INFORMATION ON THE PROCESSING OF PERSONAL DATA REGARDING THIS WEBSITE

This page contains a description of the policies for managing the website in regard to processing the personal data of the users who visit the site and their privacy. This information is provided pursuant to article 13 of GDPR 679/2016 – General European Regulation concerning the Protection of Personal Data and the individuals who interact with the web services of Pellicano Hotels, which is accessible by telematics means through the following web address: http://www.hotelilpellicano.com – to the home page of the official website of “Il Pellicano” and “La Posta Vecchia” Hotels.

This informative note is provided only for the aforementioned website and not for other websites eventually accessed by the user through links.

THE “DATA CONTROLLER”

Following access to this website, data pertaining to persons that are identified or identifiable may be processed. The “Data Controller” of the personal data collected following a visit to our website or any other data used for providing our services is IL PELLICANO S.p.A., Monte Argentario (GR), fr. Porto Ercole, Loc. Sbarcatello.

PLACE WHERE DATA IS PROCESSED

Data processing pertaining to the web services of this website [physically hosted by provider RELACTIONS ("www.www.relactions.com") by  servers located in Chicago (USA), appointed as Data Processor Responsible according art. 28 GDPR 679/2016]  is carried out at the aforementioned headquarters and said data is processed only by the technical personnel in charge of processing of the Data Processing Office, or by eventual persons in charge of processing who are entrusted to process occasional maintenance operations.

The personal data obtained from the users who submit hotel reservation requests or through informative material (informative notes, newsletters, registration, etc.) is used only to carry out the services or assistance requested and is not transmitted to third parties, except in the following possible:

  • Business partners of Pellicano Hotels to whom the Data Controller transmits the data exclusively in order to avoid on-line reservations, Leading Hotels / SynXis (www.sabrehospitality.com) to the United States of America;
  • Persons, companies or professional offices who lend assistance and consulting services to Il Pellicano S.p.A. concerning accounting, administrative, legal, financial and tax matters;
  • Subjects who are authorized to have access to the data by law or through requests by the authorities;

TYPES OF DATA PROCESSED

Navigational data

The informatics systems and the software procedures used for the functioning of this website, during their normal functioning, acquire some personal data for which the transmission of said data is implicit in the use of Internet communication protocols. This concerns information that is not collected in order to be associated with identifiable interests but due to its nature, through elaboration and association with data obtained by third parties, could allow identification of the user. The data which fall within this category are: the IP address or the name and domain of the computer used by the user who accesses the website, the address which is revealed in the URI (Uniform Resource Identifier) of the resources requested, the time of the request, the method used in submitting the request to the server, the dimensions of the file obtained as a response, the numerical code indicating the server response status (successful, error, etc.) and other parameters pertaining to the operating system and the informatics used by the user.
This data is used only to gather anonymous statistical information regarding the use of the website and to control its correct functioning and is cancelled immediately after elaboration. The data may be used for ascertaining responsibility in the case of hypothetical informatics crimes damaging to the website: except in this last case, the data of the web contacts cease to exist after seven days.

Data voluntarily provided by the user

The optional, explicit and voluntary sending of E-mail to the addresses indicated in the website results in the successive obtainment of the address of the sender which is necessary in order to respond to the request, as well as the eventual ulterior personal data inserted into the message(s). Specific information for synthesis will be progressively reported or seen in the website pages that are designed for particular services and requests.

Data will be retained only for registration request to send the newsletters or special offers and will not be disclosed to anyone. The personal information regarding the individual who visited the website is not collected or used. The visitors remain anonymous. The only exception to this rule concerns the information for personal identification needed to fulfill the contractual obligations of reservations on behalf of the user.

Reservations

In the event of reservations made through the website, the user must provide his name, address, telephone number and information regarding the payment manners and credit card used. Pellicano Hotels will use said information only for elaboration of the reservations and to send specific information, which is relevant to the confirmation of said, such as a receipt, the reservation code and the conditions. The information provided will not be used for marketing purposes and will not be sold, transmitted, given by contract or sent to third parties an any way, with the exception of our provider of on-line reservation services, The Leading Hotels of the World Ltd and Sabre GLBL Inc, only for online reservations purposes. In any event, the provider of on-line reservation services guarantees the use of scrupulous procedures in order to protect the navigational data and the use of particular precautions to protect the data pertaining to the credit card, which is provided during on-line reservations.

PERSONAL DATA PROCESSING COLLECTED FROM CURRICULUM VITAE

Pellicano Spa accept Personal Curriculum Vitae of possible candidates both on paper and in an electronic format. Sending spontaneous and voluntary of the Curriculum Vitae data will be considered as implicitly informed consent by the data subjects for personal data processing contained, only following the purposes related to the selection of potential candidates.

The data processed for the purpose of selection of candidates are personal useful to search for the particular profile. In general, the nature of the data is normal, except in some cases where you may indicate any sensitive data necessary to identify the specific requirements of the regulations, such as specifying a particular protected classes, the suitability for certain jobs and / or start-ups required, within the limits set by the General Authorisation of the Garante no. 1 of December 15, 2016, (Published in the Official Gazette no. 303 of December 29, 2016);

The provision of data relating to the selection of candidates is required. Any refusal to provide such data makes it impossible to perform an orderly selection and the possible recruitment. The data in question will not be disclosed to anyone.

General Rules for sending the CV

Any CV received spontaneously, replying to a job advertisement, will be stored directly by person in charge of the processing in accordance with the safety guidelines of personal data adopted in compliance with the security measures according to Chapter IV Section 2 of GDPR 679/2016. These will be printed only on the occasion of a meeting and a conversation with the data subject. After the interview, if the candidate is not selected, the CV will be deleted and / or destroyed. In all other cases, after a short period of time and after the talks and after the trial period (180 days) CVs will be deleted from the PC and, if printed, they will be destroyed.

To send Curriculum Vitae use only the following addresses: Human Resources Dpt, Il Pellicano Spa, Località Sbarcatello 58019 Porto Ercole (Grosseto) or send it via e mail at the address recruiting@pellicanohotels.com.

PERIOD FOR DATA RETENTION - CRITERIA USED

According to the provisions set forth in art. 5 par. 1 lett. e) of the Regulation (EU) 2016/679, collected personal data shall be kept in a form which permits identification of data subjects for a period not exceeding the purposes for which the personal data were collected and subsequently processed.

Data retention periods depend on the purposes of the processing:

  • purposes related to technical navigation data for the correct functioning of the website: retention only for the related session, after which the data are deleted;
  • purpose of reply to info request/services supply request (up to 12 months for contact requests ; 10 years for administrative / accounting / financial documentation relating to the provision of a service);
  • data collection for staff recruitment (up to 6 months);
  • newsletter, marketing or promotional communications in general (up to 24 months -until withdrawal of consent)
  • purpose of administrative / accounting / financial management: 10 years as as required by law for the conservation of administrative / accounting / financial documentation.

COOKIES

In this website we are applied cookies technologies for different purposes, including computer technology authentication or to monitor sessions, and to store specific technical information regarding the users that access the server of RELACTIONS, the website maintenance provider and SABRE, the hotel booking service provider.

Description of the cookie mechanisms adopted:

  • Cookie implanted in the user/contracting party's terminal directly (that will not be used for other purposes) such as session cookies used for on-line booking on the website, authentication or customisation cookies (for example, the choice of the browsing language); these cookies remain active only for the duration of the session.
  • Cookie used to statistically analyse accesses/site visits (the so-called "analytic" cookie) that are used for statistical purposes, and to collect aggregate information without the possibility of tracing back to the identification of the individual user personal computer. In these cases, since current legislation requires that, when using analytic cookie, the user is given clear and adequate instructions to easily oppose implementation of such (including any mechanisms to make the cookies anonymous), we give instructions on how to disable installed cookies below. The duration of analytic technical cookie is averagely of 30 minutes

How to modify settings on the cookies

Most browsers allow to clear cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored.

Therefore, to remove cookies we encourage you to follow the instructions on the pages of the most used internet browsers:
Chrome:                   https://support.google.com/chrome/answer/95647?hl=it

Fire fox:                     https://support.mozilla.org/it/kb/Gestione%20dei%20cookie

Microsoft Edge:     https://privacy.microsoft.com/it-IT/windows-10-microsoft-edge-and-privacy

Safari:                        http://support.apple.com/kb/HT1677?viewlocale=it_IT

“Third-party” cookies

Third-party cookies are code parts set by a website different than the website you are currently browsing.

This involves the transmission of cookies from third parties. In this website is carried out the google analytics technology for statistical monitoring of the website visits. This technology uses a tracking code that sets third party cookies and JavaScript files lingering on each visitor's computer. In addition to transmitting information to a Google server, these cookies store information such as whether the visitor has been to the site before (new or returning visitor), the timestamp of the current visit, and the referrer site or campaign that directed the visitor to the page.

The privacy policies available on the websites described above. Visitors in any case can turn off the advertising features of Google Analytics on this site by installing the Add-off for your browser downloadable from this  LINK.

More google analytics privacy policies available on http://www.google.com/policies/technologies/ads/

List of used cookie

Name

Destination

Type

Purpose

Expiry

Provider

PHPSESSID

USA (Adequate)

HTTP

This first party cookie is used to maintain information about each visit to the website and enable core site functionality.

6 days

hotelilpellicano.com

_gid

USA (Adequate)

HTTP

This first party cookie is used to distinguish users and only to realise statistical analysis on how the visitor uses the web site

1 day

hotelilpellicano.com

_gat

USA (Adequate)

HTTP

This Google Analytics cookie is used by Google Analytics to monitor requests rate toward their servers. This cookie helps us to identify website areas to be improved and the _gat cookie does not allow us to identify user personally as no personal information or data is tracked

1 day

hotelilpellicano.com

_ga

USA (Adequate)

HTTP

This Google Analytics cookie is used to distinguish users  when collecting information about page visits. This cookie helps us to identify website areas to be improved and the _ga cookie does not allow us to identify user personally as no personal information or data is tracked

2 years

hotelilpellicano.com

ads/ga-audiences

USA (Adequate)

Pixel

Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's on line behavior across web sites.

Session

google.com

Embedded content (Third party cookies)

Il Pellicano Spa sometimes uses content from social like Twitter, Facebook, Linkedin, Instagram and possibly embeddable content from other platforms. Il Pellicano Spa cannot control these third party cookies and for this is it possible to contact any third party to have more control over these cookies. A few links to the privacy policy of third party cookies:

Nevertheless, if you block or erase cookies, it may not be possible to reset previously specified preferences or customised settings, and our capacity to customize the user experience will be limited.

TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES

Personal data is not transferred to non-EU third countries, in compliance with the provisions of Chapter V of the RGPD 679/2016, except for any cases described above where for transfers to the USA it takes place on the basis of an adequacy decision of the EU Commission vs third country or an International organization (Article 45 GDPR), particularly the decision on the adequacy of the protection provided by the EU-U.S. Privacy Shield of 12 July 2016 that our processors (The LHW Ltd) and (RELACTIONS) and their respective sub-processors (Sabre GLBL Inc.) e (Siteground - SG Hosting Inc.) undertake to respect.

OPTION OF CONFERING DATA

Except for that which is specified for the navigational data, the user is free to provide the personal data listed in the request forms of Pellicano Hotels or through contacts with the Office in order to make on-line reservations or to solicit the receipt of informative material or other communications. A lack of conferring this data may cause an impossibility to obtain what is requested.

PROCESSING ARRANGEMENTS

Personal data is processed with automatic instruments for the length of time strictly needed to carry out the purposes for which the data was collected. Specific safety measures are observed to avoid the loss, illicit or incorrect use and unauthorized access of data.

RIGHTS OF THE INTERESTED PARTY

The data Controller is Il Pellicano Spa, Località Sbarcatello Porto Ercole 58019 (Grosseto) ITALY. The Data Protection Officer is Mr. Massimo Bruno. You may contact them at any time to exercise your rights as provided for in Chapter III GDPR 679/2016, in particular, the right to obtain confirmation as to whether or not personal data concerning you exist and the logic applied to the processing, the right to ask for their integration, the right to object to their processing on legitimate ground, and the right to request rectification, updating, erasure (right to be forgotten) or blocking of data that have been processed unlawfully, the right to obtain a copy of the personal data being processed  as well as the right to data portability, also by sending a written request to the following e-mail address: privacy@pellicanohotels.com. At the same e-mail address, it is possible to contact the Data Protection Officer.

RIGHT TO LODGE A COMPLAINT

If a data subject considers that the processing of personal data relating to him or her as performed via this website infringes the EU Data Protection Regulation, he or she has the right to lodge a complaint with the Garante pursuant to Article 77 of the Regulation, or else to bring a judicial proceeding against the Garante pursuant to Article 79 of the Regulation.