “third-party” cookies are set by a website other than the one the user is visiting. This is because on each site there may be elements (images, maps, sounds, specific links to web pages of other domains, etc.) that reside on servers other than that of the site visited.
Cookies are used for different purposes: computer authentication, session monitoring, storing information on specific configurations concerning users accessing the server, storing preferences, etc.
Technical cookies. These are cookies used to browse or provide a service requested by the user. They are not used for other purposes and are normally installed directly by the website owner.
Profiling cookies. These are cookies used to track user browsing on the net and create profiles on his tastes, habits, choices, etc. With these cookies advertising messages can be transmitted to the user’s terminal in line with the preferences already shown by the same user while browsing online.
• This site uses session, technical and profiling cookies.
• The use of session cookies (ie temporary cookies that are removed when the browser session is closed) is strictly functional for optimizing the use of the site and therefore for guaranteeing the best navigation within the site. •
• Among the technical cookies there are analytical cookies with anonymization of the IP address and in relation to which the third party undertakes not to cross-check the information contained in the cookies with others that it already has (these cookies are treated as technical cookies from the Guarantor’s clarification http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4006878). For third-party cookies: Google Analytics
• Technical cookies do not require consent and are installed automatically following access to the site.
• Third-party profiling cookies.
The purpose of these cookies is to analyze the user’s actions, the sites visited and provide, through third-party partners, commercial content and advertising in line with the user’s interests. Cookies may also be present for connection to social networks. Technology other than cookies may be used but similar to them for the same purposes.
The use of these technologies is governed by the privacy policies of the respective companies and not by this information.
Profiling cookies are installed only after the user explicitly gives consent.
Consent can be revoked at any time by removing the cookies installed by the site: Chrome – Firefox – Internet Explorer – Opera – Safari
• It is possible to disable the saving of cookies by changing the browser settings. However, this could lead to a malfunction in the site navigation. Below are the links for the configurations of the main browsers: Chrome – Firefox – Internet Explorer – Opera – Safari.
• Management of cookies. You can check the cookies present and selectively block the reception of cookies from individual operators at this address: http://www.youronlinechoices.com/it/le-tue-scelte
12. Specific information
For special processing purposes, specific information is provided with express requests for consent.
13. Safety measures
Personal data is processed in compliance with the minimum security measures provided for by Annex B of the DL 196/2003 and the provisions of the art. 32 of the Regulation (EU) 2016/679.
The Google Analytics personal data protection policy is available at this link https://support.google.com/analytics/answer/6004245?hl=it
15. Exercise of one’s rights
The Data Protection Manager appointed by us Maurizio Mantineo mobile 3126.96.36.199.33, or to the e-mail address email@example.com
You have the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and to oppose in any case, for legitimate reasons, to their treatment.
Requests should be addressed:
– via e-mail, at: firstname.lastname@example.org
– by fax: +39 0642815886
– or by mail, to E.T.G. Enif Tourism Group srl – VAT number: 12255101003 Via Francesco Crispi, 10 – 00187 ROME