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PRIVACY NOTICE
Articles 13, Legislative Decree 196/2003; Articles 13-14, European Regulation 679/2016
(including the processing of browsing data and cookies)

Centoquindici - Rooms & Suite - based in Corso Umberto I, 115 in Montesilvano, C.F. 00706600673, Data Controller pursuant to European Regulation 679/2016 and Legislative Decree 196/2003, (hereinafter, for brevity, Data Controller)
INFORMS
that the personal data provided by the data subjects through the various collection channels, directly or indirectly managed by the Data Controller, or acquired from third parties in compliance with legal conditions, will be processed lawfully and fairly, in compliance with the principles enshrined in the community and Italian legal system.

Purpose and methods of processing
The collection and subsequent processing are carried out by the Data Controller at the company premises, in compliance with the security measures and provisions imposed by the aforementioned regulations, or by persons delegated by it (carefully selected and equipped with the necessary professionalism), with manual and computerized procedures, in order to fulfill specific requests of the data subject, for pre-contractual and contractual obligations, for ordinary administrative, financial and accounting activities, to ensure the proper management of customers during the marketing and sale of products, for post-sale assistance, for compliance with legal obligations.
The processing is also aimed at the preparation of statistics in anonymized or pseudonymized form.
The processing, at the request of the data subject or upon prior acquisition of specific consent, may also be carried out through CRM and customer care, for assessing the level of satisfaction, tastes, preferences and habits of the data subject, for sending commercial information or advertising material, for direct marketing campaigns, for participation in games, competitions or prize operations, for involvement in events and demonstrations, for the provision of services, for market research and other operations directly or indirectly related to marketing activities.

Nature of the provision
The Data Controller processes personal data, contact details and banking data, as well as other data necessary to satisfy the requests of the data subjects or fulfill the commitments made. The provision is therefore mandatory, as failure to provide consent or revocation thereof will prevent processing.
It is necessary to highlight that any incorrect or insufficient communication of the requested data may result in the total or partial inability to fulfill the requests of the data subject or obligations related to the commitments made, with possible failure of the results of processing to correspond to the agreements made or obligations imposed by laws and regulations.
Other data, on the other hand, are collected solely to adapt promotional campaigns, offers and, in general, business activities, to the interests of customers and other parties involved. Therefore, their provision is not mandatory, and any refusal of consent or revocation of consent does not compromise the establishment or continuation of the main relationship.

Data of Minors
Minors under the age of 18 may not provide data without the consent of a parent or legal guardian. The Data Controller shall not be responsible in any way for any false statements made by minors and, if the falsity of the statement is detected, will proceed to the immediate deletion of any personal data and any information acquired.

Browsing data
The IT system and the software used for the web portal acquire, during normal operation, some personal data whose transmission is implicit in the use of Internet communication products.
This information is not stored to identify data subjects but, by its nature, may allow identification of the user through processing and association with other data managed by third parties.
This category of data concerns the IP addresses and domain names of the computer used by the user to connect to the site, the URLs (Uniform Resource Locator) of the requested resource, the time of the request, the method used to send the request to the server, the size of the received file, the numeric code used to indicate the status of the response given by the server (success or error, etc.) and other parameters related to the user’s operating system and computer.
These data are used only to create anonymous statistics on the use of the site and to monitor its proper functioning. They are usually deleted immediately after processing. They may be used and provided to law enforcement and the judiciary to ascertain liability in case of damage to the site or illegal activities carried out via the network.

Data provided by the user
Filling out any forms present on the site's pages involves the acquisition of data in the system's memory. The information is protected by an authentication system and can only be used by those in possession of the credentials. They are also updated and adequately protected, based on the best available practices.
Requests for information via email involve storing the user's email address, necessary to respond to the sender's requests. The data stored in the message is also included.
The Data Controller advises its customers, during their requests for services and information, not to transmit data or personal information of third parties, unless absolutely necessary.

Cookies
Like most websites, information regarding navigation on the site is stored for statistical reasons. The collection of information is made possible through the use of cookies. A cookie is a small file that is transferred to the computer's hard drive when connecting to a site.
This data is not personal in nature, as it does not allow for the specific identification of the user. The recorded data includes the geographical location of the service provider, the type of browser used, the IP address, the pages visited, etc. The information collected in this way allows for tracking the frequency of visits to a site and the activity performed during navigation.
In this way, over time, it is possible to improve the site's content and facilitate its use
Even companies that provide content to the site or whose sites are accessible via links can use cookies when the user selects the respective link.
In these cases, the use of cookies is not under the direct control of the Data Controller. Most browsers automatically accept cookies, but users can refuse them or select only some, according to their preferences.
However, if the user inhibits cookie loading, some components of the site may stop functioning and some pages may appear incomplete.

Essential technical cookies
These are cookies necessary to ensure the correct and smooth functioning of the site: they allow page navigation, content sharing, storing access credentials to make entry to the site quicker, and maintaining preferences and credentials during navigation to enhance the browsing or purchasing experience. Without these cookies, it is not possible to provide, fully or partially, the services for which users access the site.

Statistical cookies
These cookies allow understanding how users use the site so that its functioning can be evaluated and improved, creating content that is increasingly suitable for users' preferences. For example, such cookies allow knowing which pages are most and least visited, how many visitors the site has, how much time users typically spend on the site, and how visitors arrive at the site. This way, it is possible to determine optimal functionalities and the most appreciated content and how the content and functionality of the pages can be improved. All information collected by these cookies is anonymous and not linked to the user's personal data.

Third-party profiling cookies
These are cookies used by third parties not directly controlled by the Data Controller. The company cannot guarantee the use that will be made of the data, which is processed directly by an external subject.
Cookies from such third-party operators allow offering advanced functionalities, as well as more information and personal functions. This includes the possibility of sharing content through social networks and having a personalized site experience based on preferences expressed through the pages visited.
If a user has an account or uses the services of these other data controllers, they may be able to know that the user has visited the company's site. The use of data collected by such external operators via cookies is subject to their privacy policies. Third-party profiling cookies are identified by the names of their respective operators and can be disabled.

Cookie management
Users can modify cookie settings downloaded to their computer through browser functionalities. In this way, it is also possible to prevent the installation of third-party cookies and remove previously installed cookies, including those containing cookie preferences. To adjust or modify browser settings, it is necessary to consult the manufacturer's guide.
Instructions for managing and removing cookies in the most widely used browsers are available on the websites of the respective manufacturers. Disabling cookies may cause the site or parts of it to malfunction.

Acceptance and rejection of cookies
By continuing to browse the site after viewing the information that appears on the overlay, the corporate policy is accepted. It is always possible to remove cookies already downloaded through browser functionalities or specific applications.

Third-party sites.
The corporate site, even if only periodically, may contain links to other third-party sites, to provide additional services and information to the user. When the user uses these links, they leave the corporate site and access other resources that are not under the direct control of the Data Controller, who therefore will not be responsible for the procedures related to navigation, security, and the processing of personal data operated by other sites, even in the presence of co-branding or exposure of the corporate logo. It is recommended to carefully examine the security and privacy procedures of the visited site, which may transmit additional cookies, read those already present on the user's hard drive, and request/acquire further personal information.

Communication and dissemination
The processed data are exclusively of a common nature and are not intended for dissemination. The Data Controller does not request and has no interest in detecting and processing data classified by the Regulation as “particular” (sensitive, judicial, genetic, biometric, etc.) subject to legal obligations.
Data must be transferred to third parties in fulfillment of obligations arising from laws or regulations (Institutions, Law Enforcement, Judicial Authority, etc.) or for activities directly or indirectly connected to the established relationship. By way of example and not exhaustive, the following are mentioned:
Subjects who need to access the data of the data subject for purposes related to the relationship with the Data Controller (Credit Institutions, Financial intermediaries, Electronic money institutes and payment management, Debt collection companies, Customer verification companies, Carriers, );
Consultants, collaborators, service companies, to the extent necessary to carry out the duties conferred by the Data Controller;
Controlled and/or affiliated companies that can access the data, to the strictly necessary extent to perform tasks assigned by the
Data may be communicated to subjects operating within the European Union, or in countries that guarantee the same level of protection provided by European Regulation 679/2016 and Italian Legislative Decree 196/2003. They may be communicated to subjects operating in non-EU countries where expressly permitted by the data subject.
In any case, the data processing carried out in various countries will be adequate to the more restrictive regulations, in order to ensure the highest level of protection of the data subject's data. Data may be transferred to third parties, even for a fee, if the data subject has given express consent, for purposes directly or indirectly related to the activities of the Data Controller.

Data retention times
The data processed by the Data Controller, subject to legal obligations, are retained until an explicit request for cancellation by the data subject and are periodically verified, including by automatic procedures, in order to ensure their update and actual compliance with the purposes of processing. If the purpose for which they were acquired is no longer valid, the data will be deleted, unless otherwise explicitly requested by the data subject.

Rights of the data subject
Data subjects are recognized the rights set forth in Article 7 of Italian Legislative Decree 196/2003 and 13 of EU Regulation 2016/679 and, in particular, the right to withdraw consent to data processing at any time, to request rectification, updating, transformation into anonymous form, to limit its use even partially, to request portability and possible deletion. The rights can be exercised to the extent that processing is not mandatory by law or regulation. Requests related to the exercise of the rights of the data subject may be addressed to the Data Protection Officer at the following address: viale Rinascimento 141, San Benedetto del Tronto. The data subject, if not satisfied with the response provided to their requests by the Data Controller or the Data Protection Officer, may lodge a complaint with the Italian Data Protection Authority, based in Rome, Piazza di Monte Citorio n. 121, www.garanteprivacy.it