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Policy of Hotel Caravel on the processing of personal details This declaration contains information on the guidelines and regulations to which Hotel Caravel adheres in relation to the processing of the personal details of users of the www.caravelhotel.it website. Given that the site in question operates and is hosted in Italy, the information and data concerning users of the site will be processed by Hotel Caravel in compliance with the Italian legislation that implements Directives 95/46/CE and 2002/58/CE of the European Parliament and Council, or on the basis of Italian Legislative Decree No. 196, issued on June 30, 2006, and subsequent modifications and integrations. 1. Purposes of data processing and methods used We hereby inform you, as a user of our site, that the details you supply will be used for the purposes specified below, and also to keep you informed about news, promotions, competitions and initiatives relating to Hotel Caravel in general. Without prejudice to disclosures carried out in order to comply with legal requirements, your personal details may also be disclosed to the following companies and bodies, in Italy and/or overseas: - credit institutions - debt recovery companies - credit insurance companies - commercial information companies - professionals and consultants - insurance companies - private laboratories and public bodies commissioned by us to carry out tests and analyses - for direct marketing activities, including newsletters, MMS/SMS messages or other forms of direct marketing - for information-based activities - for the compiling of professional profiles on clients or consumers - for market research or other types of research geared towards the enhancement of our products and services. The data received will be processed electronically and/or manually, protected by appropriate security systems (which will be constantly updated) and stored in a safe, monitored environment. 2. Granting of access to details and consequences of the decision to withhold consent The granting of access to your personal details is optional, except for cases in which the details collected must be used to implement a contract or deliver a service you have requested. In such cases, refusal to grant access to your details will make it impossible for us to respond to, or act upon, your request. 3. Persons responsible for data processing and disclosure limits The personal details you supply will be disclosed to, and utilised by, the employees of Hotel Caravel and/or our overseas subsidiaries for the sole purpose of carrying out the activities that constitute the reason for which the details were collected in the first place (for example, to implement a sales or service contract or to send out newsletters). The data may be disclosed to other parent, subsidiary and/or associated companies of Hotel Caravel Group in Italy, the EU or countries outside the EU, on condition that the legislation in place in the destination country (or the country or countries through which the data may pass) is sufficient to ensure an adequate level of protection of your details. The adequacy of the protective measures in place will be evaluated by comparing the system used in the relevant country with the system used in Italy. Your details may also be disclosed to IT service providers, banks, financial intermediaries, credit institutions, other financial bodies, managers of centralised IT systems (risk and anti-fraud centres, etc.), insurance companies, consultants and freelance professionals who may assist us in the recovery of debts and the resolution of disputes, packaging companies, couriers and delivery companies or companies that provide postal and marketing services, bodies and companies specialising in research, and non-profit associations and foundations. 4. Your rights as the data subject The party responsible for the processing of the collected data is Hotel Caravel, located at No. 9, Via di Coize, 38069 Torbole sul Garda (TN), Italy. As the data subject, you can contact this party in writing in order to exercise your rights under Article 7 of Italian Legislative Decree No. 196/2003, which include the right to: 1) be informed as to the source of the personal details held, the purpose(s) for which they are being processed, and the systems used (when the processing operations are carried out electronically); be informed of the contact details of the party responsible for the processing operations, and receive information on the individuals and categories of individuals to whom your personal details may be disclosed 2) request the updating, correction or completion of the details held, or the cancellation, making anonymous or blocking of access to any details processed illegitimately, including those details that do not require to be stored in relation to the purpose(s) for which they were originally collected and subsequently processed; request confirmation that the requested form and content of the data-protection operations have been communicated to any individuals to whom the details have been disclosed, unless doing so would be impossible or would require the allocation of resources that are clearly disproportionate to the right being protected 3) oppose, for legitimate reasons, the processing of the personal details in question, even if still relevant to the purpose(s) for which they were collected; oppose the processing of the relevant personal details if said operations are being carried out with a view to sending you advertising, direct sales, market research or commercial material. Art. 7. Right of access to personal details and other rights (Italian Legislative Decree No. 196/2003 - the Italian Data Protection Act) 1. The data subject has the right to be informed as to the existence of any personal details that concern him or her - even if they have yet to be recorded - and to receive a copy of said details in an intelligible form. 2. The data subject has the right to be informed as to: a) the source of the personal details held b) the purpose(s) for which they are being processed c) the systems used (in cases where the processing operations are conducted using IT equipment) d) the contact details for the party legally responsible for the processing operations, the data manger and the designated representative, as per the prescriptions of Paragraph 2, Article 5 e) the parties to which the details may be disclosed, or which may be given access to the details as the designated local representatives of the State, as managers or functionaries 3. The data subject has the right to request: a) the updating, correction or, where necessary, completion of the details b) the cancellation, making anonymous or blocking of access to any details processed unlawfully, including those details that are not required to be held in relation to the original purpose for which the details were collected and subsequently processed c) confirmation that the operations described at point a) and b) have been communicated to all those to whom the details were disclosed, except when the act of fulfilling this obligation would be impossible or would require the expenditure of funds that are clearly disproportionate to the right being protected. 4. The data subject has the right to oppose, fully or partially, for legitimate reasons: a) the processing of the personal details that concern him or her, even if relevant to the purpose for which they were collected b) the processing of his or her personal details for the purposes of sending out publicity or direct sales material, or for the completion of market research surveys or for commercial communications. Article 13. Information for data subjects (Italian Legislative Decree No. 196/2003 - the Italian Data Protection Act) 1. The data subject, or any party from whom personal details are collected, must be informed in advance, either verbally or in writing, as to: a) the purposes of the processing operations and the methods to be used b) whether the granting of consent for the requested details to be processed is obligatory or voluntary c) the consequences of failing to grant consent d) the parties or categories of parties to whom the details may be disclosed, or who may be given access to the details in their roles as data processors or data managers, and the disclosure limits of said details e) the rights set out in Article 7 f) the identity of the data manager and, where designated, of the data manager's local representative (in compliance with the terms of Article 5) and of the data processor. If several data processors have been designated by the data manager, at least one of said processors must be identified, as must either the internet site on which, or any other mechanisms through which, the current list of data processors can easily be consulted. If a data processor has been designated to provide responses to data subjects in cases where the rights set out in Article 7 are to be exercised, the data processor in question must be identified. 2. The declaration described in Paragraph 1 must also contain the regulations set out in the relevant Articles of the Italian Data Protection Act, though certain regulations may not be included if they are already known to the party supplying the details or if their disclosure would compromise any monitoring and control operations being carried out by public-sector agencies for purposes of national security or for the detection, suppression or prevention of offences. 3. The Guarantor may issue a provision setting out simplified arrangements for the public to access information and support on their rights by telephone. 4. Whenever the personal details are not supplied directly by the data subject, the data subject must, in any case, be informed of the content of Paragraph 1 (including information on the categories of details to be processed) at the time in which the details are recorded, or if the details are to be disclosed to third parties, no later than when the details are disclosed for the first time. 5. The terms of Paragraph 4 shall not apply if: a) the details are being processed in order to comply with legal requirements, regulations or EU directives b) the details are being processed either to allow the counsel for the defence to conduct investigations (as per the terms of Italian Law No. 397, issued on the 12th of December, 2000) or to assert or defend a legal right, on condition that the details are processed exclusively for said purposes and for a period of time lasting no longer than that which is strictly necessary c) the provision of the relevant information to the data subject would require the allocation of resources that the Guarantor, on prescribing appropriate measures, declares to be clearly disproportionate to the right being protected, or if the provision of the relevant information to the data subject would be, in the judgment of the Guarantor, impossible.