Privacy conditions

PRIVACY POLICY

(pursuant to Articles 13 and 14 of Regulation (EU) 2016/679)

This Privacy Policy describes how the website manages the processing of personal data of users who consult it. This notice is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (hereinafter the "GDPR") to those who interact with the web services of Anita Villas S.r.l. (hereinafter also referred to as the "Company"), accessible electronically through the website AnitaVillas.com, corresponding to the homepage of the website owned by the Company. This notice applies exclusively to the aforementioned Company website and not to any other websites that may be consulted by users through links contained therein.
The Company recognises the importance of protecting personal data and considers such protection one of the primary objectives of its business activities. Therefore, before providing us with your personal data, as a data subject, we kindly ask you to read this Privacy Policy carefully.

Data Controller
The Data Controller is Anita Villas S.r.l., Via Vittorio Emanuele 1 – 61040 Mondavio (PU), Italy, VAT No. 02828750410. You may contact the Data Controller at: info@anitavillas.it

Types of Data Processed
Following consultation of and interaction with the services available on this website, personal data relating to identified or identifiable individuals may be processed, such as first name, surname, identification number, location data, an online identifier, a photograph or "one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity" of the individual.

Browsing Data
The IT systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This category of data includes IP addresses or domain names of the computers and devices used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters relating to the user's operating system and IT environment.

Such data, which are necessary for the use of web services, are also processed for the purposes of obtaining statistical information on the use of the services (most visited pages, number of visitors by time slot or day, geographical areas of origin, etc.) and checking the proper functioning of the services offered. Browsing data are retained for no longer than seven days and are deleted immediately after aggregation (except where further retention may be necessary for the investigation of criminal offences by the judicial authorities).

Data Voluntarily Provided by the User
The Company processes the data provided when you purchase a stay, as well as the personal data necessary to conclude and perform your booking. Depending on the booking, we may also request your residential address, telephone number, payment details, date of birth, the names of any other persons travelling with you and preferences relating to the stay (for example dietary preferences and mobility restrictions). To contact our customer service, you may provide communications and contact details through which we can respond to your requests, such as email address, telephone number, Skype account, etc. We may also collect information through reviews you submit, including the displayed name and avatar if you choose one. If you make a booking on behalf of a third party, personal data relating to that individual and any additional travellers must be provided during the booking process. In such circumstances, it will be your responsibility to ensure that the persons concerned are aware of this and have understood and accepted the manner in which the Company uses their information (as described in this Privacy Policy).

Following a booking made through our website, we process your personal data in order to provide and optimise the service, including payment processing and fulfilment. Where payment is made by credit card, we receive the payment ID and the last four digits of the credit card number from our payment service provider. The personal data necessary for payment processing are collected directly by the payment service provider. All data available to us are stored and verified, and we also review all previous orders made through your customer account. Such data may be modified at any time.

The Company also processes personal, tax and contact data, including email addresses, and any other data provided to the Data Controller:

when registering on AnitaVillas.com for the purpose of booking a stay, as well as when completing any data collection forms;
when sending communications to the Company through the methods provided on the Contacts page of the website;
when subscribing to our newsletter service. We offer all users the opportunity to receive our newsletter. To activate the service, it is necessary to select the relevant option and enter an email address in the designated section. Users may withdraw their consent at any time by clicking the "Unsubscribe" link included in each newsletter;
information relating to your travel habits and preferences expressed while browsing the website, including through cookies, and/or inferred from offers selected and/or purchased through our website.

Your personal data will be processed by the Company in accordance with the GDPR, applicable national legislation and any provisions issued by the competent supervisory authority (Italian Data Protection Authority), where applicable.

Cookies
For information regarding cookies used on AnitaVillas.com, please refer to the dedicated Cookie Policy.

Purposes of Processing
Personal data collected through AnitaVillas.com are collected and processed exclusively for the following purposes:

if you are a customer or prospective customer, to provide and perform the requested services, including the completion of accommodation bookings, and to manage the relationship you intend to establish with the Company or that already exists between you and the Company;
if you are a property provider or a prospective property provider using or wishing to use the AnitaVillas.com platform to rent out your property, to provide and perform the requested services and to manage the relationship you intend to establish with the Company or that already exists between you and the Company;
for administrative purposes connected with the fulfilment of contractual obligations, compliance with legal obligations such as accounting and tax obligations, responding to requests from judicial authorities or complying with legal provisions applicable to the Data Controller;
for legal purposes, including the management and resolution of legal disputes, governmental investigations and compliance reviews, enforcement of the terms of use of the online booking service, or compliance with legitimate requests from public authorities;
to communicate with you and provide assistance according to your chosen contact method, including email, post, telephone or SMS. We use the data to manage communications you send to our Company, in order to:
– respond to and manage your requests and the requests of the Travel Provider you have booked;
– invite you to complete a booking if you have left the website without finalising it;
– send administrative communications and/or security alerts;
– invite you to leave a review;
subject to your explicit consent, to send promotional messages following activation of the newsletter service. The Company informs you that you may unsubscribe from the newsletter service at any time by sending a communication to info@anitavillas.it or by clicking the link included in promotional emails;
subject to your explicit consent, to send promotional communications and commercial offers by email, SMS, or through the use of social media, social chat and/or to carry out market research and customer satisfaction surveys. The Company informs you that you may object to this purpose at any time by sending an email to info@anitavillas.it;
subject to your explicit consent, the Company will carry out analysis and profiling activities based on the data and purchasing preferences you have provided, through the inclusion of your data in our CRM system, in order to analyse your travel habits and preferences and send you personalised promotional communications (by post, email, telephone through an operator, SMS, social media and social chat). Based on the information shared, we may also display personalised offers through third-party websites/apps (including social media sites). Profiling consists of analysing your habits and consumption choices and creating a profile using the personal data provided to the Company in combination with information and preferences expressed through the use of AnitaVillas.com, in order to send personalised commercial communications. Profiling activities will have no effects on you other than the creation and communication of personalised promotional offers. The Company informs you that you may object to the above purposes at any time by sending an email to info@anitavillas.it;
to improve our services. For this purpose, we also use personal data for analytical purposes in order to improve services and enhance the user experience. Data may also be used for testing, troubleshooting and improving the functionality and quality of our services. The main objective is to optimise and personalise our online platform according to your needs, making it easier and more enjoyable to use. We undertake to use pseudonymised data exclusively for analytical purposes.

Nature of Data Provision
The provision of data in relation to the Processing Purposes referred to under letters a., b., c. and d. is mandatory in order to perform the contract, specifically to complete and administer your accommodation booking. Failure to provide such data will make it impossible for the Company to fulfil its contractual obligations.
The provision of personal data for the purposes referred to under points e., f. and g. is optional and their use is subject to the granting of explicit consent. With regard to the purposes referred to under letter g., the Company relies on its legitimate business interest in providing its services, preventing fraud and improving its services. In this respect, the Company has carried out a balancing test between your rights and interests in the protection of your personal data and the rights and interests of the Company or the relevant third party.

Methods of Processing
Personal data will be processed by the Company, its authorised personnel and third parties, through electronic systems (and manual means where necessary), in accordance with the principles of fairness, lawfulness and transparency established by applicable personal data protection legislation, while safeguarding the confidentiality of the data subject and their rights through the adoption of appropriate technical and organisational measures designed to ensure a level of security consistent with applicable legislation. Specific security measures are implemented to prevent data loss, unlawful or improper use, and unauthorised access.

Legal Basis for Processing
Pursuant to Article 6 (Lawfulness of Processing), the legal basis for processing is your consent, the necessity of processing for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, compliance with a legal obligation to which the Data Controller is subject, and the pursuit of the legitimate interests of the Data Controller.

Data Retention
With reference to the Processing Purposes referred to under points a., b. and c., personal data will be processed for the entire duration of the relationship and for the period necessary to achieve the above purposes. Personal data required to comply with legal obligations will also be retained thereafter, in accordance with such obligations and the retention periods established by applicable laws.
With reference to the Processing Purposes referred to under point d., personal data will be retained for the period necessary to fulfil the purpose for which they were collected, namely to respond to your enquiry and handle your request.
With reference to the Processing Purposes referred to under points e., f. (marketing) and g. (profiling), the personal data you provide will be retained for the periods required by law and, with regard to profiling data, for a period appropriate and proportionate to the purposes pursued and the type of personal data processed, or until you withdraw your consent.
With reference to the Processing Purposes referred to under point h., personal data will be retained for the period necessary to achieve the purpose for which they were collected, namely improving the service and correcting any errors. Further information regarding retention periods may be requested from the Data Controller at info@anitavillas.it.

Scope of Processing, Disclosure, Communication and Transfer of Data
Your data are processed by internal personnel of the Company acting on the basis of written instructions. The data collected for the achievement of the above purposes may also be processed by third parties appointed for this purpose as Data Processors or, where applicable, as independent Data Controllers and/or Joint Controllers, including:

individuals, companies, associations or professional firms providing assistance and consultancy services to the Company for the Processing Purposes referred to under letters d., e., f., g. and h., as well as accounting, administrative, legal, tax and financial services referred to under letters a., b. and c.;
companies, entities and associations providing services connected with and instrumental to the fulfilment of the Processing Purposes referred to under letters a. and b. (including credit card payment processing and IT system maintenance);
public administrations for the performance of their institutional functions within the limits established by laws and regulations;
companies and individuals who make their properties available through the platform;
companies and organisations providing services and support for the purposes described above;
advertising partners with whom we may share your email address for the purpose of promoting AnitaVillas.com services through third parties. The Company undertakes to provide such data in a secure format and through protected methods.

The complete and updated list of entities processing personal data as external Data Processors and independent Data Controllers is available upon request by contacting info@anitavillas.it. In addition, personal data may be disclosed, communicated and transferred to Public Bodies, Judicial Authorities and Law Enforcement Agencies in order to comply with requests for investigations where expressly required by law.

Communications Between AnitaVillas.com and Property Providers
The Company may access communications and use automated systems to review, scan and analyse such communications for security purposes, fraud prevention, compliance with legal and regulatory requirements, investigation of potential criminal offences, product development and improvement, research and customer engagement. The Company reserves the right to block the delivery of communications or carry out checks where deemed necessary due to the nature of the content, spam concerns or any type of risk. Property providers with whom you have booked may decide to communicate directly with you by email or through other channels outside the control of AnitaVillas.com.

Transfer of Data to Non-EU Countries
Some third parties may be located in countries outside the European Union that nevertheless provide an adequate level of data protection, as established by specific decisions of the European Commission (http://www.garanteprivacy.it/home/provvedimenti-normativa/normativa/normativa-comunitaria-e-intenazionale/trasferimento-dei-dati-verso-paesi-terzi#1). The transfer of your personal data to countries outside the European Union that do not provide an adequate level of protection will take place only after the conclusion between the Company and such recipients of specific agreements containing safeguard clauses and appropriate guarantees for the protection of personal data, known as Standard Contractual Clauses, also approved by the European Commission.
The data will not be disclosed to the public.

Redirects to External Websites
The AnitaVillas.com website may use so-called social plug-ins. Social plug-ins are special tools that allow social network functionalities to be integrated directly into a website (for example, Facebook's "Like" button). All social plug-ins on the website are identified by the relevant logo of the respective social network platform. When you visit a page on our website and interact with a plug-in (for example by clicking the "Like" button) or decide to leave a comment, the corresponding information is transmitted directly from your browser to the social network platform (in this case Facebook) and stored by it.
For information regarding the purposes, methods and scope of collection, processing, use and storage of personal data by the social network platform, as well as the methods available to exercise your rights, please consult the relevant privacy policy of the social network concerned.

Rights of Data Subjects
Data subjects may exercise the rights provided for by the GDPR (Articles 15–21) in relation to the processing of personal data described herein, including the right to:

obtain confirmation as to whether or not personal data concerning them are being processed and access such data (right of access);
request the updating, amendment and/or correction of personal data (right to rectification);
request the deletion of personal data or the restriction of processing of data processed unlawfully, including data whose retention is no longer necessary in relation to the purposes for which they were collected or otherwise processed (right to erasure and right to restriction of processing);
object to processing (right to object);
withdraw consent, where provided, without affecting the lawfulness of processing based on consent before its withdrawal (right to withdraw consent);
lodge a complaint with the Supervisory Authority in the event of a breach of personal data protection legislation;
receive a copy of the personal data provided to the Company in a structured, commonly used and machine-readable format and request that such data be transmitted to another Data Controller (right to data portability).

Requests should be addressed to the Company by sending an email to info@anitavillas.it or by ordinary mail to: Anita Villas S.r.l., Via Vittorio Emanuele 1 - 61040 Mondavio (PU), Italy.

Changes to this Policy
The entry into force of new sector-specific regulations, as well as the ongoing review and updating of services provided to users, may require changes to the way in which users' personal data are processed. Therefore, this Policy may be amended over time and visitors are invited to review this page periodically. For this purpose, the Policy document indicates the date of the latest update.

Last revision: 15/10/2018