INFORMATION ON THE PROCESSING OF CUSTOMERS' PERSONAL DATA
PURSUANT TO AND FOR THE PURPOSES OF ARTICLES 13 AND 14 ET SEQ.
EUROPEAN REGULATION 2016/679
PREMISE
G.AL.POS. SRL, with registered office in Positano (SA) at Via Pasitea, 148, tax code/VAT number 00408750636 (hereinafter the “Company”), represented by its pro tempore Legal Representative, owner of Il Tridente Restaurant & Cocktail Bar, as Data Controller (hereinafter the “Data Controller”), hereby informs you, pursuant to Articles 13 and 14 of EU Regulation 2016/679, that it is the Data Controller of your personal data. The Data Controller guarantees that it will process the data in accordance with the principles of fairness, lawfulness, transparency and protection of your privacy and rights for the purposes and in the manner indicated below and that it has also adopted technical and organizational measures to ensure a level of security appropriate to the risks associated with the processing itself.
CATEGORIES OF DATA PROCESSED
Personal data: common data, including your personal details, contact details, billing information (such as, for example, mobile number, home or residence address, email address, bank details).
Health data: data that may reveal conditions relating to your health, such as, but not limited to, allergies, pathologies, and/or food or other intolerances.
Images: within the limits and in compliance with current legislation, captured by CCTV cameras installed for a legitimate interest of the Data Controller pursuant to art. 6, paragraph 1, letter f) of EU Regulation 16/679.
PURPOSE – LEGAL BASIS – STORAGE PERIODS
The data you provide will be processed, including with the aid of IT tools, for the following purposes:
A – To acquire and confirm table reservations and/or information requests (e.g., restaurant information, wedding planning), as well as to manage the contractual relationship relating to the catering service. Since this processing is necessary for defining the contractual agreement and its subsequent implementation, your consent is not required. If you refuse to provide your personal data, we will not be able to confirm the reservation or provide you with the requested services.
Legal basis for processing: performance of a contractual relationship.
Retention period: For this purpose, your data will be retained for the entire duration of the relationship and subsequently for the period required by the respective regulations. Any Special Data you provide will be retained exclusively for the time strictly necessary to perform the requested service.
B – Per adempiere ai vigenti obblighi amministrativi, contabili e fiscali. Per tali finalità il trattamento è effettuato senza necessità di acquisire il suo consenso. Il conferimento dei dati per questa finalità è necessario per la conclusione del contratto. In caso di rifiuto a conferire i dati necessari per gli adempimenti sopra indicati, non potremo fornire i servizi richiesti.
Legal basis for processing: performance of a contractual relationship, fulfillment of legal obligations.
Retention period: For these purposes, your data will be retained for the period required by the respective regulations.
C – For marketing purposes, including sending you promotional communications and newsletters, updates on the Data Controller's offers, and communications regarding events organized by the Data Controller. Your data may be processed by the Data Controller for this purpose only with your free and explicit consent, which may be revoked at any time.
Legal basis for processing: your consent.
Retention period: For this purpose, your data will be retained for a maximum of 10 years or until you withdraw your consent.
D – For the protection of persons, property, and company assets, using a video surveillance system in certain areas of the facility, which are identified by designated signs. Your consent is not required for this processing, as it pursues our legitimate interest in protecting persons and property from potential assaults, thefts, robberies, damage, and vandalism, and for fire prevention and workplace safety purposes. Providing your data for this purpose is necessary to conclude the contract, as without your consent, you will not be able to access the hotel.
Legal basis for processing: the Data Controller's legitimate interest in protecting people and property from potential assaults, thefts, robberies, damage, and vandalism, and for fire prevention and workplace safety purposes.
Retention period: for this purpose. Recorded images are deleted after 24 hours, except on holidays or other business closures, and in any case no later than one week. They are not disclosed to third parties, except in the case of a specific investigative request from the judicial authorities or the police.
DATA PROVISION
Providing data for the purposes specified in this policy is mandatory and/or necessary only in the cases expressly indicated as such, as this data is essential for entering into a contract and/or for carrying out pre-contractual measures or complying with legal obligations. Failure to provide even partial consent to this data will prevent the contract from being concluded and/or performed.
Unless otherwise specified, providing your data is optional, and failure to provide it will only result in you not being able to benefit from the purpose described (for example, your data will not be stored for future stays, you will not receive promotional communications, etc.).
DATA PROCESSING METHODS
The processing of Personal Data will be carried out using manual, computerized, or electronic tools, suitable for guaranteeing security and confidentiality, and will be performed by appropriately appointed and trained personnel.
DATA COMMUNICATION
Please note that your data will be processed by authorized internal personnel, duly trained and informed of the procedures and measures to be adopted to adequately protect your privacy and rights. Your data may also be processed by external parties, specifically identified and with whom the Data Controller has signed an agreement pursuant to which these parties assume, pursuant to Article 28 of the European Regulation, the role of External Data Processors for the processing of your data, according to the instructions provided by the Data Controller from time to time. Specifically, if this is instrumental to the pursuit of the purposes indicated above, your data may be disclosed to:
– to third-party companies or other entities that collaborate with the Data Controller in fulfilling the contract and/or limited to the purposes indicated above (for example, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, freight forwarders, etc.).
DATA TRANSFER
Personal data is stored on servers located in Italy, and in any case within the European Union. It is understood that the Data Controller, if necessary, will have the right to move the servers outside the EU. In this case, the Data Controller hereby ensures that the transfer of data outside the EU will take place in accordance with applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.
RIGHTS OF THE INTERESTED PARTY
Pursuant to Articles 13, paragraph 2, letters (b) and (d), 15, 18, 19, and 21 of the EU Regulation, we inform you that you have the right to request from the Data Controller access to, rectification or erasure of, or restriction of processing concerning you, or to object to processing, as well as the right to data portability. You also have the right to lodge a complaint with the Italian Data Protection Authority, following the procedures and instructions published on the Authority's official website www.garanteprivacy.it.
EXERCISE OF RIGHTS BY THE INTERESTED PARTY
To exercise the rights indicated above, you may contact the DATA CONTROLLER by sending an email to: info@iltridentepositano.com.
IDENTIFICATION DETAILS OF THE OWNER
Below are the identifying details of the Data Controller: DATA CONTROLLER: G.AL.POS. SRL, with registered office in Positano (SA), Via Pasitea 148, tax code/VAT number 00408750636, email: info@iltridentepositano.com.
