Business name: Grand Hotel San Marino Spa
Registered office address: Viale Antonio Onofri, 31 47890 San Marino Città (RSM)
Economic Operator Code: SM 00075
Privacy Policy
GUIDELINES AS PER ART. 13 AND 14 - EU REGULATION 2016/679
Data subjects
Website users
Personal data processing
Hereby are described the website's management procedures www.ghsmgroup.sm whose owner is Grand Hotel San Marino Spa . These guidelines are drafted in accordance with art. 13 of the regulation 2016/679 of the European Parliament and the council of 27 April 2016 on the protection of natural persons with regard to processing of personal data. These guidelines are drafted for www.ghsmgroup.sm website and not for other websites that user may access to through their link.
Data controller
Following the consultation of this website, data referring to identified or identifiable persons can be processed.
Data controller: GHSM GROUP Spa email:info@ghsmgroup.sm , Business name: GHSM GROUP SPA legally registered in Viale Antonio Onofri, 31 – 47890 San Marino Città (RSM) .
Place of data and recipient processing
The processing relating to the web services of this website take place in ITALY as well as in the United Kingdom on the basis of an adequacy decision taken by the European Commission
Type of data processed
Browsing data
Software applications designated for GHSM GOUP Spa website correct functioning acquire certain personal data submitted via safe protocols. Such data are not collected to be associated to identified individuals but may allow to identify users through data processing and crosschecking with other data possessed by third parties. This category of data includes IP addressed, browser's identifier (user agent), URI (Uniform Resource Identifier) addresses to resources requested, the request time, the method used in submitting the request to the server , the numerical code indicating the status of the server response (e.g. successful, unsuccessful) and other parameters relating to the operating system and the user's IT environment. These data are used with the sole purpose of extracting anonymous statistical information on the use of the website to check its correct functioning.
Data voluntarily supplied by the user
To access some of the services available on GHSM GROUP SPA website - the optional and voluntary insertion of certain identification data may be requested (email, name, contacts, and information neeced to provide the required service).
Purposes and lawful basis
Service provision
Personal data supplied by users making use of the services provided by GHSM GROUP SPA (i.e.: through web browsing, form filling for various requests) are used for the sole purpose of carrying out the service or performance required. The lawful basis for the processing is the fulfillment of pre-contractual conditions in order to fulfill your request.
Further communication following a stay
Following the purchase of a stay, GHSM GROUP SPA shall forward to the user further communication even of commercial nature regarding its services. The aforementioned lawful basis of the processing is the legitimate interest of the data controller (cons. 47 GDPR).
Direct marketing
In case of specific consent (by subscribing to the newsletter) GHSM GROUP SPA shall send via email information on new products, promotions and other special offers. The user will be entitled to deactivate the service at every time through the dedicated procedure and/or methods indicated below for the exercise of his/her rights. The aforementioned lawful basis of the processing is the user's consent. Specific explanatory information, if needed, will be published or shown on the website pages used for further and specific services on request.
Data storage period
The data storage period is defined by requested service's purposes and for a further period of 60 months. Should the requested information be part of an online transaction, such data shall be stored for economic or fiscal accounting purposes for a period of 10 years. As regards technical data managed by the website, such as cookies, the storage period is defined according to the cookies technical characteristics as specified in the table "List of cookie". The storage period of personal data will be automatically extended for a further period of 60 months whenever a new consent to the processing of personal data is given and/or every time users access the services provided by entering their own log-in credentials (e.g. Login personal account).
Optionality of data provision
With the exception of what has been specified regarding browsing data, the user is free to supply to GHSM GROUP Spa the personal data requested to benefit from the services provided through the website. Failure to provide data relating to the fields marked by the asterisk (mandatory) will result in the impossibility to access such services.
Processing procedures and safety
The processing of personal data occurrs via information systems designed to guarantee data safety and privacy in compliance with the appropriate safety measures pursuant to art. 32 GDPR, via safe communication protocols with SSL encryption algorithms.
Your personal data will be processed in accordance with the aforementioned laws and privacy obligations in effect. Good practices are defined by the Italian Data Protection Authority issued provision "Guidelines on Marketing and against Spam - July 4, 2013" (published on the Official Gazette no 174 on July 26 2013), Guidelines on Personal Data Processing for online Profiling - March 19 2015 and Guidelines on Automated individual decision-making and Profiling for the purposes of the EU Regulation 2016/679.
Data transfer to non-EU countries and guarantees of adequacy
The service provider responsible for the hosting, maintenance and management of the GHSM GROUP Spa website is Blastness S.p.A., an Italian company which also uses sub-processors who transfer data to the United Kingdom on the basis of an adequacy decision by the European Commission.
Further transfer of data to non-EU countries may occur as a result of the use of the services of Facebook, Google and any other social networks or external data processing providers located in the USA. This data processing is guaranteed by the recipients' adherence to the Data Privacy Framework.
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Recipients
To carry out business activities and to provide support in organising and maintaining said activities, some of the data might be transferred or reported to recipients. Recipients are divided in the following categories: Third parties, processors and sub-processors and authorised personnel under the authority of the controller or the processor.
Third Parties
Natural and legal people, public authorities, services and other entities that do not include the data subject, the data controller or the data processor and sub-processors. In case data processing should concern administrative or accounting purposes, legal obligations, customer management and contracts, the data can be transferred to:
- Companies managing traditional and electronic postal services;
- Companies registering domain names;
- Other subjects, if data transfer is necessary for the fulfilment of the aforementioned purposes or legal obligations.
Data processors and sub-processors
is defined as a natural or legal person, public authority, service or other body which processes personal data on behalf of the data controller Blastness S.p.A. as primary data controller, and other sub-processors providing services for technological infrastructure, connectivity, and hosting services.
- Any other suppliers of IT services necessary for the provision of the service possibly located in the USA with the guarantee of the "Privacy Shield" adequacy agreement
Inside our company
Your data will be processed solely by personnel explicitly authorised by the data controller, assuring use of suitable instruction, training, privacy agreement observation by the following categories:
-Company management.
Data publishing
Your data will not be published in any way.
Rights of data subjects
Data subject (subjects which the data are referring to) can in any moment exercise the rights stated in the Regulation through a dedicated personal area. It is possible to access said area by requesting the link via the dedicated procedure in the footnote of this information note. A further procedure for the exercise of the Regulation rights, in case the user subscribed to the newsletter, can be used via the dedicated link appearing in the footnote of the email received. Specifically, users will be entitled to enforce rights pursuant to art. 15 through art. 23, and in particular: 1.Erasure of all data. 2.rectification/alteration 3.Restriction. 4.Portability. 5.Right to object to automated decision-making (profiling). If needed, report any other request in the note field. The data subjects, should the requirements be met, have the right to issue a claim to the Data Protection Authority in accordance with the necessary procedures. For further information and to exercise these rights recognised by the European regulation you can address the data controller following the aforementioned references.
Data subjects' right exercise
The requests can also be sent using the following contacts:
Data controller: GHSM GROUP Spa – Viale Antonio Onofri, 31 – 47890 San Marino Città (RSM) - email: info@ghsmgroup.sm , Business name: Grand Hotel San Marino
Having read the information note and acquisition of the data subject's consent
The undersigned data subject, having received the information provided by the data controller as per art. 13 and 14 of the GDPR, states he has read the present information note on data processing for service provision and to allow GHSM GROUP Spa to correctly manage and duly process data. Said information note also states the data processor operating on behalf of GHSM GROUP Spa is Blastness Spa .
Consent
As evidence of your explicit and unambiguous consent we will register time, date, IP address and your e-mail. We remind you that you can exercise the aforementioned rights in any moment by clicking on the link located on the footnote of the received messages or by contacting us through our communication channels.
Extended information note on the use of cookies
Extended information note on the use of cookies and pursuant to the measure of the Privacy Authority n. 229/2014, for those interacting with the web services of GHSM GROUP Spa, accessible from the internet addresses www.ghsmgroup.sm . The website of GHSM GROUP Spa uses cookies and similar technologies to guarantee the correct functioning of procedures and enhance user's experiences in online applications. This document provides detailed information on the use of cookies and similar technologies, on how they are used by GHSM GROUP Spa and how to manage them.
Definitions
Cookies are small text strings that websites visited by users sent to their terminal (usually the browser), where they are memorized to be eventually resent to the same website when the same user will visit the website again. Cookies are stored based on the user's preference by the single browser on a specific used device (computer, tablet, smartphone).
Cookie types
Based on the characteristics and use, cookies can be distinguished in different categories:
Fundamental cookies
Cookies which are mandatory to manage log-in and the access to the functions reserved to the website, generally for the updating of pages by web editors. The length of these cookies is strictly limited to the working session (they are deleted once the browser has been closed). Their deactivation affects the use of services accessible from log-in. The public part of website can still be used normally.
Technical cookies (of analysis and performances)
These cookies are used to collect and analyze traffic and the anonymous use of the website. These cookies, without identifying the user, allow, for instance, to detect if the same user returns on the website at a later time. They also allow to monitor the system and enchance performances and usability. Some website pages can www.ghsmgroup.sm memorize the user's preferences relating to the size of the font and the preferred displaying mode (graphich, high contrast or text) in order to access contents. The deactivation of said cookies may be performed without any functionality loss.
Profiling cookies
These are permanent cookies used to identify anonymously and not) the user's preferences and enhance his/her navigation experience.
Length of cookie
Some cookies (session cookies) remain active only until the browser is closed or the log-out command executed. Other cookies "survive" the closing of the browser and are available even in the user's later sessions. These cookies are called persistent and their duration is established by the browser at the time of their creation. Navigation through the website pages www.ghsmgroup.sm users can interact with all the websites managed by third parties that can create or modify profiling or persistent cookies. The temporary storage of every single cookie can be viewed in the table "list of cookies".
Management of cookie
The user can decide whether to accept or reject cookies via the browser settings. The total or partial deactivation of cookies may affect website functionalities but it will not prevent the navigation. The setting can be specifically defined for every website and web-based application. The following are the web resources which illustrate how to proceed for every main browswer: Chrome, Firefox, Internet Explorer, Opera, Safari.
