Privacy Policy of www.marlena.it
This Application collects some Personal Data from its Users.
Owner and Data Controller (Art. 4 para. 7 GDPR)
Hotel Marlena GmbH
Via Tramontana 6
39020 Marlengo
Italy
Tel: +39 0473 222266
E-Mail: info@marlena.it
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data and email address.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes 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 Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (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 Owner at any time
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purpose of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Displaying content from external platforms, Interaction with external social networks and platforms, Remarketing and behavioral targeting, Analytics, SPAM protection, Tag Management, Handling payments and Managing landing and invitation pages.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective 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:
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States - Privacy Policy. Privacy Shield participant.
Google AdWords conversion tracking (Google Inc.)
Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on this Application.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States - Privacy Policy. Privacy Shield participant.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data
Place of processing: United States - Privacy Policy - Opt Out. Privacy Shield participant.
Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services
Google may use the Data collected to contextualize and personalize the ads of its own advertising network
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US
Personal Data collected: Cookies and Usage Data
Place of processing: United States - Privacy Policy - Opt Out. Privacy Shield participant.
SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use .
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Video Vimeo (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Mapbox widget (Mapbox Inc.)
Mapbox is a maps visualization service provided by Mapbox Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
The right of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise there rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about User's Personal Data
Legal action
The User's Personal Data may be used for legal purposes by the Owner 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 Owner may be required to reveal personal data upon request of public authorities.
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.
System log 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) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How „Do Not Track” requests are handled
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.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Personal information is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes an individual identified or identifiable.
Usage Data
The information collected automatically through this Application (also from third-party applications integrated in this Application), including: the IP addresses or domain names of the computers used by the User that connects with this Application, the addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the user.
User
The individual who uses this Application which, unless otherwise specified, coincides with the interested party.
Interested party
The physical person to whom the Personal Data refers.
Data Processor (or Manager)
The physical person, legal person, public administrator and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller (or Owner)
The physical or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of processing personal data and the instruments adopted, including security measures relating to the functioning and the use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The hardware or software tool through which Users' Personal Data are collected and processed.
Service
The Service provided by this Application as defined in the relevant terms (if any) on this site / application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.
Cookie
Small portion of data stored in the User's device.
Legal references
This privacy statement is drafted on the basis of multiple legislative orders, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy statement applies exclusively to this Application.
Online Marketing and Landing Pages
Beside our website we do also operate optimized landing pages. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”). The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
You can prevent the data collection connected to your use of our online services through cookies and the processing of this data by Google, by installing the browser-plugin available at the following link:
https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence. Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. If you continue using the website or click on the respective button you consent to the use of cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.
Additive+ Marketing Automation
In order to increase customer loyalty and to sell our services and additional services we use software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”).
Therefore your data, which we gather and process in connection with your request, reservation, order, activation, registration or the transmission of other contact forms on our website, will be analysed and used to provide you with automatically generated offers for our services and additional services. The adequate level of data protection is based on data processing agreements.
You can deny the use of your data for this purpose anytime by clicking on the “unsubscribe” link in the respective message.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the prevention of competitive disadvantages, the increase in brand awareness and the maximisation of our economic success through an optimal use of the acquired contacts.
Additive+ Vouchers
On our website you have the possibility to buy vouchers. To process your purchase and to save and store your data we use software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”). Through the use of these services and systems your data will be processed and stored in the EU.
The data you provide is required to fulfil the contract or to carry out pre-contractual measures. Without this data we cannot conclude a contract with you. The data will not be transferred to an outside third party, except for your credit card data which will be transferred to the payment provider and to our tax accountant to fulfil our tax obligations.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) and/or lit b (processing necessary for the performance of a contract) of the GDPR.
Additive+ Newsletter
On our website you have the possibility to subscribe to our newsletter. For the subscription we need your email address and your consent to receive our newsletter through ADDITIVE, our provider for hotel e mail marketing. To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin in our hotel newsletter tool.
After signing up for our newsletter you will receive an email containing a link to confirm the subscription.
Your subscription can be cancelled any time by clicking on the cancellation link in the respective newsletter.
To process your subscriptions and to send our newsletters we use software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”). Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.