Lefay Resorts & Residences - Trattamento della Privacy & Cookies

BOOK

PRIVACY POLICY ON PROCESSING USER’S PERSONAL DATA
pursuant to Regulation (EU) No. 2016/679 and any applicable Italian legislation

Dear Guest,

In order to ensure that the relationships with our guests are completely transparent and at the same time, protect their personal data, Lefay Resorts S.r.l. (VAT ID no. 02786260980), a company having its registered office and operating base at Via Santigaro 4, in S. Felice del Benaco (BS), ITALY, and its operating base at Via Feltrinelli 136, in Gargnano (BS), ITALY, as the Data Controller, informs you that any personal data you provided via the form called ‘Abbraccia il cambiamento’ (Italian for ‘Embrace Change’), which is part of the Lefay Spa Method, will be processed in full observance of the provisions under Regulation (EU) 2016/679 and any applicable Italian legislation.

1) Your personal data (pursuant to art. 4, paragraph 1 of Reg. (EU) 2016/679) will be used to prepare the most suitable treatments within the ‘Lefay SPA Method’ you requested.

You are informed that your data will not be processed using fully automated procedures and may be processed and filed in the company’s printed and electronic archives for the sole purpose of providing the requested services. The legal basis for the processing is your express consent, as well as contractual and legal obligations.

2) Your personal data will be deleted from the IT and physical databases of LEFAY RESORTS S.r.l. within 30 days after the date you check-out. This period is necessary for purely organisational purposes.

3) You are informed that if you refuse to give your consent to the processing of the data requested in the ‘Abbraccia il cambiamento’ form, this would prevent the company from providing, in full or in part, the services of the ‘Lefay Spa Method’, whereas other hotel services, such as the use of the swimming pools, could be provided.

4) The personal data you submit will not be disseminated but may be disclosed to operators who are part of the company’s staff and/or external parties who collaborate with the company as data processors or independent data controllers or such operators may become aware of such personal data, such as, for example:

self-employed professionals (doctors, physiotherapists, etc.) providing services at the SPA;
companies belonging to the LEFAY RESORTS Group;
other subjects to whom it should be necessary to disclose data for the correct and complete development of the contractual relationship and/or to fulfil legal obligations.

5) We would like to inform you that the company controlling the processing has appointed external managers who may have IT equipment in countries outside the European Union. This processing, however, will only take place in countries that have obtained an adequacy decision from the European Commission and guarantees of processing security. For any clarifications and requests, please contact the data protection officer (DPO) at the addresses stated below.

6) You are informed that you are entitled to withdraw your consent to the processing of data at any time, without prejudice to the processing already carried out.

7) We would also like to inform you that you have the right to request from the data controller company (Lefay Resorts S.r.l.) access to your personal data, and the right to obtain their rectification, erasure and restriction. You also have the right to object to the processing of your personal data and exercise the right to data portability. The rights stated in this paragraph may be exercised as provided by articles 15,16,17,18, 20,21 of EU Regulation 2016/679, which we enclose with this policy for your convenience.

All rights may be exercised in respect of the company controlling the processing; you also have the right to lodge a complaint with the supervisory authority envisaged by current national law.

8) For any explanations and to exercise the aforementioned rights, you are invited to contact the Data Controller company (Lefay Resorts S.r.L.) by contacting the Data Protection Officer (art. 37 of Regulation (EU) 2016/679) who can be reached at the Privacy Office of the company at Via Santigaro 4, S. Felice del Benaco (BS) ITALY, or by telephone at 0365/441711 or via e-mail at marketing@lefayresorts.com.

We would like to take this opportunity to wish you a pleasant stay.

Lefay Resorts S.r.l.

*This policy complements and completes elements already known to the data subject.

EXTRACT FROM EU REGULATION 679/2016

Article 15 Right of access by the data subject The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, access to the personal data and the following information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such data processing for the data subject. 2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. 3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. 4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16 Right to rectification The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17 Right to erasure (“right to be forgotten”) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 4.5.2016 IT Official Journal of the European Union L 119/43 b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing; c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); d) the personal data have been unlawfully processed; e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1). 2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: a) for exercising the right of freedom of expression and information; b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3); d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or e) for the establishment, exercise or defence of legal claims.

Article 18 Right to restriction of processing 1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject. 2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. L 119/44 IT Official Journal of the European Union 4.5.2016 3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 20 Right to data portability 1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and b) the processing is carried out by automated means. 2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21 Right to object 1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. 4.5.2016 IT Official Journal of the European Union L 119/45 4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.