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Privacy Statement

Welcome to Fortysevenhotel; we are pleased to liaise with you and offer you our services.

As you can imagine, in order to properly execute our duties, we collect and use your personal information.

Fortysevenhotel is committed to protecting and respecting your privacy: this Privacy Statement provides information about your rights in relation to the information we collect and process and about the measures we adopt in order for your privacy to be protected.

We are aware that this is a long document, but we ask you nonetheless to take the time necessary to read this Privacy Statement carefully.

In the index below are listed the topics covered, to make it easier for you to read these notices.

 

Index

 

Some useful definitions for informed reading

What personal data does Fortysevenhotel collect

How we use personal information

Which is the legal basis for processing personal data

Sharing your data with third parties

IP addresses and Cookies

Data security. Where personal information are stored and processed

Do we transfer data outside the European Union?

How long we retain your data for?

Consequences of failure to provide personal data

Do we process your data through automated means?

Do we process data relating to children?

What are your rights?

Changes to current privacy policy

Contacts

 

Some useful definitions for informed reading

First of all, we hereby inform you that when we mention “Fortysevenhotel”, or “us”, we refer to hotel management company Sogeal S.p.A., VAT n. 06249491009, represented by its pro-tempore appointed legal representative, with offices in Rome, Italy, Via Luigi Petroselli n. 47.

 

Sogeal S.p.A. shall be the “Data Controller”.

 

The terms “Client” or “User” mean you as the recipient of our services.

 

By the terms “Services” and/or “Products” we refer to all products and services we provide.

 

By the terms “Devices” or “Computers” we mean your smartphone, your personal computer or laptop computer you use to interact with us and our website.

 

By the term “Personal Data” we mean both the information you provide us with for the use of our Services as well as information which are collected through automatic means during your interaction with our website or with third party suppliers who work with us.

 

What personal data does Fortysevenhotel collect

  • We receive and store any data you provide us with in connection with the Services we offer when you request them through our website and/or if you are a guest of our Hotel, even only as a host of an event of ours. You can elect not to provide some data but in such a case you could not being able to use many of our Services.
  • You provide us with your data voluntarily by interacting through your Device on our website to request our Services: your name; your address and your phone number; payment information; your age; e-mail addresses; the content of reviews and e-mails sent to us; information and documents relating to identity and your status, if required; information related to your creditworthiness; VAT number; the log files and device configurations, including Wi-Fi credentials, if you choose to synchronize them automatically with other devices.

We may collect some of your data through automated means:

  • The data we collect and use through automated means are your Internet Protocol (IP) address when you connect to the Internet; your email address and the password you chose to access our Services whereas it is required to create one; information about your Computer, Device and connection such as the Device applications, the browser used for access, the operating system and the time zone setting; the Device or Computer geolocation; the telephone numbers you use to contact us; your interaction with the contents of our website.
  • We use personal information for email marketing if such an option has been selected in the relevant contact form. It is possible to withdraw consent at any time. For more information please go to the Cookie Policy section, by clicking here.

How we use personal information

We shall collect and process the Personal Data for the following purposes:

  • to receive and manage your requests, to provide our Products and Services, to process payment transactions and communicate with you regarding your requests, Products, Services and promotional offers;

·         to provide the Services you have subscribed to and/or you have requested by registering on our website;·         to provide assistance when you request it, by contacting our customer service by e-mail, chat or telephone;·         to adapt contents and resources to users’ preferences;·         to communicate with you, answer your requests or questions by phone, chat, text message or e-mail;·         to e-mail you other information and communications that you might be interested in;·         to create, publish and improve contents that are most relevant to you;·         to ensure that the content provided via the website is presented in the most effective way for you based on your Device;·         to allow you to use interactive features of the website, if desired;·         to develop and further improve the website and systems to provide you with a better service.

 

You have no obligation, either imposed by law or by contract, to provide your Personal Data.

However, since the communication of your data for the aforementioned purposes is necessary for the provision of all our Services, the failure to communicate some of your data makes it impossible to provide the Services, as the delivery of the same depends on the collection of some of your personal data, such as your name and surname and your payment information. The use of your data as described above is permitted by the applicable law on data protection, because: ·         it is necessary for our legitimate interests in pursuing the aforementioned purposes; in any case, these interests do not conflict with users’ right to privacy;·         in some cases, it is necessary to fulfill our legal or regulatory responsibilities, such as obligations to communicate with authorities, government or regulatory bodies;·         in some cases, it is necessary for the performance of a task carried out in the public interest and, when we use particular categories of Personal Data, it is necessary for the establishment, exercise or defense of legal claims, or when the processing relates to Personal Data already in the public domain;·         in limited circumstances, and subject to your consent, to send news and marketing communications via e-mail. If you wish and, therefore, with your explicit consent, your data may be used for advertising purposes in relation to our business activity or that of a third party, in the following ways: • market researches, economic analysis and statistics;• evaluation of usage data and preferences through the use of analytical tools in order to adapt the contents to users’ interests and thereby improve our offer;• sending of information notices and newsletters;• creation of user profiles, including geolocation data and payment data;• marketing of our Services and/or of third party services; sending of advertising / informative / promotional material including that regarding participation in initiatives and offers aimed at rewarding our customers;• for the purpose of carrying out and accounting of any commercial operations;• surveys on customer satisfaction about the quality of services provided.

 

Which is the legal basis for processing personal data

 

The legal basis that legitimizes the processing of Personal Data that you provide us with and/or that we collect even automatically when we send you e-mails or communications, is the execution of a contract to which you are party or the execution of pre-contractual steps taken on your request, or the compliance to legal obligations. In particular, we process your Personal Data for the following purposes: • to provide you with the assistance you wish to receive when you request our Services. In such cases, we inform you that in accordance with applicable legislation on data protection, the acquisition of your consent is not required if the processing is necessary for the fulfillment of the obligations arising from the contract to which you are party, while, during negotiation phase, it is also not mandatory to acquire consent if the processing is necessary to respond – before signature of the agreement – to specific requests of yours or for the execution of pre-contractual measures.• When you register on our website, by creating your profile (your account) you will allow us to process your requests, provide you with our Services and communicate with you via chat, sms, e-mail or phone to perform said Services according to your requests;• in some cases, processing is necessary for the performance of a task carried out in the public interest and, when we use particular categories of Personal Data, it is necessary for the establishment, exercise or defense of legal claims, or when the processing relates to Personal Data already in the public domain;• our business is in continuous development: we could therefore sell or buy other companies or services. Generally, in such transactions, the data relating to customers are part of the corporate assets that are transferred, but remain subject to the relevant applicable Privacy Statement (unless, of course, the customer does not consent otherwise). In case our corporate assets were acquired by third parties, Personal Data relating to customers would naturally fall within the transferred assets.

Sharing your data with third parties

We do not sell your Personal Data to third parties. Nonetheless, Fortysevenhotel may share your Personal Data between group and/or controlled companies, which are subject either to this Privacy Statement or otherwise to procedures that provide legal protection similar to that described in this Privacy Statement.

In order to facilitate the efficient use of data we collect and to provide users with content and / or resources, such data is disclosed to third parties. In any event, such disclosure will occur only in the following circumstances:

  • we may employ third party companies and individuals to perform certain activities on our behalf, i.e. to process your orders, send paper and/or electronic mail, remove recurring information from customer lists, analyse data, provide marketing assistance, search results and links;
  • we may employ third party suppliers to process payments, transmit contents, calculate credit risks and provide customer assistance services;
  • we share data relating to the account and other Personal Data when we believe that such communication complies with legal obligations; to enforce the agreements related to the sale of our Services; to defend the rights, assets and security of Fortysevenhotel, our customers or others. The foregoing includes the exchange of information with other companies and organizations that provide for the prevention of fraud or the reduction of credit risk;
  • on our web pages, the use of the so-called « social plugin » of social networks such as Facebook, Twitter, Instagram and Google+ is subject to the conditions set out below. While browsing our website, social plugins are disabled, i.e. they do not send any data to the respective social networks. If you wish to use one of the social networks, you must click on the respective social plugin to establish a connection with the corresponding server. If you have a user’s social network account and when you activate the social plugin you have already logged in, the social network can associate your visit of our web pages to your user account. If you wish to avoid this, before activating the social plugin you must log out of the social network. If you activate a social plugin, the social network transmits the contents made available directly to your browser that links them to our web pages. In such situation, transmissions of data initiated and managed by the respective social network may also occur. When connecting to a social network, data transmission between the social network and your system and your interactions on this platform are ruled by the respective social network’s data protection provisions. The social plugin remains active until you disable it or delete your cookies.

These third party service suppliers only have access to the Personal Data that are necessary for them to perform their activities, but they are not authorized to process such data for further purposes. In addition, such third parties are required to process the Personal Data they can access in accordance with this Privacy Statement and applicable data protection regulations.

In cases other than those listed above you will be informed if your Personal Data are shared with third parties and you will have the opportunity to choose whether or not to consent to such communication.

IP addresses and cookies

We collect information about your Computer and Device, including (where available) your IP address, operating system and browser version, for system administration. These are statistical data on the actions and browsing behavior of our users.

Likewise, we are able to collect information about how users browse the internet, through a cookie file saved in the Device. Cookies help us improve the website and provide better, more targeted content. For more information on the use of cookies on our website, see our Cookie Policy.

 

Data security. Where personal information are stored and processed

As specified above in paragraph “Sharing your data with third parties”, we share Personal Data with:

  • Suppliers, contractors or third party agents: when we employ suppliers, contractors or third party agents, Personal Data remains under our control and we have systems to ensure that such data is adequately protected.

 

We are committed to taking all measures reasonably necessary to ensure that your Personal Data is processed securely and in accordance with this Privacy Statement.

 

Fortysevenhotel has designed all the systems that allow the collection, the storage and processing of your Personal Data according to the highest security standards, to ensure the respect of your privacy.

 

All subjects who will be involved in the Personal Data processing on our behalf have been instructed by us and engaged to ensure the respect of your privacy.

 

We use a latest generation software, even in relation to payment transactions and management of credit card data.

 

Do we transfer data outside the European Union?

Your Personal Data may be transferred and processed in one or more countries within or outside the European Union. Whenever Personal Data is transferred outside the EEA – European Economic Area we will ensure that such data is transferred in accordance with this Privacy Statement and applicable data protection regulations.

 

How long we retain your data for?

We retain your Personal Data to allow you to use our Services for as long as necessary to provide the Services requested and to comply with the provisions of this Privacy Statement, such as tax and accounting purposes or, subject to your consent, our commercial purposes.

 

Consequences of failure to provide personal data

The provision of Personal Data is discretionary. Nonetheless, in case of failure to provide data indicated as “mandatory” we will not be able to provide the Service.

In case of failure to provide the remaining data not indicated as “mandatory” we will be able to provide the Service but we will not be allowed to send you our updates and our promotional communications.

 

Do we process your data through automated means?

Fortysevenhotel may process your data through automated systems / processes and an automated decision procedure (such as profiling) to offer you and our customers the required Services. For example, in order to implement our Services in certain periods of the year, we can carry out an automated profiling process.

 

Do we process data relating to children?

We do not process Personal Data relating to minors. If you are aged under 18, you will be allowed to access our Services exclusively through a parent or a guardian of yours. In particular, Fortysevenhotel will ensure, through the use of available technologies, that the consent is given by said parent or guardian.

What are your rights?

According to the applicable data protection law, the user has the following rights:

  • right to access and obtain a copy of your Personal Data: you have the right to request confirmation of the fact that we are processing any Personal Data of yours. In this case, you will have access to your Personal Data and some information on how they are processed. In some cases you can ask us to provide an electronic copy of your data;

·         right to obtain the rectification of Personal Data: if you are able to demonstrate the inaccuracy of Personal Data of yours in our possession, you may ask for them to be updated and/or otherwise rectified;·         right to be forgotten / right to erasure: in certain circumstances, you can have your Personal Data erased. The request can be presented at any time; Fortysevenhotel will evaluate if it can be agreed. Nonetheless, this right is subject to legal rights or obligations that could impose data retention. In all situations where the applicable law provides that the request of erasure of Personal Data must be granted, Fortysevenhotel will proceed without undue delay.

 

To exercise your rights, you can write to us any time at the following email address: privacy@fortysevenhotel.comTo the extent that the processing of Personal Data is based on your consent, you also have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legitimacy of any processing based on consent given prior to such withdrawal.It is also possible to file a complaint regarding the processing of Personal Data with the relevant Data Protection Authority.

 

Changes to current privacy policy

The conditions of this Privacy Statement may change from time to time. We will publish any substantial changes to this Statement by means of proper communication on this website or by contacting the user via other channels.

 

Contacts

Questions, comments and requests relating to this Privacy Statement are welcome and should be addressed to Sogeal S.p.A., at the following e-mail address: privacy@forysevenhotel.com

 

Data controller: Sogeal S.p.A., VAT n. 06249491009, represented by its pro-tempore appointed legal representative, with offices in Rome, Italy, Via Luigi Petroselli n. 47.

Last update: December 2018