We wish to inform you, pursuant to articles 12,13 and 14 of the European Regulation 2016/679 also known as the ‘General Data Protection Regulation’ (hereinafter ‘GDPR’) on the protection of individuals with regard to the processing of personal data and on the free movement of such data, that the information and data supplied by you or otherwise acquired as part of the services provided by Residence Escoffier Srl will be processed in compliance with the aforementioned provisions and with the obligations of confidentiality that inspire the activity of our organisation.
By processing of personal data we mean any operation or set of operations, carried out even without the aid of electronic instruments, concerning the collection, registration, organisation, conservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, diffusion, cancellation and destruction of data, even if not registered in a database.
The purpose of this notice is to make transparent the purposes for which we may use your data, how we will handle it, to whom it may be disclosed, where it may be transferred (within or outside the EU) and what your rights are.
1. Who processes your data?
Your data will be processed by Residence Escoffier Srl as Data Controller.
In addition to Residence Escoffier Srl we would like to inform you that there are External Persons in charge of the processing of personal data who have been duly mapped, surveyed, contracted and appointed by Residence Escoffier Srl on the basis of the provisions of art. 28 of the GDPR. The list of external Data Processors for the processing of Personal Data is available at the offices of Residence Escoffier Srl.
2. Why do we need your data?
Residence Escoffier Srl will use your data exclusively for the following purposes: Purposes related to the management of the contractual relationship and the provision of Services. Your data will be processed for the following purposes: establishment, management and termination of the contractual and commercial relationship; fulfilment of accounting and tax obligations; fulfilment of legal obligations anti-money laundering controls; tax and accounting audits; management of disputes; provision, support, updating and information regarding the Services offered. Purposes related to marketing activities and newsletters. With your specific consent, your data will be processed for the following purposes: sending newsletters, advertising, informative and promotional material and updates on initiatives, promotions and offers by Residence Escoffier Srl.
3. Purposes related to the processing of images with photos and videos.
With your explicit consent, data concerning you (for example: images, videos and other material collected during events organised by Residence Escoffier Srl in which you will take part) will be processed for promotional activities. Residence Escoffier Srl will carry out processing:
on the basis of your consent;
because it is necessary to fulfil the contractual obligations indicated in point 1;
because it is necessary to fulfil the legal obligations to which you are subject
because the processing is required in order to pursue a legitimate interest (e.g. safeguarding of strategic company interests and business relations).
It follows that the provision of Personal Data is strictly necessary for the purposes referred to in point 1.
Failure to provide data will result in the impossibility of achieving the aforementioned purposes and therefore of continuing the contractual relationship.
Purposes 2 and 3 do not derive from a legal obligation and the provision of the relevant consent is optional.
The extent and adequacy of the Data conferred will be evaluated from time to time, in order to determine the consequent decisions and avoid the processing of Data in excess of the purposes pursued.
Residence Escoffier Srl undertakes not to use your personal data for purposes other than and in addition to those described in this informative note, unless we inform you in advance and, where necessary.
4. How will we use your data?
Residence Escoffier Srl has as its objective the protection of its customers' data, imprinting their processing to the principles of correctness, lawfulness and transparency. We therefore inform you that your personal data will be processed using instruments and procedures that guarantee maximum security and confidentiality, by means of archives and paper supports, with the aid of digital supports, computerised and telematic means. We would like to remind you that you have the right to exercise your right to object, which, in the absence of your indication to the contrary, will apply to both traditional and automated communications.
5. How long will we keep your data?
Your personal data will be kept for no longer than is necessary for the purposes for which it was collected and subsequently processed. Personal data will be retained for the entire duration of the contract you have concluded and also for a period thereafter in accordance with the following criteria:
within the terms established by the legislation in force;
within the terms established by the legislation, including secondary legislation, which impose the retention of data (e.g. tax returns);
within the period necessary to protect the rights of the data controller in the event of any disputes relating to the provision of the service. In any case, the maximum data retention time is estimated at 10 years from the date of the data collection.
6. Will we share your data with other parties?
For the purposes indicated above (‘Why we need your data’) your Data may be communicated to third parties, in order to fulfil obligations deriving from the law, regulations, community norms or for aspects concerning the management and execution of the contractual relationship.
Moreover, Data will be processed by internal resources of Residence Escoffier Srl, adequately trained, who act as persons authorised to process the Data.
Access to archived Data may only be carried out by public authorities, in the cases and modalities foreseen by the laws in force, in the event of legal disputes. Your Personal Data will not be subject to dissemination.
7. What are your rights?
At any time, you have the right to request:
access to your personal data;
their correction in case of inaccuracy;
their deletion;
the limitation of their processing.
8. You will also have:
the right to object to the processing of your personal data, even if the processing is carried out in the pursuit of a legitimate interest of Residence Escoffier Srl;
the right to the portability of your personal data, i.e. to receive your personal data in a structured, commonly used and machine-readable format.
We will process your request with the utmost care to ensure the effective exercise of your rights.
Finally, you will have the right to lodge a complaint with the national supervisory authority (Garante Privacy). Please refer to Chapter III of the GDPR for full details of your rights.
9. Can you revoke your consent once given?
Yes, you may revoke your consent at any time, without this however: affecting the lawfulness of processing based on the consent given before revocation; affecting further processing of the same data based on other legal grounds (for example, contractual obligations or legal obligations to which Residence Escoffier Srl is subject).
The identification details of the Data Controller for the processing of the data you have provided are as follows: Residence Escoffier Srl with registered offices in Sanremo (IM) via Escoffier, N.18 info@residencesanremo.com to which you may refer at any time to exercise the rights provided for by the GDPR and listed in detail above.
The Data Controller
Residence Escoffier Srl