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Data controller

The controller of the processing of personal data is HOLIDAY SERVICE s.r.l., represented by its legal representative pro tempore, with registered office at Plan de Gralba 10, 39048 Selva di Val Gardena (BZ), Tax Code and VAT no. 02230670214 ("HS" or the "Controller").

Data Protection Officer (DPO)

A Data Protection Officer has been appointed and can be contacted at: info@fildamont.com

This privacy policy is provided pursuant to Article 13 of Regulation (EU) 2016/679 (the “GDPR”) to inform you about how your personal data is managed by the Controller. Any personal data you provide or otherwise transmit will be processed in accordance with the provisions of the Regulation and any other applicable data protection laws, such as Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018 (the “Privacy Code”). The processing of personal data by the Controller will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality.

Additionally, Personal Data may include special categories of personal data, such as data revealing health status, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, and data concerning a person’s sex life or sexual orientation, pursuant to Article 9 of the GDPR (the “Special Categories of Data”).

Personal Data Processed

While browsing and using the services offered through the website — such as: table reservations; managing reservations (modification or cancellation, etc.); purchasing value and/or product vouchers; sending promotional and marketing communications including newsletters; submitting job applications; and/or accessing sections of the Website (collectively, the “Services”)—personal data is processed.

Personal data may include identifiers such as name and surname; identification numbers and online identifiers such as phone numbers (mobile and/or landline) and email addresses; other contact information such as home address; or any other elements that characterizes the data subject’s physical, physiological, psychological, economic, cultural, or social identity and that could render the person identified or identifiable (the “Personal Data”). The Personal Data processed through the Website include the following:

Browsing data. The IT systems and software procedures used to operate the Website acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. These data are not collected to be associated with identified individuals but, by their very nature, could allow users to be identified through processing and association with data held by third parties. This category of data includes IP addresses or domain names of the computers used by users who connect to the Website, the URI (Uniform Resource Identifier) 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 server's response (successful, error, etc.), and other parameters related to the user’s operating system and IT environment. These data are used solely to obtain anonymous statistical information on the use of the Website, to ensure its proper functioning, and to identify anomalies and/or abuse, and are deleted immediately after processing. The data may be used to determine liability in the event of hypothetical cybercrimes against HS or third parties.
Data voluntarily provided by the data subject. When using certain services on the Website, you may provide Personal Data. The provision of some Personal Data may be necessary to access specific services. The optional, explicit, and voluntary submission of your Personal Data through contact forms and/or availability or reservation requests on the Website, or by sending emails to the addresses listed on the Website, entails the subsequent acquisition of the data communicated, including your name, surname, email address, phone number (mobile or landline), home address, and your consent to receive any response messages to your requests. The Personal Data provided in this manner will be used by HS exclusively for the provision of the requested Services and to process or respond to your inquiries, and will only be shared with third parties if necessary for that purpose. If you provide Personal Data of third parties while using the Website, you must ensure that there is a valid legal basis under Article 6 of the Regulation to lawfully process such Personal Data.
Special Categories of Personal Data. In using certain sections of the Website, you may submit Special Categories of Personal Data. The legal basis for processing such data is either the necessity to comply with obligations and exercise specific rights of the Controller or the data subject in the field of employment law (Art. 9(2)(b) of the Regulation), or—if the data is voluntarily provided by the applicant—their explicit prior consent (Art. 9(2)(a) of the Regulation). Therefore, you are kindly requested not to submit unnecessary Special Categories of Data. If such data is nonetheless provided, the Controller may process it only to the extent permitted by law and by adopting appropriate security measures.
Data Collected Through Cookies. While browsing the Website, certain Personal Data may be collected through the use of so-called "Cookies". For more information, please refer to the following link: www.hotelsella.it/en/cookies

Purposes of Processing, Legal Bases, and Data Retention Periods

The Controller processes Personal Data for the following purposes:

Provision of the requested Services (i.e.: (i) the procedure for booking a stay; (ii) management of the reservation—modification or cancellation, etc.; (iii) the procedure for purchasing value and/or product vouchers), as well as responding to requests for assistance, information, or bookings. The legal basis for the processing is the performance of pre-contractual measures and/or the performance of a contract (Art. 6(1)(b) of the Regulation), as the processing is necessary to provide the requested Services or to respond to the data subject’s inquiries. The provision of Personal Data for these purposes is optional, but failure to provide such data would make it impossible to activate the requested Services or respond to the inquiries. Such Personal Data will be retained for only as long as necessary to achieve the stated purposes. If the Personal Data is provided in connection with a service request, it will be retained for the period necessary to provide the service and, in any case, for a maximum period of 24 months, in accordance with Article 2946 of the Italian Civil Code.
Analysis of CVs and Recontacting of Candidates. The legal basis for this processing is the performance of pre-contractual measures and/or the execution of a contract (Art. 6(1)(b) of the Regulation), as the processing is necessary for the analysis and evaluation of submitted CVs.
Regarding the review of professional social media profiles that are freely available online (e.g., LinkedIn), the legal basis is the legitimate interest of HS to assess any risks related to the candidate's suitability for the specific open position (Art. 6(1)(f) of the Regulation). During the recruitment process, the Controller may come into possession of Special Categories of Data. Such data will only be processed if necessary to fulfill obligations and exercise specific rights of the Controller or the data subject in the field of labor law (Art. 9(2)(b) of the Regulation), or upon the explicit consent of the candidate if provided voluntarily (Art. 9(2)(a) of the Regulation).
Candidates are therefore requested not to include unnecessary Special Categories of Data in their CVs for the position they are applying for. If such data are nonetheless included, the Controller may only process them within the limits permitted by law and while adopting appropriate security measures. For the above-mentioned purposes, Personal Data will be retained for a maximum period of 24 months.
Compliance with Legal, Accounting, or Tax Obligations. The legal basis for this processing is compliance with a legal obligation (Art. 6(1)(c) of the Regulation). Once the Personal Data are provided, the processing is necessary to comply with a legal obligation to which HS is subject. For this purpose, Personal Data will be retained for the period required by the relevant legal obligation or applicable regulation.

Provision of the “Südtirol Alto Adige Guest Pass.”
The legal basis for processing is the execution of pre-contractual measures and/or the performance of the contract (Art. 6(1)(b) of the Regulation). The Personal Data provided will be transmitted to the Central Coordination Center for Guest Cards in order to enable the creation and use of the Guest Pass and the provision of related services. Regarding the issuance of the Guest Pass, your Personal Data will be transmitted to the Mobility Consortium, with VAT number 02735170215, which, as the owner of the guest card and central coordination center, acts as an independent data controller of the transmitted Personal Data.

For more information about the processing of your Personal Data, you may send an email to privacy@moko.bz.it.

Sending of Newsletters and Promotional Communications. The legal basis for sending promotional and marketing communications regarding products or services—including those related to other facilities owned by HS—through automated (e.g., email) and non-automated means (e.g., postal mail) is the data subject's freely given and specific consent (Art. 6(1)(a) of the Regulation). Failure to provide consent for this purpose will not affect the use of the services. Furthermore, pursuant to Art. 130, paragraph 4 of the Italian Privacy Code, the Controller may use your email address to send promotional communications about products or services similar to those you have already purchased (so-called “soft spam”), unless you object. For these purposes, Personal Data will be retained until consent is withdrawn by the data subject or, in the absence of such withdrawal, for a maximum period of 24 months.
Prevention and Management of Disputes and Legal Proceedings. The legal basis for this processing is the legitimate interest of HS to prevent and/or manage disputes, and to defend itself in legal proceedings (Art. 6(1)(f) of the Regulation). For this purpose, Personal Data will be retained for a period of 10 years, unless an objection is raised and excluding the time necessary for legal defense.

For more information on the retention period of Personal Data and the criteria used to determine such period, please contact: info@fildamont.com

Recipients and Transfers of Personal Data

Your Personal Data may be disclosed to the following recipients:

Individuals acting under the authority of HS, who have been authorized to process Personal Data pursuant to Art. 29 of the Regulation in the context of their job duties and who are bound by confidentiality or a suitable legal obligation of confidentiality (e.g., employees, collaborators).
Data Processors pursuant to Art. 28 of the Regulation, who process Personal Data on behalf of the Controller and under a contract with the Controller, including: (i) individuals, companies, or professional firms providing HS with assistance and consultancy services in the fields of accounting, administration, legal matters, taxation, finance, and credit recovery; (ii) entities necessary for the provision of services (e.g., hosting providers, resources providers, software developers, marketing agencies); (iii) the operator of the job application platform; (v) entities in charge of technical maintenance (system administrators).
Independent data controllers to whom your personal data must be disclosed for the provision of services,
e.g., the Mobility Consortium (VAT No. 02735170215) for the creation of the “Südtirol Alto Adige Guest Pass” and the provision of related services.
Subjects, entities or authorities to whom your Personal Data must be disclosed pursuant to legal provisions or authority orders.

If any of your Personal Data is shared with recipients located outside the European Economic Area, HS ensures that such processing will occur in compliance with the Regulation and with appropriate safeguards as set out therein.

For more information regarding the processing of your Personal Data by third parties, please contact: info@fildamont.com

Your Rights

Pursuant to Articles 15 et seq. of the Regulation, you have the right to request at any time from HS access to your Personal Data, rectification or erasure of such data, objection to its processing, restriction of processing in the cases provided for in Article 18 as well as data portability in the cases provided for in Article 20, i.e., to receive your data in a structured, commonly used, and machine-readable format.

Requests can be submitted via email to: info@fildamont.com

You are also informed that you may withdraw your consent at any time for any processing not required for the provision of services. Specifically, you can opt-out of receiving newsletters and promotional communications at any time by clicking the unsubscribe link at the bottom of every email or by emailing: info@fildamont.com

Please note that the withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal, as stated in Article 7(3) of the Regulation.

In any case, you have the right to lodge a complaint with the competent Supervisory Authority (in Italy: Garante per la Protezione dei Dati Personali), pursuant to Article 77 of the Regulation, if you believe the processing of your Personal Data violates applicable law.

Modifications

HS reserves the right to amend or update this policy, in whole or in part, also in response to changes in applicable law. You will be notified of any such changes through their publication on the website. HS therefore invites you to regularly check this section to stay informed about the most recent and updated version of the privacy policy and to remain aware of how your data is collected and used.

Security and protection of your personal data

We are committed to protect your personal data. Therefore, we collect data only in accordance with the GDPR. In our privacy policy we inform you about the most important aspects of data processing concerning our website.

To protect your details against any possible loss of information or any form of unlawful processing, this site has taken appropriate organizational and technical measures.

Definitions

Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject ('lawfulness, fairness and transparency'). For the purposes of this Regulation:

Personal data
'personal data's means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing
'processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing
'restriction of processing' means the marking of stored personal data with the aim of limiting their processing in the future.
Profiling
'profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation
'pseudonymisation' means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Filing system
'filing system' means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
Controller
'controller' means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor
'processor' means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient
'recipient' means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party
'third party' means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Consent
'consent' of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Lawfulness of processing

Processing shall be lawful only if and to the extent that at least one of the following applies (legal basis for data processing: Article 6, paragraph 1, point a – f of the GDPR):

the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which the controller is subject;
processing is necessary in order to protect the vital interests of the data subject or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Collection and storage of personal data and the nature and purpose of their use

You can in principle use our website without revealing your identity. When you visit our website, the browser used on your device automatically sends information to our website’s server. This information is temporarily stored in a so-called log file. The following information will be collected without your intervention and stored until automated deletion (legal basis for data processing: Article 6, paragraph 1, page 1, point f of the GDPR):

IP address
Date and time of access
Name and URL of the retrieved file
Website from which access takes place (referrer URL),
Browser used and, if applicable,
the operating system of your computer as well as
the name of your access provider

The data mentioned are processed by us for the following purposes:

Ensuring a smooth connection to the website
Ensuring comfortable use of our website
Evaluation of system security and stability, as well as
Other administrative purposes.

Use of Cookies

This site uses cookies to help us provide you with a better user experience tailored to your personal preferences. By using cookies this site makes sure that you do not receive or need to enter the same information every single time you visit this website. Cookies are also used to optimize the performance of the website. For example, cookies make the checkout process easier or help you to find a specific piece of equipment faster.

Minors

Our offer is basically aimed at adults. Persons under the age of 18 should not transmit any personal data to us without the consent of their parents or legal guardians.

Rights of the data subject

Right of access
You shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data are transferred to a third country or to an international organisation, you shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Right to rectification
You shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure ('right to be forgotten')
You shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay.

Right to restriction of processing
You shall have the right to obtain from the controller restriction of processing.

Right to data portability
You shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

Right to object
You shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point e or f of Article 6, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Automated individual decision-making, including profiling
You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information, please see this link: https://policies.google.com/privacy/partners?hl=en.

Google AdWords and Google Conversion-Tracking

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Application. Google Privacy Policy: https://www.google.de/policies/privacy/.

YouTube Video

YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Google Privacy Policy: https://www.google.de/policies/privacy/.

Google Tag Manager

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. Google Privacy Policy: https://www.google.de/policies/privacy/.

By registering with our newsletter system, you agree to regularly receive information by means of a newsletter. You can withdraw your consent to the use of your personal data at any time. You can withdraw consent, for example, by clicking on the button at the end of each newsletter to unsubscribe. As soon as you unsubscribe from the newsletter, all your data will be deleted from our mailing list. We use these data exclusively for the purpose of sending the requested information and do not pass them on to third parties.

Facebook Pixel

Our website measures conversions using visitor action pixels from Facebook, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”).

These allow the behavior of site visitors to be tracked after they click on a Facebook ad to reach the provider’s website. This allows an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization.

The data collected is anonymous to us as operators of this website and we cannot use it to draw any conclusions about our users’ identities. However, the data are stored and processed by Facebook, which may make a connection to your Facebook profile and which may use the data for its own advertising purposes, as stipulated in the Facebook privacy policy. This will allow Facebook to display ads both on Facebook and on third-party sites. We have no control over how this data is used.

Check out Facebook’s privacy policy to learn more about protecting your privacy: www.facebook.com/about/privacy/.

You can also deactivate the custom audiences remarketing feature in the Ads Settings section at www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You will first need to log into Facebook.

If you do not have a Facebook account, you can opt out of usage-based advertising from Facebook on the website of the European Interactive Digital Advertising Alliance: www.youronlinechoices.com.