TH Solidarity
The commitment of the TH Resorts group is expressed through concrete support to three non-profit organizations that carry out social initiatives capable of bringing concrete aid to families and communities, in Italy and abroad.

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Privacy and Cookies Policy

PRIVACY INFORMATION AND COOKIES INFORMATION

 

Purposes and principles of data processing. In fulfillment of legal obligations on the matter, this page describes how to manage the website with reference to the processing of personal data of users who navigate it and interact with web services accessible electronically from the address: www .th-resorts.com.
We inform you that HOTELTOURIST will use your personal data to manage access to the portal and the services included therein, manage technical practices, carry out all the activities necessary or useful for the constant improvement of the service provided, and to ascertain responsibility in the event of crimes to the detriment of the Site and/or of offenses committed through the Site. Specific additional purposes relating to individual treatments can be identified in detail, through supplementary information, within the various services included in the portal.
Consultation of the Site may involve the processing of data relating to identified or identifiable persons. The personal data provided by users who consult the Site are processed by the recipient of the communication in order to follow up on the requests received.
Index of topics (you can navigate between them by positioning the mouse on the list and clicking on the relative text)

  – Type of data

  – Purpose and duration of the treatment

Logics and forms of organization of treatment

Le logics and forms of organization of treatment will be strictly related to the individual purposes respectively indicated above. The treatments will take place electronically, telematically and/or on paper. During processing, the data is subjected to protection measures activated by HOTELTURIST in order to guarantee the data against the risk of authorized access or unauthorized processing. for example, personal data managed on a computerized level can only be consulted by having access to the various data processing or entry programs, by typing in mandatory personal passwords, by only personnel authorized by HOTELTURIST, who must in any case comply with predetermined limits of use.

  – Obligatory and optional nature of data communication and consequences of failure to provide it

Are there cases of simplified consent or exceptions to the obligation of consent for direct marketing purposes?

Are there cases of simplified consent or exceptions to the obligation of consent for direct marketing purposes?
As permitted by current legislation and for the purposes of the fulfillment of privacy obligations by HOTELTURIST in compliance with the principles of simplification (referred to in the General Provision of the Privacy Guarantor of 15.05.2013 - "Consent to the processing of personal data for "marketing" purposes direct" through traditional and automated contact tools"), consent requested by HOTELTURIST regarding the secondary purposes of profiling and direct marketing it is unitary and comprehensive for all possible means used for processing for marketing purposes (electronic/telematic, paper), as well as for all possible direct marketing purposes (that is, without multiplying the consent formulas for each distinct marketing purpose pursued).

NB: HOTELTURIST may process personal data, through the use of telephone calls with an operator and the use of ordinary mail, for the aforementioned secondary purposes, without the prior specific consent of the interested party (in this case the right of the interested party to oppose the treatment with simplified methods and also electronically by registering the telephone number of which the interested party is the holder and other personal data relating to subscribers in the paper and electronic lists available to the public, in the Public Opposition Register (http://www.registrodelleopposizioni.it/) required by the Decree of the President of the Republic No. 178/2010).
In the event that HOTELTURIST asks you - for direct marketing purposes - for your telephone number and you have given your optional and specific consent to its use, HOTELTURIST can process it even if the user is registered by you in the Public Opposition Register: in how much the number in this case is communicated by you and not taken from public telephone directories.

We also point out that the Privacy Code allows the so-called "soft spam". This means that without having to acquire your express consent, we can use the e-mail address you provided as part of a previous purchase, in order to proceed with sending through email, to commercial communications and sales offers, provided they relate to products and services similar to those you have already purchased.
Upon receipt of each communication and/or promotional email sent by HOTELTURIST for the purposes already envisaged, you will be informed of the possibility to oppose the treatment at any time, easily and free of charge (by notifying your opt-out choice through our online platform).

Does the data subject's consent to processing for profiling and direct marketing purposes also apply to the communication of data to third parties?

Does the data subject's consent to processing for direct marketing and profiling purposes also apply to the communication of data to third parties?
HOTELTURIST communicates some data to other companies belonging to the HOTELTURIST group or to third parties who by contract and as "data processors" are delegated to process the data (for example, transmit commercial communications) on behalf of HOTELTURIST the data based on the same specific marketing consent (including that to the communication to third parties for these purposes) already provided by you in favor of HOTELTURIST.
HOTELTURIST can also, exclusively with prior tor further, separate, additional consent, documented, express optional, operate the communication or transfer of data to third parties who treat them in the capacity of co-owners or independent data controllers (as a rule they are third party partners in the promotion of Events), who use them for direct marketing or profiling purposes).

Revocation of consent

Even after having given your consent to data processing for profiling and direct marketing purposes, as an interested party you can at any time notify HOTELTURIST of a different will, through one of the following alternative methods:

  • by clicking on the "unsubscribe" button, made available to the user at the bottom of the promotional emails sent to the interested party, an email will automatically be sent to HOTELTURIST and consequently the name of the registered interested party, in a special black-list, preventing further future direct marketing actions by of HOTELTURIST against the same;
  • by sending HOTELTURIST your declaration of revocation of consent by ordinary mail or email (which in this case will be manually recorded in the Company's CRM). This method of communication is always necessary in the event that the interested party wishes to express a more analytical selective will, either with regard to the use of certain individual means and not of others (e.g. only paper, only electronic, refusing that sent via systems automated, etc.) for receiving, with prior consent, marketing communications from HOTELTURIST, either with regard to individual marketing purposes among those actually possible (by choosing, for example, to receive only newsletters and not sent to our Events);
  • by informally sending a clear telephone communication of withdrawal of consent to HOTELTURIST. Upon receipt of this opt-out request, HOTELTURIST will proceed with the removal and cancellation of the data from the databases used for processing for direct marketing purposes and, where possible, will inform any third parties to whom the data has been communicated for the same purposes of this cancellation. .
    The mere receipt of the cancellation request will automatically be valid as confirmation of the cancellation.
  • In case you want to revoke your consent to any advertising communications that come from you social channels (e.g. Facebook, Twitter, etc.), you will have to communicate the revocation directly to the single social platform, according to the methods made available from time to time by the same and/or by the browser you use (as HOTELTURIST is not technically capable of influencing this end on third-party social platforms).

The aforementioned opposition will not produce any consequences on the provision of any contract activities in progress.

Disclosure of data to third parties

As part of the primary purposes and without prejudice to the communication to third parties made in execution of legal obligations or deriving from regulations or other Community legislation, or at the request of judicial offices or other third parties to whom the faculty is recognized by the aforementioned provisions, the data are communicated by us to all subjects whose intervention in the processing is reasonably necessary based on the services requested by the interested party and/or by regulatory obligations, by way of example only:

  1. banks and credit institutions, or electronic money institutions for the management of payments;
  2. insurance companies (in the case of claims connected to your stay, that of your family or people accompanying you) involving our responsibility;
  3. debt collection companies, factoring companies, leasing companies, credit insurance or assignment companies, credit consortia (for the sole purpose of credit protection and better management of our rights relating to the individual commercial relationship);
  4. commercial information company;
  5. consultants;
  6. professionals and professional firms (lawyers, chartered accountants, statutory auditors, members of 231 supervisory bodies, and auditors;
  7. subjects that provide web hosting and/or maintenance and/or IT assistance services in relation to our systems and databases and IT services;
  8. suppliers (e.g. intermediary travel agents, tour operators, airlines, hotels, tour guides, escorts, entertainers, photographers, car rentals, carriers, couriers, etc.) and subcontractors, who provide tourist services to you or ours that require the knowledge of your data;
  9. other companies, entities and/or natural persons who carry out instrumental, supportive or functional activities for the execution of the contracts or services requested by you;
  10. other companies of the HT Resorts Group (parents, subsidiaries or affiliates) or affiliates of the TH Resorts brand operating in the tourism/hotel sector;
  11. in the case of direct marketing and/or profiling purposes, marketing consultants, advertising, communication and public relations agencies, companies in charge of the design, printing and maintenance of advertising or promotional editorial materials and/or their online management, companies website production or management companies, web marketing companies, direct e-mailing service companies (e.g. Mail-up or similar), call center service companies with registered offices and operational centers in Italy, consultants and/or other entities entrusted by us with activities functional to said purposes; third party commercial partners with whom HOTELTURIST activates co-marketing actions.

To make a payment on the site, you can use the online service provided by a third party supplier. To complete the purchase, the user must enter the requested data on the screen of interest (eg credit card, expiration date, security code, etc.). These data will be processed by the supplier - as independent Data Controller - without passing through the HOTELTURIST server, which will only receive the order code issued and notification of payment.

In the case of treatment only for secondary purposesand (profiling, direct marketing), pursuant to the General Provision of the Guarantor of 4 July 2013 containing the "Guidelines for combating spam" we inform you that we will also communicate the data - prior vs. specific prior consent, on which see below – also to the following product or economic categories of third party recipients: marketing consultants, advertising, communication and public relations agencies, companies in charge of the design, printing and maintenance of advertising or promotional editorial materials and/or of their online management, website production or management company, web marketing company, direct e-mail service company (e.g. Mail-up or similar), call center service company with registered office and centers operating in Italy, consultants and/or other entities entrusted by us with functional activities for said purposes; third party commercial partners with whom HOTELTURIST activates co-marketing actions.

We have appointed in writing as external managers the categories of third party recipients to whom we communicate the data, except in the case in which they assume the role of independent data controller by virtue of the decision-making area reserved for them as regards the purposes and/or means of the treatment.
The data will also be processed by our internal representatives belonging to the functional areas that manage the booking and management of the services you purchase from you (administration, commercial, IT, customer care, logistics offices).
The data will not be disseminated.

Data transfer abroad

The data may be transferred outside the EU by the data controller, for the primary purposes indicated above (and provided that the chosen destination is towards these countries), to:

  • Foreign countries for which there is an adequacy decision by the EU Commission pursuant to art. 45 GDPR and/or adequate guarantees pursuant to art. 46 GDPR such as specifically: – Andorra – Argentina – Australia – PNR – Canada, Faroe – Guernesey – Isle of Man – Israel – Jersey – New Zealand – Switzerland – Uruguay;
  • other non-EU countries for which there is no adequacy decision by the EU Commission pursuant to art. 45 GDPR or art. 46 GDPR; in this case it should be noted that, as it is excessively burdensome for the data controller to enter into written agreements with third-party foreign importers aimed at obliging them to comply with technical and organizational data protection measures and other management measures of the same compliant to the GDPR, the customer will not be able to exercise the rights or use the means of appeal provided for by the GDPR either towards the data controller or data controllers or directly towards third party recipients (such as, by way of example: hoteliers, local carriers, local insurance companies, etc. ) because such an obligation to process and/or store data according to EU standards is not required by the laws of the country of the data importer; nevertheless, where the chosen destination is to these countries, the transfer operated by HOTELTURIST is lawful, even without the express consent of the customer, because it is necessary for the execution of a contract concluded between the interested customer and HOTELTURIST, the data controller, or for the execution of pre-contractual measures adopted at the request of the interested party; o it is necessary for the conclusion or execution of a contract stipulated between HOTELTURIST data controller and another natural or legal person (consisting of a foreign supplier or partner of HOTELTURIST) in favor of the interested party.

Legal basis of the processing

Legal basis of the processing. HOTELTURIST may lawfully process data for the following reasons:

  • In the case of primary purposes, the processing is necessary, depending on the case, for the execution of pre-contractual measures adopted at the request of the interested party (e.g. requests for clarification, sending of information or commercial offers), for the stipulation and execution of a contract of which the concerned is a party, or to fulfill a legal obligation to which HOTELTURIST is subject and/or to pursue the legitimate interest of HOTELTURIST (prevailing over the interests or fundamental rights and freedoms of the interested party) to process data to efficiently manage the relationship with its users, customers and/or suppliers and to organize internal and external production and management processes necessary. Furthermore, there is the legitimate interest of the suppliers and partners of HOTELTURIST to receive and process personal data from HOTELTURIST in order to be able to manage the activities connected to the request of HOTELTURIST to receive support to manage the activities towards the interested parties and for the purpose of verifying correct fulfillment by HOTELTURIST of the legal and contractual obligations towards the interested party and/or third parties (e.g. verification by the public authority regarding the fulfillment of tax obligations, verification by the board of statutory auditors or the auditors regarding the fulfillment of legal obligations, etc.).
  • In the case of secondary purposes (profiling, direct marketing) the treatment is based on legitimate interest of HOTELTURIST to promote its products and/or services to customers via off-line and on-line methods (e.g. sending so-called soft spam or commercial communications via public telephone numbers). and, alternatively, on the consent of the interested party, not subsequently revoked.

Cookies Policy

Il Privacy Guarantor with provision dated 8 May 2014 it implemented, with definitive entry into force in Italy starting from 2 June 2015, the European directive 2009/136/EC which requires web page administrators to publish information on the cookie policy of the site that visitors are browsing.

This Policy can be updated at any time due to changes in current legislation or for any change in the configuration and type of cookies used, therefore we suggest that you periodically view this cookie policy in order to find out about all subsequent updates to it.

The Site may contain links to other Web sites that have their own privacy policy which may be different from the one adopted by the SEO-positioning of the Site and which therefore is not responsible for these sites.

What are cookies and how they are used

Cookies are short strings of information (text files) regarding the user's activity on the website, which are memorized, during the first navigation on the website, on the device (computer, smartphone or tablet) of the user browsing internet, to then be retransmitted to the same sites on a possible subsequent visit by the same user, allowing our site to automatically recognize the user (or other users who use the same tool) after the first visit and therefore improve their user experience.

Their functioning is totally dependent on the navigation browser that the user uses and they can be enabled or not by the user himself.

In order to always guarantee the best navigation possible, our site offers the best performance with cookies enabled. By default, almost all web browsers are set to automatically accept cookies.

Cookies can be:

  • "first party" when they are managed directly by the website manager;
  • "third party" when cookies are set up and managed by managers unrelated to the website visited by the user.
    Third-party cookies fall under the direct and exclusive responsibility of the manager himself, and in relation to their installation, the manager of the first-party site assumes the mere role of technical intermediary.

Which cookies we use and for what purpose

The Site uses or may use, also in combination with each other, the following categories of cookies:

  • Permanent or “persistent” cookies: these cookies remain stored on the device even after leaving the website or in any case closing the browser: in particular, they remain until their expected expiry or until they are manually deleted by the user. Persistent cookies fulfill many functions in the interest of surfers (such as password storage), however in some cases they can also be used for promotional purposes.
  • Session (or temporary) cookies: They have a limited duration for the visit and are deleted when the browser is closed, which ends the "session" for accessing the website. As a rule, they allow the user to access personalized services and to take full advantage of the site's functions, avoiding the use of other IT techniques that could potentially compromise the privacy of users' browsing.
  • Technical-functional cookies, for example for the transmission of session identifiers necessary to allow safe and efficient exploration of the site. These cookies avoid the use of other IT techniques potentially prejudicial to the privacy of users' browsing.
    For the use of technical cookies, the law requires the mere release of the information to the interested party, as occurs with this communication, i.e. also without the creation of specific banners on the Site.
    For all non-technical cookies, on the other hand, the legislation in force subordinates their installation to the manifestation of prior consent in the simplified forms provided for by the Provision of 8.5.2014 of the Guarantor, i.e. through the publication of a synthetic banner that can be viewed by the user upon first "landing" on the site and which allows to generate a further use action of the Site (based on the "scroll", or on the continuation of navigation within the same web page) with which the user can implicitly communicate his consent, or, alternatively, to access an analytical cookie information (i.e. this information), within which you can express your necessary consent or dissent. This consent or not can be formulated by the user not with reference to the individual cookies installed but in relation to broader categories of cookies, or to specific producers and/or intermediaries with which the Site has established commercial relations.
  • Analysis cookies (so-called "analytics"): these cookies can be both temporary and permanent, and allow for the collection and analysis of aggregated and/or disaggregated statistical information relating to accesses (e.g. geographical area of ​​origin of the user, access tool used, age, etc.) and in general to the behavior of users on the site and therefore to improve the experience and the content provided.
    These analytical cookies can be assimilated to technical cookies only if they are created and used directly by the first-party site (without, therefore, the intervention of third parties). For example, the site makes use of log files (that is, it records the history of operations as they are performed) and log files (which include IP addresses, browser type, operating system used by the user's device, Internet Service Provider (ISP), date, time, entry and exit page and the number of clicks, but also the pages visited on the site, the third party sites from which the user comes). All this to analyze user behavior trends and administer and optimize the site. The information collected in this way has no personal value as the data is collected and analyzed anonymously.
    However, if analytical cookies are created and/or used by third parties (i.e. different from the owner of the first-party site), they cannot be assimilated to technical cookies and have a different legal treatment.
  • "Profiling" (or advertising) cookies (always permanent). they are used to obtain information, aggregate or otherwise, useful for evaluating the use of the website and the activities carried out by the visitor (choice of viewing specific pages, specific products and/or services, etc.), used by the owner for the formulation of targeted commercial advertisements for products and/or services, i.e. based on the user's previous activities (instead of the generalist ones offered without distinction to all).

List of cookies actually present on the website

The aforementioned premise does not automatically imply that this website currently uses all the categories of cookies indicated above. The list of cookies actually used by HOTELTURIST is indicated below.

Cookie name Session/permanent Function (technical, analytical, advertising) Duration (if permanent and if not deleted first by the user himself)
_gat_UA-52126534-11 session analytical 1 minute
_ga permanent bases analytical two years
_gid session analytical 24 hours
fr permanent bases analytical 3 months
mktz_client permanent bases analytical two years
mktz_sess session analytical 24 hours
cookie_notice_accepted permanent bases analytical 1 month

The Site also uses Google Analytics cookies (Google Inc. cookies, which is an American company, third party). We specify that through the functions of Google Analytics no strictly personal information is collected, but, only in aggregate statistical form, data on the age, gender, and preferences of interest of our visitors (for the purpose of better evaluating the use of the our website and the activities carried out by the visitor and to better target the services provided). These cookies are stored on servers that can be located in the United States or in other countries. Google reserves the right to transfer the information collected with its cookie to third parties where this is required by law or where the third party processes information on its behalf.

The "Analytics" function is in any case configured by HOTELTURIST, by default, in such a way as to significantly mask portions of the user/visitor's IP address, and therefore the data relating to the IP address thus collected is already anonymized at 'origin and therefore the analytical cookie does not allow to trace even indirectly - and in particular through further processing - the identity of the user / visitor. For this reason, HOTELTURIST, which from time to time is the manager of the site, is not even required by law to comply with the obligations and fulfilments provided for by the legislation on cookies (for example, notification of the processing of cookies to the Privacy Guarantor). The user can always disable Google analytics cookies, using a special add-on made available by Google, at the following link.

In the event that HOTELTURIST decides in the future to modify the configuration of the "Analytics" function at any time in such a way as to allow the collection of data relating to the user consisting of the last three numbers that make up the IP address of the same, such the choice must be notified in advance to the Privacy Guarantor by the data controller operated through the portal or site, to protect the user.

We inform you that Google also ensures, as of now, in turn, not to associate the user's IP address with any other data held by Google in order to obtain a more detailed user profile.

No named profiling cookies are used on this site, i.e. based on personal identification data.

Our site use remarketing lists and ads from the display network, i.e. online advertisements based on categories of general interests expressed by categories of users through previous web browsing.

Stopping the generality of the foregoing, our site have used the specials Google Analytics Advertising Features, which allow you to activate additional features not available through the standard implementations of Google Analytics and related cookies.
These advertising features also allow for the collection of traffic data (through Google advertising cookies and anonymous identifiers) in addition to the data normally already collected by us through a standard implementation of Google Analytics. The advertising features of Google Analytics are as follows:

  • Remarketing with Google Analytics
  • Google Display Network impression reporting (when used through AdWords)
  • Integrations with the DoubleClick platform
  • Google Analytics Demographics and Interests Reports

 

  • Social cookies: these cookies are from third parties, i.e. connected to services provided directly from the domains of the most common social media networks that are connected to our website. Site via links to official pages, content sharing buttons and links. The use of these buttons and features implies the exchange of information (eg texts, photographs, videos, etc.) with these sites. In the event that a social service is installed, even if the Users do not use the service, the same collects traffic data relating to the pages in which it is installed.
    • Like button and social widgets for Facebook (Facebook, Inc.)
    • Click "Like" Facebook and social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.
    • Personal data collected: Cookie and Usage Data.
    • Place of treatment: USA
    • Tweet button and social widgets to Twitter (Twitter, Inc.)
    • The Tweet button and Twitter social widgets are interactive services with the social network Twitter, provided by Twitter, Inc.
    • Personal data collected: Cookie and Usage Data.
    • Place of treatment: USA
    • 1 + button and Google+ social widgets (Google Inc.)
    • The + 1 and Google+ social widgets are interactive services with the Google+ social network, provided by Google Inc.
    • Personal data collected: Cookie and Usage Data.
    • Place of treatment: USA

 

The management of information and the methods for deleting these social cookies is regulated by the social media sites themselves: the user is invited to consult the respective privacy policies of each of them, at the following Left:

o Facebook: https://www.facebook.com/policies/cookies/ or https://www.facebook.com/privacy/explanation
o Twitter: https://help.twitter.com/it/rules-and-policies/twitter-cookies or https://twitter.com/it/privacy
or YouTube: https://www.google.com/policies/technologies/types/
or Pinterest: https://policy.pinterest.com/it/privacy-policy
or Instagram: https://help.instagram.com/519522125107875
or Linkedin: https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy
or Google+: https://policies.google.com/privacy?hl=it

The use of these cookies is of a purely anonymous nature, no personal information is collected unless the user intends to provide it explicitly by sending contact forms and/or information request forms.
Further information on privacy and the use of social cookies can be found directly on the websites of the respective third-party managers.

How cookies work and how to disable them
Accepting or rejecting cookies is your right

By default, browsers generally accept the use of cookies both from our site and from third party sites. To allow the site to function properly, take advantage of its features and use it in its entirety, we recommend that you accept the use of cookies.
However, the user is enabled to modify the predefined (default) configuration at any time. To manage the operating modes of cookies, as well as the options to limit or block cookies, it is in fact sufficient for the user to change the settings of his Internet browser via the relative toolbar. It is possible to choose between the unconditional acceptance of all cookies (in particular: by navigating in any form on our site after the initial appearance on the screen of the synthetic banner that warns you of the presence of cookies on our website, you implicitly consent to the use of cookies), the indistinct refusal of all cookies definitively, or the display of a popup window (Notice) each time a cookie is proposed, in order to be able to evaluate whether or not to accept it through an explicit action by of the user.

Below are the links for configuring the most popular browsers that describe how to manage cookies:

- Chrome: https://support.google.com/accounts/answer/61416?hl=it

– Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie

– Internet Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies

- Opera: http://help.opera.com/Windows/10.00/it/cookies.html

– Safari: https://support.apple.com/it-it/HT201265

To change the cookie settings in browsers other than those listed, refer to the help documentation prepared by the manufacturer of the specific browser.

The user can also selectively disable the action of Google Analytics by downloading and installing on his browser the additional opt-out component specifically provided by Google for his browser, at the following link:

– http://tools.google.com/dlpage/gaoptout

Remember that you must set cookie preferences for each device and each browser used to navigate the internet.

For any further information relating to Google Analytics, please refer to the Privacy Policy at the following link:

– http://www.google.com/intl/it_ALL/analytics/learn/privacy.html

To delete cookies from the Internet browser of your smartphone / tablet, it is necessary to refer to the user manual of the device.
For more information on cookies and privacy, we invite you to consult the appropriate document prepared by the Privacy Guarantor at the following link:

– http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/2142939

Owner and external manager of the treatment

Data controller of personal data is:

  • HOTELTURIST SPA, based in Via Forcellini, 150 – 35128 Padua, VAT number 01047360910, email: privacy@th-resorts.com, tel. +39.049.2956414, fax +39.049.8033785;

External data processor of personal data is:

  • the company - controlled by HOTELTURIST SPA - that manages the accommodation facility, from time to time constituting the object of the reservation.

A complete and updated list of external managers can be consulted at the Company upon written request from the interested party.

The Responsible for the protection of personal data ("RDP" or "DPO") of the HOTELTURIST SPA Owner is the lawyer. Luca De Muri, domiciled for the purpose at the same company.

Rights of the party concerned

With regard to the processing of personal data, the interested party can exercise his rights by writing to the Data Controller:
– ask the Data Controller to confirm whether or not personal data concerning him is being processed and, if so, to obtain access to personal data and the following information: a) the purposes of the processing; b) the categories of personal data in question; c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients from third countries or international organizations; d) when possible, the envisaged retention period for personal data or, if this is not possible, the criteria used to determine this period; e) the existence of the right of the interested party to ask the data controller to rectify or cancel personal data or limit the processing of personal data concerning him or to oppose their treatment; f) the right to lodge a complaint with a supervisory authority; g) if the data are not collected from the interested party, all the information available on their origin; h) the existence of an automated decision-making process, including profiling and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the data subject.
– if personal data is transferred to a third country or to an international organisation, the interested party has the right to be informed of the existence of adequate guarantees relating to the transfer;
– request, and obtain without unjustified delay, the rectification of inaccurate data; taking into account the purposes of the processing, the integration of incomplete personal data, also by providing a supplementary declaration;
– request the deletion of data if a) the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed; b) the interested party revokes the consent on which the treatment is based and there is no other legal basis for the treatment; c) the interested party opposes the processing, and there is no prevailing legitimate reason to proceed with the processing, or opposes the processing carried out for direct marketing purposes (including functional profiling for such direct marketing); d) the personal data have been processed unlawfully; e) personal data must be canceled to fulfill a legal obligation established by Union or Member State law to which the data controller is subject; f) the personal data have been collected in relation to the offer of information society services.
– request the limitation of the processing that concerns the interested party, when one of the following hypotheses occurs: a) the interested party disputes the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is unlawful and the interested party opposes the cancellation of personal data and instead requests that their use be limited; c) although the data controller no longer needs it for processing purposes, personal data are necessary for the data subject to ascertain, exercise or defend a right in court; d) the interested party has opposed the processing carried out for direct marketing purposes, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party;
– obtain from the data controller, upon request, the communication of the third party recipients to whom the personal data have been transmitted;
– revoke at any time the consent to the treatment where previously communicated for one or more specific purposes of one's personal data, it being understood that this will not affect the lawfulness of the treatment based on the consent given before the revocation.
– receive, in a structured format, commonly used and readable by an automatic device, the personal data concerning the interested party provided by them to the Data Controller and, if technically feasible, to have such data transmitted directly to another data controller without impediments by the Data Controller to whom it has provided them, if the following (cumulative) condition occurs: a) the processing is based on the data subject's consent for one or more specific purposes, or on a contract to which the data subject is a party and to which carrying out the processing is necessary; and b) the processing is carried out by automated means (software) (overall right to the so-called "portability"). The exercise of the so-called portability right is without prejudice to the aforementioned right to cancellation;
– the interested party has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects his person in a similar way.
– the interested party can also lodge a complaint with the competent Supervisory Authority based on the GDPR (that of his place of residence or domicile) at any time.
The aforementioned rights must be exercised separately towards HOTELTURIST or towards the third party recipients of the data, each to the extent of its own competence.

Change of policy

This privacy policy starting from its publication date replaces any previous version of the same. Unless otherwise specified, the previous privacy policy will continue to apply to the personal data collected up to that moment. HOTELTURIST reserves the right to make changes to this privacy policy at any time by giving notice to users on this page. Please consult this page often, referring to the date of the last modification indicated at the bottom. In the event of non-acceptance of future changes, the interested party must cease using the website or the functions to which the privacy change refers, and in the absence of such abstention, the changes will be understood as accepted (except for those that change the conditions for obtaining consent, where mandatory, for processing).

Types of data

Through the web forms available on the sites, we never ask you for "particular" personal data (personal data capable of revealing racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions , associations or organizations of a religious, philosophical, political or trade union nature, as well as personal data suitable for revealing the state of health and sexual orientation) or "judicial" (data relating to criminal records, or relating to the status of defendant or suspect, etc.). The data we process can be of three general categories:

Navigation data

When (even via mobile via smartphone or tablet) you access this website or use our services, computer systems and software procedures used to operate the site acquire, during their normal operation, some information about you, which can be qualified as "personal data" whose transmission is implicit in the use of Internet communication protocols.
These include the hardware model, operating system and version, information about the mobile network and country you are accessing from, the time of the request, the method used in submitting the request to the server, the access time , the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), the details relating to the itinerary followed within the web pages with particular reference to the pages visited and other parameters relating to the user's operating system and IT environment (browser used, version, geographical location, last page visited before accessing the services of the IEG Site) and unique device identifiers (e.g. the IP address or domain names of the computers used by users, the address in URI notation - Uniform Resource Identifier, the MAC address - Media Access Control).
This is information that is not collected to be directly associated with identified interested parties, but which by their very nature could, in theory, through processing and association with data held by third parties (in particular, third party internet connectivity service providers), allow to identify users.
However, these data are used by us only to obtain statistical information in aggregate and anonymous form on the use of the site, to better understand the user's browsing behavior in order to offer the user a better browsing experience, to make possible the technical functions of the site, to control and optimize its functioning, to improve the quality of the services offered by the site as well as guarantee the maintenance of the related database and IT support infrastructure.
These navigation data after the aforementioned processing in anonymous form are canceled within 12 months from the date of collection.
The navigation data can also be used to ascertain responsibility in the event of crimes against the Site or committed through the Site (malware attempts, spamming, abusive access to computer systems, etc.) and in this case the retention continues. for as long as necessary to protect the rights of IEg and/or third parties.

Data provided actively by the interested party

By these are meant:
• information sent by users on an optional and voluntary basis to the addresses indicated on the Site (eg e-mail address, subject of the e-mail, name or company name, name and surname, etc.);
• personal data provided by users to use services accessible on the Site or to participate in initiatives promoted through the Site;
• personal data provided by users who request the dispatch of news and/or informative material;
• personal data provided by users who send job application proposals (“curriculum vitae”, etc.).

Data collected from third parties

In the event of the sale of travel packages and tourist services by HOTELTURIST to third party intermediaries of the resale to the final customer, HOTELTURIST collects, through forms delivered by the same intermediaries to the latter, personal data of the interested party such as name and surname, nationality, code type and number of identity document and expiry date, date of birth, family unit composition, membership of organizations on behalf of which HOTELTURIST makes reservations, landline or mobile telephone number, zip code, city, address, email address, data relating to content and methods of delivery of the service purchased by the end customer, price, payment method. Among the data collected there may also be data on food intolerances of the interested party or on membership of organizations that reveal religious beliefs.

The user is invited to however, do not provide information constituting particular data (by them we mean only data relating to health - for example stays of disabled people, health visits, medical certificates, diets, etc. - and/or which reveal racial or ethnic origin) own or third parties, without having previously given your consent to treatment in accordance with the law (consent in writing).
The treatment will be carried out, with or without the aid of electronic tools, according to principles of correctness, lawfulness, transparency, so as to protect the privacy and rights of the interested party at all times, in compliance with the provisions of current legislation.

 

Purpose and duration of the treatment

The data will be processed for the following purposes and respective durations:

To acquire and confirm - also by registering on this Site - your booking of tourist packages and services, other ancillary and non-ancillary services and to provide you with the same organizing all internal and external management and production activities instrumental to this. The processing may also concern "particular" data, meaning only data relating to health (e.g. stay of disabled people, health check-ups, medical certificates, food diets, etc.) and/or which reveal racial or ethnic. We do not process data relating to life and sexual orientation, genetic data, biometric data, data revealing political opinions, religious or philosophical beliefs, trade union membership. The data is also processed for the purpose of managing competitions and prize events in which the interested party participates. The treatment does not require your consent. The provision of personal data is optional but in case of refusal to provide them, with the exception of "particular" data, we will not be able to confirm the reservation and/or provide you with the requested services. In the event of disputes, we will process the data for the protection of our rights and until the settlement of the same; in any case we will process the data for the duration referred to in point 4 below.

To speed up the procedures registration in case of your subsequent stays At our facility. For this purpose, based on our legitimate interest in reducing internal management activities, your data will be kept for a maximum period of fifteen (15) years, and will be used when you are our guest again for the purposes referred to in the previous points; this treatment does not require your consent.

(limited to the details of the identity document, name and surname and date of birth of you and/or of your family members or people staying with you) To fulfill the obligation established by the "Consolidated text of public safety laws" (art. 109 RD 18.6.1931 n. 773) which requires us to communicate to the Police Headquarters and/or the local Public Safety Authority, for public safety purposes, the personal details of the clients accommodated according to the methods established by the Ministry of the Interior (Decree of 7 January 2013). The provision of data is mandatory and does not require your consent, and without the same we will not be able to host you in our structure. The data acquired for this purpose are kept for the strictly necessary time (7 days). For this purpose, the data is kept for the strictly necessary time (48 hours), without prejudice to the provisions of point 4 below. In the case of groups of guests, or families, the aforementioned data relating to the details of the identity document collected and processed concern only the group leader or the head of the family.

fulfill current administrative, accounting and tax obligations. The provision of data is mandatory and does not require your consent. In case of refusal to provide the necessary data, we will not be able to provide you with the requested services. The data is kept by us for the time required by the respective regulations (ten years and, in the case of tax assessments, even longer, until the definition of the same).

perform the function of receiving and transferring messages and telephone calls, delivering mail and parcels addressed to you, your family and/or people present with you during your stay. The provision of data is optional and failing that, we will not provide the aforementioned services. For this purpose, your consent is required, which can be revoked at any subsequent time. The treatment will cease upon your departure.

For purposes of protection of people and company assets through a video surveillance system of some areas of the accommodation facility, the location of which can be identified through the presence of specific external signs. Your consent is not required for this treatment, as it pursues our legitimate interest in protecting people and property against aggression, theft, robbery, damage, vandalism and the like. The recorded images are automatically deleted after 24 hours, except for holidays or other cases of closure and in any case no later than one week. They are communicated to third parties only in the event that a specific investigative request from the judicial authority or judicial police must be adhered to and in this case they can also be communicated to lawyers and IT experts.

(subject to your express consent) To send you newsletters and/or our promotional messages and updates on the rates and offers we apply for tourist packages or services and ancillary and non-ancillary services, by e-mail, sms, instant messaging, social networks, telephone calls with or without operator, paper shipments. The provision of data and your consent to the processing are optional and your lack of consent will prevent us from carrying out the aforementioned activities while it will not in any way interfere with your right to obtain the services you have booked or the other information you request from us. You may at any time oppose the processing (so-called opt-out) or revoke the previously given consent.
Your prior consent is not required in the case of sending promotional emails for services and/or products similar to those you have already purchased from us, or when we contact you using telephone numbers available on public directories and/or registers. Your data will be processed for a maximum period of twenty-four (24) months.

8. (subject to your express consent) To carry out promotional activities, information and updates on the rates and offers made by other subjects belonging to the same group TH Resorts (subsidiaries and/or affiliates or parent companies) to which we can transfer the data for this purpose.
Your consent is optional. Your lack of consent will prevent us from profiling you and (therefore we will not be able to personalize the direct marketing initiatives concerning you), while it will not in any way interfere with your right to obtain the services booked by you or the other information that you provide us requires The consent can be revoked by you at any subsequent time. The duration of the treatment carried out by third parties is managed by them.

(subject to your express consent) For purposes of profiling.
For your profiling we use data (for example name and surname, company name of the company or organization to which you belong, residence or registered office, landline and mobile phone, e-mail address; which you release to us when you use individual services (also associating them to data of your navigation on the HOTELTURIST websites or of the use of the services provided by the site (eg cookies) or of data collected through other communication channels (eg like a social media with which you interact, linked from our site).
We process the data to analyze even predictively and/or create groups of natural persons divided into market segments based on a minimum set of elements (e.g. geographical area of ​​origin, contact language), up to profiles more advanced based on age, gender, preferences and interests declared by you, age, marital status, composition of the family nucleus, previous purchases, browsing behavior on our. websites and/or on our apps (which web pages you visited, which offers or contents you viewed, any data loaded on online registration forms, other logs), the methods of your interaction with our. promotional e-mail messages (how many and which messages have you opened and/or viewed), the devices you use to interact with our online platforms.
This activity has a dual purpose: to better understand customers, both as groups and individuals, and to analyze the effectiveness of marketing to develop and update our services and offers in line with your preferences.
Profiling aims to align the services and goods offered by HOTELTURIST with current and potential demand, measure the results of specific promotions, undertake corrective actions aimed at improving company results (e.g. reducing the risk of investing resources in marginal thematic areas for the target) and the effectiveness of commercial processes (e.g. by ascertaining how many messages and promotional content we have sent you have been seen and clicked on by you), limit the sending of promotional communications that are not relevant to your probable expectations or preferences through unwelcome channels ). This means that HOTELTURIST does not send the same offers to all interested parties and will be able to send you advertising communications as close as possible to your tastes and interests or preferences, or via your preferred contact methods, improving your experience. purchase, even for your own benefit.
Profiling does not imply your exclusion from specific advantages or from the possibility of freely exercising your rights in relation to the personal data processed by HOTELTURIST; in particular, it does not affect the possibility for the interested party to use the ordinary services (eg online pre-registration, purchase of services) sold by HOTELTURIST.
The provision of data is not necessary because we already have the same due to the previous booking of our. services performed by you. Your prior consent is discretionary. Your lack of consent will prevent us from profiling you and (therefore we will not be able to personalize the direct marketing initiatives concerning you), while it will not in any way interfere with your right to obtain the services booked by you or the other information that you provide us requires. You may revoke the previously given consent at any time. Your data will be kept for a maximum period of two years.

The purposes referred to in the previous points from 1 to 6 are defined as "primary purposes”; the purposes referred to in points 7 to 9 are defined as "secondary purposes".