Privacy Policy

Information concerning the processing of personal data, in accordance with article 13 of Legislative Decree no. 196/20003

In accordance with D.Lgs. June 30, 2003, No. 196 and subsequent changes, we hereby supply you all due informations concerning the purposes and methods for your personal and sensitive data processing in our possession.
This information is not valid for other web sites which might be visited through links contained in all the web sites of data controller’s domain name. The data controller shall not be considered responsible for third parties’ web sites.
This privacy policy is given pursuant to art. 13 d. lgs. 196/2003 and it’s inspired also to Recommendation n. 2/2001 adopted by Data Protection European Authorities on the 17th of May 2001, in order to identify minimum requirements for on line personal data collection, and in particular, methods of data processing, terms and nature of underwriting, and also in deference to European Directive 2002/58/CE, updated with Directive 2009/136/CE related to Cookies.

1. DATA CONTROLLER, pursuant to Article 28 of Italian Data Protection Code is Esse2Elle srl –  with Headquarter in Via Bari, 52 – 00043 – Ciampino (Roma), Italy, in person of its legal representative.

PLACE OF DATA PROCESSING
The personal data treatments are carried out at Data Controller’s Headquarter and at identified Third parties’ headquarters.

2. CATEGORIES OF PROCESSED DATA

Personal data and identification data.
Personal data shall mean any information related to natural person that is or can be identified, even indirectly, by reference to any other information, including a personal identification number . Identification data shall mean personal data allowing a subject to be identified directly (for  example, name, surname, place and date of birth, address, email address, telephone number, etc.).

Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. These pieces of information are not collected to be associated with identified interested parties, but, through elaborations and associations with data held by third parties, due to their own nature, may allow the user’s identification.
This data category shall including IP addresses or computers’ domain names used by users who surf the present website, the URI-mapped addresses (URI stands for Uniform Resource Identifier) of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (successful, error, and so on) and other parameters related to the operating system and to the computing environment of the user.
These data are exclusively used in order to obtain anonymous statistics related to website’s use and to control the correct functioning.  These data are immediately delete after processing.

Judgment defence

The User’s Personal Data may be used  by the Data Processor for legal defense in judgment or in the preparatory phases of the judgment, in order to defense Data Processor’s rights in case of  improper use of this website or to solve matters related to an improper use of services provided by the Data Processor.
The data could be used to determine the responsibility in case of computer crimes against the website.

Maintenance– The User’s Personal Data may be treated with additional methods and objectives related to system maintenance.

Data provided voluntarily by the user
Sending explicit voluntary and optional emails to the addresses listed on the present website entails the subsequent acquisition of the sender email address , necessary to reply to the user’s request, and also of any other personal data.

Specific policies– Specific policies related to specific matter may be present in the different pages of the present website, in connection with particular services or processing of data provided by the user.

Cookies
The specific policy regarding cookies is available to the following link: cookies policy.

3. PURPOSES OF DATA PROCESSING FOR WHICH YOU GRANT CONSENT WHERE REQUIRED (ARTICLE 23 D. LGS. 196/03.)

AVoluntarily-provided personal and sensible data shall be processed for following purposes, unless otherwise notified:
– to surf the current internet website;
– to fill in the forms available in the present website in order to submit quotation request, contact request or to send your CV application;
– to fill in the forms in order to perform on line booking procedure;
– for administrative and accounting activities in general. Data processing for administrative and accounting purposes are those related to organizational, administrative, financial and accounting activities regardless of the nature of data processed. In particular, internal organizational activities, those following contractual obligations’ fulfilment and information activities are related to these purposes.

B) Personal data provided by filling in the forms in Data Controller websites or others contact forms (e.g. name, surname, e-mail address) will be processed, with your prior consent, by Data Controller and/or Data Processor for promotional, commercial purposes, also through mailing list subscription for newsletter service.

4.METHODS OF DATA PROCESSING – DATA RETENTION
The personal data processing will be carried out by electronic, automated and / or manual instruments, with methods and tools to ensure maximum security and confidentiality, by persons authorized to do so in compliance with the requirements of Art. 31 and following of D. Lgs 196/03. The personal data will be kept for a period not exceeding the purposes for which the data were collected and subsequently processed.

5.COMMUNICATION AND DATA DIFFUSION
The personal data to be processed will be treated confidentially and will not be diffused. Your data may be shared with companies contractually involved with Esse2Elle srlwithin the European Community, pursuant to Legislative Decree No. 196/2003, article 42, in order to comply with contractual obligations or related purposes. Furthermore, these data may also be disclosed to following third parties:
– entities that provide services for the management of the information system used by Esse2Elle srl and the telecommunications networks, including e-mail service, newsletter service and website service management;
– firms or companies which provide assistance and advice;
– competent authorities who enforce the law and/or regulations promulgated by public bodies, on request.
The above mentioned entities shall act as Data Processor or may perform their tasks fully independently, as if they were the Data Controller. The list of potential Data processor list  is constantly updated and it is available at Esse2Elle srl.

6.NATURE OF UNDERWRITING
With exception of what above specified concerning navigation data, the user is free to provide personal data. The provision of personal data for the above mentioned A) purpose is necessary and the eventual non-submittal of  personal  data for this purpose may results the impossibility to get the required service.
The prior consent for data processing related to B) purpose is optional and the refuse and/or non submittal of personal data for this purpose won’t affect data processing for A) purpose.

7. RIGHT TO ACCESS PERSONAL DATA AND OTHER RIGHTS
You can exercise your rights according to articles 7, 8, 9 and 10 of Legislative Decree no. 196 of 30th June 2003, by contacting the Data Controller, or the Data Processor at the following telephone number +39 067962304, or by sending an email to info@lavillettasuite.it.
You have the right, at any time, to obtain confirmation of the existence of your data and ask for their content and origin, verify their accuracy or request their integration or updating, or correction (Article 7 of the Italian Data Protection Code). For the purposes of this Article you can ask the cancellation, the transformation into anonymous form or the arrest of the personal data processed in contravention of the law, and you can oppose for legitimate reasons to their treatment.
In case you’ll contact the Data Controller you are required to provide your email address, name, address or phone number, in order to allow the Data Controller to manage your request.

8.CHANGES TO THE PRIVACY STATEMENT
The Data Controller reserves the right to modify, update, add or remove portions of the current Privacy Policy at his discretion and at any time. We encourage you to periodically review this page for the latest informations on our privacy practices. To make this review easier for you, our privacy statement will contain the date of the publication on the website and updating. Using the website, after the changes post, will mean silent acceptation of the privacy policy.

9. SOCIAL PLUG-IN
Our webpages may contain Social Networks (i.e. FaceBook.com , managed by Facebook Inc. , 1601 S. California Ave , Palo Alto, CA 94304 , U.S.A. ( “Facebook “).
In case you visit one of our webpages in witch this kind of plug-in is included, your internet browser directly connects with the Social Network and plug-in will be displayed on the screen thanks to the connection with the browser . Before using these plug – in please we invite you to check for Social Network privacy policies, available on their official pages.