Privacy Policy

Privacy Policy pursuant to Articles 13 and 14 of Regulation (EU) 2016/679

WEBSITE WWW.PRIORISECRETGARDEN.IT

In accordance with current legislation on the protection of personal data, PSG SRL, as the owner of this digital platform and the Data Controller, informs you that this Privacy Policy aims to describe the purposes and methods of processing your personal data carried out by the website www.priorisecretgarden.it, hereinafter referred to as the “Website,” and also provides you with all the information regarding the rights that are recognised by Regulation (EU) 2016/679, hereinafter referred to as “GDPR.”

PSG SRL also specifies that the software and IT applications used for the operation of the Website may acquire some of your personal data, the processing and transmission of which are implicit in the use of internet communication protocols.

1. DATA CONTROLLER

PSG SRL

Via Vermiglioli, 3, 06123 Perugia (PG) VAT No: 02074820545 PEC: [email protected] PEO: [email protected] Telephone: +39 075 5723378

2. TYPES OF DATA PROCESSED

As a result of browsing this Website, the processing activities carried out by the aforementioned company will be aimed at acquiring the following personal data:

3. CATEGORIES OF DATA SUBJECTS

The processing activities are aimed at the following categories of data subjects: Website Users/Visitors and Clients of Priori Secret Garden Hotel.

4. SUBJECT AND METHODS OF PROCESSING

   1. For the purposes of this Privacy Policy, the term “Processing of Personal Data” refers to any operation performed, even though automated processes, such as viewing, using, collecting, recording, storing, modifying, extracting, consulting, communicating, disseminating, or any other form of making available, including the deletion or destruction of data.
   2. The processing of personal data will be carried out in such a way as to ensure their security and confidentiality and will be performed through manual, electronic, and digital tools.
   3. Following the navigation of the Website by the user/visitor, PSG SRL will process the data communicated or legitimately collected. In particular the following Personal Data may be processed:

1. Navigation Data

The software and IT systems used for the operation of the Website, during their normal operation, acquire certain personal data that are implicitly transmitted in the use of internet communication protocols. This information, which by its nature could allow the identification of users/visitors (e.g., IP address), is used exclusively for statistical purposes and to check the correct functioning of the Website. No navigation data will be communicated or disseminated to third parties.

2. Personal and Tax Data provided voluntarily by the users/visitors

By connecting to the website www.priorisecretgarden.it, users/visitors voluntarily communicate their personal data to access certain services, such as: a. Requesting information through instant messaging services; b. Submitting a request through the contact form; c. Using the online booking service through the “Slope” Booking Engine software, integrated directly into the official website of the Priori Secret Garden Hotel.

Regarding point a), on multi-platform IP messaging systems belonging to Facebook and the cloud-based instant messaging service provided by Telegram LLC, users/visitors are advised to review the respective data processing policies at the following links:

• • • https://www.whatsapp.com/legal/

    • https://telegram.org/privacy

    • https://www.messenger.com/privacy

Regarding point c) on the online booking method, users/visitors are reminded that the acquisition of personal and tax data by the Data Controller will only take place with the explicit consent of the data subject; this functionality is optional, therefore its non-use does not preclude the possibility of navigating the Website and accessing other services that may be offered by the hotel.

In addition to the Data Controller, in some cases, external parties authorised under the direct control of the External Data Controller may have access to the data.

For further details and to review the “Privacy and Data Processing Policy” and the “Cookie Policy” provided, prepared, and implemented by Slope S.r.l. for the online booking panel, users are advised to view the dedicated booking engine section accessible from the “Book Now” button on the Website’s Home page. In the footer of the booking panel, clearly visible links to the mentioned documents are positioned.

3. Cookies

In addition to the data explicitly provided to the Data Controller, other data deriving from the navigation of the Website may be recorded when the user accesses it. The Website www.priorisecretgarden.it, like any other digital platform, can automatically send the user “cookies” during the viewing of the Website pages, which are small text files used to make navigation more convenient and to obtain information about the actions of the individual user, allowing the functioning of certain services that require the identification of the user’s path through the different sections of the Website. For more information on the use of cookies and how to manage, select, and/or delete them, please refer to the Cookie Policy of this Website.

4. Data acquired in the “Work with Us” section

Personal Data voluntarily provided to PSG SRL to submit a job application, only if the user/visitor has consented to their acquisition and has previously read this Information Notice.

5. PURPOSES AND LEGAL BASIS OF PROCESSING

1. 1. Personal data collected during navigation are processed to allow the user to use and learn about the services offered by the Website priorisecretgarden.it, as well as for maintenance and technical assistance to ensure the proper functioning and improve the quality and structure of the Website itself. All data processing is carried out within the limits and conditions provided by law, using direct and/or automated tools, including electronic, digital, and telematic means. PSG SRL will process the Personal Data of the user/visitor to achieve specific purposes, which will be communicated to you from time to time, and will process your Personal Data only when one or more of the following legal bases apply:

1. 1. The user/visitor has given their free, specific, informed, and unequivocal consent to the processing; b. The processing is necessary to execute a contract to which the user/visitor is a party or to carry out pre-contractual measures taken at their request, c. There is a legitimate interest of PSG SRL, always respecting the rights and fundamental freedoms of the data subject that require the protection of personal data, d. There is a legal obligation.

2. PSG SRL may also carry out the following activities, only with the explicit consent of the data subject, for purposes related to the operation of the hotel business: a. Sending commercial communications about products and services similar to those purchased; b. Sending commercial/promotional communications about Priori Secret Garden Hotel services via phone call, SMS, email, messaging services (e.g., WhatsApp, Messenger, Telegram), postal mail, social networks, digital channels, and newsletters. c. Conducting statistics and market research, analysing interests, habits, and consumption choices, including with the help of electronic tools, to improve service offerings and present personalised promotional information and activities.

6. RECIPIENTS AND TRANSFER OF PERSONAL DATA

Role	Recipient or Category of Recipient
Data Processor	Hosting Service Providers
Data Processor	ICT Systems Maintenance Services
Data Processor	Slope Booking Engine Software Provider
Data Processor	Consultancy Service Provider
Economic Data	Employees of the Data Controller

1. 1. For the purposes mentioned in point 5, PSG SRL may need to communicate users’ Personal Data to third parties to execute the contract, comply with legal obligations, or carry out activities instrumental to the provision of the requested services. The data may therefore be disclosed to employees, consultants, collaborators, and any other person performing activities based on instructions received from PSG SRL as Authorised Persons to Process Data. Additionally, data may be disclosed to entities belonging to the following categories: a. Public and private authorities, entities, and organisations connected to the hotel business, the provision of products, and/or the services of PSG SRL, or as required by specific legal provisions; b. Subjects performing technical or organisational tasks, data storage and processing, control, assistance, and consultancy, including legal consultancy, for PSG SRL.The entities belonging to the categories mentioned above will process the data as external Data Processors or as autonomous Data Controllers, or as Authorised Persons to Process Data, designated by PSG SRL; they will be given appropriate instructions to ensure confidentiality, security, and integrity of the data and the adoption of adequate security measures.

      Users’ Personal Data will be processed within the European Union and stored on servers located within the European Union

7. DATA RETENTION PERIOD

The Personal Data processed for the purposes described above will be retained in compliance with the principles of proportionality and necessity, subject to further retention where necessary to fulfil specific legal obligations or orders from authorities, manage disputes and claims, collect debts, and pursue possible legal actions.

8. SOCIAL MEDIA PAGES – FACEBOOK AND INSTAGRAM

When a user makes use of the Page administered by the Data Controller, the social media Facebook and the associated Instagram profile collect information such as the types of content viewed or interacted with, the actions performed, and information about the devices used (IP addresses, operating system, browser type, language settings, cookie data). The Page administrator may also view aggregated and anonymised statistical data regarding visits and interactions with the Page, without accessing any individual visitor’s personal data. To learn more about the processing of personal data performed by Facebook and Instagram, users are advised to consult the following documents:

https://www.facebook.com/privacy/explanation

https://www.facebook.com/legal/terms/information_about_page_insights_data

https://www.facebook.com/policies/cookies/

9. RIGHTS OF THE DATA SUBJECT