XENIA HOTELS COLLECTION
GUARANTEE OF DATA PROTECTION AND CONFIDENTIALITY
Pursuant to the new Regulation 679/2016, in accordance with the accountability principle, any processing of personal data shall be lawful, fair and transparent. According to said principles, the Data Subject shall be informed of the existence of the same, the purposes thereof and the rights he/she can exercise. In this context, the Data Controller provides the Data Subject with the information necessary to ensure correct use in accordance with the accountability principle.
You are therefore kindly requested to read the following information notice.
Xenia S.r.l. with head office in via Fiume, 20 - 50123 Firenze (FI), Italy, in its capacity as Data Controller, in the person of the legal representative for the time being, in accordance with and for the purposes of the EU Regulation 2016/679, hereby informs the Data Subject that the personal data concerning him/her, acquired by the Data Controller or requested subsequently and/or communicated by third parties, are necessary and will be used for the purposes indicated below. The personal data processed will be, generically, personal details or company names or email addresses or telephone numbers.
PURPOSE OF THE PROCESSING
The personal data collected will be used for purposes connected with pre-contractual, contractual, legal, fiscal and accounting requirements, for service communications, for complaints management and to inform you of our initiatives in general.
The personal data processed do not require your consent. In fact, the personal data collected are processed in connection with pre-contractual and contractual aspects and to inform you of services identical or similar to those requested. Provision of the personal data is necessary for pre-contractual and contractual purposes.
You will be free to request cancellation from our mailing list at any time, by writing to email@example.com
PROCESSING METHOD AND OBLIGATION OF CONFIDENTIALITY
The data are processed by means of IT tools and/or hard copy, by persons who are bound by confidentiality, using logic appropriate for the purposes and in any case in order to guarantee the security and confidentiality of the data. The data collected will not be disclosed or disseminated to third parties pursuant to the law.
COMMUNICATION TO THIRD PARTIES
Your personal data can be communicated to third parties known to us only for the above-mentioned purposes, and to the following categories in particular: external companies and professionals who carry out services on our behalf (as duly appointed external Data Processors); Bodies and Public Administrations for compliance with legal requirements.
The personal data of the Data Subjects will be kept for the time necessary for performance of the relations existing between the parties and for fulfilment of the relative obligations, without prejudice to storage thereof pursuant to the law in force, at the end of which they will be cancelled.
RIGHTS OF THE DATA SUBJECT
In accordance with the law in force, the Data Subject can assert his/her rights vis-à-vis the Data Controller, as stated by the Regulation 679/2016, i.e.:
- Right of access (art. 15);
- Right to rectification (art. 16);
- Right to erasure (art. 17);
- Right to restriction of processing (art. 18);
- Right to data portability (art. 20);
- Right to object (21);
- Right to withdraw consent;
- Right to lodge a complaint with a supervisory authority.
The individual rights of the Data Subject are detailed below:
RIGHT OF ACCESS (ART. 15);
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 recipient 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 processing for the Data Subject.
1. 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.
2. 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.
The right to obtain a copy shall not adversely affect the rights and freedoms of others.
RIGHT TO RECTIFICATION - art. 16
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.
RIGHT TO ERASURE - art. 17
1. 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;
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.
RIGHT TO RESTRICTION OF PROCESSING - art. 18
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.
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.
RIGHT TO DATA PORTABILITY – art. 20
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.
RIGHT TO OBJECT - art. 21
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. 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.
In addition to the above-mentioned rights, the Data Subject has the right to lodge a complaint with the Supervisory Authority as and when established by the law.
DATA CONTROLLER AND PRIVACY COMMUNICATIONS
The Data Controller is Xenia S.r.l., with head office in via Fiume, 20 - 50123 Firenze (FI), Italy.
The Data Controller provides the following address for all communications pursuant to the above articles of the EU Regulation 2016/679: firstname.lastname@example.org