Privacy Statement for Business Partners
This privacy statement applies to
www.luxuryrelaisrome.com owned and managed by Luxury Relais Rome, Via Gregorio VII, 350, 00165 Roma (RM), Italia. P.IVA: 14147511001. It describes how Luxury Relais Rome collects and
processes personal data about (potential, existing or former) Trip
Providers and other business partners.
This Privacy Statement therefore applies to
personal data of owners, employees, representatives or other individuals
acting on behalf of a Trip Provider or other business partners (Trip
Providers, other business partners and the related individuals are
hereafter together or individually referred to as "Business Partners" or
"you"). A Business Partner within the meaning of this Privacy Statement
may be a Trip Provider (including the provider of accommodation,
attractions, park, museum, etc.), business partners enabling the
reservations of Trips through their websites and/or apps or other means,
including travel agencies, third party vendors and other business
partners maintaining a business relationship with Luxury Relais Rome.
For information on how Luxury Relais Rome uses cookies, click here.
Data collection
The personal data Luxury Relais Rome collects in regards
to Business Partners depends on the context of the business relationship
and interaction with Luxury Relais Rome, the choices made by a Business Partner
and the products, services and features used. The personal data Luxury Relais Rome collects about a Business Partner can include the following - depending
on the specific situation, not all of the following data items may be
considered personal data because they may relate to a business instead
of an individual:
Personal data you give to us
- Contact details: We collect
contact data of Business Partner, such as first name/ last name, date
of birth (as required), business e-mail address and address, telephone
and fax number.
- Financial data: We collect
data necessary for payment, including invoicing purposes, including your
bank details: bank account number, VAT number, credit slips.
- Verification details: As
part of the registration process, Luxury Relais Rome can ask (representatives of)
Business Partners to provide a copy of their ID card or passport, a
photo, video or other relevant information to verify the authenticity of
the Business Partner
Other information we collect automatically
When using the Luxury Relais Rome online services, such as
the online registration form, an online user account (e.g. extranet or
partner center), or make use of a Luxury Relais Rome app, Luxury Relais Rome also collects
information automatically, some of which may be personal data. This
includes data such as language settings, IP address, location, device
settings, device OS, log information, time of usage, URL requested,
status report, user agent (information about the browser version),
operating system, result (viewer or booker), browsing history, and type
of data viewed.
By sharing other individual’s personal data in
relation to your business (for example of your staff members), you
confirm that these individuals have been informed about the use of their
personal data by Luxury Relais Rome in accordance with this Privacy Statement and
provided any necessary consents.
Other information we receive from other sources
- Information on insolvencies:
In insolvency matters, Luxury Relais Rome can receive information from insolvency
administrators, courts or other public authorities relating to a
Business Partner.
- Data related to law enforcement and tax authority requests:
Law enforcement or tax authorities can contact Luxury Relais Rome with additional
information about Business Partners in case they are affected by an
investigation.
- Fraud detection: In certain
instances, and as permitted by applicable law, Luxury Relais Rome may need to
collect data through third party sources for fraud detection and
prevention purposes.
Processing purposes
Luxury Relais Rome uses the previously described Business
Partner information, some of which may be personal data, for the
following purposes:
A. Registration and account administration
Luxury Relais Rome uses account details, financial data and contact details for
registrations with Luxury Relais Rome, including verification purposes to manage
the business relationship with the Business Partner
B. Customer service
uses the
information provided, which may include personal data, to provide
support services, such as to respond to Business Partners’ requests,
questions and concerns
C. Other activities, including marketing
If
a Business Partner is making use of an online registration facility and
has not finalized the registration, Luxury Relais Rome may send a reminder to
carry on with the registration. We believe that this additional service
is useful to our (future) Business Partners because it allows to carry
on with the registration without having to fill in all the registration
details from scratch. Luxury Relais Rome may invite Business Partners to attend
and hosts events Luxury Relais Rome believe may be of relevance to a Business
Partner or use personal data to offer and host online forums to enable
Business Partners to find answers to commonly asked questions on the
usage of the Luxury Relais Rome services and the offering of their products and
services. Luxury Relais Rome uses personal data, such as contact data, to also
inform about system/product updates, to send the Luxury Relais Rome newsletter, to
invite a Business Partner to participate in referral programs or
competitions or for other marketing communications. When we use personal
data for direct marketing messages in electronic form, Luxury Relais Rome will
include a link to unsubscribe.
D. Messaging tools
Luxury Relais Rome
may offer certain Business Partners different means to communicate with
its guests. Business Partners can contact Luxury Relais Rome to forward
information or questions about reservations to guests or communicate by
use of e.g. alias emails, which always include Luxury Relais Rome as a recipient.
Luxury Relais Rome may access communications and uses automated systems to review,
scan, and analyse communications for security purposes; fraud
prevention; compliance with legal and regulatory requirements;
investigations of potential misconduct; product development and
improvement; research; customer engagement, including to provide guests
with information and offers that we believe may be of interest to them;
and customer or technical support. Note, all communications sent or
received using Luxury Relais Rome communication tools will be received and stored
by Luxury Relais Rome.
E. Analytics, improvement and research
Luxury Relais Rome uses the information provided, which may include personal data, for
analytical purposes. This is part of our drive to improve the Luxury Relais Rome
services and enhance user experience, but can also be used for testing
purposes, troubleshooting and to improve the functionality and quality
of the Luxury Relais Rome online services. Luxury Relais Rome also invites Business Partners
regularly to participate in surveys or conducts other market research.
Certain Business Partners may be invited to join a dedicated online
platform to interact with Luxury Relais Rome and/or exchange experiences with
other Business Partners. Please consult the information provided when
invited to participate in survey, market research or join the online
platform to understand how personal data may be treated differently from
this Privacy Statement.
F. Security, fraud detection and prevention
We
process the information provided, which may include personal data, in
order to investigate, prevent and detect fraud and other illegal or
violating activities. This may be personal data a Business Partner has
provided to Luxury Relais Rome, for example for verification purposes as part of
the registration process, personal data collected automatically, or
personal data obtained from third party sources (including from guests).
Luxury Relais Rome may also use personal data to facilitate prosecution where
necessary. For these purposes, personal data may be shared with law
enforcement authorities and external advisors. Luxury Relais Rome can use personal
data for risk assessment and security purposes, including the
authentication of users.
G. Legal and compliance
In
certain cases, Luxury Relais Rome needs to use the information provided, which may
include personal data, to handle and resolve legal disputes, for
regulatory investigations and compliance, or to enforce the agreement(s)
with Business Partners or solve a complaint with a booker as reasonably
expected.
Note that accommodation information, including
the name and address of the accommodation, will be used in accordance
with the General Delivery Terms as part of the separately executed
Accommodation Agreement (e.g. to display on third party websites to
enable the making of a Trip Reservation).
If we use automated means to process personal
data which produces legal effects or significantly affects you, we will
implement suitable measures to safeguard you rights and freedoms,
including the right to obtain human intervention.
Legal Bases: In view of purpose
A and B, Luxury Relais Rome relies on the legal basis that the processing of the
personal data is necessary for the performance of the agreement between
the Business Partner and Luxury Relais Rome. If the required information is not
provided, Luxury Relais Rome cannot register a Trip Provider or otherwise work
with a Business Partner, nor can we provide customer service. In view of
purposes C to G, Luxury Relais Rome relies on its legitimate commercial business
interest to provide its services or obtain services from Business
Partners, to prevent fraud and to improve its services. When using
personal data to serve Luxury Relais Rome’s or a third party's legitimate
interest, Luxury Relais Rome will always balance the Business Partners’ rights and
interests in the protection of their information against Luxury Relais Rome’s
rights and interests or those of the third party.
For purposes F and G, Luxury Relais Rome relies also where
applicable on compliance with legal obligations (such as lawful law
enforcement requests).
If you wish to object to the processing set out
under C to E and no opt-out mechanism is available to you directly (for
example, in your account settings), to the extent applicable, please
contact: vcrelais@gmail.com
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Facebook permissions asked by this Website
This Website may ask for some Facebook
permissions allowing it to perform actions with the User's Facebook
account and to retrieve information, including Personal Data, from it.
This service allows this Website to connect with the User's account on
the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
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Access to third-party accounts
This type of service allows this Website to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (this Website)
This service allows this Website to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Access private data and Current City.
Place of processing: United States –Privacy Policy.
Stripe account access (Stripe Inc)
This service allows this Website to connect with the User's account on Stripe, provided by Stripe, Inc.
Personal Data
collected: various types of Data as specified in
the privacy policy of the service.
Place of processing: United States –Privacy Policy.
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Contacting the User
Contact form (this Website)
By filling in the contact form
with their Data, the User authorizes this Website to use these details
to reply to requests for information, quotes or any other kind of
request as indicated by the form’s header.
Personal Data
collected: address, city, company name, country,
date of birth, email address, fax number, first name, gender, last name,
phone number, province, state, Tax ID, various types of Data, VAT
Number and ZIP/Postal code.
Mailing list or newsletter (this Website)
By registering on the mailing
list or for the newsletter, the User’s email address will be added to
the contact list of those who may receive email messages containing
information of commercial or promotional nature concerning this Website.
Your email address might also be added to this list as a result of
signing up to this Website or after making a purchase.
Personal Data
collected: address, city, company name, Cookies,
country, date of birth, email address, first name, gender, last name,
phone number, province, state, Usage Data, website and ZIP/Postal code.
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Handling payments
Payment processing services enable
this Website to process payments by credit card, bank transfer or other
means. To ensure greater security, this Website shares only the
information necessary to execute the transaction with the financial
intermediaries handling the transaction.
Some of these services may
also enable the sending of timed messages to the User, such as emails
containing invoices or notifications concerning the payment.
Gestpay Banca Sella (Banca Sella S.p.A.)
Gestpay is a payment service provided by Banca Sella S.p.A
Personal Data
collected: various types of Data as specified in
the privacy policy of the service.
Place of processing: Italy –Privacy Policy.
MyBank UniCredit (UniCredit S.p.A)
MyBank is a payment service provided by UniCredit S.p.A.
Personal Data
collected: various types of Data as specified in
the privacy policy of the service.
Place of processing: Italy –Privacy Policy.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data
collected: various types of Data as specified in
the privacy policy of the service.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data
collected: various types of Data as specified in
the privacy policy of the service.
Place of processing: United States –Privacy Policy.
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Heat mapping and registrazione sessioni
Heat mapping services are used to
display the areas of a page where Users most frequently move the mouse
or click. This shows where the points of interest are. These services
make it possible to monitor and analyze web traffic and keep track of
User behavior.
Some of these services may record sessions and make them available for later visual playback.
Smartlook (Smartsupp.com, s.r.o.)
Smartlook is a session recording and heat mapping service provided by Smartsupp.com, s.r.o.
Personal Data
collected: Cookies, Usage Data and various types
of Data as specified in the privacy policy of the service.
Place of processing: Czech Republic –Privacy Policy.
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Hosting and backend infrastructure
This type of service has the purpose
of hosting Data and files that enable this Website to run and be
distributed as well as to provide a ready-made infrastructure to run
specific features or parts of this Website.
Some of these services
work through geographically distributed servers, making it difficult to
determine the actual location where the Personal Data are stored.
ArubaCloud (Aruba S.p.A.)
ArubaCloud is a hosting service provided by Aruba S.p.A.
Personal Data
collected: various types of Data as specified in
the privacy policy of the service.
Place of processing: Italy –Privacy Policy.
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Interaction with live chat platforms
This type of service allows Users to
interact with third-party live chat platforms directly from the pages
of this Website, for contacting and being contacted by this Website
support service.
If one of these services is installed, it may
collect browsing and Usage Data in the pages where it is installed, even
if the Users do not actively use the service. Moreover, live chat
conversations may be logged.
Facebook Messenger Customer Chat (Facebook, Inc.)
The Facebook Messenger Customer
Chat is a service for interacting with the Facebook Messenger live chat
platform provided by Facebook, Inc.
Personal Data collected: About Me, Cookies and Usage Data.
Place of processing: United States –Privacy Policy.
Tawk.to Widget (tawk.to ltd.)
The Tawk.to Widget is a service for interacting with the Tawk.to live chat platform provided by tawk.to ltd.
Personal Data collected: Cookies and Usage Data.
Place of processing: United Kingdom–Privacy Policy.
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Infrastructure monitoring
This type of service allows this
Website to monitor the use and behavior of its components so its
performance, operation, maintenance and troubleshooting can be improved.
Which
Personal Data are processed depends on the characteristics and mode of
implementation of these services, whose function is to filter the
activities of this Website.
Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)
Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.
Personal Data
collected: various types of Data as specified in
the privacy policy of the service.
Place of processing: Turkey –Privacy Policy.
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Remarketing and behavioral targeting
This type of service allows this
Website and its partners to inform, optimize and serve advertising based
on past use of this Website 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 pagina di opt-out del Network Advertising Initiative.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a
remarketing and behavioral targeting service provided by Google Inc.
that connects the activity of this Website 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.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a
remarketing and behavioral targeting service provided by Facebook, Inc.
that connects the activity of this Website with the Facebook advertising
network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States–Privacy Policy – Opt Out.
Remarketing through Google Analytics for Display Advertising (Google Inc.)
Google Analytics for Display
Advertising is a remarketing and behavioral targeting service provided
by Google Inc. that connects the tracking activity performed by Google
Analytics and its Cookies 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.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a
remarketing and behavioral targeting service provided by Facebook, Inc.
that connects the activity of this Website with the Facebook advertising
network.
Personal Data collected: Cookies and email address.
Place of processing: United States –Privacy Policy – Opt Out.
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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.
Display Advertising extension for Google Analytics (Google Inc.)
Google Analytics on this Website
might use Google's Interest-based advertising, 3rd-party audience data
and information from the DoubleClick Cookie to extend analytics with
demographics, interests and ads interaction data.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States–Privacy Policy – Opt Out.
User ID extension for Google Analytics (Google Inc.)
Google Analytics on this Website
makes use of a feature called User ID. This setup allows for a more
accurate tracking of Users by associating that User with the same ID
over various sessions and devices. It is set up in a way that doesn’t
allow Google to personally identify an individual or permanently
identify a particular device.
The User ID extension might make it
possible to connect Data from Google Analytics with other Data about the
User collected by this Website.
The opt-out link below will only opt
you out for the device you are on, but not from tracking performed
independently by the Owner. Contact the Owner via the email address
provided in this privacy policy to object to the aforementioned tracking
as well.
Personal Data collected: Cookies.
Place of processing: United States –Privacy Policy – Opt Out.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data
collected: Usage Data and various types of Data as
specified in the privacy policy of the service.
Place of processing: United States –Privacy Policy.
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 Website, 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.
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
Website.
Personal Data collected: Cookies and Usage Data.
Personal Data collected–Privacy Policy.
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 Website.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States –Privacy Policy.
Wordpress Stat (Automattic Inc.)
Wordpress Stats is an analytics service provided by Automattic Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States –Privacy Policy.
Data sharing
- Sharing with affiliates. In
order to support the use of the Luxury Relais Rome services, your information,
which may include personal data, may be shared with subsidiaries of the
Luxury Relais Rome corporate family which act as service providers for Luxury Relais Rome,
including in relation to customer support services.
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Sharing with third parties.
We share Business Partners’ information, which may include personal
data, with third parties as permitted by law and as described below. We
do not sell or rent the personal data to third parties.
- Service providers (incl. suppliers).
We share personal data with third party service providers to provide our
products and services, store data or conduct business on our behalf.
These service providers shall process personal data only as instructed
by and to provide the service to Luxury Relais Rome.
- Payment Providers and other financial
institutions. To process payments between a Business Partner and
Luxury Relais Rome or a booker and a Business Partner, personal data, as relevant,
is shared with Payment Providers and other financial institutions.
- Compelled disclosure. When legally
required, strictly necessary for the performance of our services, in
legal proceedings, or to protect our rights or the rights of other
members of the Luxury Relais Rome Srl group or users, we disclose personal data to
law enforcement authorities, investigative organisations, or other
group members.
Sharing and disclosure of aggregated data:
we may share information in aggregate form and/or in a form which does
not enable the recipient of such information to identify you, with third
parties, for example for industry analysis and demographic profiling.
International data transfers
The transmission of personal data as described
in this Privacy Statement may include overseas transfers of personal
data to countries whose data protection laws are not as comprehensive as
those of the countries within the European Union. Where required by
European law, we shall only transfer personal data to recipients
offering an adequate level of data protection. In these situations, as
may be required, we make contractual arrangements to ensure that your
personal data is still protected in line with European standards. You
can ask us to see a copy of these contractual agreements using the
contact details below.
Security
In accordance with European data protection
laws, Luxury Relais Rome observes reasonable procedures to prevent unauthorised
access to, and the misuse of, information including personal data.
We use appropriate business systems and
procedures to protect and safeguard information including personal data.
We also use security procedures and technical and physical restrictions
for accessing and using the personal data on our servers. Only
authorised personnel are permitted to access personal data in the course
of their work.
Data retention
We will retain personal data for as long as we
deem it necessary to manage the business relationship with a Business
Partner, to provide the Luxury Relais Rome services to a Business Partner, to
comply with applicable laws (including those regarding document
retention), resolve disputes with any parties and otherwise as necessary
to allow Luxury Relais Rome to conduct its business. All personal data we retain
will be subject to this Privacy Statement and our internal retention
guidelines. If you have a question about a specific retention period for
certain types of personal data we process about you, please contact us
via the contact details included below.
Your choices and rights
We want you to be in control of how your personal data is used by us. You can do this in the following ways:
- you can ask us for a copy of the personal data we hold about you;
- you can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you;
- in certain situations, you can ask us to
erase, block or restrict the personal data we hold about you, or object
to particular ways in which we are using your personal data;
- in certain situations, you can also ask us to send the personal data you have given us to a third party
Where we are using your personal data on the
basis of your consent, you are entitled to withdraw that consent at any
time subject to applicable law. Moreover, where we process your personal
data based on legitimate interest or the public interest, you have the
right to object at any time to that use of your personal data subject to
applicable law.
We rely on you to ensure that your personal data
is complete, accurate and current. Please do inform us promptly of any
changes to or inaccuracies of to your personal data by contacting us.
Questions or complaints
If you have questions or concerns about our
processing of your personal data or you want to exercise any of your
rights you have under this Privacy Statement, please contact our data
protection officer via vcrelais@gmail.com.
All privacy related questions and complaints reported to Luxury Relais Rome will
be investigated. Luxury Relais Rome will attempt to resolve complaints and
questions in line with internal policies. You may also contact your
local data protection authority with questions and complaints.
Changes to the Privacy Statement
Just as our business changes constantly, this
Privacy Statement may also change. If we make material changes or
changes that will have an impact on you (e.g., when we start processing
your personal data for other purposes than set out above), we will
contact you prior to commencing that processing.