Articles 13, Legislative Decree 196/2003; Articles 13-14, European Regulation 679/2016

(includes the processing of navigation data and cookies)
Centoquindici - Rooms & Suite - based in Corso Umberto I, 157 in Montesilvano, C.F. 00706600673, Data Controller pursuant to European Regulation 679/2016 and Legislative Decree 196/2003, (hereinafter, for brevity, Owner)
that the personal data provided by the interested parties through the various collection channels, directly or indirectly managed by the Data Controller, or acquired from third parties in compliance with the legal conditions, will be processed lawfully and fairly, in compliance with the principles established by the Community system and Italian.

Purposes and methods of processing
The collection and consequent processing are carried out by the Data Controller at the company's premises, in compliance with the safety measures and requirements imposed by the rules indicated above, or by subjects delegated by it (specially selected and equipped with the necessary professionalism), with manual procedures. and computerized, in order to execute specific requests of the interested party, for pre-contractual and contractual obligations, for ordinary administrative, financial and accounting activities, to ensure the correct management of customers during the marketing and sale of products, for '' after-sales assistance, for the fulfillment of legal obligations.
The processing is also aimed at the elaboration of statistics in anonymized or pseudonymized form.
The processing, at the request of the interested party or after obtaining specific consent, can also be carried out through CRM and customer care, for the detection of the degree of satisfaction, tastes, preferences and habits of the interested party, for sending commercial information or advertising material, for direct marketing campaigns, for participation in games, competitions or prize draws, for involvement in events and exhibitions, for the provision of services, for market research and other operations directly or indirectly attributable to marketing activities.

Nature of the provision
The Data Controller processes personal data, telephone and electronic contact numbers and bank data, as well as other data essential to satisfy the requests of the interested parties or fulfill the commitments undertaken. The conferment is therefore mandatory, as it is not possible, in case of failure to grant consent or revocation of the same, to give rise to the processing.
It is necessary to point out that any incorrect or insufficient communication of the requested data may result in the total or partial impossibility of executing the requests of the interested party or the obligations connected to the commitments undertaken, with consequent possible mismatch of the results of the processing with the agreements taken or the obligations imposed by rules and regulations.
The other data, on the other hand, is collected for the sole purpose of adapting promotional campaigns, offers and, in general, the business activity, to the interests of customers and other parties involved. Their provision, therefore, is not mandatory and any refusal to process or revoke consent does not affect the establishment or continuation of the main relationship.

Data of Minors
Children under the age of 18 cannot provide data without the consent of the parent or guardian, if any. The owner will not be in any way responsible for any false declarations that may be provided by minors and, should he ascertain the falsity of the declaration, he will immediately delete any personal data and any information acquired.

Navigation data
The IT system and the software used for the web portal acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication products.
This information is not stored to identify the data subjects but, due to its nature, can, through processing and association with other data managed by third parties, allow the identification of the user.
This category of data concerns the IP addresses and domain names of the computer used by the user to connect to the site, the URL (Uniform Resource Locator) addresses of the requested resource, the time of the request, the method used to send the request to the server, the size of the file received, the numerical code used to indicate the status of the response given by the server (executed or error, etc.) and other parameters relating 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 check its correct functioning. They are usually deleted immediately after processing. They can be used and provided to the police and the judiciary to ascertain responsibility in case of damage to the site or offenses perpetrated through the network.

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

As with most websites, information regarding navigation on the site is kept for statistical purposes. The collection of information is possible thanks to the use of cookies. A cookie is a small file that is transferred to your computer's hard drive when you connect to a site.
These data are not of a personal nature, as they do not allow specific identification of the user. The data collected relate to the geographic location of the service provider, the type of browser used, the IP address, the pages visited, etc. The information thus collected allows you to see the frequency of visits to a site and the activity carried out during navigation.
In this way, over time, it is possible to improve the contents of the site and facilitate its use
Even companies that transmit content to the site or whose sites are accessible via links, can use cookies when the user selects the relative link.
In these cases, the use of cookies is not under the direct control of the Data Controller. Most browsers automatically accept cookies, but you can reject them or select only some of them, according to the preferences set by the user.
However, if the user inhibits the loading of cookies, some components of the site may stop working and some pages may be incomplete.

Essential technical cookies
These are cookies necessary to ensure a correct and fluid functioning of the site: they allow the navigation of the pages, the sharing of contents, the storage of access credentials to speed up entry into the site and to keep preferences and credentials active during navigation and improve the browsing or shopping experience. Without these cookies it is not possible to provide, in whole or in part, the services for which users access the site.

Statistical cookies
These cookies allow us to understand how users use the site in order to then be able to evaluate and improve its functioning and create content that is increasingly appropriate for users' preferences. For example, these cookies allow you to know which pages are the most and least visited, how many visitors to the site are, how much time is spent on the site by the average user and how visitors arrive on the site. In this way it is possible to determine which are the optimal functioning and the most liked contents and how the contents 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
They are cookies used by third parties not directly controlled by the Owner. The company cannot provide guarantees with respect to the use that will be made of the data, the processing of which is directly operated by an external party.
Cookies from these third party operators allow to offer advanced features, as well as more information and personal functions. This includes the ability to share content through social networks and to have a personalized site experience based on the preferences expressed through the pages visited.
If you have an account or if you use the services of these other controllers, they may be able to know that you have visited the company's website. The use of the data collected by these external operators through cookies is subject to their privacy policies. Third-party profiling cookies are identified with the names of the respective operators and can be deactivated.

Management of cookies
You can change the settings of the cookies that are downloaded to the user's computer through the browser functions. By doing so, it is also possible to prevent the installation of third-party cookies and remove previously installed cookies, including those containing preferences regarding cookies. To adjust or change your browser settings you need to consult the manufacturer's guide.
The instructions for managing and removing cookies from the most popular browsers are available on the websites of the respective manufacturers. Disabling cookies can cause the site to malfunction or part of it.

Acceptance and waiver of cookies
By continuing to browse the site after viewing the information that appears superimposed, the company policy is accepted. It is always possible to remove cookies already downloaded using the browser functions or specific applications.

Third party sites.
The company website, even if only periodically, may contain links with other third-party sites, to provide additional services and information to the user. When the user uses these links, he leaves the company website and accesses other resources that are not under the direct control of the Data Controller, who, therefore, will not be responsible for the procedures relating to navigation, security and data processing. personal data operated by other sites, even in the presence of co-branding or display of the company logo. A careful examination of the security and confidentiality procedures of the visited site is recommended, which may transmit additional cookies, read those already on the user's hard drive and request / acquire additional personal information.

Communication and dissemination
The data processed are exclusively of a common nature and are not intended for dissemination. The Data Controller does not require and has no interest in detecting and processing data classified by the Regulation as "particular" (sensitive, judicial, genetic, biometric, etc.) without prejudice to legal obligations.
The data must be transferred to third parties in the fulfillment of obligations deriving from laws or regulations (institutions, law enforcement agencies, judicial authorities, etc.) or for activities directly or indirectly related to the established relationship. By way of non-exhaustive example, the following are mentioned:
Subjects who need to access the data of the interested party for purposes relating to the relationship with the Data Controller (credit institutions, financial intermediaries, electronic money institutions and payment management, credit recovery companies, customer verification companies, carriers,) ;
Consultants, collaborators, service companies, within the limits necessary to carry out the assignment conferred by the Owner;
Subsidiary and / or associated companies that can access the data, within the limits strictly necessary to carry out tasks entrusted by
The data may be disclosed to subjects operating within the European Union, or in countries that guarantee the same level of protection provided for by the European Regulation 679/2016 and by Legislative Decree 196/2003. They may be disclosed to subjects operating in non-EU countries where expressly permitted by the interested party.
In any case, the data processing carried out in the various countries will be adapted to the most restrictive rules, in order to ensure the highest level of data protection of the interested party. They may be transferred to third parties, even for consideration, if the interested party has given express consent, for purposes directly or indirectly related to the owner's activity.

Data retention times
The data processed by the Data Controller, without prejudice to legal obligations, are kept until an express request for cancellation by the interested party and in any case periodically verified, also with automatic procedures, in order to guarantee their updating and effective compliance with the purposes of the treatment. If the purpose for which they were acquired has ceased, the data are deleted, unless otherwise expressly requested by the interested party.

Rights of the interested party
The interested parties are entitled to the rights referred to in Article 7 of Legislative Decree 196/2003 and 13 of Regulation EU / 2016/679 and, in particular, the right to withdraw consent to the processing of data at any time, request its rectification, updating, transformation into anonymous form, limiting even partially its use, requesting its portability and eventual cancellation. The rights can be exercised to the extent that the processing is not required by law or regulation. Applications relating to the exercise of the rights of the data subject can be addressed to the Data Protection Officer at the following address Viale Rinascimento 141, San Benedetto del Tronto. If the interested party is not satisfied with the response provided to his requests by the Data Controller or the Data Protection Officer, he can lodge a complaint with the Guarantor Authority for the Protection of Personal Data, based in Rome, Piazza di Monte Citorio n . 121, www.garanteprivacy.it


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