La Speranzina Relais Sirmione

Privacy

OUR POLICY OUTLINES HOW WE PROTECT YOUR PERSONAL INFORMATION

We are committed to protecting and respecting your privacy very seriously and treat all your personal data with great care. This policy (together with the other provisions of our terms of use and any other documents referred to on it) sets out the basis on which personal data we collect from you, or that you provide to us, will be processed

- For the purpose of the EU General Data Protection Regulation (“GDPR”), the data controller is La Speranzina S.p.A. Via Dante 16 – 25019 Sirmione (BS) - Italy.
- This Privacy Policy describes which personal data is collected and for which purposes this personal data is processed by La Speranzina. It also states which rights you have under the applicable data protection legislation.

Information we may collect from you

- Information that you provide by filling in forms on lasperanzina.it (“our site”) to use our products and services. This includes information provided when registering to use our site, subscribing to our newsletter, posting material or requesting further services, booking a room, including preferences about the room and its location, information about disabilities and dietary requirements. We may also ask you for information when you enter a competition or promotion sponsored by La Speranzina, and when you report a problem with our site.

- Enquiries made when you contact our reservations team to make a booking or use the facilities at any of our properties. Facilities include, but are not limited to, meeting rooms, bars and/or restaurant, function rooms, and guest Wi-Fi.

- Records or correspondence should you contact us.

- Optional surveys we may ask you to complete that we use for research purposes.

- Details of transactions you carry out through our site and in the fulfilment of your booking.

- Information collected when you have provided your consent, in order to:

- Subscribe to any of our marketing communication

- Complete customer surveys, enter competitions or provide feedback. Information collected when we do business with you, which will usually include: Full or partial contact details including names and addresses (including business details if you are making a corporate booking), telephone and email details.

- Details about diet, disability or any other preferences that you may have concerning special requirements. Payment card information should you choose to use this form of payment for purchasing or guaranteeing use of our products and services.

- Your birthdate and other significant dates for making special offers to you around your birthday and other anniversaries.

- Passport and/or identity details for our guests visiting from overseas.

Information and personal data collected automatically

- Website data collected through our site

We automatically log information about you and your computer or mobile device when you access our site. The information about your use of our site comprises http header information that your browser transmits to our webserver, information collected through the use of cookies and log information. For example, when visiting our site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our site.

- CCTV recordings

We operate CCTV systems. These are in operation and video recordings may be made. This activity is carried out for security and service reasons for the better management of La Speranzina and security for all its clients and staff.

How we use and store your information

- Storage of your personal data, regardless of when or who you book La Speranzina through, will be made in

Centralised systems which are under the control of the Strand Palace Hotel and accessible by authorised staff of the Strand PalaceHotel or our suppliers, and
Some local systems controlled solely by the Strand Palace.

- Information we collect about you is used to process your bookings, answer your queries, process your gift card purchases, provide our hotel and restaurant facilities and services, and enable you to manage your website user account. With your consent where appropriate, we will contact you via our marketing and sales channels (email/phone/post) about other related products and services we provide which we think may be of interest to you. Our marketing communications are generally sent by email but we may sometimes use other methods of delivery such as by post or SMS.

- Personal data is mainly collected, stored and processed in two different stages:

- Before you visit our hotel
- Our Site – When you visit our site (lasperanzina.it), we collect information about your use of our site. This includes both information we collect directly from you, and information we collect about your behaviour. This information may constitute ‘personal data’ under applicable law. We use this information to provide you with (personal) offers, both on our Website and via advertisements on other websites you visit.
- General Advertising – We may use other companies to serve third-party advertisements when you visit and use our site. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to our site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
- Targeted Advertising – We use our site information to provide you with (personal) offers, both on our site and via advertisements on other websites you visit. In order to serve offers and advertisements that may interest you, we may display targeted advertisements on our site, or other digital properties or applications in conjunction with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide personal data to advertisers when you interact with an advertisement.

- When you visit, or have visited, La Speranzina Restaurant & Relais
-Transactional Communications – When you make a reservation, you will have to provide us with your name, email address, phone number, the dates you are staying with us and a credit card token or other payment information as applicable. We use this personal data to process the reservation, for billing purposes, and to allow us to communicate with you about your reservation. When you stay in La Speranzina, we will collect personal data about your preferences, use of our services, and location.

- We may at each of the stages outlined above use your personal data but only when and to the extent the law allows us to. Most commonly, we will use your personal data in the following circumstances where:
- We need to perform the contract we are about to enter into or have entered into with you.
- It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- We need to comply with a legal or regulatory obligation.
- You have provided your consent

Legal bases that allow for the processing of your personal data

- For your convenience, we have made an overview of activities that involve the processing of your personal data, and the corresponding legal basis/legal bases that allow us to process this data.

TYPE OF INFORMATION & PURPOSE OF USE

Personal data used for administrative purposes.	Consent, where required In order to enter into or perform a contract to which you are a party

Information that government regulations require us to ask you when you arrive at La Speranzina.	Compliance with a legal obligation

This may include information such as birth date, nationality, place of residence, date of arrival and profession.

Information used to verify your identity when you arrive at La Speranzina. We will use your passport or other identification documents. We will not store a copy of your passport, except to the extent permitted by law.	In order to enter into or perform a contract to which you are a party For the purposes of our, or a third party’s, legitimate interests, including keeping our records up to date

Personal data stored in our database(s), also after your transaction has been completed and after you have stayed in our hotel to the extent required by law, and you have opted to do so, to be able to contact you and welcome you again in the future.	Compliance with a legal obligation For the purposes of our legitimate interests, including: keeping our records up to date and managing our on-going relationship with you

Personal data transferred to servers located in Italy, or to servers located in countries within the European Economic Area (‘EEA’), which is required for technical and organisational reasons as many of our business purposes required cloud-based services.	In order to enter into or perform a contract to which you are a party. For the purposes of our, or a third party’s, legitimate interests,including the provision of administration and IT services and network security, and in preventing fraud

Data used to process your booking, howsoever made directly via our website or via a third party (online) travel agent.	In order to enter into or perform a contract to which you are a party

Services and products shared via email, telephone or other media that you request from us, or in which we may think you are interested. These marketing communications contain commercial offers and news of La Speranzina and related third parties. The email newsletter is sent to the email address you provide. If you no longer wish to receive the newsletter or correspondence, you can unsubscribe and we will no longer send you these marketing communications.	Consent, where required In order to enter into or perform a contract to which you are a party For the purposes of our, or a third party’s, legitimate interests

We endeavour to provide a high level of security of both the information we store as well as our facilities, (IT) systems and premises, by means of encryption, physical security measures, passwords, company procedures and policies and professional IT support. La Speranzina and its vendors may process personal data in this context.	For the purposes of our, or a third party’s, legitimate interests, including maintaining appropriate physical and IT/network security

We endeavour to prevent our services and facilities (properties) from being used for illegal purposes of any kind. La Speranzina and its vendors may process personal data in this context, such as through CCTV surveillance.	Vital interests For the purposes of our, or a third party’s, legitimate interests, including protecting you during your stay

We engage in activities required for compliance with legal obligations, third-party claims or requests from public authorities, such as (i) the mandatory storage/containment of certain information because of a criminal investigation, (ii) requests from third parties for access to information (iii) any further instructions from third parties, such as supervisory authorities, that involve data processing.	Consent, where required In order to enter into or perform a contract to which you are a party For the purposes of our, or a third party’s, legitimate interests Compliance with a legal obligation

Special categories of personal data in relation to diet or disability where required.	Consent Vital interests