Privacy Policy

As delegate of the Mima Club Hotel group, with headquarters in Milano Marittima, IX Traversa, 20, al, and Tax Code and VAT number 01039220395 (hereinafter, “Owner”), and as data controller, Hotel Solemare S.a.s. informs you, to Article 13 of EU Regulation no. 2016/679 (hereinafter “GDPR”), that your data will be processed in the following manner and for the following purposes:

The Data Controller processes personal, identifying data (for example, name, surname, company name, address, telephone, e-mail, bank and payment references) subsequently, “personal data” or even “data”) communicated by you in occasion of the conclusion of contracts for the services of the Data Controller.

Your personal data are processed:

A) subject to express consent pursuant to art. 6 lett. b), e) GDPR, for the following Service Purposes:

• respond to your requests for information;
• conclude the contracts for the services of the Data Controller;
• fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with you;
• fulfill the obligations established by law, by a regulation, by community legislation, or by an order of the Authority (such as in the matter of anti-money laundering);
• exercise the rights of the Owner, for example the right of defense in court;

B) subject to your consent pursuant to art. 6 lett. b), e) GDPR), for the following Service Purposes: preparation and sending of estimates.

C) marketing purposes and newsletters.
Subject to your consent, which is optional in itself, the company may process your personal data (email addresses, addresses and telephone number) to send you commercial proposals, new offers and newsletters.
We point out that if you are already our customer, we will be able to send you commercial communications relating to the Owner’s services and products similar to those you have already used, unless you disagree (art. 130 c. 4 Privacy Code).

The processing of your personal data is carried out by means of the operations indicated in art. 4 no. 2) GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper and electronic and/or automated processing.

The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes and in the case of data processing for the purpose of an estimate, the data are kept for 3 years.

For the purposes referred to in point C, the duration is 2 years.

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B)-2C):

• to hotel employees and collaborators, in their capacity as persons in charge and/or internal data processors and/or system administrators;
• to third-party companies or other subjects (as an example, web agency) who carry out outsourced activities on behalf of the Data Controller, in their capacity as external data processors.

Without the need for an express consent art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to supervisory bodies (such as IVASS), judicial authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers.

Your information will not be disseminated.

Personal data is stored on servers located in the EU and on local storage units located within the company, within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses envisaged by the European Commission.

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we will not be able to guarantee you the Services of the art. 2.A).

The provision of data for the purposes referred to in Article 2 B is mandatory. In the absence of the same, we will not be able to carry out the service described in the point in question.

The provision of data for the purposes referred to in art. 2.C) is instead optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, you will continue to be entitled to the Services pursuant to art. 2.A).

In your capacity as an interested party, you have the rights referred to in articles 15 et seq. GDPR and precisely the rights of:

• i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
• ii. obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) of the logic applied in case of treatment carried out with the aid ofelectronic tools; d) of the identification details of the owner, of the managers and of the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as designated representative in the territory of the State, managers or agents;
• iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means manifestly disproportionate to the protected right;
• iv. object, in whole or in part: a) for legitimate reasons, to the processing of your personal data, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and/or by traditional marketing methods by telephone and/or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.

Where applicable, you also have the rights pursuant to articles 16-21 GDPR (Right to rectification, right to be forgotten, right to limitation of treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority.

You can exercise your rights at any time by sending: a registered letter with return receipt at the registered office of the Hotel Solemare S.a.s. di Boni Piero & C., Milano Marittima, IX traversa, 20.

The Data Controller is Hotel Solemare S.a.s. di Boni Piero & C., with headquarters in Milano Marittima, IX traversa, 20.