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Privacy Policy 2

Privacy Policy

This Privacy Policy describes how personal data of users visiting the website
www.palmaserahospitality.com is processed, in accordance with Regulation (EU) 2016/679 (“GDPR”) and applicable Italian data protection law.


1. Data Controller

The Data Controller is:
FRACAM srls
Address: Via del Mirto 5, 08022 Cala


2. Types of data processed

a) Browsing data

IT systems and software procedures used to operate the website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

Such data may include, for example:
• IP addresses
• domain names of the devices used
• URI addresses of requested resources
• time of the request
• method used to submit the request to the server
• size of the file received in response
• server response status code
• other operating system parameters

This data is used exclusively for:
• obtaining anonymous statistical information
• ensuring proper functioning and security of the website


b) Voluntarily provided data

Sending emails voluntarily or filling in forms on the website results in the collection of the data provided by the user, such as:
• first and last name
• email address
• phone number (if requested)
• message content

Such data is used exclusively to respond to requests.


3. Purpose and legal basis of processing

Personal data is processed for the following purposes:
a) enabling website navigation
b) responding to information requests
c) managing bookings
d) complying with legal obligations
e) aggregated statistical analysis of the website (where applicable)
f) sending promotional communications (only with consent)

Legal bases:
• performance of pre-contractual measures
• legal obligations
• user consent
• legitimate interest of the Data Controller


4. Online bookings – Booking Engine

Bookings are managed through an online booking system provided by Blastness S.r.l., acting as Data Processor pursuant to Article 28 of the GDPR.

Data entered during the booking process (e.g. personal details, contact information, stay details) is processed for:
• booking management
• communication with the customer
• contractual and administrative obligations

Further information is available in the privacy notice provided during the booking process.


5. Statistical analysis and digital tools

The website may use analytics tools to collect aggregated and anonymous information about website usage (e.g. pages visited, time spent, traffic sources), solely to improve services.

The website may also include links or integrations with social platforms such as:
• Instagram
• Facebook

Interaction with these platforms may involve the processing of personal data by those platforms, acting as independent Data Controllers.


6. Recipients of personal data

Personal data may be disclosed to:
• technical and IT service providers
• hosting and website maintenance providers
• booking engine providers
• professional advisors (legal, tax, accounting)
• competent authorities, when required by law


7. Data transfers

Personal data is primarily processed within the European Union.

Any transfer to non-EU countries is carried out in compliance with the GDPR and with appropriate safeguards.


8. Data retention period

Personal data is retained:
• for as long as necessary for the stated purposes
• for the duration of the contractual relationship (in case of booking)
• in accordance with legal obligations
• until consent is withdrawn (where applicable)


9. Data subject rights

Users may exercise the rights provided under Articles 15–22 of the GDPR:
• access to personal data
• rectification or deletion
• restriction or objection to processing
• data portability (where applicable)

Users may also file a complaint with the Italian Data Protection Authority.


10. How to exercise rights

Requests may be sent to the Data Controller:

FRACAM srls
Via del Mirto 5, 08022 Cala Gonone (NU), Italy
info@palmaserahospitality.com


11. Changes to this policy

This Privacy Policy may be updated from time to time.
Users are encouraged to review it periodically.