Capitali Russe (Mezza Pensione)

PRIVACY POLICY

Website Booking.sostravel.com

Information pursuant to art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR")

Dear User,

the methods of processing personal data collected automatically or provided by you through navigation or use of the website are illustrated below https://booking.sostravel.com/ (hereinafter, the "Website").

1.    Data Controller

The Data Controller is Digital Destination Company Srl, in the person of its legal representative, domiciled at the registered office in via marsala 34/A – 21013 Gallarate (VA) (hereinafter "SOS", "Company" or "Data Controller").

2.    Type of data processed

To allow you to use the Website and its services, including the possibility of creating an account, making reservations and requesting quotes (hereinafter, the "Services"), the Data Controller needs to know and process some Your personal data.

Data communicated voluntarily by the user

To allow the use of the Website and its Services, including the possibility of creating your account, you must provide DDC with your personal data (name and surname), your contact details (email address and telephone) and the country of residence.

In order for you to make reservations, the Data Controller needs to process your personal data (name, surname, tax code), your email address, your telephone number and your residential address, as well as any other necessary personal data. to billing.

To allow you to retrieve your booking, the confirmation number and the email used will be requested.

The optional, explicit and voluntary sending of e-mail messages involves the acquisition of your personal data, your e-mail address, as well as any other data entered in the message or in the forms you sent. Should you contact our call center, your name and surname, any booking number, as well as any other information necessary to satisfy your requests will be requested.

Navigation data

procedures software to operate the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in the URI (Uniform Resource Identifier) notation 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 response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment.

These data, necessary for the use of the Website, are processed for the sole purpose of obtaining statistical information on the use of the Services (most visited pages, number of visitors per hour or day, geographical areas of origin, etc.) and to check the correct functioning of the Services offered.

The navigation data do not persist for more than seven days and are deleted immediately after their aggregation, without prejudice to the possible need to ascertain crimes by the judicial authority.

Cookie Policy

The Website uses the following types of cookies and other tracking identifiers.

Technical

Technical and session cookies are used, which are small text files containing a certain amount of information exchanged between your terminal or your browser and the Website, allowing it to function and be used correctly.

First and third party analytical cookies

This Website uses cookies first and third party analytical cookies are cookies used to collect information on the use of the Website, in aggregate form, in particular on the number of users and on how they visit the site, also providing anonymous statistical analysis in order to improve the use of the Site. Web and make the contents more interesting and relevant to the wishes of users.

To view the links to the privacy policies of third parties, disable all or some of the aforementioned cookies, please refer to the following https://booking.sostravel.com/#j_id_1r_2r:cookiesPolicy .

Profiling

This website uses cookies first and third party profiling. These cookies are not essential, but they help to personalize and improve your experience on the Website. For example, they help us to know and remember your preferences and to show relevant and personalized advertisements. They also allow us to limit the number of times each ad is shown, measure the effectiveness of the advertising campaign, remember the visit and share the collected data with third parties, such as advertisers.

The elimination of these cookies, therefore, although it does not affect the general usability of the Website, could still lead to a limitation of some functions.

To view the links to the privacy policies of these third parties, disable all or some of the aforementioned cookies, please refer to the following https://booking.sostravel.com/#j_id_1r_2r:cookiesPolicy.

Options regarding the use of cookies by the Website through the browser settings

The delivery of all cookies can in any case be deactivated by changing the settings of your browser. It should be noted, however, how intervening on these settings could make the site unusable if the cookies essential for the provision of our Services are blocked. However, each browser has different settings for disabling cookies. Below are links to instructions for the most common browsers: Apple Safari,Google Chrome,Microsoft Internet Explorer,Mozilla Firefox,Opera.

3.    Purpose, Legal Basis of the Processing and Nature of the Contribution

•  Use of the contents and services of the Website(i, ii) and guarantee of network and information security(iii). This purpose includes the possibility of allowing the reaction of your account, which is necessary to make reservations through the Website, as well as to manage them. This may also involve the processing of some of your particular data to follow up on specific requests, such as, for example, those for special assistance.This purpose also includes the possibility of forwarding requests and communications through the Website. Furthermore,this purpose includes the processing of personal data relating to traffic, to an extent strictly necessary and proportionate to guarantee the security of networks and 'information.
• (i) Execution of a contract to which you are a party
• (ii) Fulfillment of legal obligations 
• (iii) Legitimate interest In the case of particular data, the legal basis of the processing is your express consent.
• The provision of your data is mandatory.
• Failure to authorize their treatment would make it impossible to use the contents and services of the Website.
• Furthermore, failure to authorize their treatment would make it impossible to guarantee network and information security. 
• In the case of particular data, the provision is optional. However, failure to authorize their treatment could make it impossible to follow up on your specific requests.

• Receipt of marketing, including newsletters and commercial information(i). This purpose includes the possibility to subscribe to our newsletter and to have communications and information of a commercial and direct marketing nature on our Services and offers, on discounts and on any other promotional and loyalty initiative adopted, both through traditional contact systems and fully automated, such as, for example, through the use of your e-mail address.
• (i) Express consent
• The provision of your data is optional.
• Failure to authorize their treatment, while not preventing the use of the Website in any way, may not allow you to take full advantage of the advantages we offer to our community through information of an advertising, commercial and direct marketing nature.

• Receipt of offers, discounts and other benefits based on a profiling process(i). This purpose includes the possibility of receiving offers, discounts and any other benefits and promotional initiatives modeled on your specific needs and purchasing propensities, also by participating in loyalty programs, which provide for registration, identification and profiling of data relating to your purchase volumes, your habits and consumption choices.
• (i) Express consent
• The provision of your data is optional.
• Failure to authorize their processing, while not preventing the use of the Website in any way, may not allow us to send you personalized communications based on your browsing habits and choices. 

4.    Retention period

Personal browsing data and those acquired through the use of the Website will not be stored for more than seven days.

With regard to your personal data processed for the contents and services of the Website, DDC will keep them for 10 years from the booking.

With regard to the processing of your personal data for direct marketing purposes, the Company has established to provide for the automatic cancellation of your personal data, or their transformation into anonymous form in a permanent and non-reversible way, within 24 months of registration. of the collected data.

With regard to the processing of your personal data for profiling purposes, in compliance with regulatory requests and provided that they have been explicitly authorized by you, the Company has established to provide for the automatic cancellation of your personal data, or for their transformation into anonymous form in a permanent and non-reversible way, within 12 months from the registration of those used for profiling purposes.

With regard to the other personal data acquired, not being able to accurately predetermine their retention period, the Data Controller undertakes from now on to inspire their treatment to the principles of adequacy, relevance and data minimization, as required by the GDPR, verifying the need for their conservation annually. This, without prejudice to the case in which it is necessary to keep such data to fulfill regulatory obligations, or to ascertain, exercise or defend a right in court.

5.    Categories of Recipients of Personal Data

The personal data processed will not be disclosed to third parties, but may in any case be disclosed in relation to the processing purposes previously set out to the following subjects:

• those who can access the data by virtue of the provisions of the law provided for by law of the European Union or that of the Member State to which the Data Controller is subject;
• subjects that perform auxiliary purposes to the activities and services referred to in paragraph 3, or companies that offer transport services, accommodation facilities, companies that offer payment services, companies that offer advertising, marketing and communication services, companies that offer infrastructure information technology and IT assistance and consultancy services as well as design and implementation of software and Internet sites, companies that offer services useful for personalizing and optimizing our services, companies that offer data analysis and development services (including those relating to user interactions with our services), service centers, companies or consultants appointed to provide additional services to the Data Controller, within the limits of the purposes for which they were collected.

Furthermore, our employees may also become aware of your personal data, provided that they are previously designated as a subject acting under the authority of the Data Controller pursuant to art. 29 of the GDPR or as System Administrator.

6.    Transfer of Personal Data to Third Countries

The Data Controller may transfer your personal data to third countries outside the European Union and, in particular, the United States for the management of payments. Such transfer is always subject to adequate guarantees through the use of European Union Standard Contractual Clauses. For more information on the data transfer rules to countries outside the European Union, including the mechanisms we rely on, you can consult the European Commission website here. To request a copy of those signed by DDC, you can send an email to privacy@amareitalia.com.

7.    Any Automated Decision-making Processes

If you explicitly authorize the processing of your personal data for profiling purposes, the Data Controller will use automated decision-making processes aimed at profiling your browsing habits, your preferences and your interactions with the Website. The aim is to allow you to use the Website in a manner consistent with your interests and preferences, as well as to offer you the opportunity to take advantage of offers, discounts and any other benefits and promotional initiatives tailored to your specific needs. For the purposes of their operation, these processing activities provide for registration, analysis and profiling the destination, the requested structure, the number of nights, the purchase volume, the check-in and check-out, the number of people, the type of customer.

The logics applied to the profiling process are based on clustering through aggregative methodologies, which, through the analysis of the personal data collected, allow us to identify types of users sharing similar preferences. Therefore, as a result of profiling activities, you will be able to take advantage of viewing content targeted exclusively on your interests, as well as receiving communications that could respond to your interests or habits.

As required by art. 22, paragraph 3, of the GDPR, the Data Controller implements all the most appropriate measures to protect your rights and freedoms even in the case of profiling, in addition to any further and legitimate right as better explained in the following paragraph 8 ("Rights of the data subject") of this Privacy Notice.

8.    Rights of the data subject

In relation to the processing of your personal data you, as the data subject, have the right to revoke your consent at any time and to obtain from the Company access to your personal data. You also have the right to ask the Company to correct or delete your personal data. Furthermore, you have the right to obtain the restriction of the processing of personal data concerning you, as well as the right to the portability of such data.

In addition to the above, you have the right to object at any time, for reasons connected with your particular situation, to the processing of your personal data carried out pursuant to art. 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions, as required by art. 21 of the GDPR. Furthermore, if your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you carried out for these purposes, including profiling to the extent that it is connected to such direct marketing.

Finally, you have the right to propose to a supervisory authority or to take the appropriate judicial offices, if you believe that the treatment that concerns you violates the GDPR.

To exercise each of your rights, you can contact the Data Controller, in the person of the legal representative, by sending a communication to the registered office in via marsala 34/A – 21013 Gallarate (VA) , or by sending an email to privacy@sostravel.com or to Data Protection Officer: Dr. Vincenzo Pacelli at dpo@sostravel.com