Newsletter Policy

PRIVACY POLICY

Pursuant to Italian Legislative Decree no. 196 dated 30 June 2003 and EU Reg. 2016/679

Pursuant to Italian Legislative Decree no. 196/2003 and art. 13 of EU Reg. 2016/679, in relation to personal data of which HOTEL GARDEN S.P.A., based in Corso delle Terme, 7, Montegrotto Terme, Italy (35036 - PD), VAT no. 00898530282, represented by its legal representative pro tempore, comes into possession, we hereby inform you of the following:

1. PURPOSE OF DATA PROCESSING

The processing aims to collect, store, and process data for commercial purposes, for example sending advertising materials, direct sales, conducting market research, and facilitating commercial communication, with particular reference to the processing of the e-mail address, including for newsletter purposes.

2. METHOD AND LEGAL BASIS OF THE PROCESSING

The data processing may be carried out with or without the aid of electronic or automated tools. The processing is carried out by individual, specifically appointed data processors under the supervision and according to the instructions of the Data Holder and/or the various specifically appointed data controllers. The legal basis for processing lies in the specific consent of the Data Subject, granted through the specific function on the hotel website.

3. PROVISION OF DATA AND RETENTION PERIOD

The provision of general personal data (identification data and address details) referred to in this policy is not mandatory but is necessary for the purpose of performing the activities set forth in sec. 1. If the deletion of the data/opposition to processing/termination of the service (this specific function shall be available at the end of every message of the newsletter) is not requested, the data shall be retained for the duration of the newsletter service for the aforementioned purposes. The Data Subject shall have the right to revoke the consent originally provided at any time, which will result in the immediate termination of the processing of the provided data.

4. REFUSAL TO PROVIDE DATA

Any refusal by the Data Subject to provide the personal data set forth in sec. 3, or the erroneous communication of said data, shall make it impossible to carry out the activities set forth in sec. 1.

5. DISCLOSURE AND SHARING OF DATA

Personal data may be disclosed to public/private entities for the purposes outlined in sec. 1 for which disclosure is either mandatory or necessary to comply with legal obligations. Additionally, it may be disclosed to constitutional bodies or bodies with constitutional functions. The personal data collected shall not be shared.

6. RIGHTS OF THE DATA SUBJECT AND COMPLAINTS

EU Reg. 2016/679 grants the Data Subject specific rights, including the right to access their personal data and have them made available in an intelligible form; the Data Subject also has the right to updating, rectification (if erroneous), integration (if incomplete), or deletion of data (in case of unlawful processing), data portability (right to receive or transmit data to another holder in a commonly used, structured format readable by automatic devices), revocation of consent (if legal basis for processing), transformation into anonymous form or blocking/limitation of data processed in violation of the law; the Data Subject has the right to oppose, for legitimate reasons, the processing of data. With reference to the processing of the data provided, in the event that the Data Subject identifies violations of the privacy legislation, they will have the right to lodge a complaint with the Privacy Guarantor. The Data Subject may exercise their rights by submitting a request to either the Data Holder or the Data Protection Officer (including by requesting to receive the respective forms and, if necessary, obtaining the complete list of appointed data controllers from them).

7. DATA HOLDER AND DATA PROTECTION OFFICER

The Data Holder for the purposes of processing is HOTEL GARDEN S.P.A. (VAT no. 00898530282 – certified e-mail gardenterme@no-spam.pec.no-spam.it – e-mail garden@no-spam.gardenterme.no-spam.it), based in Corso delle Terme, 7, Montegrotto Terme, Italy (35036 - PD). The Data Protection Officer is Mr Francesco Cecchinato (lawyer, tax code CCCFNC89M07G224U – certified e-mail francesco.cecchinato@no-spam.ordineavvocatipadova.no-spam.it – e-mail cecchinato@no-spam.cebavvocati.no-spam.it) with address for service in Padua, Italy (35129 - PD), Via G.A. Longhin n. 11