PRIVACY POLICY

1)

Purpose of processing

Italianway manages “short-term rental agreements” for third parties. The data provided by the client interested in leasing will be processed for the following purposes:

• to conclude a short-term rental agreement

• to validate the booking through the payment of an amount defined by the commercial policies on the website. The payment is managed by an external entity (Stripe), through its systems, operating as an autonomous data controller which requires the data for its execution.

• to send commercial communication related to the accommodation services, perform direct sales activities, or carry out market surveys or researches (including surveys on the quality of the services). Italianway SpA shall be using automated means of contact (such as e-mails, SMS, instant messaging, social networks, apps, automated calling systems without human involvement, etc.) and/or traditional means (such as calls with an operator, and ordinary mail).

Italianway will only process the data provided on the booking form. Specifically, the booking form does not require any sensitive data of the client or of the people who will be staying with them. In the event that the client decided to provide personal data classified as sensitive in the field “notes”, such data will be stored by Italianway and communicated to the personnel in charge of preparing the accommodation and of welcoming the client.

2)

Data collecting

The data collecting is carried out through spontaneous provision of the data by the client, when they decide to finalize their booking filling in the dedicated form and confirming their choice.

3)

Optional data provision and consent to their processing - consequences of a refusal

Notwithstanding the freedom of the clients to provide their data, it should be noted that not communicating the identifying (name, surname) and contact (e-mail address) data will lead to the impossibility to complete the booking procedure.

4)

Data communication and disclosure

In order to achieve the purposes above mentioned, the data provided by the clients will be communicated to the personnel in charge of preparing the accommodation and of welcoming the clients. Exceptions are made for any communications to the Legal Authority or to the Police upon their own request, to which Italianway is compelled to respond. The Italianway personnel responsible for the customer care will be able to access the data solely upon the request of the clients to resolve any problems related to the use of the “booking” service they may encounter.

Italianway will not disclose the data it collects and retains by any means.

5)

Methods by which data is retained and processed & for how long

The client’s data will be archived electronically by Italianway SpA on its servers hosted by the Amazon provider on its data centre located in Ireland.
The data will never be transferred outside of the European Economic Area (EEA).
The archived data will be retained for 10 years, after which they will be deleted.
The data will not be processed through automated decision-making processes.

6)

Rights of the data subject

The clients are entitled to ask Italianway SpA access to their personal data, its correction or erasure, or to object to its processing at any time; they have the right to request the limitation of the processing in the cases provided for by the Article 18 of the Regulation, as well as to obtain the data relating to them in a structured, commonly used format, readable by an automatic device, in the cases provided for by the Article 20 of the Regulation.

The requests can be sent to Italianway SpA to the address indicated in the following art. 7.

The clients are at all times entitled to lodge a complaint with the competent Supervisory Authority (Data Protection Supervisor), pursuant to Article 77 of the Regulation, if the clients consider that the processing of their Personal Data is contrary to the existing legislation.

7)

Data Controller

The Data Controller is Italianway SpA with registered office in Milan Via Luisa Battistotti Sassi 11 and operating headquarters in Milan, Via Luisa Battistotti Sassi 11. E-mail (privacy@italianway.house).

1)

Purpose of data processing

2)

Data collecting and type of collected data

For every section of the website:

• the data collection is carried out through spontaneous provision of the data by the user, when they fill in the contact form or send an e-mail and attach any further documents;

• the collection is only related to the common personal data

• if the user thinks it appropriate that indicating particular personal data, as defined by the art. 9 of the Regulation, such as:

  • data which reveal the ethnic or ratial origin;

  • political opinions, religious of philosophical beliefs;

  • trade unions membership;

  • data related to the health or the sexual life or the sexual orientation of the person;

• is necessary to the evaluation of their request, Italianway SpA will only process the data relevant to this purpose, to the extent that the collection of such data is strictly necessary.

3)

Optional data provision and consent to their processing - consequences of a refusal

For every section of the website:

• the user spontaneously decides to communicate their data to Italianway SpA by filling in the forms or by sending e-mails;

• the data defined as mandatory in the form is necessary to contact the user and provide them with answers related to their needs. If such information is not provided, the system will not send the form to Italianway SpA;

• if the user interacts by e-mail, they are free to communicate the data they deem most appropriate; if they do not indicate any contact data, Italianway Spa will send the answer to the sender’s e-mail address.

4)

Data communication and disclosure

4.1 Data communication

In order to achieve the purposes as set in Article 1, the data provided by the users and collected through the different sections of the website will be communicated to the departments of Italianway SpA responsible for the activities, and to third parties that collaborate with the company, as described in the following table:

Furthermore, for every section of the website:

• Where not currently contemplated, if Italianway SpA decided to collaborate with external subjects in managing the data, such fact will be reported updating the present policy.

• Where contemplated, the names of the third parties which collaborate with Italianway SpA can be found out contacting the company through the addresses indicated in the art. 7.

4.2 Data communication

For every section of the website:
The data will not be disclosed under any circumstances.

5)

Methods by which data is retained and processed & for how long

5.1 Where the data is retained

For every section of the website:

• The clients’ data will be archived electronically by Italianway SpA on its servers hosted by the Amazon provider on its data centre located in Ireland.

• The data will never be transferred outside of the European Economic Area (EEA).

5.2 How long the data will be retained

The data will be retained for different periods of time in relation to the purposes of the processing, as shown in the following table. In all cases, the data will be deleted at the end of the retention period.

5.3 Methods of the data processing

The data will be processed with different methods in relation to the purposes of the processing, as shown in the following table:

6)

Rights of the data subject

For every section of the website:

• The users are entitled to ask Italianway SpA access to their personal data, its correction or erasure, or to object to its processing at any time; they have the right to request the limitation of the processing in the cases provided for by the Article 18 of the Regulation, as well as to obtain the data relating to them in a structured, commonly used format, readable by an automatic device, in the cases provided for by the Article 20 of the Regulation.

• The requests can be sent to Italianway SpA to the address indicated in the following art. 7.

• The users are at all times entitled to lodge a complaint with the competent Supervisory Authority (Data Protection Supervisor), pursuant to Article 77 of the Regulation, if they consider that the processing of their Personal Data is contrary to the existing legislation.

7)

Data controller

For every section of the website:

• The Data Controller is Italianway SpA with registered in Milan Via Luisa Battistotti Sassi 11 and operating Headquarters in Milan, Via Luisa Battistotti Sassi 11. E-mail privacy@italianway.house.