Privacy Policy and Cookie Policy

Hotel Lindenhof GmbH, with registered office at Kirchweg 2, 39025 Naturno, Italy (hereinafter "Lindenhof"), is committed to protecting the personal data of users of its online presence. This declaration has been drawn up pursuant to Art. 13 of Regulation (EU) 2016/679 (hereinafter: "Regulation") in order to explain our privacy policies and how your personal information is managed when using our websites (www.lindenhof.it, hereinafter collectively the "Website"). Where applicable, this declaration also serves the purpose of enabling you to weigh and provide informed consent for the processing of your personal data (consent valid only for persons aged 16 and over). The information and data provided or otherwise transmitted by you in the context of using Lindenhof's services (e.g. booking enquiries, arrangement of holiday packages, issuance of vouchers, newsletter registration), hereinafter "Services", are processed in accordance with the provisions of the Regulation and within the framework of appropriate confidentiality obligations.

In accordance with the provisions of the Regulation, the processing carried out by Lindenhof is conducted in good faith and in accordance with the principles of lawfulness, transparency, purpose and storage limitation, data minimisation, accuracy, completeness and confidentiality.

Contents

1. Controller
2. Personal data being processed
   
   1. Browsing data
   2. Special categories of personal data
   3. Data voluntarily provided by data subjects
   4. Cookies
3. Purpose of data processing
4. Legal basis, voluntary nature or necessity of processing
5. Recipients of personal data
6. Transfer of personal data
7. Storage of personal data
8. Rights of the data subject
9. Amendments

1. Controller

Lindenhof is responsible for the processing of personal data through the Website. To obtain specific information on the processing of personal data by Lindenhof, such as the list of processors who process data on behalf of the controller, please contact the following email address: info@lindenhof.it.

2. Personal data being processed

We would like to point out that Lindenhof processes personal data when you browse the Website. Personal data consists of an identifier such as a name, an identification number, an online identifier, or one or more special characteristics (which are an expression of the physical, physiological, psychological, economic, cultural or social identity of the data subject) that identifies the natural data subject or makes them identifiable (hereinafter "personal data").

a. Browsing data

The IT systems and software procedures that ensure the functioning of the Website acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected for the purpose of being associated with identified data subjects, but which by its nature could, through processing and matching with data held by third parties, allow users to be identified. This data includes IP addresses or domain names of the computers used by the user to access the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the identification number of the status of the response given by the server (successful, error, etc.), and other parameters relating to the operating system and IT environment of the user. This data is used only to collect anonymous statistical information on the use of the Website, to check its correct functioning and to detect malfunctions and/or abuses, and is deleted immediately after processing. The data may be used to ascertain liability in the event of cybercrime offences against the Website or third parties. Apart from this exceptional case, browsing data is not stored for longer than a few days.

b. Special categories of personal data

When using the Services, you may transmit personal data belonging to so-called "special categories of personal data". Pursuant to Art. 9 of the Regulation, the processing of personal data "revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation" is prohibited. We ask that you do not transmit such data unless strictly necessary. Please note that in the event of transmission of special categories of personal data without the data subject's specific consent to processing, Lindenhof assumes no liability and cannot be held responsible, as the data in this case are made public by the data subject pursuant to Art. 9(2)(e) of the Regulation. Should you wish to transmit such information, it is nevertheless necessary to provide explicit consent to the processing of special categories of personal data.

c. Data voluntarily provided by the data subject

When using some of the Website's Services (for example, ordering vouchers or making booking enquiries), processing of personal data of third parties that you transmit to Lindenhof may occur. In this case, you yourself become the controller and assume all legal obligations and responsibilities for the processing. In this sense, you undertake to hold Lindenhof harmless and indemnified on this point should third parties file complaints or assert claims, demands for damages, etc., because their personal data have been processed in violation of applicable legal provisions. If you transmit or otherwise process personal data of third parties when using the Website, you must ensure that the processing is based on an appropriate legal basis pursuant to Art. 6 of the Regulation and that the processing of the information in question is lawful.

d. Cookies

Definitions, characteristics and application of the rules

Cookies are small text files that visited websites send to the user's computer or terminal device, where they are stored and sent back the next time the user visits the same pages. Thanks to such cookies, a website recognises a user's activities and preferences (such as login data, language choice, character size, other display settings, etc.); these therefore do not need to be entered again when you revisit the Website. Cookies are used to perform IT authentications, monitor sessions and store information on the browsing behaviour of users of a website, and may also contain an identification code that makes it possible to trace the pages of the Website accessed by the user for statistical or advertising purposes. When browsing a website, cookies from websites or servers other than the visited website (third-party cookies) may also be placed on the user's computer. Some operations would not be possible without the use of cookies; in some cases, therefore, they are technically necessary for the functioning of the Website.

There are cookies with different properties and functions, and they may remain on the user's computer for different periods of time. So-called session cookies are automatically deleted when the browser is closed; persistent cookies remain on the user's device until their predetermined duration has expired.

Under the regulations in force in Italy, the use of cookies does not always require the user's express consent. In particular, mandatory "technical cookies" (i.e. those used solely for the purpose of carrying out the transmission of a communication over an electronic communications network, or strictly necessary in order to provide a service explicitly requested by the user) do not require express authorisation. These are always cookies that are essential to the functioning of the Website or necessary for carrying out an activity requested by the user.

According to the Italian Data Protection Authority (see Regulation "Identification of simplified procedures for information and obtaining consent for the use of cookies" of 8 May 2014 and subsequent clarifications, hereinafter "Provision"), the following are also considered technical cookies that do not require express consent for their use:

• "Analytical cookies", provided they are used directly by the Website operator to collect aggregated information on the number of users of the Website and their browsing behaviour.
• Navigation or session cookies (for authentication purposes).
• Functionality cookies, which allow users to browse according to specific criteria they have chosen (for example, language, products selected for purchase) in order to improve the service provided.

However, for "profiling cookies", i.e. those that create a user profile and are used to send advertising messages in line with the preferences shown by the user while browsing the internet, the user's prior consent is required.

Cookies used by the Website and possible opt-in/opt-out

The Website uses the following cookies, which can be opted in or out of (except for third-party cookies, for which the opt-in/opt-out procedures must be followed directly through the relevant links):

• Technical navigation or session cookies, which are strictly necessary for the functioning of the Website or for the use of the requested content or services.
• Functionality cookies, which are necessary to activate specific features of the Website and a series of selected criteria (e.g. language) to improve the service offered.
  

  WARNING: if technical and/or functionality cookies are opted out of, the Website may not be accessible, or some services or specific features of the Website may not be available or functional, and it may be necessary to re-enter some information or preferences each time you visit the Website.

• Third-party cookies, i.e. cookies from websites or servers other than Lindenhof, which are used by third parties for their own purposes. It is emphasised that these third parties, listed below with their respective links to their privacy policies, are normally independently responsible for the data collection carried out through the cookies they place. Therefore, in accordance with the cited Provision, their policies on the processing of personal data, legal notices and consent forms (opt-in and opt-out of the relevant cookies) must be observed. For completeness, it should also be emphasised that Lindenhof does everything possible to be able to trace the cookies on its Website. These are regularly updated in the table below, which also lists the cookies placed directly by Lindenhof and their purposes. With regard to third parties placing cookies through our Website, we list the links to the relevant privacy policies. As already emphasised, these third parties are liable for providing appropriate legal notice and obtaining your consent. This liability applies not only to cookies placed directly by third parties, but also to any additional cookies placed through our Website when using services from which these third parties benefit. Lindenhof has no control over these third-party cookies and is aware of neither their characteristics nor their purposes.

Third-party cookie notices:

• Google LLC: https://policies.google.com/privacy
• Google Analytics: https://support.google.com/analytics/answer/6004245
• Google Tag Manager: https://policies.google.com/privacy
• Facebook: https://de-de.facebook.com/full_data_use_policy
• Giggle Tips: http://giggle.tips/privacy.html
• AddThis Inc.: http://www.addthis.com/privacy/privacy-policy

Specifically, the cookies placed by Lindenhof through the Website are as follows:

Cookies on the Website

Cookie settings

Technical and functionality cookies can be blocked or deleted (in whole or in part) via specific browser functions. However, we point out that the lack of consent to technical cookies may make it impossible to use the Website, access content and use its services. If functionality cookies are blocked, some services or specific features of the Website may not be available or function correctly, and it may be necessary to enter some information or preferences manually each time you visit the Website.

The settings made in relation to the cookies on the Website are themselves stored in a dedicated cookie. However, this cookie may not function correctly under certain circumstances. In such cases, you should delete unwanted cookies and also block their use through your browser functions.
Your cookie settings must be made again if you use a different browser to access the Website.

Viewing and modifying cookies through the browser

You can block or delete cookies (in whole or in part) via specific functions of your browser. For more information on setting preferences regarding the use of cookies through the browser, please refer to the following instructions:

• Internet Explorer
• Firefox
• Chrome
• Safari

3. Purpose of data processing

The processing of your personal data carried out by Lindenhof takes place (where necessary, with your specific consent) for the following purposes:

1. Performance of the Services requested by you, namely: i) booking enquiries; ii) ordering of holiday packages/vouchers; iii) fulfilment of the accommodation contract or booked services; iv) registration for the newsletter;
2. Responding to enquiries and providing assistance;
3. Fulfilment of any legal, accounting or tax obligations;
4. Marketing purposes: the data provided may, with explicit and specific consent, be used to send advertising and marketing material relating to the hotels of the DolceVita Group, including the periodic sending of newsletters and postal mailings.

4. Legal basis, voluntary nature or necessity of processing

The legal basis for the processing of personal data for the purposes indicated in sections 3.a and 3.b is Art. 6(1)(b) of the Regulation, as the processing is necessary in order to perform the Services or respond to the data subject's enquiries. The provision of personal data for these purposes is voluntary, but failure to provide it makes it impossible to activate the services provided by the Website or to respond to enquiries.

The purposes of the processing referred to in section 3.c constitute legitimate processing of personal data pursuant to Art. 6(1)(c) of the Regulation. Following the provision of personal data, processing in these cases is necessary in order to fulfil legal obligations to which Lindenhof is subject.

The legal basis for processing for the purposes referred to in section 3.e is, pursuant to Art. 6(1)(a) of the Regulation, the consent of the data subject. Lack of consent to this processing purpose in no way affects the provision of the Services.

For processing carried out for direct marketing purposes, direct sales, or carrying out market research or commercial communications relating to products or services similar to those you have already purchased or booked, the controller may use email addresses and postal addresses without your consent. This may be done pursuant to Art. 130, paragraph 4 of Italian Legislative Decree 196/2003 and the Provision of the Data Protection Authority of 19 June 2008, and within the limits set out therein. The legal basis for the processing of your data for these purposes is the legitimate interests of Lindenhof pursuant to Art. 6(1)(f) of the Regulation.

5. Recipients of personal data

Your personal data may be transferred for the purposes set out in section 3 to:

1. Third parties typically responsible for processing, namely: i) persons, service providers or companies that provide Lindenhof with assistance and advice on business, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services; ii) third parties with whom there is interaction for the provision of the service (e.g. providers of hosting services or payment processing services); iii) third parties entrusted with carrying out technical maintenance work (system administrators), including the maintenance of network equipment and electronic communications networks; (all hereinafter collectively referred to as "Recipients");
2. Institutions or authorities to which your personal data must be reported by virtue of legal provisions or orders;
3. Third parties tasked by Lindenhof with processing personal data in the context of providing services, who have undertaken to maintain confidentiality or are subject to a legal obligation of confidentiality (e.g. Lindenhof employees);
4. Other hotels of the DolceVita Group (Resort Lindenhof, Feldhof, Alpiana Resort, Preidlhof Resort and Jagdhof), which are united in the DolceVita Consortium and act as joint controllers in accordance with internal agreements, in order to handle enquiries and provide the requested services.

6. Transfer of personal data

Some of your personal data is exchanged with recipients that may also be located outside the European Economic Area. Lindenhof ensures that the processing of your personal data by these recipients takes place in accordance with the Regulation. In fact, transfers may be based on an adequacy decision, on standard contractual clauses approved by the European Council, or on another appropriate legal basis. For more information, please contact Lindenhof at: info@lindenhof.it.

7. Data storage

The personal data processed for the purposes referred to in sections 3.a and 3.b are stored only for the period strictly necessary to achieve those purposes. Since these are processing operations carried out for the provision of services, Lindenhof in any case stores the personal data for the period provided for in the regulation for the protection of its own interests (Art. 2946 of the Italian Civil Code as in force).

The personal data processed for the purposes referred to in section 3.c are stored for as long as required by the specific obligation or by the applicable legal provision.

The personal data processed for the purposes referred to in section 3.d, however, are stored until consent is withdrawn by the data subject, or for a maximum period considered appropriate, should such withdrawal not occur.

For further information on the data retention period and on the criteria for determining this period, please contact Lindenhof at info@lindenhof.it.

8. Rights of data subjects

In accordance with Art. 15 et seq. of the Regulation, you have the right at any time to request information about the personal data processed by Lindenhof concerning you, as well as the right to request correction or deletion of the data. You may also object to the processing and, in the cases provided for in Art. 18 of the Regulation, request a restriction of the processing, as well as, in the cases provided for in Art. 20 of the Regulation, request to receive the data concerning you in a structured, commonly used and machine-readable format. The relevant requests should be sent in writing to Lindenhof at: info@lindenhof.it.

In any event, you have the right, pursuant to Art. 77 of the Regulation, to lodge a complaint with the competent supervisory authority (for Italy: Garante per la protezione dei dati personali) if you consider that the processing of personal data concerning you infringes the applicable legal provisions.

9. Amendments

This Privacy Policy has been in force since 25 May 2018. Lindenhof reserves the right to modify or update the content, in whole or in part, including as a result of changes to the applicable provisions. Lindenhof will publish any changes on the Website as soon as they are introduced, and these will apply from the date of publication. Lindenhof recommends that you visit this section regularly to check the latest version of the Privacy Policy and to remain informed at all times about the data collected and its use by Lindenhof.