Privacy Policy

### Data Subjects: Users visiting the website www.riccionehotelsadria.com of “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA”

**WHY THIS INFORMATION IS PROVIDED**

Pursuant to Regulation (EU) 2016/679 (hereinafter “Regulation” or “GDPR”), this page describes the methods of processing the personal data of users who visit the website of “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA,” accessible online at the following address: www.riccionehotelsadria.com.

This information does not concern other sites, pages, or online services that may be accessible via hyperlinks published on this site, but which refer to resources outside the domain www.riccionehotelsadria.com.

**DATA CONTROLLER**

As a result of visiting the site, data relating to identified or identifiable natural persons may be processed. The Data Controller is “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA,” with registered and operational office at Viale Tassoni, 10 – 47838 Riccione (RN), VAT: 03570920409 CIN: IT099013A1PHRXWSRF.

**TYPES OF DATA PROCESSED, PURPOSE OF PROCESSING, AND LEGAL BASIS**

1. **Browsing Data**
– **Legal Basis:** Data processing necessary for website navigation – contract obligation – Art. 6, para. 1, letter b) GDPR.
– The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of the computers and terminals used by users, URI/URL addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (success, error, etc.), and other parameters related to the user’s operating system and computer environment.

These data, necessary for navigating the site and utilizing the information contained within it, are also processed by the Data Controller for the purpose of:
– obtaining aggregated and anonymous statistical information on the use of the site (most visited pages, number of visitors per time slot or day, geographic areas of origin of visitors, etc.);
– verifying the correct functionality of the content offered by the site;
– preventing or countering any possible cybercrime, the fraudulent use of the site’s functionalities, including the reconstruction of security incidents and their traceability.

– **Retention Period:** Browsing data will be stored for no longer than necessary to achieve the technical purposes previously described for which they are collected and processed, subject to any necessity for legal investigations by judicial authorities.

2. **Data Provided by Users**
– **Legal Basis:** Data processing necessary to respond to users’ inquiries – contract obligation – Art. 6, para. 1, letter b) GDPR.
– The voluntary, explicit, and voluntary sending of messages to the contact addresses of “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA,” private messages sent by users to institutional profiles/pages on social media (where this option is provided), as well as the completion and submission of forms on the sites of “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA,” involve the acquisition of the sender’s contact data, necessary to respond, as well as all personal data included in such communications.
– Specific information is published on the pages of the site prepared for the provision of certain services, where necessary, the user’s consent is collected, informing them each time of the purposes and the optional nature of the provision.

– **Retention Period:** Data provided by users are stored for the time necessary to handle individual requests, subsequent storage for statistical purposes involves the anonymization of such data (subject to any necessity for legal investigations by judicial authorities).

3. **Cookies and Other Tracking Systems**
– **Technical Cookies:** Necessary for user navigation, facilitating correct navigation of the site and the usability of content by the user. **Legal Basis:** contract, as they are functional and necessary.
– **Analytical Cookies:** Used to process aggregated statistical analyses on the use and interaction with the site by the user, with the user’s prior consent. **Legal Basis:** consent.
– **Profiling Cookies:** Allow the collection of information about user preferences during navigation and generate reports for targeted advertising and marketing campaigns. **Legal Basis:** consent.

Information on data processing, purposes, retention, and complete cookie management, including consent and revocation, are available in the “Cookie Management” document also present in the footer.

4. **Social Media Policy: Information on the processing of personal data carried out through the Social Media platforms used**
– For information on personal data processing carried out by Social Media platform operators, refer to the information provided by them through their respective privacy policies. The Data Controller processes the personal data provided by users through the pages of the dedicated Social Media platforms, within its promotional and corporate advertising purposes, to manage interactions with users (comments, public posts, messages, shares, etc.) in compliance with current personal data protection regulations and this privacy policy; where necessary, user consent is collected, informing them each time of the purposes and the optional nature of the provision. Personal or “sensitive” data entered in comments or public posts within the social media channels may be removed.

The platforms used are:
– Facebook: https://www.facebook.com/hotel.4.stagioni.riccione
– Instagram: @hotel_4-Stagioni_riccione

**DATA RECIPIENTS**

Recipients of the data collected following the consultation of some of the services listed above are some subjects designated by the Data Controller pursuant to Article 28 of the Regulation as Data Processors, and other service providers within the scope of web agencies, digital communication, system assistance, and any other digital service providers, for which the complete list can be requested by writing to info@riccionehotelsadria.com. Some data and information may be transmitted or acquired by subjects identified as independent Data Controllers; such data relate to cookies usually anonymized before sending, for statistical purposes. If a transfer to Non-EU Countries is provided, the guarantee measures taken will be indicated, described in paragraph 6 of this document. The personal data collected are also processed by the staff of “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA,” who act on the basis of specific instructions provided regarding the purposes and methods of the processing.

**DATA PROCESSING SECURITY**

Personal data transmitted and stored for the necessary duration for the declared purposes are protected by specific technical and organizational security measures in reference to Art. 32 of the Regulation, able to guarantee on a permanent basis the confidentiality, integrity, availability, as well as the ability to promptly restore the availability and access to personal data in case of physical or technical incident, also in the face of risks of destruction, loss, modification, unauthorized disclosure, or accidental or unlawful access to personal data transmitted, stored, or otherwise processed.

**TRANSFER OF PERSONAL DATA TO NON-EU COUNTRIES**

The Data Controller does not transfer personal data to Non-EU Countries. If necessary, data subjects will be informed in advance, and guarantee measures for the transfer to the recipients will be adopted, which depending on the cases may include: verifying the existence of adequacy decisions for the destination country by the Commission, signing standard contractual clauses, verifying the adoption of any supplementary measures in accordance with EDPB Recommendation 01/2020. In derogation of these guarantees, for data processing (referring to Art. 49 of the GDPR), where applicable, the existence of a contract or pre-contractual measures in favor of the data subject or consent to the transfer will be verified.

**DATA SUBJECTS’ RIGHTS**

Data subjects have the right to obtain from “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA,” in the cases provided for, access to their personal data, rectification, erasure of such data, restriction of processing concerning them, data portability, or to object to processing and to withdraw consent (where used as a legal basis) in accordance with Articles 15 to 22 of the Regulation. The request is submitted through the contact details of “ALBERGO QUATTRO STAGIONI DI ZANGHERI GIANLUCA” with registered and operational office at Via Tassoni, 10 – 47838 Riccione (RN).

To exercise the rights, it is also possible to use the model prepared and available on the website of the Data Protection Authority at this link: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/9038275

**RIGHT TO COMPLAIN**

Data subjects who believe that the processing of personal data concerning them carried out through this site is in violation of the provisions of the Regulation have the right to lodge a complaint with the Data Protection Authority, as provided for by Art. 77 of the Regulation itself, or to take appropriate legal action (Art. 79 of the Regulation). The model to file a complaint is available on the website of the Data Protection Authority at this link: https://www.garanteprivacy.it/home/docweb/-/docweb-display/docweb/453552