This page outlines the operational methods of the website regarding the treatment of personal data of users consulting it. This information also complies with article 13 for legislative decree no. 196/2003 – Code for the protection of personal data, for users who interact with the Hotel Michelangelo’s web services, accessible telematically from the address :
http://www.hotel-michelangelo.com, which corresponds to the first page of the official website. This informative note is valid solely for the Hotel Michelangelo website and not for other sites which the user may consult from links.
This informative note is inspired also by Recommendation no. 2/2001 adopted by the European authorities for the protection of personal data, acting as the Group instituted by article 29 of directive no. 95/46/CE, on 17 May 2001, to identify certain minimum criteria for the online collection of personal data, and, specifically, the time and the nature of the information that service providers must supply to users when the latter connect to web pages, regardless of the purpose of the connection.
The Recommendation and a summary of its purposes are available on other pages of this website.
THE “HOLDER” OF DATA PROCESSING
Subsequent to the consultation of this site, data regarding persons identified or identifiable may be processed. The “holder” of this processing is Hotel Michelangelo Srl, with registered office in Milano Marittima, Viale 2 Giugno no. 113, CAP 48015.
THE DATA PROCESSOR
The company VAS sas has been appointed “processor” of the data, in accordance with article 29 of the Code for the protection of personal data, and is responsible for the maintenance of the technical aspects of the site.
LOCATION OF DATA PROCESSING
All data processing linked to web services on this site takes place at the aforementioned premises of the Hotel Michelangelo and is supervised by technical staff of the Office responsible for processing. If necessary, data may be processed by staff of the company responsible for the technical maintenance of the site, VAS sas (the data processor, in accordance with article 29 of the Code for the protection of personal data), at the premises of the company itself or at the premises of advisers to the company.
TYPES OF DATA PROCESSED:
Digital systems and software procedures responsible for the functioning of this website acquire, during their normal operation, certain personal data, whose transmission is inherent in the use of internet communication protocols. This information is not collected in order to associate with identifiable users, but it may, by its very nature, allow the identification of users through processing and association with data held by third parties.
This category of data includes the IP addresses or domain names of computers used by individuals to access the site, addresses in URI (Uniform Resource Identifier) form of services requested, time of request, method used to relay the request to the server, size of the file obtained in response, numerical code indicating the status of the response given by the server (successful, error etc) and other parameters regarding the operating system and the user’s computer use.
This data is used solely to extract anonymous statistical information regarding the use of the site and to check its correct functioning, and is deleted immediately after processing. The data may be used to ascertain responsibility in the case of alleged IT fraud detrimental to the site: excepting this eventuality, data regarding web contact is not retained for more than seven days.
Data provided voluntarily by the user
The optional, explicit and voluntary sending of electronic mail to addresses indicated on this website entails the subsequent acquisition of the sender’s address, necessary to respond to the request, as well as other personal data which may appear in the communication. Specific summarised information will be shown or made available for viewing on the website pages provided for particular optional services.
No users’ personal data is acquired by the site itself.
Cookies are not used for the transmission of information of a personal nature; neither are persistent cookies of any kind used, nor systems for tracing users. The use of session cookies (which are not memorised long-term on the user’s computer and are deleted when the browser closes) is strictly limited to the transmission of session indentifiers (consisting of random numbers generated by the server) necessary to ensure safe and efficient use of the site. Session cookies used on this website do not have recourse to other IT techniques which may potentially prejudice the privacy of users’ navigation of the site and do not allow the acquisition of data which could identify the user.
THE OPTIONAL NATURE OF PROVIDING DATA
In addition to the rules governing navigation data, the user is free to provide personal data included in Hotel Michelangelo enquiry forms or otherwise indicated in Hotel Michelangelo contacts, to request the newsletter, informative material or other communications. Failure to provide this information may make it impossible to comply with the request.
METHODS OF DATA PROCESSING
Personal data is processed using automated systems for the time strictly necessary to satisfy the purposes for which it has been collected. Specific security measures are in place to prevent the loss, illicit or incorrect use of data and unauthorised access.
THE RIGHTS OF THE USER
Individuals who provide personal data have the right at any time to obtain confirmation of its existence or otherwise and to know the content and origin of the data, check its correctness or ask for it to be supplemented, updated or rectified, in accordance with article 7 of the Code for the protection of personal data.
In accordance with the same article, the user has the right to delete, anonymise or block data processed in violation of the law, and to refuse processing of their data for legitimate reasons.
Requests should be addressed:
– by email to the address: firstname.lastname@example.org
-or by post, to Hotel Michelangelo, at Viale 2 Giugno no. 113, Milano Marittima (RA), CAP 48015
ART. 13 LEGISLATIVE DECREE 196/2003 (Informative note)
l. The interested party or person whose data is collected is previously informed verbally or in writing about:
a) the purposes and processing methods to which the data is subject;
b) the obligatory or optional nature of data collection;
c) the consequences of any refusal to respond;
d) the individuals or categories of individuals to whom personal data may be communicated or who may come across it during their duties as handlers responsible for or transmitters of the data;
e) the rights stipulated in article 7;
f) the identity of the data holder, and, if applicable, their state representative, in accordance with article 5, and the data processor. When the holder has appointed several processors, at least one of these must be indicated, together with the website or the means by which it is possible to easily find the updated list of processors. When one processor has been appointed as responsible for user feedback, in the event of article 7, this processor must be named.
2. The informative note stated in the previous clause also contains elements stipulated by specific regulations of this code and may not include elements already known to the person who provides the data or whose knowledge may hamper the execution, by public bodies, of inspection or checking operations carried out for state defence purposes, or the prevention, investigation or repression of crime.
3. The authorities may identify, with due process, simplified methods for handling information provided specifically by telephone assistance services and public information.
4. If the personal data is not collected from the interested party, the informative note referred to in clause 1, including the categories of data processed, dates from the interested party’s action of registering their data or, when their communication is required, no later than the first communication.
5. the regulation stipulated in clause 4 is not applicable when:
a) data is processed in compliance with a legal obligation, requirement or European law;
b) data is processed for the purposes of an investigation such as outlined in clause 1. 7 December 2000 no. 397 or, otherwise, to uphold and defend a right in a court of law, as long as the data is used exclusively for this purpose and for the time strictly necessary for this end.
c) the informative note entails the use of methods which, in the view of the authorities, in their requirement for appropriate measures, declare to be manifestly disproportionate to the right being upheld, or when considered impossible.
ART. 7 LEGISLATIVE DECREE 196/2003 (The right to access personal data and other rights)
1. The interested party has the right to obtain confirmation of the existence or otherwise of personal data concerning them, even if not yet registered, and whether the data is communicated in intelligible form.
2. The interested party has the right to obtain information of:
the origins of the personal data;
the purposes and methods of processing;
the logic applied in the case of processing carried out by electronic tools.
the identity of the data holder, processor and their designated representative, in accordance with article 5, clause 2;
the individuals or categories of individuals to whom personal data may be communicated or who may come across it in the course of their duties as designated representative for their area of responsibility or charge.
3. The interested party has the right to obtain:
the updating, rectification or, when applicable, the supplementing of the data;
the deletion, anonymisation or blocking of data processed in violation of the law, including instances where it is not necessary to hold data for the purposes for which it was collected and subsequently processed;
confirmation that the operations referred to in a) and b) above, and the related content, have been made known by those to whom the data has been communicated or transmitted, except in cases where such an action is impossible or entails the use of means manifestly disproportionate to the right in question.
4. The interested party has the right to oppose, wholly or partially:
for legitimate reasons, the processing of personal data concerning them, even though it may be pertinent to the purpose of collection;
the processing of data regarding them for the purposes of sending advertising or direct sales material or for market research or commercial communication in general.