PRIVACY & COOKIES POLICY

I - INFORMATION RELATED TO THE PRIVACY POLICY

This section contains information on how San Michele Boutique Hotel manages the data related to the users of San Michele Boutique Hotel website.
This information is also valid for the purpose of Article 13 of the EU Regulation n. 2016/679 (GDPR), concerning the protection and the free circulation of personal data, for those who interact with San Michele Boutique Hotel which can be reached at the address corresponding to the home page: sanmicheleprocida.com
The information is provided only for San Michele Boutique Hotel and not for other websites that may be consulted by the user via links contained therein. By visiting the sanmicheleprocida.com website, the practices described in this Privacy Policy are implicitly accepted.
The purpose of this document is to provide information about the methods, timing and nature of the information that data controllers must provide to users when connecting to the San Michele Boutique Hotel web pages, regardless of the purpose of the connection itself, according to Italian and European legislation.
This document may be changed due to the introduction of new regulations; therefore the user is invited to periodically check this page.
If the user is under 14, pursuant to article 8, regulation 1 (EU) 2016/679, and of the Art. 2 - Quinquies of Legislative Decree 196/2003, as amended by Legislative Decree 181/18, must legitimize its consent through the authorization of its parents or guardians.

II - DATA MANAGEMENT 1 - Data Holder

The data holder is the individual or legal entity, the public authority, the service or other body that, individually or together with others, determines the purpose and means of the processing of personal data. He also deals with security profiles.
Regarding this website, the data holder is: Luciana Careri, and for any clarification or exercise of the user's rights you can contact her at the following e-mail address: info@sanmicheleprocida.com.

2 - Responsible for data processing

The person responsible for data processing is the individual or legal person, the public authority, the service or other body that deals with personal data on behalf of the controller.
According to Article 28 of the Regulation (EU) 2016/679, on the appointment of the data holder, the person responsible for data processing of the San Michele Boutique Hotel website is: Luciana Careri.

3 – Other data recipients

Data related to the services provided by this website are managed only by the company's technical staff. No data acquired by the web will ever be disclosed.
Data may be disclosed to the parties acting as independent holders of the data processing such as:
- supervisory and control bodies and, in general, individuals, public or private, entitled to request data;
- lawyers, accountants, auditors.
The data can also be processed on behalf of the company by external parties appointed to process the data. Those entities, such as companies providing system maintenance services, will be provided with appropriate operational instructions.
The list of recipients can be requested by contacting the address above.

4 – Location of data processing

The processing of the data generated by the use of San Michele Boutique Hotel takes place in Via Cavone 4, Procida 80079, Naples, Italy, legal headquarters of DESEO Ltd. and at La Suite Boutique Hotel, headquarters of Deseo Srl, Via Flavio Gioia, 73 bis 80079 Procida (Napoli) Italy.
If necessary, the data related to the newsletter service may be processed by the processor or persons responsible for this purpose at its location.

III - COOKIES 1 - Cookies types

The San Michele Boutique Hotel website uses cookies to make the user's browsing experience easier and more intuitive: cookies are small text strings used to store some information that may relate to the user, his internet access device (computer, tablet, or mobile) and are primarily used to adjust the operation of the site to the user's expectations, providing a more personalized browsing experience and storing previous choices.
A cookie consists of a small set of data transferred to the user's browser from a web server and can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.
Cookies do not record any personal information and any identifiable data will not be stored. If you want, you can prevent some or all cookies from being saved. However, in this case, the use of the site and the services offered may be compromised. To proceed without changing the options related to cookies, simply continue with the navigation.

Those are the types of cookies that the site uses: 2 – Technical Cookies

There are numerous technologies used to store information on the user's computer, which are then collected by the sites. Among these the best known and used is that of HTML cookies. They are used for navigation and to facilitate the access and use of the site by the user. They are required for the transmission of communications over the electronic network and are required by the provider to provide the service requested by the customer.
The setting for managing or disabling cookies may vary depending on the internet browser you are using. In any case, the user can manage or request the deactivation or deletion of cookies, changing the settings of their internet browser. This deactivation can slow down or prevent access to certain parts of the site.
The use of technical cookies allows the safe and efficient use of the site.
Cookies that are inserted in to the browser and re-transmitted via Google Analytics or through the statistics service of bloggers or similar are technical only if used for the purpose of optimization of the site directly by the owner of the site, which can collect information in aggregate manner about the number of users and how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, provided for technical cookies.
From the point of view of duration you can distinguish between temporary session cookies that are automatically deleted at the end of the browsing session and serve to identify the user and thus avoid login on each page visited, and permanent ones which remain active in the PC until they expire or are deleted by the user.
Session cookies may be installed in order to allow access and stay in the restricted area of the portal as an authenticated user. They are not stored persistently but exclusively for the duration of the navigation until the browser closes and vanishes with the closing of the same. Their use is strictly limited to the transmission of session identifiers consisting of random server-generated numbers required to enable safe and efficient site navigation.

3 - Third-party cookies

Two types of cookies can be identified based on where they come from: cookies sent to the browser directly from the site you are visiting; and third-party cookies sent to your computer from other sites and not from the one you are visiting.
Permanent cookies are often third-party cookies.
Most third-party cookies consist of tracking cookies used to detect online behavior, understand interests and then customize advertising proposals for users.
Third-party analytical cookies may be installed. They are sent from domains of those third parties outside the site.
Third-party analytical cookies are used to detect information about user behavior on the San Michele Boutique Hotel website. The detection takes place anonymously, in order to monitor the performance and improve the usability of the site. Third-party profiling cookies are used to create user-related profiles in order to offer advertisements in line with the choices made by the users themselves.
The use of these cookies is governed by the rules laid down by the third parties themselves, therefore, users are invited to review the privacy policies and directions to manage or disable cookies published on the relevant web pages.

4 - Profiling cookies

Profiling cookies are those that create user profiles and are used in order to send advertisements in line with the preferences expressed by the user in the context of internet browsing.
When using these types of cookies the user will have to give an explicit consent.
Article 22 of the Regulation (EU) 2016/679 and Article 122 of the Data Protection Code will apply.

IV - PROCESSED DATA 1 - Data processing mode

Like all websites, this site also makes use of log files that store information collected in an automated way during user visits. The information collected may be as follows:

- internet protocol (IP) address;
- type of browser and parameters of the device used to connect to the site;
- name of the internet service provider (ISP);
- visit date and time;
- web page of the visitor's origin (referral) and output;
- the number of clicks, if necessary.

This information is processed in an automated form and collected in an aggregate-only form in order to verify the proper functioning of the site, and for security reasons. This information will be treated according to the rightful interests of the holder.
For security purposes (spam filters, firewalls, virus detection), automatically recorded data may also include personal data such as the IP address, which could be used, in accordance with applicable laws, in order to block attempts to damage the site or to cause harm to other users, or otherwise malicious activity or constituting offense. Such data is never used for the identification or profiling of the user, but only for the purpose of protecting the site and its users, that information will be treated according to the rightful interests of the owner.
If the site allows comments, or in the case of specific services requested by the user, including the possibility to send the CV for a possible business relationship, the site automatically detects and records some data user identifiers, including the e-mail address. This data is intended to be voluntarily provided by the user at the time of the service delivery request. By entering a comment or other information, the user expressly accepts the privacy policy, and agrees that the content entered is freely disseminated to third parties as well. The data received will be used only for the provision of the requested service and for the only time required to provide the service.
The information that users of the site will consider making public through the services and tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any liability in any violations of the laws. It is up to the user to verify that he has permissions to enter personal data from third parties or content protected by national and international rules.

2 - Purpose of data processing

The data collected by the site during its operation is used for the above purposes and also for the following purposes:

- management of the user and customer relationship;
- carrying out the ordinary activities of a hotel and other related activities such as improving products and services offering;
- Sending a message before arrival and after departure to the user;
- executing, confirming, modifying and cancelling a reservation;
- notifying of special offers and promotions as required in this privacy policy;
- sending satisfaction surveys or market research;
- sending information about new products and services, special offers and other information that we believe may interest the user;
- sending information about the products and services users have purchased at San Michele Boutique Hotel.
The data will be retained for the period strictly necessary to achieve the purpose indicated above and, in any case, no more than 10 years.
Data used for security purposes (blocking attempts to damage the site) is retained for as long as it takes to reach the previously indicated purpose.

3 - User-supplied data

As mentioned above, the optional, explicit and voluntary sending of e-mail to the addresses listed on San Michele Boutique Hotel website involves the subsequent acquisition of the sender's address, which is necessary to respond to requests, as well as any other personal data entered in the message.
Apart from what is specified for the navigation data, the user is free to provide the personal data reported in the application forms or otherwise indicated in the appropriate sections of the site to prompt the submission of information material or other communications. Failure to do so may make it impossible to obtain what is required. Personal data is processed with automated tools for the time strictly necessary to achieve the purpose for which they were collected.
Specific summary information will be progressively reported or displayed on the pages of the site prepared for specific services on demand.

4 - Support in setting up your browser

The user can also manage cookies through the setting of his browser. However, deleting cookies from the browser may remove the preferences you have set for the site.
For more information and support you can also visit the specific help page of the web browser you are using:
- Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
- Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
- Safari: http://www.apple.com/legal/privacy/it/
- Chrome: https://support.google.com/accounts/answer/61416?hl=it
- Opera: http://www.opera.com/help/tutorials/security/cookies/

5 - Social Network Plugin

This site also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies at the access of the page, to safeguard the privacy of the users. If necessary, cookies are set, if so provided by social networks, only when the user makes effective and voluntary use of the plugin. Keep in mind that if the user navigates being logged into the social network then he has already consented to the use of cookies conveyed through this site at the time of registration to the social network.
The collection and use of information obtained through the plugin is regulated by the respective privacy policies of the social networks, to which please refer:
- Facebook: https://www.facebook.com/help/cookies
- Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter
- Google: http://www.google.com/policies/technologies/cookies
- Pinterest: https://about.pinterest.com/it/privacy-policy
- AddThis: http://www.addthis.com/privacy/privacy-policy
- Linkedin: https://www.linkedin.com/legal/cookie-policy

V - USER RIGHTS

Art. 13, c. 2 of regulation (EU) 2016/679 lists the user's rights.
The San Michele Boutique Hotel website intends to inform users of the existence of users’ rights, according to the following articles of the EU Regulation 2016/679:
- Based on art. 15, the right of the person to ask the data holder to access to personal data, based on art. 16 the possibility of rectifying the data provided, based on art. 18 the possibility of supplementing or limiting the data management, based on art. 21 the opportunity for opposing, for legitimate reasons, to their treatment, based on art. 20 the right for data portability;
- Under art. 17, the right to request deletion, the anonymous transformation or blocking of data processed in violation of the law, including those which do not need to be retained in connection with the purpose for which the data was collected or subsequently processed.
- the right to obtain proof that the operations of updating, rectifying, integrating data, erasing, blocking of data, transformation have been brought to the attention, including with regard to their content, of those to whom the data has been communicated or disseminated, except in the case where such fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right.
Requests can be directed to the controller, without formality or, alternatively, using the model provided by the Data Protection Authority, or by sending an email to: info@sanmicheleprocida.com
If the data are managed based on art. 6, clause 1, lett. a) – consent to use the data, or on art. 9, clause 2 lett. a) – consent expressed to the use of genetic, biometric, health-related data, which reveal religious beliefs, or philosophical or union membership, which reveal racial or ethnic origin, political opinions- the user has the right to revoke consent at any time without prejudging the legality of the consent-based treatment provided before revocation.
Similarly, in the event of a violation of the law, users have the right to complain to the Personal Data Protection Authority, as a processing authority in the Italian State.
For a more in-depth review of the rights that are related to the users, Articles 15-22 of the Regulation (EU) 2016/679 can be reviewed.

VI - DATA TRANSFER TO EXTRA EU COUNTRIES

This site may share some of the data collected with services located outside the European Union area. Particularly with Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of the Regulation (EU) 2016/679, so no further consensus is needed. The companies mentioned above guarantee their membership of the Privacy Shield.
Data will never be transferred to third countries that do not comply with the conditions of Article 45 and subsequent, of the Regulation (EU).

VII - SECURITY OF THE PROVIDED DATA

This website treats user data lawful and correctly, taking appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. The treatment is carried out by computer and/or electronic tools, with organizational methods and with logic closely related to the stated purposes.
In addition to the owner, in some cases, they may have access to the data categories of appointees involved in the organization of the web site and DESEO srl (administrative, commercial, marketing, legal, system administrators) or external entities (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies).

VIII - CHANGES TO THIS DOCUMENT

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