1) Object of the handling
The Holder handles personal, identifiable and sensitive data (in particular, name, surname, fiscal code, VAT number, email, telephone number, allergies, food intollerances, – in the following, “personal and sensitive data” or also “data”) communicated from you directly to V.T.E. Villaggio Europa S.p.A. during the information request phase and/or booking, and/or booking confirmation.
Your personal data is handled:
A) Without your explicit consent, for the following ends of Service:
- To fulfill pre-contractual, contractual and fiscal obligations, which derive from relations that you have in them;
- To fulfill the obligations anticipated by the “Consolidated text of public security laws” (article 109 Royal Decree 18.6.1931 n. 773) which enforces that we communicate to the police headquarters, for public safety, the general information of the accommodated clients;
- To fulfill obligations established by the law, by a regulation, by the community legislation or by orders from Authority;
- To exercise the handler’s rights, for example the right of defense in court.
- To obtain and confirm your accommodation reservation and ancillary services, and to provide the requested services.
- For the safety of the people, the property and corporate assets through a systems of video surveillance in some areas of the structure, identifiable by the presence of the appropriate signs.
- To allow you to register on our web site;
- To allow the subscription to our newsletter service, offered by the Holder, and eventually the other Services you request;
- To carry out the service of receiving messages and phone calls directed to You during your stay;
- To send you our promotional messages and updates on rates and offers;
3) Processing methods and data retention times
The processing of your personal data is done through the following operations and specifically: gathering, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blockage, communication, cancellation and destruction of data. Your personal data is submitted to both a paper and an electronic processing.
The Holder will process the personal data for the necessary time in order to fulfill the ends also established above and for no more than 10 years from the termination of the relationship for the Service purposes and for no more than 5 years from the gathering of the data for Marketing purposes, except for the exercise of the rights of the interested party and/or other law obligations. The personal data provided to the Holder for requests of information and/or preventive which have not followed up with booking confirmation, shall be processed for 3 months.
4) Data access
Your data can be made accessible for the reasons of articles 2.A) and 2.B):
- To employees and collaborators of the Holder, as authorized personnel and/or internal managers of the process and/or system administrators;
- To external companies for the maintenance of the computerised systems, for the storage of personal data, etc. or to third parties (for example, provider for the management and maintenance of the web site, service providers, credit institutions, professional studios, etc) which carry out outsourcing activities on behalf of the Holder, as external managers of the processing.
5) Communication of data
Without your explicit consent, the Holder can communicate your data for the reason such as in the article 2.A) to supervisory bodies, judicial authorities and all other subjects to whom communication is compulsory due to laws for the performance of the above stated reasons. Your data will not be spread.
6) Data transfer
The management and conservation of the personal data will take place on servers located inside of the European Union of the Holder and/or third-party agencies entrusted and duly appointed as Responsible for processing. At the moment our servers are located in Italy.
The data will not be object to transferring outside of the European Union. It is intended that the Holder, in cases proven necessary, will have the ability to move the location of the servers in Italy and/or European Union and/or non-European countries. In this case, the Holder assures, already from this moment on, that the transferring of non-European data will take place in accordance with the applicable legal provisions by entering into, if necessary, agreements that guarantee an adequate level of protection and/or adopting standard contract terms provided by the European Commission.
7) Nature of the data conferral and consequences of refusal to answer
The conferral of data for reasons established in art. 2. A) is compulsory. In their absence, we will not be able to guarantee the Services in article 2.A).
The conferral of data for reasons established in art. 2.B) instead is optional.
Therefore, you can choose not to provide any data or to subsequently deny the option of managing the provided data: in this case, the Services such as in point 2.B will not be able to be granted. In any way, you will continue to benefit from the Services established in art. 2.A).
8) Rights of the data subject
As the interested person, you have rights such as in art. 15 GDPR and specifically the rights to:
A) Obtain the confirmation of the existence or not of personal data which involve you, even if not yet registered, and their communication in a readable and comprehensible form;
B) Obtain information regarding:
- The origin of the personal data;
- The ends and modes of management;
- The logic applied in cases of data handling through electronic means.
- The identification details of the Holder, of the managers and of the designated representative; and of the subjects or the category of subjects to which the personal data can be communicated to or that can be made aware of it as designated representatives of the State territory, of managers or of those in charge;
- The update, or the rectification, when it interests you, of the data integration;
- The cancellation, the transformation in an anonymous form or the blockage of data managed in violation of the law, including those of which the conservation is not necessary in relations to the reasons for which the data was gathered or successively treated;
- The claim that the operations as in articles 8.A) and 8.B) have been brought to your attention, also their content, of those to who the data was communicated to or spread to, except for the case in which its fulfilment proves impossible or would mean the use of objectively unproportioned means when compared to the protected person’s rights;
D) Oppose, completely or partially:
- For legitimate reasons regarding the managing of the personal data, even if they are relevant to the reason for gathering them;
- To the treatment of your personal data that involve you in order for us to send you advertising or marketing material through email and/or through traditional marketing modes by telephone and/or paper mail.
- When applicable, you also have the rights as in the articles 16-21 GDPR (The right of rectification, the right to be forgotten, the right to limit the data management, the right to data portability, the right of opposition), as well as the right of complaint to the guarantor.
9) Modes of exerting your rights
You can exercise your rights at any moment by sending:
- A registered letter addressed to: V.T.E. Villaggio Europa S.p.A., with legal headquarters in via Locchi 2 – 34170 Gorizia (Go)
The services provided by the Holder are also intended for minors under 18 years of age and the Holder gathers personal information regarding minors only through those exercising the parental rights.
11) Holder, managers and those made in charge
The Holder of the management is V.T.E. Villaggio Europa S.p.A. as the legal representative pro-Tempore, with legal headquarters in via Locchi 2 – 34170 Gorizia (Go). The updated list of the managers and those in charge of the managing is secured at the headquarters of the Holder.
12) Changes to the stated information
The stated disclosure can undergo changes. We suggest, therefore, that you regularly check this information and seek out the version that is best updated.
offices of VTE or other locations included in the latter’s ownership.
information are not specifically derogated or modified.
1) Types of personal data collected and for those interested
In the limits of their finality and defined in the present information, the following are subject to being processed:
a) Data regarding body temperature and those resulting from auto-certifications requested from the required safety measures to contain the spread of Covid 19.
The personal data subject to being processed refers to:
b) The providers, the carriers, the contractors, the visitors, the clients and every other third party authorized to access the premises and offices of VTE or other locations included in the latter’s ownership.
2) Finality and legal foundation of the processing
The personal data will be exclusively processed in order to prevent the spread of Covid-19, executing the Protocol of anti-infection safety measures taken from the laws of article 1, n.
7, reading. d) of DPCM 11 March 2020. As modified and integrated from the DPCM 17 May 2020, Attachment 10 – Criteria for protocols in the sectors elaborated from the technicalscientific committee in the date of 15 May 2020 and recalled in the DL 33 of 16.5.2020.
•DPCM 17 May, Attachment 17 – Guidelines for the reopening of economic and productive activities of the Regional Conference and those of the autonomous province of 16 May
2020. The legal basis of the processing is, therefore, of the implementation of the safety protocols for anti-infection as according to the article. 1, n. 7, reading. d) of the DPCM 11 March 2020. As modified and integrated in the DPCM 17 May 2020, Attachment 10 - Criteria for protocols in the sectors elaborated from the technical- scientific committee in the date of 15 May 2020 recalled in the DL 33 of the 16.5.2020 and subsequent modifications and integrations.
•DPCM 17 May, Attachment 17 – Guidelines for the reopening of economic and productive
of the Regional Conference and those of the autonomous province of the 16 May 2020.
3) The nature of the provision of personal data
The provision of data is necessary to access the premises and offices of VTE or other locations included in the latter’s ownership. A refusal to accept would prevent us from
4) Modes, methods and duration of the data processing.
The processing of data is done by the VTE staff that acts based on specific instructions given to them in order to meets the ends and methods of the processing.
Making reference to the measuring of the body temperature, VTE does not write down or register any of that data. The identifications of whom it interests and the registration of the
passing of the temperature testing could take place only if it were necessary to document the reasons that have prevented access on the grounds. In this case, those involved will be
informed of those circumstances. The personal data will not be object to being spread, nor will be communicated to third parties, if not for specific reasons following the regulatory provisions (ex. In the case in which it is requested on behalf of the Health Authorities to go through the steps and reconstruct the thread of eventual close contacts of a worker that has resulted positive at the COVID-19 test).
The data will be processed for strictly the necessary time period to follow through with the cited methods of prevention from the contagion of COVID-19 and will be stored no more
than the duration that the state of emergency will last, at the moment established as the 31 July 2020 from the resolution of the Council of Ministers on 31 January 2020.