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Privacy Policy

Web privacy policy & Cookie

This Privacy Policy is intended to describe how this application is managed, notably with regard to the use of Cookies and to the processing of personal data of users/visitors.

It is an Information Notice, pursuant to Articles 13 and 122 of the Personal Data Protection Code (Legislative Decree 196/03, the so-called Privacy Code) and to the obligations of the General Resolution on Cookies adopted by the Italian Data Protection Authority on May 8, 2014, provided to those who connect to the application www.excelsiorpalace.it.

Users/visitors are invited to carefully read this Privacy Policy before sending any personal information and/or filling out any electronic form on the application.

Data Controller: Excelsior Palace S.r.l.
Via San Michele di Pagana 8 16035 Rapallo, Italia

A. Type of data processed

This application acquires three types of personal data: navigation data, Cookies, data provided voluntarily by users/visitors.

1. Navigation data.

The IT systems and software procedures that ensure the functioning of this application acquire personal data in the course of their standard operation which are implicitly communicated whilst using Internet communication protocols.

This information is not collected to be associated with identified data subjects; yet, by reason of its nature, it might allow for users/visitors to be identified (e.g. IP addresses, domain names of the computers of users connecting to the application, the code indicating the status of the server’s response, the type of browser. etc.) via processing with data held by third parties.

This data it used solely to identify the user and to provide the service requested by him. Failure to provide requested personal data, or the refusal of consent to its processing, will make it impossible to obtain registration and, therefore, the service requested by the user.

2. Cookie policy.

This application can use Cookies.

2.1 General information on Cookies

Cookies are small text files that are sent by the applications visited by users to their terminal equipment (typically to users’ browser), where they are stored and then re-transmitted to the same applications every time these are visited via the same terminal equipment.
Depending on their duration, Cookies can be session Cookies (i.e. temporary Cookies which are automatically cancelled by the terminal equipment at the end of the browsing session, closing the browser) and persistent Cookies (i.e. Cookies that remain stored on the terminal equipment until their expiry or cancellation by the user).

2.2. Technical Cookies

This application uses technical Cookies to carry out the transmission of a communication or to provide the service requested by the user, as follows:

Activities strictly necessary for the functioning
This application uses technical Cookies in order to handle the session of the user and complete activities that are strictly necessary for the functioning of the same, for example in relation to the distribution of traffic.

Rescue activities preferences, optimization and statistics
This application uses Cookies to save your browsing preferences and optimize the browsing experience user. Among these Cookies includes, for example, the ones to set the language and the currency or for the management of statistics by the owner of the site.
This application not use Cookies for further purposes, typically to analyse user behaviour and to send targeted ads messages (so-called “profiling” Cookies) or even only to obtain, via third party services, aggregate information on the number of users and on how they visit the application (so- called (“analytics Cookies”) the user’s prior consent is required.

2.3. Third party Cookies

This application allows for the transmission to the user’s terminal equipment of Cookies of third parties with which Excelsior Palace S.r.l. collaborates. As a technical intermediary, Excelsior Palace S.r.l. simply sends these Cookies without managing their operation (thus having no control over or access to any information given/acquired) because their operation falls within the responsibility of third parties.

As Excelsior Palace S.r.l. uses services operated by third parties, these may – in addition to what is specified and also the knowledge of the owner – making activity tracking user. For detailed information, please consult the privacy policy of the services listed:
Statistics

The services contained in this section are used to the Data Controller to monitor and analyze traffic data and are used to keep track of user behavior.
Google Analytics (Google)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses personal information collected for the purpose of evaluating the use of this application, compile reports and share them with other services developed by Google.

Google may use this personal information to contextualize and personalize the ads of its own advertising network.
Personal data collected: Cookies and data usage.
Place of treatment : USA – Privacy Policy – Opt Out

Managing contacts and sending messages.
This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the user, as well as when the user interacted with it, such as by clicking on links included in the message.
Amazon Simple Email Service (Amazon)
Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.
Personal data collected: Email.
Place of treatment : USA – Privacy Policy – Opt-Out
Like button and social widgets for Facebook (Facebook, Inc.)
Click “Like” Facebook and social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.

Personal data collected: Cookies and data usage.
Place of treatment : USA – Privacy Policy
Tweet button and social widgets to Twitter (Twitter)
The Tweet button and social widgets are services of Twitter to interact with the social network Twitter, provided by Twitter Inc.

Personal data collected: Cookies and data usage. Place of treatment : USA – Privacy Policy

How can I manage the installation of Cookies?

In addition to what is specified in this document, the user can manage preferences for Cookies directly from within their own browser and prevent – for example – third parties from installing them. Through the browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that might possibly have saved the consent for the installation of Cookies by this website. It is important to note that by disabling all Cookies, the functioning of this site may be compromised. Users can find information about how to manage Cookies in their browser at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer.

In the case of services provided by third parties, users can exercise their right to withdraw from the tracking activity by utilizing the information provided in the third party’s privacy policy, by clicking the opt-out link – if provided – or by contacting the third party.
Notwithstanding the above, the Data Controller informs that users may take advantage of: Your Online Choices. This service allows users to select their tracking preferences for most of the advertising tools. The Data Controller thus recommends that users make use of this resource in addition to the information provided in this document.

3. Data provided voluntarily by users/visitors

When users/visitors, connecting to this application, send their personal data to have access to given services or to send email requests, or access to informing texts at the same time as data collection, this implies the acquisition by Excelsior Palace S.r.l. of the sender’s address and/or other personal data that are processed solely to respond to the user’s request or to supply the service.

The personal data supplied by users/visitors will be communicated to third parties only where such communication is required to meet the users/visitors’ requests

Users are responsible for any personal data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

B. Methods and place of processing personal data

Data processing procedures.
The Data Controller processes the data of users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data.
The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the owner. The updated list of these parties may be requested from the Data Controller at any time.

C. Place of processing

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

D. Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

E. Use of the collected Data

The data concerning the user is collected to allow the owner to provide its services, as well as for the following purposes: statistics, interaction with external social networks and platforms.
The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:
Like button and social widgets for Facebook (Facebook, Inc.)
Click “Like” Facebook and social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.
Personal data collected: Cookies and data usage.
Place of treatment : USA – Privacy Policy
Tweet button and social widgets to Twitter (Twitter)
The Tweet button and social widgets are services of Twitter to interact with the social network Twitter, proTvided by Twitter Inc.
Personal data collected: Cookies and data usage.
Place of treatment : USA – Privacy Policy
Google Analytics (Google)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses personal information collected for the purpose of evaluating the use of this application, compile reports and share them with other services developed by Google.
Google may use this personal information to contextualize and personalize the ads of its own advertising network.
Personal data collected: Cookies and data usage.
Place of treatment : USA – Privacy Policy – Opt Out
Managing contacts and sending messages.
This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Amazon Simple Email Service (Amazon)

Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.
Personal data collected: Email.
Place of treatment : USA – Privacy Policy – Opt-Out

Registration and authentication

By registering or authenticating, users allow this application to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some data, stored by these third party services, for registration or identification purposes.
Direct registration (This Application)

The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data collected: email address and password.

F. Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this application or the related services.
The user declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

G. Additional information about user’s Personal Data

In addition to the information contained in this privacy policy, this application may provide the user with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

H. System Logs and Maintenance

For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this application (System Logs) or use for this purpose other Personal Data (such as IP Address).

I. Information not contained in this policy

More details concerning the collection or processing of personal data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

L. The rights of users

Users have the right, at any time – in accordance with Article 7 of Legislative Decree no. 196/2003 and in compliance with the procedures specified under Articles 8 et seq. of the same Legislative Decree no. 196/2003 – to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.
To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

M. Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a user objects to any of the changes to the Policy, the User must cease using this application and can request that the Data Controller removes the personal data. Unless stated otherwise, the then-current privacy policy applies to all personal data the Data Controller has about users.