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Privacy Policies

Your data and our website

How does it work?

Transparency first of all!

We will use Your data only to enable you to use our website.

On this page you will find all information about the processing of your personal data, where, when, how and why we process your data, as well as the list of your rights.

Your data will not be sold or transferred to Third Parties

Your data (data You entrust to us) will only be used by Vita S.r.l.

We will never sell or transfer your data.

In case we avail ourselves of external providers, they will only operate on our behalf and in accordance with our requirements.

How to contact us

Data Controller is Vita S.r.l., based in Via Giacomo Puccini, 3 - 20121 Milano

You may contact us anytime writing to our Data Protection Officer (RPD – DPO) at dpo@halldis.com

Our Website Privacy Policy

How we use Your personal data

Last update: 19th September 2024

Why this policy?

The present policy, provided in accordance with articles 13 and 14 GDPR, refers to halldis.com website (the “Site”) and is provided by Vita S.r.l., with registered office in Via Giacomo Puccini, 3 - 20121 Milano, FC 13361100962, VAT Code 10537050964, as Data Controller for the Processing of personal data.

The Site is property of Vita S.r.l., who is also the subject holder of the corresponding domain name.

In the present policy, the singular definitions also include the plural ones, and vice versa.

In accordance with GDPR, with the present Policy we want to inform You that Vita S.r.l. will process personal data received and collected through the Site as described below.

Data Controller

Vita S.r.l., as Data Controller for the Procesing of personal data may be contacted at:

  • Address: Vita S.r.l. - Via Giacomo Puccini, 3 - 20121 Milano

  • Telephone: +39 02 3859 2848 (Monday - Friday 9.30 - 13.30 and 15.00 - 18.00)

  • E-mail: privacy.team@halldis.com

Vita S.r.l., in accordance with the current legislation, has appointed a Data Protection Officer who may be contacted any time at dpo@halldis.com

What information do we collect, for what purposes and on what legal bases?

Vita S.r.l. will process personal data collected and/or provided through the Site according to the modalities and for the purposes described in this section.

Bookings through the Site

  • Processed Data. The moment the User decides to register on the Site to make a booking, Vita S.r.l. will process the following categories of personal data:

    • registration data:

      • name, surname;

      • e-mail address;

      • telephone number;

      • nationality;

    • booking data:

      • name, surname;

      • e-mail address;

      • telephone number;

      • nationality;

      • check-in/check-out date;

      • quantity of guests;

      • transaction amount;

    • invoicing data:

      • name, surname;

      • e-mail address;

      • telephone number;

      • residential address;

      • fiscal code;

    • data concerning the payment method (e.g. bank details, postal data).

    For further information concerning the processing of data related to the payment cards of the users please see paragraph 3.

  • Purpose of the Processing. The Data mentioned in the previous paragraph will be processed to allow the conclusion of the contract and the correct execution of the operations connected with it (and, if necessary according to the sector regulation, to fulfil tax obligations). Data will be also processed to activate the User account, as well as, to enable the User to access the reserved area on the Site and to use the online services offered by Vita S.r.l. to the registered Users.

  • Legal base. The legal base of the Processing is the need to execute the contract signed by the specific user upon booking a prop erty on the Site (art. 6, par. 1, lett. b) GDPR).

  • Need to provide data. Providing the data mentioned in this paragraph is necessary and failing this, it will not be possible to buying stays in the Properties and additional services through the Site of Hal ldis S.p.A..

  • Data Retention period. Vita S.r.l. will retain the processed data to allow the purchase of stays in the properties through their own Site for a maximum period of 10 (ten) years from the booking, except for the possibility to extend the ret ention period in case it is necessary to comply with a legal obligation which Vita S.r.l. is subjected or to protect a right of Vita S.r.l. in front of a competent authority. Data provided to create the account will be retained by Vita S.r.l. unti l the cancellation of it by the data subject which they refer.

Pre check-in

  • Processed Data. In order to carry out the guest communication to the Police headquarters within the meaning of art. 109 of TULPS and the communication to Istat concerning the number of tourists within the meaning of art. 7 of Legislative Decree n. 322/1989 and of DPR 25th November 2020, approval of the National statistical programme - Update 2019, Vita S.r.l. will process the following categories of personal data of the User:

    • name, surname, gender, nationality, date of birth;

    • city, region and country of birth, country of residence;

    • e-mail;

    • check-in/check-out date;

    • typology, number and expiry date of the identity document;

    • location (city/nation) of issue of the document;

    • Purpose of the Processing. The data mentioned in this paragraph wil be processed to carry out the guest communication to the Policy Headquarters and the communication to Istat concerning the number of tourists.

    • Legal base. The legal base of the processing is the nee d to comply with a legal obligation which Vita S.r.l. is subjected (art. 6, par. 1, lett. c) GDPR)

    • Need to provide data. Providing the data mentioned in this paragraph is necessary and, failing this, it will not be possible to comply with the legal obli gations and consequently it will not be possible to execute the contract.

    • Data Retention period. Vita S.r.l.will retain the processed data to allow the pre-check-in through their own Site for a maximum period of 10 (ten) years from the booking, except for the possibility to extend the retention period in case this is necessary to comply with alegal obligation Vita S.r.l. is subject or to protect a right of Vita S.r.l. in front of acompetent authority.

    Marketing activities

    • Processed Data. Some of the data provided by Users upon registration on the Site or upon purchasing a product through the Site, as: e-mail address, telephone number, and postal addresses.

    • Purpose of the Processing. Vita S.r.l. will be able to process the personal data mentioned in this paragraph to fulfil marketing activities, that may be realized in the following ways:

      • limited to the customers of Vita S.r.l., by sending e-mail messages – to the coordinates provided by them in the context of the purchase of a stay through the Site or upon registration - referred to services similar to the ones bought through the Site (so-called soft-spam)

      • by sending promotional newsletters, carrying out market surveys, also aimed at evaluating the level of users’ satisfaction, and by sending advertising material related to products and/or services by Vita S.r.l., also by means of automated systems, such as e-mails, or through traditional modalities e.g. paper mail or brochures) (marketing purposes), referred to services different from the ones bought by a customer through the Site or addressed to users that are not yet customers of Vita S.r.l.. The promotional messages and communications under consideration may refer, besides products and/or services by Vita S.r.l., also to products and/or services provided by companies belonging to the same group as Vita S.r.l.. In this regard, Vita S.r.l. will not share data subjects’ data with these companies but will directly send messages and communications related to their own products. In this case the legal base of the processing is the consent of the date subjects to the execution of such activities;

    • Legal bases of the processing. The legal bases on which the processing of personal data carried out by Vita S.r.l. for direct marketing purposes is based, are respectively:

      • the legitimate interest of Vita S.r.l. in case of communications related to services similar to the ones bought from their customers on the Site (soft-spam), in accordance with what is foreseen from art. 6, par. 1, lett. f) GDPR and from art. 130, comma 4 D.lgs. 196/2003 (“Privacy Code”). The users have the possibility to object to the processing in the modalities referred to in the following paragraph and

      • the consent of data subjects in case of promotional messages sent to interested parties that are not customers of Vita S.r.l. or related to services different from the ones bought from a customer of Vita S.r.l. (art. 6, par. 1, lett. a) GDPR).

    Data subjects can object to the processing of their own personal data for such purposes sending an e-mail to the Company’s Data Protection Officer at dpo@halldis.com or through the specific link mentioned at the end of any e-mail with promotional content sent by Vita S.r.l.. The objection expressed with these modalities extends to communications sent by postal service.

    • Need to provide data. Providing the data mentioned in this paragraph, as well as giving consent to the processing where required, is optional and, the possible lack will not affect neither the registration of a user on the Site, nor the completion of a purchase through the same.

    • Data retention. Data processed for direct marketing purposes will be retained for a period of 24 (twenty-four) months from the provision of these and the consent to the processing, where required. At the end of this period, Vita S.r.l. will require the renewal of consent to the processing of data. Vita S.r.l. can extend the above-mentioned retention period if this is necessary to comply with a legal obligation retained by Vita S.r.l. or to protect a right of Vita S.r.l. in front of a competent authority.

    Data provided in occasion of contacts with the data subjects

    • Processed Data. Vita S.r.l. will be able to process the personal data provided by the data subjects (e.g. name, surname, contact details, any other piece of information included in the data subject’s inquiries) when they decide to contact the company owner through the contact details present on the Site (e.g. telephone number, e-mail, paper post), in the context of a customer care service or for any other request related to services and activities of Vita S.r.l.

    • Purposes of the processing. Vita S.r.l. will process the personal data mentioned in this paragraph for the sole purpose of providing a response to the requests submitted by the data subjects.

    • Legal bases of the processing. The legal bases of the processing described in this paragraph are represent by:

      • the need to execute a purchase contract in the case of data subjects who contact Vita S.r.l. for customer care activities (art. 6, par. 1, lett. b) GDPR);

      • the consent of data subjects in case they contact Vita S.r.l. for any other type of information (art. 6, par. 1, lett. a) GDPR). In particular, the decision of a data subject to contact Vita S.r.l. submitting a request will be considered an unequivocal positive action equivalent to a written consent within the meaning of art. 4, n.11) GDPR.

    • Need to provide data. Providing the data mentioned in this paragraph is optional but, failing this, Vita S.r.l. will not be able to provide a response to the inquiries submitted by data subjects.

    • Retention period. Data processed according to what is reported in this paragraph will be retained for a period that is strictly necessary to provide a response tore data subjects’ inquiries. Vita S.r.l. can extend the above-mentioned period in case this is necessary to comply with legal obligations which they are subject or to protect a right of Vita S.r.l. in front of a competent authority.

    Browsing data

    When a user visits the Site, Vita S.r.l. collects the following browsing data:

    • technical information, including IP address, information on the devised used from the site visitors, on the browser and on the operating systems, etc.;

    • information on the Site navigation, including the URL of the visited pages and the activities carried out on the page, date and times of navigation, time spent on the Site, click stream.

    This data is collected for the Site correct functioning, management, maintenance and improvement, as well as to grant a safety navigation for the data subjects and to ensure the responsibility in case of cyber-security breaches. This data is also used to enable Vita S.r.l. to obtain statistical analysis on the use of the Site with the chance to analyze the data in aggregate form and to receive advertisements in line with their interests and desires.

    The processing of browsing data is also necessary to allow the completion of purchases through the Site.

    The Site users are free to decide whether they should provide their browsing data, for example by deciding to disable cookies through the browser settings. However, refusing to provide data necessary for the purpose of browsing may make it impossible to perform activities strictly connected to the browsing and, therefore, including the consultation and interaction with our Site, as well as the completion of purchases through the Site.

    This data is stored for the period that is strictly necessary to carry out the purposes they are collected for.

    Browsing data are collected through the use of cookies. To better know how cookies work, how to enable and disable them, consult our cookie policy

    Plug-in and interaction with social networks

    The Site allows the interaction with third parties’ sites and social networks (Google, Instagram, Facebook) through hyperlink, sharing buttons, social plug-in and other similar tools.

    By accessing one of the Site areas provided with this kind of tools, the Internet browser will connect data subjects directly with third parties servers, transferring their personal data to the site managers.

    The transfer of data will be carried out based on the consent of data subjects, unequivocally expressed when the click on a specific hyperlink, plug-in button or another similar tool.

    Depending on the specific arrangements with the site managers, Vita S.r.l. will be able to operate as independent Data Controller or Joint Data Controller with regards to data transfers. As regards methods used to protect privacy and the processing of personal data collected by third party site operators with which interactions take place, please refer to the relative sites.

Data relating to payment cards

To make a payment by means of one of the types of payments cards mentioned on the Site, the user inserts sensitive data relating to the payment card directly on the page that communicates via secure encryption protocol with the provider of Banca Sella’s Gestpay payment service (who operates as independent Data Controller) without transit from the server of Vita S.r.l. who, therefore, will not process in any way this data. Data will be acquired in encrypted format.

As regards the processing of data relating to the payment card, please note that this is necessary to allow the conclusion of the online purchase contact with Vita S.r.l.. Failure to provide this data will not allow users to complete the online purchase process

Processing modalities

The Processing of data subjects’ personal data will be mainly carried out with the aid of electronic or in any case automated means, with the modalities and with the appropriate tools to grant data security and confidentiality according to GDPR. In particular, all technical, IT, organizational, logistical and procedural security measures will be taken to ensure the minimum level of data protection required by law, enabling the access only to persons in charge of processing or Data processors appointed by Vita S.r.l.

The data acquired and the processing modalities will be relevant and not excessive for the typologies of services provided. Moreover, data will be managed and protected in environments under constant control.

Who do we share data with?

  • to all those subjects (including Public Authorities) who have access to the personal data pursuant to administrative and regulator measures;

  • to companies and third parties who provide services purchased through the Site;

  • to subjects in charge of check-in/check-out operations;

  • to banking institutions managing national and international payment circuits through which users make payment on line for products purchased through the Site;

  • to companies, consultants or professionals in charge for installing, maintaining, updating and, in general, managing hardware and software that Vita S.r.l. owns or use to provide their services;

  • to external companies in charge for sending advertising communications on behalf of Vita S.r.l.;

  • to employees and/or collaborators of Vita S.r.l.;

  • to subjects managing on-line payment transactions;

  • to all public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancies, Judicial Offices, Chambers of Commerce, Trades Councils, etc), in case the communication turns out to be necessary or functional to the correct fulfillment of the contractual obligations, as well as legal obligations.

Data subjects’ personal data will not be disclosed, except in anonymous and aggregated form, for statistics or research purposes.

Data transfer outside the EEA

Vita S.r.l. will not transfer data subjects’ personal data towards Countries outside the European Economic Area (“EEA”), that includes, besides the member states of European Union, Norway, Lichtenstein and Iceland.

In case it is necessary to fulfill the purposes of the processing described in this policy, Vita S.r.l. grants that all potential transfers of data outside the EEA will take place in order to grant the complete protection of rights and freedoms thereof. Where, with respect to the third Country of destination, the European Commission has not issued adequacy decisions, data transfer will be carried out adopting the guarantees provided by articles 46 and following of GDPR including standard contractual clauses approved by the European Commission, and a considered evaluation of the legislation of the third Country of destination.

Your data and how to contact us

We would like to remind you that you have the right to obtain from Vita S.r.l., where applicable, the access to personal data, their rectification and cancellation or the restriction of processing concerning you or to object to the processing (articles 15 and following of the Regulation).

Requests shall be addressed:

  • by e-mail, to the subject responsible for dealing with data subjects: privacy.team@halldis.com

  • or by post, in Vita S.r.l. - Via Giacomo Puccini, 3, 20121 Milano (Italia)

Right to complain

Data subjects who believe that the processing of their personal data is in violation of what is provided by the Regulation, have the right to lodge a complaint with the Data Protection Authority, as foreseen by art. 77 of the same Regulation or to take the appropriate judicial seats (art. 79 of the Regulation).

Changes

Vita S.r.l. has the right to make changes to this policy at any time, providing a suitable notification to the site users and granting in any case an adequate and similar protection of personal data. In order to view any updates, please consult this policy on a regular basis.

In any case, if Vita S.r.l. should make substantial changes to the present policy (e.g. processing of personal data for different and further purposes), they will inform data subjects by e-mail.