Relais privacy

Technological development, changes in the legal situation or our services and other reasons may require the updating to our privacy policy. We therefore reserve the right to change this privacy statement at any time and ask you to keep yourself regularly informed of the changes and the current state.

HOLDER OF THE PROCESSING OF PERSONAL DATA
GESTIONI BENACENSI S.P.A.
Via Fossalta, 42 - 37017 - Lazise (VR)
Vat Number 02219040231

OWNER'S EMAIL ADDRESS
info@pianidiclodia.it

TYPES OF DATA COLLECTED
If you are only using the website www.relaisvillaclodia.it without providing us with information, i.e. if you do not enroll or otherwise, we will only collect the personally identifiable information that your browser transmits to our server. If you want to view our website, we collect the following data, by itself or through third parties, that is technically necessary for us to ensure both the stability of the website and its security, as well as to display it.
Among the types of Personal Data that www.relaisvillaclodia.it collects, by itself or through third parties, there are:
email address, Cookies, Usage Data, Name, last name, phone number, nation, town, postal code and various types of Data, cities and unique identifiers of devices for advertising (Google Advertiser ID or IDFA identifier, for example).
Specific explanations displayed prior to the Data collection or in the specific sections of this privacy policy provide complete information on each type of Personal Data.
Personal Data may be, in case of Usage Data, collected automatically when using www.relaisvillaclodia.it or may be freely provided by the User.
Unless specified otherwise, all Data requested by www.relaisvillaclodia.it is mandatory and failure to provide this Data may make it impossible for www.relaisvillaclodia.it to provide its services. In cases where www.relaisvillaclodia.it specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. If Users are uncertain about which Personal Data is mandatory, they should contact the Owner.
Any use of Cookies – or of other tracking tools – by www.relaisvillaclodia.it or by the owners of third-party services used by www.relaisvillaclodia.it serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through www.relaisvillaclodia.it and confirm that they have the third party's consent to provide the Data to the Owner.

MODE AND PLACE OF PROCESSING THE DATA
METHODS OF PROCESSING
The Owner has taken appropriate technical and operational security measures to protect user data from manipulation, loss, destruction or access, accidental or intentional, by unauthorized persons. Our security measures are constantly reviewed and updated to keep up with technological changes.
In addition to the Owner, in some cases, the Data may be accessible to other persons in charge, involved with the operation of www.relaisvillaclodia.it (administration, legal, sales, system administration, marketing) or external parties (such as third-party technical service providers, hosting providers, IT companies, communications agencies, mail carriers,) appointed, if necessary, as Data Processors by the Owner. The updated list of the persons in charge, if necessary, could be requested to the owner.

LEGAL BASIS OF PROCESSING
The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner, without relying on consent or any other legal bases as follow, may be allowed to process Personal Data until the User objects to such processing (“opt-out”). This does not apply, whenever the processing of Personal Data is subject to European data protection law;
• Providing Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• The owner is subject to a legal obligation and data processing is necessary for compliance with it;
• Data processing is related to a task that is performed in the exercise of official authority vested in the Owner or in the public interest;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
The Owner will gladly help to clear up the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

PLACE
The Data is devised at the Owner's operating headquarters and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.
To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

RETENTION TIME
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:

• for the duration of subscription services and subscription to the newsletter
• 10 years for preservation of accounting documentation pursuant to art. 2220 cc
• 10 years for marketing, unless revocation of consent and cancellation from the newsletter
The Owner may be allowed to retain Personal Data for more than the indicated period whenever the User has given consent to such processing, until the consent is not withdrawn. The Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to data portability, the right to erasure, the right to rectification and the right to access cannot be enforced after expiration of the retention period.

THE PURPOSES OF PROCESSING
The Owner collects the Data concerning the User to provide its services and for the following purposes: Contacting the User, Managing contacts and sending messages, Advertising, Interaction with external social networks and platforms, Heat mapping and session recording, Analytics, Remarketing and behavioral targeting, Hosting and backend infrastructure, SPAM protection and Displaying content from external platforms.
To find out more about such purposes and about the specific Personal Data used for each purpose please read the respective sections of this document.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA
Personal Data is collected for the following purposes and using the following services:

CONTACTING THE USER

MAILING LIST OR NEWSLETTER (www.relaisvillaclodia.it)
User may authorize the sending of the newsletter containing information, including commercial and promotional, relating to www.relaisvillaclodia.it, expressing the consent pursuant to Art. 6 par. 1 a of the GDPR.
For the newsletter Users have only to give the email address. Users can voluntarily provide additional data , separately marked, used for direct communications with the User. After confirmation of the User, his email address will be saved in a list, according to the Art. 6 par. 1 of the GDPR.
The User has the right to withdraw at any time the consent to receive the newsletter and to unsubscribe by clicking on the link in each newsletter or by contacting the Data Protection Manager.

CONTACT FORM (www.relaisvillaclodia.it)
User authorizes www.relaisvillaclodia.it to use Data filled in into the contact form to reply to requests for information, quotes or any other kind of request, as indicated by the form’s header.
Personal Data collected: email address, first name, last name, city, zip code, nation, phone number and other types of Data.
This information is provided on a voluntary basis and with the consent of User, pursuant to Art. 6 par. 1a GDPR. As far as this is related to information about communication channels (e-mail address or telephone number), the User also agree that we may also contact you him via this communication channel to answer his request. Users may of course revoke this consent at any time. We delete the data that arises in this context after saving is no longer required, or limit processing if there are statutory retention requirements.

MANAGING CONTACTS AND SENDING MESSAGES
This service allows the website to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
Date and time may also be collected when the message was viewed by the User and when the User interacted with it, such as by clicking on links included in the message.

INTERACTION WITH EXTERNAL SOCIAL NETWORKS AND PLATFORMS
Il sito web www.relaisvillaclodia.it utilizza i plug-in social del fornitore.

• Facebook (operatore: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, Stati Uniti)
• Twitter (operatore: Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, Stati Uniti)

These plug-ins collect data from you and transmit it to the respective vendor’s server. We have taken technical measures to ensure that your data cannot be collected by the vendors of the respective plug-ins without your consent. These will initially be deactivated when you visit a site connected to the plug-ins. You have to click on the respective symbol to activate it and to you give your consent to have your data transmitted to the respective vendor. The legal basis for plug-in use is Article 6, par. 1a and f of the GDPR.
If activated, the plug-ins collect personally identifiable information, such as your IP address, and send it to the respective vendor’s server, that saves it. Activated social plug-ins also set a cookie with a unique identifier when the User visits the respective website and allows the vendor to create profiles of user's behaviour as well. This happen even if User is not a member of the vendor’s social network.
If the user is a member of the vendor’s social network and is logged in during the visit to the Website, all data and information about the visit can be linked with the User's profile on the social network. We do not have any particular information about the extent to which your data is collected by the vendor.
For more information please see the data protection notices at the following addresses: Facebook - Twitter

SPAM PROTECTION
This type of service analyzes the traffic of www.relaisvillaclodia.it, if necessary with Users' Personal Data, with the possibility to filter it from parts of traffic, messages and content that are recognized as SPAM.

GOOGLE RECAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

• Personal Data collected: Cookies and Usage Data.
• Place of processing: United States -Privacy Policy. Privacy Shield participant.

REMARKETING AND BEHAVIORAL TARGETING

This type of service allows www.relaisvillaclodia.it it and its partners to give information, optimize and display ads based on past use of this Website by the User.
The partners receive Usage Data and Cookies that transfer to them information that are used to study and manage the remarketing and behavioral targeting activity.
By visiting the Network Advertising Initiative opt-out page Users may opt out of a third-party service's use of cookies as well as they can decide not to stick to any of the services below.

FACEBOOK REMARKETING (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of www.relaisvillaclodia.it with the Facebook advertising network.

• Personal Data collected: Cookies and Usage Data.
• Place of processing: United States -Privacy PolicyOpt Out. Privacy Shield participant.

FACEBOOK CUSTOM AUDIENCE (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of www.relaisvillaclodia.it with the Facebook advertising network.

• Personal Data collected: Cookies and email address
• Place of processing: United States -Privacy PolicyOpt Out. Privacy Shield participant.

ADWORDS REMARKETING (Google Inc.)
On our website we use the remarketing and behavioral dynamic targeting of Google Inc. that links the activity of www.relaisvillaclodia.it with the Adwords advertising network and the Doubleclick Cookie. This technology makes it possible to insert automatically generated ads and oriented towards target groups, after the visit of a user to the website www.relaisvillaclodia.it. Ads are oriented towards products and services that User clicked on during the last visit to www.relaisvillaclodia.it. Cookies are used by Google to create interest-based ads. Cookies are small text files that are stored in the browser when the user visit www.relaisvillaclodia.it. In this process, Google typically stores information like the web request, browser type and language, IP address and the date and time of your request. This information is only used for mapping the web browser on a specific device and it cannot be used to identify an individual. If the user do not want to receive user-based advertising from Google, he can disable the placement of ads by using Google’s ad settings.

• Personal Data collected: Cookies and Usage Data.
• Place of processing: United States -Privacy PolicyOpt Out.

STATISTICS
The services of this section allow the Owner to analyze and monitor the web traffic and can be used to track users' beahviour.

GOOGLE ANALYTICS (Google Inc.)
www.relaisvillaclodia.it uses Google Analytics, a web analysis service by Google Inc. (“Google”). Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the collected Data in order to monitor and analyze the use of www.relaisvillaclodia.it, to write reports on its activities and share them with other Google services.
Collected Data can be used by Google to create tailor-made ads of its own advertising network.
The legal basis for using Google Analytics is Article 6, par. 1 f of the GDPR. Data sent from www.relaisvillaclodia.it and linked to cookies, user information (such as user ID) and promotional IDs are deleted after 50 months from the last use of our services. Data whose archiving period has expired are automatically deleted once a month.

• Personal Data collected: Cookies and Usage Data.
• Place of processing: United States -Privacy PolicyOpt Out.

GOOGLE TAG MANAGER (Google Inc.)
For transparency reasons, we would like to inform Users that www.relaisvillaclodia.it use Google Tag Manager. Google Tag Manager does not itself collect any personally identifiable information. Tag Manager makes it easier to manage the tags, that are small elements of code that are used to measure traffic and user behaviour; tags are also used in order to test and optimise websites, to record the effects of online advertising and social channels and establish re-marketing and focus on target groups. Google Tag Manager takes into consideration the deactivation of tags. More Information about Google Tag Manager here.

FACEBOOK ADS CONVERSION TRACKING(Facebook, Inc.)
Facebook Ads conversion tracking is a service provided by Facebook, Inc. that links data from the Facebook advertising network with actions performed on www.relaisvillaclodia.it.

• Personal Data collected: Cookies and Usage Data
• Place of processing: United States -Privacy Policy. Soggetto aderente al Privacy Shield.

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS
This type of service enables Users to view content hosted on external platforms directly from the pages of www.relaisvillaclodia.it and interact with them.
Web traffic data can be collected from this type of service for the pages where it is installed, even if Users do not use it.

GOOGLE FONTS (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows www.relaisvillaclodia.it to incorporate content of this kind on its pages.

• Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.
• Place of processing: United States -Privacy Policy. Privacy Shield participant.

WIDGET VIDEO YOUTUBE (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows www.relaisvillaclodia.it to incorporate content of this kind on its pages

• Personal Data collected: Cookies and Usage Data.
• Place of processing: United States -Privacy Policy. Privacy Shield participant.

HOSTING AND BACKEND INFRASTRUCTURE
This type of service has the function of hosting data and files that allow www.relaisvillaclodia.it to function, allow and make available a ready-to-use infrastructure to provide specific features of this site.
Some of these services work through geographically dispersed servers in different locations, making it difficult to determine the exact location where Personal Data is stored.

THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do as follow:

• Withdraw their consent at any time. Users have the right at any time to withdraw consent, even if they had previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. If the processing is carried out on a legal basis other than consent the User has the right to object to the processing of his Data. For any other detail, please check the other section in this policy.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding some aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users can, under certain circumstances, restrict the processing of their Data. If this happens, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the cancellation of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if possible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users have at any time the right to objects the processing Data for direct marketing purposes without giving any justification. To know whether Personal Data is processing for direct marketing purposes, please read the dedicated sections of this policy.

HOW TO EXERCISE THESE RIGHTS
The contacts provided in this policy could be used from Users to exercise their rights. These requests will be addressed by the Owner as early as possible and can be exercised free of charge; they will be addressed by the Owner always within one month.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING
LEGAL ACTION
The Owner can used User's Personal Data for legal purposes, both in Court or in the stages leading to possible legal action arising from improper use of www.relaisvillaclodia.it or related services.
The User has to know to be aware that the Owner may be required to reveal personal data upon request of public authorities.

ADDITIONAL INFORMATION ABOUT USER'S PERSONAL DATA
Apart from the information contained in this privacy policy, www.relaisvillaclodia.it may provide the User with additional and contextual information regarding particular Services or the collection and processing of Personal Data upon request.

SYSTEM LOGS AND MAINTENANCE
If operating and maintenance actions are needed, www.relaisvillaclodia.it and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

INFORMATION NOT CONTAINED IN THIS POLICY
More information about the collection or processing of Personal Data may be requested from the Owner at any time. At the beginning of this policy Users can find more information.

HOW “DO NOT TRACK” REQUESTS ARE HANDLED
www.relaisvillaclodia.it does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

DEFINITIONS AND LEGAL REFERENCES

PERSONAL DATA (or DATA)
Any information that in connection with other information that directly or indirectly — including a personal identification number — allows for the identification or identifiability of a natural person.

USAGE DATA
Information collected automatically through www.relaisvillaclodia.it (or third-party services used in this Website), which can include: domain names of the computers utilized by the Users who use www.relaisvillaclodia.it or the IP addresses, the URI addresses (Uniform Resource Identifier), the method utilized to submit the request to the server, the time of the request, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the size of the file received in response, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the information about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

USER
The individual using www.relaisvillaclodia.it which is the Interested Party or any other person authorized by the Interested Party, whose personal data are the subject of data processing.

DATA SUBJECT
The natural person to whom the Personal Data refers.

DATA PROCESSOR (OR SUPERVISOR)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

DATA CONTROLLER (OR OWNER)
The natural or legal person, public administration or any other agency responsible, either individually or jointly with any other controller, for decisions on the purposes and methods of data processing and the instruments used, including data security procedures, with regard to the operation and use of the site. The Controller of Data Processing, unless otherwise specified, is the owner of www.relaisvillaclodia.it.

www.relaisvillaclodia.it (OR THIS APPLICATION)
The hardware or software instrument by which the Personal Data of the User is collected and processed.

SERVICE
The service provided by www.relaisvillaclodia.it as described in the relative terms (if available) and on this site/application.

EUROPEAN UNION (OR UE)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

COOKIE
Small sets of data stored in the User's device.

LEGAL INFORMATION
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to www.relaisvillaclodia.it, if not stated otherwise within this document.