PRIVACY POLICY FOR CLIENTS AND SUPPLIERS IN ACCORDANCE WITH GDPR 679/2016

CLICK HERE PRIVACY POLICY FOR OWNERS IN ACCORDANCE WITH GDPR 679/2016

This policy is provided by Emma Villas S.p.A. pursuant to art. 13 of Legislative Decree No. 196 of 30 June 2003 "Personal data protection code" and to art. 13 GDPR 679/16 “European regulation on the protection of personal data”.

Data Controller

The Data Controller of individuals is Emma VIllas S.p.A. with registered office in Via Antonio Bertoloni 8, 00197 Rome (RM)
The Data Controller can be contacted at the following email address: [email protected]

DPO

Emma Villas S.p.A. have decided to acquire a DPO (Data Protection Officer) who can be contacted at the following email address: [email protected]

Data Source

The personal data processed is that which the interested party will provide in the process of registering their account at Emma Villas.

Purpose of the Processing

• Manage reservations
• View estimates, including historical ones
• Verify invoices and payments
• Manage consents
• Define a wishlist
• Consult documents generated by Emma Villas
• Access the catalogue of Services
• Purchase additional services and/or insurance

The same data may be used to finalise a new booking, if requested, together with the data necessary for the booking but which is not part of the set of data needed for the registration of an account.
Subject to consent, the data relating to telephone contacts may be used via an instant messaging system to request or receive information relating to the current stay.

In addition, the same data and the choices made may be used, in the presence of consent, to implement client profiling in order to carry out market surveys and offer customised promotions.

Data Recipients

The personal data processed by the Data Controller will not be disclosed, that is, it will not be disclosed to indeterminate individuals, in any possible form, including that of making it available to them or for simple consultation. Instead, it may be communicated to the Data Controller's employees and to a few external individuals who collaborate with them. It may also be communicated, within strictly necessary limits, to individuals who, for the purpose of issuing orders or requests for information and estimates, need to supply goods and/or perform assistance or services. Finally, it may be communicated to individuals legitimised to access it by virtue of legal provisions, regulations and EU legislation. In particular, on the basis of the roles and duties performed, some employees have been legitimised to process personal data, within the limits of their competences and in accordance with the instructions given to them by the Data Controller.

Data Transfer

It is possible for the data to be transferred to partner companies of Emma Villas operating in Italy, in the European Community or in countries with which the European Community has a data transfer agreement. However, Emma Villas S.p.A. retain the possibility of also using services in Cloud; the providers of these services will be selected only if they can provide adequate guarantees to ensure compliance with Italian and European privacy laws.

Data Retention

The personal data referred to above will be entered in the company archives and will remain there according to the terms of the law and, if applicable, until a request for modification or cancellation by the interested parties is made.
Emma Villas S.p.A. store and process the personal data for the time necessary to fulfill the purposes indicated. Subsequently, the personal data will be stored, and not further processed, for the time established by the current provisions on civil and fiscal matters.

Rights of the Interested Party

The interested party has the right:

• to request confirmation of the existence of personal data concerning them (right of access);
• to know its origin;
• to receive intelligible communication thereof;
• to have information about the logic, methods and purposes of the processing;
• to request updating, rectification, integration, cancellation, transformation into anonymous form, blocking of data processed in violation of the law, including that no longer necessary for the pursuit of the purposes for which it was collected;
• in cases of processing based on consent, to receive at the sole cost of the eventual support, the data provided to the Data Controller, in a structured and readable form by a data processor and in a format commonly used by an electronic device;
• the right to lodge a complaint with the Supervisory Authority (Privacy Guarantor);
• and, more generally, to exercise all the rights that are recognised by the current provisions of the law.

The interested party exercises their rights by sending a registered letter to the Data Controller, or by email, specifying the subject of their request and attaching a copy of a valid ID.

Consent and Revocation

Pursuant to art. 23 of Legislative Decree 196/2003 and subsequent amendments and art. 6 of the GDPR 679/16, the interested party can revoke the consent at any time. However, a specific treatment may be lawful and permitted even in the absence of consent, if necessary for the execution of a contractual obligation, a law, and the presence of a necessary interest.

Lodging a Complaint

The interested party has the right to lodge a complaint with the supervisory authority of the state of residence (Privacy Guarantor) if they believe that their data is being processed improperly.

Refusal to Provide Data

The interested party may refuse to provide the Data Controller with their personal data. However, the provision of personal data is necessary for a correct and efficient management of the contractual relationship. Therefore, any refusal to provide data may compromise all, or part of, the contractual relationship itself.

Automated Decision-making Processes

Emma Villas S.p.A. currently does not process the personal data it possesses on the basis of contracts with customers and suppliers that lead to automated decision-making processes.