Privacy policy

We care and are committed to protecting the personal data of visitors of our website and users of our services. With this document we provide the data subjects with the information on the processing provided for by art. 13 and 14 of the Regulation EU 2016/679 – General Data Protection Regulation (“GDPR”).

This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service user; in other words, where we determine the purposes and means of the processing of that personal data.

By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

The Data Controller of the processing is Roma Borgo91 Bed & Breakfast, and its legal representative, who can be contacted at the email address info@romaborgo91.it. In this document we refer as “we”, “us” and “our” to Roma Borgo91 Bed & Breakfast or the Data Controller.

In this Section we describe:

• the general categories of personal data that we may process;
• the purposes for which we may process personal data; and
• the legal bases of the processing.

We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. Our analytics tracking system (Google Analytics) processed these data and produces aggregate anonymous reports for the purposes of analyzing the use of the website and services.

The legal basis for this processing is our legitimate interests of monitoring and enhancing our website and services (article 6.1.f), applicable because the anonymous form of the report does not present any risks for the individual data subjects.

We may process information contained in any inquiry you submit to us via telephone, email, web or social networks  regarding our goods and/or services (“inquiry data“).  Inquiry data may include Name, Last Name, language, telephone or fax number, email. Inquiry data may be processed for the purposes of offering and selling relevant services to you.

The legal basis for this processing is to take steps at the request of the data subject prior to entering into a contract (art. 6.1.b).

We may process your personal data that are provided by you in the course of the use of our services (“service data“). The service data may include your name, last name, telephone number, email address, gender, date and place of birth, place of residence, identity document numbers. The source of the service data is you or your employer. The service data may be processed for fulfilling the contract for providing our services.

The legal basis for this processing is the performance of a contract between you and us (art. 6.1.b) and a legal obligation (art. 6.1.c) that we, as Data Controller, have to register your stay with the Police (art. 109 of the Italian TULPS).

Within the Service Data we may process only Name, Last Name, Telephone and email to perform direct marketing activities for goods and services similar to the ones you have already purchased from us.

The legal basis for this processing is the art. 130 of the Italian Privacy Code (D.Lgs 108/18) that allows us to perform direct marketing activities without consent of the data subject, provided that he can exercise the right to stop such processing.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“).  The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.

The legal basis for this processing is the performance of a contract between you and us (art. 6.1.c) a legal obligation (art. 6.1.c) that we, as Data Controller, have to maintain proper fiscal records of the transactions.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data are Name, Last Name and email may be processed for the purposes of sending you the relevant notifications and/or newsletters.

The legal basis for this processing is consent (art. 6.1.a).

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person’s personal data to us, unless we prompt you to do so.

In processing your personal data we have taken all the necessary precautions to the maximum possible security, adopting the technical and organizational measures provided for by the art. 32, 33, 34, 35 and 36 of the GDPR. In particular:

• All operators who have access to personal data have been properly trained and have been authorized to process by the Controller.
• All computers on which personal data is processed are protected by login credentials (username and password);
• All computers on which personal data is processed are protected by malicious software (viruses and malware) through software programs updated to the latest available releases.
• All personal data is subject to periodic backups to guarantee availability.

All technical and organizational measures are subject to periodic reviews and are modified in line to best-practice available security norms, standards and technologies.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Financial transactions relating to our services may be handled by our payment services providers and banks. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at their relative websites.

We may disclose your inquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the inquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. In general the retention period is set to 10 years.

Personal data that use for direct marketing purposes will be kept as long as data subject does not request to stop the processing.

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

In this Section, we have summarized the rights that you have under GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Right to access – you have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.

Right to rectification – have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

Right to erasure – in some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

Right to restrict processing – in some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

Right to object to processing – you have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Right to data portability – to the extent that the legal basis for our processing of your personal data is:

• consent, or
• that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

Right to complain to a supervisory authority – if you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

Right to withdraw consent – to the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to our contacts.

The Data Controller is Roma Borgo91 Bed & Breakfast.

We are located in Borgo Vittorio 91, 00193 Rome – Italy.

Any request for information or for exercising data subject rights on personal data can be sent in either of the following:

• by email, to the address published on our website.
• by standard or registered mail, to the postal address above.

This is version 1.0 of 15/08/2022.

We may update our Privacy Policy by publishing a new version on our website.

Please check this page regularly to be informed of any modifications to our policy.