This Policy (made in accordance with European Regulation 679/2016) is issued with reference to personal data communicated or otherwise collected during navigation on the website www.popiliaresort.it The policy, however, does not cover sites, pages or online services that can be reached through hypertext links, referring to resources outside the domain of the data controllers.
The data controller is the company Popilia S.r.l. a single member, based Località Cutà, 89843 Maierato (VV). The company Popilia S.r.l. a sole shareholder belongs to the "Callipo Group" and is subject to the management and coordination activities exercised pursuant to art. 2359 c.c. by the company Callipo Group S.r.l, with registered office in Via Riviera Prangi, 156 - 89812 Pizzo (VV), which will process personal data as a co-processor according to the definition in Article 4 point 7) of Regulation 679/2016, having to be understood as "two or more companies that jointly determine the purposes and means of processing" as provided for in Article 26 of the Regulation.
The Joint Data Controllers (hereinafter "The Companies") have entered into a co-ownership agreement by which they have undertaken to:
jointly determine certain purposes and methods of personal data processing;
jointly determine, in a clear and transparent manner, the procedures for providing timely feedback should the data subject wish to exercise his or her rights, as provided for in Articles 15, 16, 17, 18, 19, 20 and 21 of the Regulations
jointly define this notice, indicating all the information required by the Regulations.
Personal data processed.
The website www.popilaresort.it processes the following personal data:
common identity data and sensitive data, such as: name and surname of the user who makes a reservation, number and identity of guests -including any minors-, period of stay, stay preferences, also of a sensitive nature, details of the identity card or other suitable document attesting to the identity of the person;
common contact data, such as: e-mail address and telephone number (reservation, newsletter subscription, information request);
Common payment data, such as tax code and VAT number, credit card numbers and/or other electronic payment instruments (reservation);
Social media data (Facebook, Twitter, LinkedIn; Pinterest; Google).
It should be noted that, within the facilities, there is a video surveillance system due to which the processing of personal data will also involve images.
Legal basis, purpose of processing and nature of data provision.
Personal data will be collected and processed for the following purposes and legal basis:
Personal data are provided voluntarily and are aimed at finalizing the reservation at the Popilia Resort facility. The data necessary for the management of the reservation are indicated with an asterisk symbol ("*"). The provision of identity card details, on the other hand, is mandatory under Article 109 R.D. 773/1931. Failure to provide this data results in the impossibility of establishing or continuing the contractual relationship.
Data regarding stay preferences, on the other hand, are processed in order to offer a better level of hospitality at the facility. They are not necessary data and failure to provide them results in the impossibility of providing the specific services requested.
The legal bases for processing are legal obligation and the execution of the contract.
Request for information.
Personal data will be used to inform you of the progress of your reservations and to process any requests regarding the site as well as the services deliverable through it.
The provision of such data is free and optional. Failure to provide it results in the impossibility of processing the user's requests. The legal basis for processing is the execution of the contract or pre-contractual measures.
Subscription to the newsletter service.
Personal data provided when subscribing to the newsletter will be processed for the periodic sending of commercial and advertising communications through the e-mail address relating to the products and services of the Callipo Group, in particular of the following Companies: Giacinto Callipo Conserve Alimentari S.p.a., Popilia S.r.l. a socio unico, Callipo Sport S.r.l., Gelateria Callipo S.r.l.
The provision of such data is free and optional. Failure to give consent will not affect any contract that may have been concluded or any pre-contractual measures in progress, but will only have the effect of preventing the Contractors from sending advertising messages. The legal basis for the processing is the consent of the data subject.
Personal information, including preferences expressed during the stay, will be entered into a cloud-based CRM in order to optimize customer loyalty operations, launch marketing campaigns, via email or text message, and then test their effectiveness. The legal basis for the processing is the consent of the data subject. Failure to give consent will not affect any contract that may have been concluded or any pre-contractual measures in progress, but will only have the effect of preventing the Contractors from sending advertising messages.
Video surveillance within the facility.
Finally, the Holders make use of a video surveillance system for which no prior consent is required. Video surveillance is based on the legitimate interest of the Holders to pursue purposes of protection of people and property against possible attacks, theft, robbery, damage, vandalism, fire prevention.
Collection and publication of user-generated content
Personal data will be used to ensure the collection and publication of user-generated content. This activity allows the use of publications of images, videos, reviews, ratings and other content that the user can freely decide to share with the brand or publish on the site, as well as on any other media used (e.g., social media). However, such processing is subject to the consent of the data subject.
Method of data processing.
The processing of personal data is carried out in accordance with the requirements of the Regulations and any other applicable regulations and is performed with the help of electronic, automated, manual means. Data are also processed through a C.R.M. module, called Scrigno PMS, of the Company GP Dati S.p.a. - Zucchetti Group.
Video surveillance, on the other hand, is carried out avoiding surrounding and particular irrelevant places.
The Data Controller will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing.
The information collected is used in a manner that is lawful, relevant and not excessive in relation to the purposes pursued.
Categories of subjects to whom the data may be communicated.
Personal data related to bookings, information requests, registration to the newsletter service and browsing will be processed only by authorized personnel, who may use it for the exclusive purposes indicated in this policy. Such data may also be processed by technicians external to the corporate organization, in connection only with the management of the software used, subject to appropriate assignment given in writing.
Personal data collected for contractual purposes or for legal obligations may be communicated to accountants, public bodies (Internal Revenue Agency, Tax Offices, Police Headquarters), banking institutions, insurance companies and, where necessary, to lawyers. In all these cases, third parties carry out processing as autonomous data controllers who carry out separate processing, however strictly limited to contractual and/or pre-contractual purposes.
Browsing data will be disclosed to Google and the multinationals that manage the social platforms accessible through plug-ins on our site.
In addition, in the event of overbooking (which occurs when the number of customers, with regular reservations, exceeds the number of places available at the facility), the Contractors will be obligated to secure alternative accommodation in the immediate area. In this specific case, the Co-owners will transfer the personal data acquired with the reservation to another manager, who will carry out data processing independently.
Browsing data will be disclosed to Google and the multinational companies that manage the social platforms accessible through plug-ins on our site.
Period of data retention.
Reservation data: personal data will be processed for the time necessary to fulfill contractual and/or pre-contractual purposes, and in any case for no longer than 10 years from the conclusion of the contract, as established by the provisions of Article 2220 of the Civil Code, without prejudice to any delayed payment of fees that would justify its extension,
Personal data entered in the C.R.M.: will be processed for a period not exceeding 12 months.
Inquiry handling data: personal data will be kept for the time strictly necessary to handle your possible inquiries or to forward the information you need. At the end of these operations, the data will be deleted.
Registration for the newsletter service: personal data will be kept for two years, after which it will be deleted from all our servers and databases. To stop receiving the newsletter, the data subject can enter their e-mail address in the "Unsubscribe" form.
Browsing data: the duration is variable and is indicated on web pages accessible through hyperlinks
Collection and publication of user-generated content: the duration is until consent for this purpose is revoked and/or two years have passed since the last interaction with the Company in relation to the brand.
Retention of video surveillance data, on the other hand, is limited to twenty-four hours after collection.
Rights of the data subject.
At any time, the data subject has the right to access and rectify personal data. He or she also has the right to request deletion, restriction and opposition to the processing of personal data.
He or she may also request a digital file of his or her personal data (data portability).
He or she may revoke the consent given at any time.
A data subject who believes that the processing of personal data is taking place in violation of the provisions of the Regulation has the right to lodge a complaint with the Guarantor, as provided for in Article 77 of the Regulation itself, or to take the matter to the appropriate courts (Article 79 of the Regulation).
To consult the full text of the rights recognized by the European Regulation (Articles 15-21), you can visit the following webpage.
To exercise the above rights, the interested party may send an e-mail to email@example.com or write to Gruppo Callipo - Privacy Office - S.S. 110 km 1.6 - 89843 Maierato - Tel 0963 99623254 - Fax 0963 9962145.
The Data Controllers