Last updated: 18 May 2018
DATA RESPONSIBLE MANAGER
Via Magenta, 39
the visit visit or stay at one of our facilities or other type of offline interaction.
PERSONAL DATA COLLECTION
“Personal data” means information that identifies you or which relates to identifying a person.
At each point of contact along your route we collect your personal data according to the methods established by law, such as:
Credit / debit card number or other payment details
Financial information in certain circumstances
Date and place of birth
Nationality, passport, visa or other identification data issued by the government
Important information such as birthdays, anniversaries and special occasions
Data on affiliation or loyalty program (including o-branding payment cards and affiliations to travel partner programs)
Data from the employer
Information regarding the travel itinerary, the tourist group or the activities
Previous stays or interactions with guests, goods and services purchased, special services and requests for services
Account IDs on social media, profile photos and other public information or available on your social media or loyalty accounts
In more limited circumstances we could also collect:
- Data regarding family members and partners, such as names and age of children
Biometric data, such as digital images
- Images, video and audio through a) surveillance cameras located in public areas of our facilities, such as entrances and corridors; b) video cameras worn by our agents involved in the prevention of theft and other security personnel
- Custom preferences and data (“Personal preferences”), such as interests, activities, hobbies, food and beverage preferences, services and comforts that you have requested or have come to know during your visit
METHOD OF COLLECTION OF PERSONAL DATA
We collect personal data in different ways.
Online Services We collect Personal Data when you make a reservation, when you purchase goods and services from our Websites, when you send us messages, when you contact us, when you post on social media, when you sign up for a newsletter or participate in surveys, contests or promotional offers.
Visits to the structure and interactions offline We collect personal data when you visit our facilities or use our services. We collect personal data even when you participate or participate in promotional events hosted by our structure or when you provide your personal data to promote an event.
Customer Service Centers We collect Personal Data when you make a telephone booking, when you send us an e-mail or fax, or when you contact customer service. These communications could be recorded in order to guarantee the quality and training of the personnel.
Strategic Business Partners We collect Personal Data from the companies we work with to provide you with goods, services and offers based on your experiences at our facilities or that we believe may be of interest to you (“Strategic Business Partners”). Strategic Business Partners include travel partners, timeshare partners, car rental providers and travel booking platforms. The strategic business partners are independent of the Hotel Sileo.
Other sources We collect Personal Data from other sources, such as public databases, joint marketing partners and other third parties.
COLLECTION OF OTHER DATA
“Other data” means information that does not reveal your identity or that does not relate directly to a person. If the Other data reveal your identity or refer to a person, we will treat this information as Personal Data. The
Other data include:
- data on the browser and on the device
- data collected through cookies, and other technologies
- demographic data and other data provided by you
- aggregated data
METHODS FOR COLLECTING OTHER DATA
We collect the Other data in different ways.
Certain information is collected from cookies, which are pieces of information that are stored directly on the computer you are using. Cookies allow us to collect information such as the type of browser used, the time spent on online services, the pages visited, the URL of origin, language preferences and other aggregate data on traffic. We use information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical data, to personalize your experience of use of online services and to recognize your computer and assist you during the use of online services. We also collect statistical data on the use of online services in order to continuously improve the design and functionality, as well as to understand how they are used and to solve problems.
If you do not want your data to be collected via cookies, find out how to set them up at http://www.allaboutcookies.org/manage-cookes/index.htm.
You can choose to accept cookies by changing your browser settings or tracking preferences by clicking on “Tracking preferences” at the bottom of our homepage. However, if you do not accept cookies, you may have some difficulty while using the online services. For example, we may not be able to recognize your computer and you may have to log in each visit. In addition, you may not receive advertisements or other offers from us that may interest you or be useful to you. Currently we do not respond to the “Do Not Track” browser signals.
IP Address The IP address is a number that is automatically assigned by your Internet Service Provider (ISP) to the computer you are using. The IP address is identified and automatically linked to the log files of our server each time a user accesses the Online Services, along with information regarding the time of the visit and the pages visited. We use IP addresses to calculate usage levels, analyze server problems and manage online services. We may also use your IP address to trace your approximate location.
USE OF PERSONAL DATA AND OTHER DATA
We use Personal Data and Other Data to provide you with Services, develop new offers and protect Hotel Sileo and our guests as indicated below. In some cases we will ask you to provide your Personal Data and Other Data directly to us. If you do not provide the requested data or forbid us to collect such information, we may not be able to provide the requested Services.
We use Personal Data and Other Data for our legitimate business interests, including the following.
Provision of the required Services We use the Personal Data and Other Data to provide you with the Services requested, as well as:
to facilitate bookings, make payments, send messages of an administrative nature, send confirmation messages or before arrival, assist you during meetings and events and to provide other information about the area and the structure where you will be staying;
to complete your booking and your stay, for example to process your payment, ensure that your room is available and to provide you with assistance;
to support our electronic receipts program. When you use an e-mail address to make a reservation, we use this address to send you a copy of your invoice. If you make a reservation for another person using your e-mail address, that person’s invoice will always be sent to your address. You can cancel the invoice sending by e-mail and instead receive a hard copy by contacting the front desk.
We will use Personal Data and Other Data to manage the contractual relationship established with you, as it is in our interest and / or to comply with legal obligations.
Customizing the Services according to your Personal Preferences We use Personal Data and Other Data to customize the Services and improve your experiences, even when you contact our call center, visit one of our facilities or use the Online Services in order to:
customize your experience based on your personal preferences;
submit offers based on your personal preferences.
We will use Personal Data and Other Data to provide Personalized Services based on your Personal Preferences, either with your consent or because it is in our interest to do so.
Communication on goods and services based on personal preferences We use personal data and other data for:
send you marketing communications, promotional offers, market research and periodic surveys on customer satisfaction or quality
We will use Personal Data and Other Data to communicate with you with your consent, to manage the contractual relationship established with you and / or because it is in our interest to do so.
We use Personal Data and Other Data in these ways and with your consent to manage the contractual relationship established with you and / or because it is in our interest to do so.
Commercial Purposes We use Personal Data and Other Data for the following activities: data analysis, auditing, security monitoring, fraud prevention (including the use of closed circuit televisions, electronic keys and other security systems), development of new goods and services, improvement or modification of our services, identification of usage trends, evaluation of the effectiveness of our promotional campaigns, management and expansion of our commercial activities.
We use Personal Data and Other Data in these ways and your consent to manage the contractual relationship established with you, to comply with legal obligations or because it is in our interest to do so.
DISCLOSURE OF PERSONAL DATA AND OTHER DATA
Our goal is to offer you hospitality and services at the highest levels and in doing so we share your Personal Data and Other Data with the subjects indicated below.
Strategic Business Partners We disclose Personal Data and Other Data to selected Strategic Business Partners who provide goods, services and offers that enhance your experience at our facilities or that we believe may be of interest to you. By sharing data with these strategic business partners, we are able to deliver and make personalized services and unique travel experiences available to you. For example, sharing allows spa, restaurants, spas, within our facilities to offer you services. Sharing allows us to provide you with a single source for purchasing packages that include travel services, such as airline tickets, car rentals or vacation packages.
OTHER USES AND RELATIONSHIPS
We will use and disclose Personal Data when we deem it necessary or appropriate: (a) to comply with applicable legislation, including laws outside your country of residence; (b) to comply with the judicial process; (c) to respond to requests from public and governmental authorities, including authorities outside your country of residence, and to meet security requirements and ensure enforcement of the law; (d) to apply our Terms and Conditions; (e) to protect our activities; (f) to protect the rights, privacy, security and facilities of the Hotel Sileo, yours or those of others; (g) to allow us to proceed legally or to limit any damage suffered.
We may use and disclose the Other Data for any purpose, except for cases not permitted by applicable law. In some cases we may associate the Other data with personal data (for example your name to your location). In doing so, we will process this information as Personal Data until it is associated.
ENTITIES NOT BELONGING TO HOTEL SILEO
This privacy statement is not intended, and we assume no responsibility for the privacy, data or procedures of entities not belonging to Hotel Sileo, including affiliates, owners, authorized licensees, strategic business partners or third parties who manage sites o Services linked to the Services, payment services, loyalty programs or websites that refer to the destination page of high-speed Internet service providers at our facilities. Adding a link to the Online Services does not imply endorsement by us of the linked site or service. We have no control and do not assume any responsibility for the collection, use and disclosure of your personal data by third parties.
We also assume no responsibility for the collection, use, disclosure and data security policies and procedures of other companies such as Facebook, Apple, Google, Microsoft, RIM or any other application developer, application provider, provider of social media platforms, operating system providers, service providers or wireless devices, also in relation to the Personal Data you provide to other companies through the Apps or our Pages on social media.
We are committed to taking all appropriate organizational, technical and administrative measures to protect personal data. Unfortunately, no data transmission or storage system can guarantee 100% security. If you feel that your interaction with us is no longer secure (for example, if the security of your account seems to have been compromised), please notify us immediately in the manner described in the section “Contacting us”.
The criteria used to establish data retention periods are the following:
how long have we started the relationship with you by providing you with our Services (for example, since you have opened an account with us or since you use our Services);
if we are subject to a legal obligation (for example, under some laws we are required to file your transactions for a certain period of time before we can cancel them);
if it is advisable to keep the data taking into account our legal position (for example, in the case of prescriptions, disputes or regulatory inquiries.
Except where specifically requested, we ask you not to send us or disclose Sensitive Personal Data through the Services or any other means (such as social security number, national identification numbers, ethnic or racial information, political opinions, religious beliefs and ideologies, health, biometric data or genetic characteristics, criminal record, union membership, proceedings or administrative or criminal penalties).
USE OF SERVICES BY MINORS
The Services are not intended for children under the age of sixteen (16), who must not provide Personal Data through the Services.
HOW TO CONTACT US
Via Magenta, 39
PREFERENCES ON COOKIES
“if you wish to communicate other preferences or exercise your individual rights in accordance with the general data protection regulations (gdpr) please email us at firstname.lastname@example.org or at the following ordinary email address:
Via Magenta, 39