3. TOUREXP SRL’S PRIVACY PRINCIPLES
a. Transparency: when collecting and processing Your PI, we will provide You with relevant information and notice, for what purposes and who are the recipients.
e. Access, Rectification and Objection: : we offer You ways to access, modify, correct or delete Your PI. You also have the opportunity to object to the processing of Your PI for marketing purposes. Please see contact details below.
f. Confidentiality & Security: we will implement reasonable technical and organisational measures to protect Your PI against accidental or unlawful alteration or loss, or from unauthorized use, disclosure or access.
5. WHAT PERSONAL INFORMATION?
As a Tourexp srl ’s guest, You may be asked, at various times, to provide PI about Yourself and Your family members, such as:
◦ Contact information, e.g. name, telephone numbers, e-mail addresses, postal addresses, etc;
◦ Other personal details: date of birth; nationality,
◦ Children Information: name, birth date and age;
◦ Credit card details (only in transactional related system)
◦ Membership card numbers of any Accor S.A. (our franchisor) loyalty program or any membership number of frequent flyer or any other partner You are registered with;
◦ Your dates of arrival and departure/visit from our hotels;
◦ Your preferences and interests, e.g. smoking or non-smoking room, preferred location of Your room (low floor, high floor, etc.), type of bed, preferred newspaper, sports and cultural interests;
◦ Any questions/comments You may have during or after Your stay in one of our hotels.
We do not knowingly collect PI from children under the age of 18, except name, date of birth and nationality as provided directly by an adult on their behalf or with adult’s permission. Please make sure that Your children do not provide us with any PI without Your permission, e.g. online. If You believe Your child has submitted PI to us, please contact us so that we can delete such PI.
Generally, we do not knowingly collect sensitive information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sex life details.
In addition, depending on the applicable law, other data than those listed above may also be considered as sensitive data: credit card number, leisure habits, personal activities and hobbies, cultural habits, smoker/ non-smoker status, etc. However, we may need to collect such data which may be considered as sensitive, to satisfy Your request or provide You with specific services such as specific diet or any disability access facilities. In such case, if required by applicable law, we will ask You to expressly consent that we collect and process such sensitive information.
6. WHEN IS MY PERSONAL INFORMATION COLLECTED?
PI may be collected in certain circumstances including without limitation as follows:
a. Hospitality activities such as :
◦ Booking of an hotel room;
◦ Check in and check out;
◦ Consumption during a stay in an hotel as tracked through room charges;
◦ Claims, requests and/or disputes.
b. Participation in marketing programs:
◦ Registering with loyalty programs;
◦ Contribution to guests surveys and/or comments (e.g. “Guest Satisfaction Survey”, “Contact us”; “Guests comments”; “Satisfait ou invité”);
◦ Subscription to newsletters, to receive e-mail offers or promotions.
c. Provision of information by third party service providers:
◦ Tour operators, travel agencies, GDS reservation systems, others, ...
d. Internet activities:
◦ Connection to www.villaromanazzi.it (IP address);
◦ Fill in of an online collection form (e.g. online bookings, questionnaire, etc.).
7. WHAT ARE THE PURPOSES?
We use Your PI for the following purposes:
a. To manage Your reservation and booking:
◦ To book and reserve hotel rooms and requested accommodation;
◦ To establish and maintain business records and comply with accounting requirements;
◦ For back office processing; including managing a list of undesirable guests, further to a non-payment, or to improper behaviour, etc.
b. To manage Your stay at the hotel:
◦ To track consumption (telephone, bar, Internet, pay TV…);
◦ To access rooms.
c. To improve our hospitality services, including:
◦ To process Your PI in our clients relationship management program;
◦ To better understand Your needs and requests;
◦ To tailor our products and services to better suit Your desires.
d. To send You newsletters, promotions and marketing material or contact you about tourism, hospitality or services, hotel promotions. You can choose to unsubscribe from our Email Newsletters service by clicking a link in one of our email newsletters.
e. To improve our services, including:
◦ To conduct surveys and analyze guests’ questionnaires and comments and activity patterns
◦ To manage guests’ complaints.
◦ To let you benefit from our loyalty program
f. To secure and improve Your use of our Internet website, including:
◦ To improve website navigation and;
◦ To implement security and fraud prevention means.
g. To comply with local regulations (e.g. retention of business or accounting documents).
8. SHARING OF YOUR PERSONAL INFORMATION
a. We may share Your PI with any entity authorized individuals who need to access Your PI to provide You with the requested services or in the context of an action as a consequence of You providing such PI:
◦ Hotel Staff;
◦ Reservation Staff using Tourexp srl ’s reservation tools;
◦ Information Technology, commercial partnership and marketing departments;
◦ Medical services, if any;
◦ Legal Department, if necessary; and
◦ Any relevant individuals of Tourexp srl entities for specific categories of data.
b. External service providers and partners: we may share Your PI with third parties for providing You with the requested services and improving Your stay with us:
◦ Third party service providers: IT subcontractors, international call centers, banks, credit card providers; outside counsels, mailing service providers, printing companies;
◦ Commercial Partners.
c. Local authorities – internal investigations: we may also share information with local authorities if required by local law or as part of internal investigations in compliance with local regulations.
9. INTERNATIONAL TRANSFERS
10. DATA SECURITY
Tourexp srl takes appropriate technical and organisational measures, in accordance with local law requirements, to protect Your PI against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To this end, we have implemented technical measures such as firewalls and organisational measures such as a login/efficient password system, physical protection, etc.
You may have to enter Your credit card details to complete Your reservations; in such event, Tourexp srl uses Secure Socket Layer (SSL) technology to encrypt such PI.
This policy does not concern the access to the websites of any third parties and Tourexp srl is considered not to be responsible for the policy of those websites or for PI use.
11. DATA STORAGE
12. ACCESS AND MODIFICATION
If You wish to exercise Your rights on Your PI held by a specific hotel, then You must contact the hotel directly. Our contacts are listed in “Contacts” section.of our website.