Introduction

This website does not contain any forms for the collection of personal data. The data entered into the information request form or the booking engine reservation form are processed in accordance with the following Policy.

Dear Visitor,

we are aware of the importance of protecting personal data. For this reason, the data we collect through the cookies used by the website to facilitate navigation will be processed in compliance with the applicable legislation.

We therefore invite you to read the following information, provided pursuant to Article 13 of Regulation (EU) No. 2016/679 (“Regulation”), concerning the methods of management and processing of data collected through cookies. Please note that we may update this privacy notice at any time, subject to publication of the changes on the Website: we therefore invite you to periodically review the relevant page.

1. Types of data collected (“Data”), purposes, legal basis of processing and retention period

a) Browsing data

The IT systems and software procedures responsible for the operation of the Website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes IP addresses or domain names of the users’ devices connecting to the website, MAC (Media Access Control) addresses, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server’s response (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment.

We use these Data for the following purposes:

– to obtain anonymous statistical information on the use of the Website and to verify its proper functioning. We delete the Data used for this purpose immediately after processing; however, they may be used to ascertain liability in the event of cybercrimes against the Website. The legal basis for this processing is Article 6(1)(b) of the Regulation, as it is necessary to allow you to use the requested service (i.e., browsing the Website).

– to comply with legal obligations or requests from judicial authorities. The legal basis for this processing is Article 6(1)(c) of the Regulation, as the processing is necessary to comply with a legal obligation to which we are subject.

b) Data voluntarily provided by you

Whenever you send emails to the addresses indicated on the Website, we process your email address and any additional personal data contained in the message for the following purposes:

– to respond, by email, to your requests. The legal basis for this processing is Article 6(1)(b) of the Regulation, as it is necessary to provide the requested service (i.e., responding to your inquiries);

– to comply with legal obligations or requests from judicial authorities. The legal basis for this processing is Article 6(1)(c) of the Regulation, as the processing is necessary to comply with a legal obligation to which we are subject.

We kindly ask you not to send to our addresses any “special categories of data” as defined by the applicable legislation (for example, data relating to your health status or religious beliefs). Such data, if provided, will be immediately deleted.

c) Cookies

Our Website uses exclusively technical cookies (session and navigation cookies) in order to ensure its normal browsing and proper functioning (for example, enabling authentication and access to restricted areas).

For all information relating to the processing of Data through cookies, please refer to the relevant policy, accessible in the footer on each page of the Website as well as via the relevant link.

2. Data retention period

We retain browsing Data for the entire period of service provision and will delete or anonymise them within 7 days from their collection.

We retain the Data that you independently send to us through the tools available on the Website after we have provided the requested service or responded to your communication, except for data necessary to comply with tax, accounting and administrative regulations or to fulfil other legal obligations and to document the activities carried out.

3. Processing methods

Your Data will be processed by expressly authorised personnel through electronic tools, organised into databases and stored on appropriate media for their retention (for example, digital and paper-based systems).

In any case, we do not use automated decision-making processes.

In order to prevent loss of Data, unlawful or incorrect use, or unauthorised access, we have implemented specific security measures. In particular, the servers hosting the Website are regularly monitored and certified against intrusions by companies specialised in IT security, ensuring their security and reliability.

4. Provision of Data

In order to use the Website, it is necessary to provide browsing data. Such provision is mandatory: without it, we will be unable to allow you to browse the Website.

The provision of Data for the purposes described above is optional: in the absence of such provision, there will be no consequences. The installation of technical, analytical and third-party cookies is also optional (as mentioned, it can be prevented through your browser settings); however, failing this, you may encounter difficulties in browsing the Website or using some of its services.

5. Communication of Data

We may communicate the Data provided by you to:

(i) entities to whom legal provisions or secondary regulations grant the right and interest to access your Data;

(ii) companies, associations or professional firms that we engage for the performance of specific activities, compliance with legal obligations and any organisational and administrative requirements necessary to provide the requested services, subject to their prior appointment as Data Processors (“Processors”).

Should you wish to know the identity of the appointed Processors, we invite you to submit a specific request to the contact details indicated in section 9.

It is understood that we will not disclose your Data.

6. Transfer of Data outside the EU or to international organisations

We do not transfer Data collected through browsing or use of the services available on the Website to countries outside the European Union or to international organisations.

7. Links to third-party websites or services

This privacy notice applies solely to the processing of personal Data carried out through the Website or the tools provided therein, and not to other websites that you may consult, even via a link.

Please note that the operators of such websites act as independent data controllers and may adopt different processing policies. We therefore invite you to carefully review their privacy notices.

8. Your rights

As a data subject, you may exercise at any time the rights provided by the Regulation, including the right to:

– request information about:
(i) the origin of the Data;
(ii) the purposes and methods of processing;
(iii) the logic applied in case of processing carried out using electronic tools;
(iv) our identification details and those of our Processors;

– obtain:
(i) access to, updating, rectification or completion of the Data;
(ii) erasure, anonymisation or blocking of Data processed unlawfully;
(iii) restriction of processing;
(iv) a copy of the Data in a standard format;

– object, in whole or in part, to processing carried out:

a) for scientific, historical or statistical research purposes, where such objection is based on reasons related to your particular situation;

b) for the performance of a task carried out in the public interest or in connection with the exercise of official authority, or for the pursuit of our legitimate interest;

c) for the sending of promotional and advertising material and direct marketing;

– withdraw, at any time, any consent previously given, without affecting the lawfulness of processing carried out before its withdrawal;

– lodge a complaint, if you believe that our processing of the Data violates the legislation, with the supervisory authority of the Member State where you habitually reside or work, or where the alleged violation occurred.

We also remind you that the Italian supervisory authority (Garante per la Protezione dei Dati Personali) may be contacted using the details provided on its official website.

9. Data Controller

The Data Controller is Le Due Stelle (Tax Code MSTSST71S27H501M), Via Delle Gondole Scala B Int. 4, 109 Ostia (RM), in the person of its pro tempore legal representative.

We can be contacted at the following address: info@leduestelle.it.