This information document (the Document) is issued pursuant to Reg.(UE) 2016/679 of 27 April 2016 related on the protection of natural persons with respect to the processing of personal data (GDPR), it provides information on the processing of the personal data collected by Bluserena SpA (the Company) and describes the way they are used.
The Document is an integration to any other information received in other circumstances and provides important information on the following:
- PROCESSING OF PERSONAL DATA
- COLLECTED PERSONAL DATA
- PURPOSE OF THE PROCESSING OF PERSONAL DATA
- COMMUNICATION AND DISCLOSURE OF PERSONAL DATA
- PROTECTION OF THE PRIVACY OF MINORS
- SAFETY AND CONFIDENTIALITY OF PERSONAL DATA
- SOCIAL MEDIA
- RIGHTS OF THE INTERESTED PARTY
- DATA STORAGE
- CONTROLLER – DATA PROTECTION OFFICER – CONTACT DETAILS OF THE COMPANY
- UPDATES OF THIS DOCUMENT - COMMUNICATIONS
- COOKIE AND SIMILAR PROCESSES POLICY
1. PROCESSING OF PERSONAL DATA
In this Document, the term “Personal Data” is used with reference to any information that allows the Company to identify you (or to identify any third party whose data are provided by you), directly or indirectly, including any information related to the purchase of services, or that you choose to provide to or share with the Company during the use of the Websites or at the holiday facilities managed by (the Facilities). Personal Data will be processed in compliance with the GDPR. The Company reserves the right to further process the data as required by the law, i.e. within criminal proceedings or investigations or any other kind of proceedings.
2. COLLECTED PERSONAL DATA
Origin of the data, the Company only collects personal data that you provide of your own free will, for example:
asking for a quote, asking for information, contacting the Company by sending a comment or a question, confirming or finalising your reservation, registering to the newsletter by e-mail, sending your CV through the relevant form;
E-mail, texts and other electronic messages
Exchanging communications with the Company.
Asking for assistance, informing about special needs or complaining about anomalies in the services;
Filling in the documents provided when checking in, interacting with the staff, complaining about anomalies on the services or giving feedback on them, requiring or purchasing services;
Registering in the Bluserena Più Club;
Asking to connect to the Wi-Fi network of the facility;
Taking part in events, surveys, market research activites and other promotions – also online – reserved to Bluserena customers;
Close-circuit TV system at the holiday facility
If you provide the Company with personal data of third parties (e.g., relatives, other customers or potential customers), you should make sure that they are informed and have authorized the use of their data as described in this Document.
Types of data
The Company can collect and use several types of personal data according to the specific purposes as described below:
a. Personal information such as name, surname, age/date of birth, place of birth, identity document number;
b. Contact information such as home address, e-mail address, telephone number, mobile number;
c. Payment information, such as payment method (credit or debit card, bank transfer, etc.) and relevant details;
d. Information related to the purchased services, such as facility and date of stay, detail of the reserved services and related amounts, feedback on the services, complaints, refunds, travel companions or other information related to the requested services and that can be collected in compliance with the current laws;
e. Habits and profile, such as data related to the reserved services (reservations history, including facility, services and related amounts), information on activities and initiatives related to the management of the relationship with the customers (date and type of actions taken or to be taken and their outcome), notes on purchasing habits or special needs, other information that can be collected in compliance with the current laws;
f. Information related to family and members of the same reservation, such as number of children, dates of birth and other data that can be collected in compliance with the current laws;
g. Footage shot within the holiday facility by the close-circuit TV system
h. When sending a CV: personal data, contact details, curriculum vitae, other data provided of your free will, source of information about the job offer, special data provided (e.g., status of protected person, data that can disclose the health status, etc.);
i. In case you use our medical services: data related to your health status.
3. PURPOSES OF THE PROCESSING OF PERSONAL DATA
According to the specific circumstances of your interaction with the Company, your personal data may be used for the following purposes.
3.1 Reservation of the stay and delivery of the reserved services
The personal data provided by you or collected during the reservation, either online or interacting with our Booking Office or with your Travel Agent, or at the facility of your stay – i.e. basic personal data, contact information, data related to the reserved services, tax data, payment details, special requests, feedback on the services and any other data required for the delivery of the reserved services – will be used to comply with the current legal, accounting and tax obligations and for purposes related to the mutual obligations resulting from the contract (e.g., to assist you in your reservations, to provide the requested services, to meet your needs during your stay, to process your feedback, to arrange a detailed bill, etc.) or to meet, before executing the contract, your specific requests.
The processing of your personal data for these purposes does not need your consent, as it is necessary to comply with legal requirements and to execute the contract; any denial might make it impossible to have you as our guest (e.g., with respect to the data on your identity document) or to provide the requested services.
3.2 Specific purposes for which you provided the data
Your personal data provided by you or collected when you require a specific services (e.g., stating special needs, asking for information, subscribing to our newsletter, registering to our Bluserena Più Club, filing complaints) – such as personal and contact information, and data required to follow up your request – will be used for:
a. Providing the requested services (e.g., answering a question or contact request, providing the requested services, assisting and managing complaints);
b. Processing the subscription to our newsletter, if you subscribed;
c. Processing the registration in Bluserena Più Club, if you registered;
d. Allowing to use the Wi-Fi connection:
e. Providing medical assistance
In these cases, it is necessary to provide your personal data for the above mentioned purposes and any denial would make it impossible to fulfil your request.
3.3 For marketing purposes
Your personal and contact information such as name, surname, address, e-mail address, landline and mobile phone numbers, facility and year of stay, can be used to call you and to send you, also automatically, information, greetings, and regular documentation – also promotional material, published and sent by third parties (e.g., periodical publications) – on the hotels of the Bluserena Group, in order to keep you informed on the prices, services and offers reserved to you or the others members of your stay.
The consent for this use of your personal data is optional; if denied, we will not be able to provide you with commercial information.
3.4 For performing messaging services and forwarding phone calls to you
Your personal data (name and surname), the dates of start and end of your stay, the room number, your presence at the facility, your mobile number will be used to deliver messages from third parties during your stay, putting phone calls from outside through to your room, informing third parties who wish to contact you of your presence in the facility.
The consent for this use of your personal data is optional; if denied, we will not be able to collect messages or calls addressed to you and to inform third parties about your presence in the hotel. This use will end at the end of the stay.
3.5 For profiling activities aimed at making personalised offers
Your personal data provided upon reservation and/or check-in, such as personal data, home address and contact information, selection of stay (e.g., period, facility, type of holiday reserved), those that we can collect during your stay with respect to the services reserved or any specific requests as well as your feedback can be used – with your prior, explicit and specific consent – for profiling activities aimed at making personalised offers and initiatives based on your interests, as well as personalising our services according to your preferences.
The consent for the profiling activities is optional; its denial does not prevent the normal enjoyment of all our services, except that our Company cannot inform you – by phone, text, e-mail or mail – about offers or promotions for services based on your profile.
3.6 For safety purposes
The facilities are monitored by a close-circuit TV system for protecting the safety of our customers, our staff and our company assets.
3.7 For recruiting and assessing the staff
The personal data provided online through the specific form in the “Work with us” area will be processed for the recruitment and assessment of the staff, with the aim of establishing a work relationship and to assess the effectiveness of the communication channels for our job offers (with respect to such channels the data will be processed anonymously). Therefore, you can be contacted by phone, e-mail or text message or you can receive communications and information about job openings by Bluserena according to your profile.
The data marked with a star in the data collection form are required; if they are missing, wrong or partial, your CV cannot be filed in Bluserena SpA data base. All other personal data are optional; if they are missing, wrong or partial, we may not be able to perform our recruitment activity at our best.
4. COMMUNICATION AND DISCLOSURE OF PERSONAL DATA
Your personal data will not be disclosed, unless required by the law or expressly authorised, and can be communicated to the companies of the Carlo Maresca SpA Group and relevant officers, to companies, bodies and subjects (e.g., external professionals, public authorities and private companies, banks, insurance companies, trade associations, etc.) with which Bluserena S.p.A. has relationships for the management of its services (e.g., administration and accounting services, shuttle services, e-mail and text messages management services, mail shipping services, marketing, web-marketing and customer care support services, etc.).
Such companies, bodies and organizations will only receive the personal data required to performed the relevant services and will not be authorised to use them for any other purpose.
With specific reference to the recruitment and assessment of staff, the data will not be subject to disclosure or to automated decision-making processes and can only be communicated to the companies of the Carlo Maresca SpA Group and their officers, who can use them only for the above mentioned purposes.
In the event of corporate or assets transactions (such as, but not limited to: mergers or takeovers, company reorganizations or liquidation, establishment or termination of a lease of a company branch, etc), the collected data might be one of the transferred assets and, as allowed by the law and according to the interest of the receiving company, made available to the receiver if the corporate object allows it.
The Company can also provide your personal data to third parties if required by the current laws (e.g., public safety authorities, local authorities), in case of legal proceedings, as a response to a request by the law enforcement authorities based on legitimate reasons, to protect the rights, the privacy, the safety or the property of the Company or of the public.
Moreover, as allowed by the law, the Company can provide your personal data to third parties in the event of complaints about the use of the Websites or the wi-fi connection, if necessary for investigating, preventing or taking measures against illegal activities and suspected fraud.
The full list of the people in charge of processing the personal data and the third parties who can receive them can be requested to the contact people indicated in this Document.
5. PROTECTION OF THE PRIVACY OF MINORS
The Websites are addressed to the general public, however its services are aimed at people aged 18 or more. The Company does not deliberately collect, use and disclose personal data provided by people aged less than 18 online or at our holiday facilities, unless required by the law. If you are under 18, please do not make online reservations and ask an adult (i.e. your parents or guardian) to perform the necessary procedures.
Access to personal data is only allowed to Bluserena SpA employees and collaborators in charge of their processing, in compliance with the technical and organizational measures implemented by the Company to ensure the appropriate processing of your data, in accordance with the actual need to know such information and using multi-level control tools for the access.
7. SAFETY AND CONFIDENTIALITY OF THE PERSONAL DATA
Your personal data will be processed in accordance with the principles of correctness, lawfulness and transparency, both on electronic and paper support and in a way to ensure the appropriate safety of your personal data from unauthorized or unlawful uses as well as from loss, destruction or accidental damage, by means of appropriate technical and organizational measures.
In the unlikely event that the Company believes that the safety of your personal data was or can be compromised, you will be informed according to the methods required by the current laws and using the appropriate means of communication (by providing the Company with your e-mail address, you consent to receive such communications though that e-mail address).
8. SOCIAL MEDIA
9. RIGHTS OF THE INTERESTED PARTY
At any time and free of charge, by sending an e-mail to email@example.com, you can ask to access, correct or delete your data or limit their processing; you can also receive your electronic personal data in a normally used structured format, which can be mechanically read and transmitted to another data processing controller (data portability).
The requests for data deletion are subject to the current legal obligations about document storage for Companies. You have also the right to revoke your consent at any time, without prejudice to the lawfulness of the processing based on your consent granted before.
Also with specific reference only to profiling, you can exercise all the rights expressed in this Document, objecting any further profiling of your data. If you believe there is a problem in the way your personal data are managed, you can file a complaint with the Garante per la Protezione dei dati personali (Data Protection Commissioner) as appointed authority according to the current procedures.
10. DATA STORAGE
Considering the purposes for which they were collected, the legal obligations and the protection of the rights of the party, these data will be stored for a period not exceeding the necessary time (e.g., 10 years for accounting purposes, for the duration of the storage obligation for tax purposes, 90 days for the credit card number for the payment of extras, or, as regards the subscription to the newsletter or registration in the BluserenaPiù Club, until the consent for that purpose is revoked and anyway for a period of time in compliance with the current law and, upon expiration of such period of time, they will be deleted or made permanently anonymous), or to allow the Company to keep evidence of the mutual rights and obligations.
With specific reference to the closed-circuit TV system, please be aware that the personal images will be stored for not more than 24 hours, unless otherwise provided by the current laws, and they cannot be disclosed or communicated to third parties, except for police or justice purposes.
Please be informed that the data collected for commercial profiling purposes as described above will be stored for no more than 2 years; at the end of such period of time, they will be automatically deleted or made permanently anonymous, unless otherwise required by the current laws. With specific reference to the staff recruitment and assessment activities, the provided data will be stored for the period of time that is necessary for the above mentioned purposes, not exceeding 3 years anyway, during which you can update the CV already submitted.
11. CONTROLLER – DATA PROTECTION OFFICER – CONTACT DETAILS OF THE COMPANY
For any other information, please contact the Controller, Bluserena S.p.A., Via Caravaggio 125 - 65125 Pescara (PE) – Italy, e-mail: firstname.lastname@example.org or the Data Protection Officer sending an e-mail to: email@example.com or writing to: Responsabile della protezione dei dati – Via Caravaggio 125 – 65125 Pescara – Italy.
You can contact the above mentioned subjects to exercise your rights and in particular to access your personal data, ask for their correction, deletion or portability, to limit their use or revoke your consent. When contacting the Company, please make sure you indicate your full name, e-mail address, home address and/or phone number(s) so that your request can be appropriately processed.
12. UPDATES OF THIS DOCUMENT - COMMUNICATIONS
The Company, at its own discretion, reserves the right to change, modify, add or remove parts of this Document at any time, publishing the reviewed version on this page of the Website and updating the date of the “last version” indicated below.
In some cases, the Company can provide further communications related to significant changes to this Document by publishing a notice on the home page of this Website. If the changes involve new or further processing and in the cases provided for by the current laws, your data will not be subject to the further processing without your explicit consent.
This document is effective as of 17 July 2018.
13. COOKIE AND SIMILAR PROCESSES POLICY
While browsing our websites, Bluserena SpA, with headquarters in Via Caravaggio 25 – Pescara – Italy, will place some technical and analytics cookies in your browser in order to make the services simple and efficient for its users and for purposes related to a better management of the website. Bluserena SpA will control the processing of all the personal data related to the use of the cookies installed. Moreover, through the same website, some third parties might install other cookies on your browser.
Each third party that, with your prior consent, will install its cookies on your browser, will control the processing of all the personal data related to the use of the cookies installed. Please find below some useful information in order to decide whether to provide your consent to the installation of cookies with profiling purposes, as well as the necessary tools to allow you to express your consent to our Company and third parties that use these pages for the installation of the cookies.
What are cookie?
Cookies are small text files that are placed in your browser, used to memorize information on your browsing activity, your preferences or the manage the access to the reserved areas on the website. You can find more general information on cookies here: https://en.wikipedia.org/wiki/HTTP_cookie
Cookies are useful to improve our services. Some are strictly necessary for the operation of the website and your consent is not required for their installation; on the other hand, others – offering a better experience and use of the website functions and content – require the user’s consent before installation.
Technical cookies not requiring consent
While browsing on its websites, Bluserena Spa will install on your device – and particularly on your browser – some technical cookies that allow to memorize some useful data that are used, for example, for:
- Recognising that you have already visited our website through your browser;
- Registering any viewing preference set during the navigation, such as the language.
The use of these cookies and the processing of your data related to it are necessary to allow us to provide you with the contents published on our website in an effective and user-friendly way, and it does not have any other purpose. The installation of these cookies and the relevant processing does not require your consent in compliance with the current laws.
Moreover, Bluserena SpA will install or will let third parties install on your device – and in particular on your browser – some cookies that are necessary to collect aggregate information with low identification potential related to the navigation on websites managed by Bluserena SpA.
These are, in particular, the cookies related to the statistical analysis service Google Analytics, an analysis services that is offered by Google, Inc. ("Google") free of charge. Google Analytics uses "cookies” to analyse how users use the website. All information generated by the cookie on the use of the website is transferred and stored at the servers of Google in the USA. Google will use this information in order to examine the use of the website, make reports on the activities of the website for its operators and provide other services related to the activities of the website and the use of the internet. Google can also transfer this information to third parties if required by the law or if these third parties process such information on its behalf. The service is used in _anonymizehelp mode, which allows to hide the IP addresses of those who visit our website.
You can stop Google from collecting the data (including your IP address) through cookies and the relevant data processing by downloading and installing the following plug-in here: http://tools.google.com/dlpage/gaoptout?hl=it
Please find more information on Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
According to the current laws, your consent is not required for these cookies and the relevant data processing.
Cookie that require your consent
These include the so-called profiling cookies, which collect information on your interests and habits in order to provide your with commercial communications that are based or consistent with your interests. These cookies might be installed if you interact with third-party services and plug-ins, as described below.
Bluserena SpA does not use profiling cookies, however such cookies might be installed on your device by third parties through the services and plug-ins used by Bluserena SpA. In particular, these are the cookies of the social media functions (Facebook, Juicer) such as login, sharing, commenting. If you wish that these cookies are not installed, please follow the instructions that you can find in the section “How to manage the cookies on your computer”, related to the management of cookies in the browser. Please find below the links to the Privacy Policies of these websites, where you can have more information on how they process your personal data:
For the processing of personal data that, with your consent, third parties unknown to Bluserena SpA might perform through the cookies, go to this link and use the service to customise your preferences: http://www.youronlinechoices.com/it/le-tue-scelte
How to manage cookies on your computer
If you wish to manage the cookies directly from your browser, delete any cookies already on your computer or enable/disable cookies, please follow the instructions provided below:
Cookies installed by social media plug-ins
On its websites, Bluserena SpA uses social media plug-ins (“plug-ins”), in order to offer some content sharing functions on social networks like Facebook, Google +.
Facebook is run by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). Facebook plug-ins are characterized by the Facebook logo.
Google + is run by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
The plug-in is clearly visible on the website by means of the added component “+1” on white or coloured background. This means that when you visit the bluserena.it website, your browser creates a direct connection to the social network servers. The content of the plug-in is transferred from the social network directly to your browser and connected to the website.
Thanks to the plug-in, the social network is informed that you are visiting the bluserena.it website and, if logged in to the social network, you can associate your visit to your account. If you interact with the plug-ins, for example if you log in, if you press the “Like” button, if you vote, the relevant information is transferred from your browser directly to the social network and stored. These operations might involve the installation of some cookies on your browser.
If you wish that the social network does not collect your data through our website, just log out of the social network before visiting https://www.bluserena.it/en/home.