Personal data protection code

Legislative decree n. 196 of 30 June 2003

This page will describe management of our web site as regards processing the personal data of users that visit us. This information is provided - also in pursuance of Section 13 of Legislative Decree no. 96/2003. The information provided only applies to our web site and does not concern any web sites that may be visited by an user via external links. The information provided is also based on the guidelines contained in Recommendation no. 2/2001, which was adopted on 17 May 2001 by the European data protection authorities within the Working Party set up under Article 29 of European Directive 95/46/EC in order to lay down minimum requirements for the collection of personal data online - especially with regard to arrangements, timing and contents of the information to be provided by data controllers to users visiting web pages for whatever purpose. The above Recommendation as well as a summary of its purposes can be found in another section of this site.

DATA CONTROLLER AND DATA PROCESSOR

Visiting this site may result into the processing of data concerning identified or identifiable persons. The data controller and the data processor is the ower of this website.

PLACE WHERE DATA IS PROCESSED

The processing operations related to the web-based services that are made available via this website are carried out at the aforementioned office of the ower of this wbsite. The personal data obtained from the users who submit hotel reservation requests or through informative material (informative notes, newsletters, registration, etc) is used only to carry out the services or assistance requested and is not transmitted to third parties, except in the following possible cases:

• Business partners of the ower of this website transmits the data exclusively in order to avoid on-line reservations;
• Persons, companies or professional offices who lend assistance and consulting services to ower of this website concerning accounting, administrative, legal, financial and tax matters;
• Subjects who are authorized to have access to the data by law or through requests by the authorities;

CATEGORIES OF PROCESSED DATA

Navigation Data

The information systems and software procedures relied upon to operate this web site acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties.

This data category includes IP addresses and/or the domain names of the computers used by any user connecting with this web site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment.

These data are only used to extract anonymous statistical information on website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the website.

Data Provided Voluntarily by Users

Sending e-mail messages to the addresses mentioned on this website, which is done on the basis of a freely chosen, explicit, and voluntary option, entails acquisition of the sender's address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the messages. Data will be retained only for reservations, registration request to send the newsletters and or special offers, and will not be disclosed to anyone. Specific summary information notices will be shown and/or displayed on the pages that are used for providing services on demand. The personal information regarding the individual who visited the website is not collected or used. The visitors remain anonymous. The only exception to this rule concerns the information for personal identification needed to fulfill the contractual obligations of reservations on behalf of the user.

Reservations

In the event of reservations made through the website, the user must provide his name, address, telephone number and information regarding the payment manners and credit card used. Grand Hotel Palace will use said information only to process the reservations and to send specific information, which is relevant to the confirmation of said, such as a receipt, the reservation code and the conditions. The information provided will not be used for marketing purposes and will not be sold, transmitted, given by contract or sent to third parties an any way. In any event, the

administrator of the website guarantees the use of scrupulous procedures in order to protect the navigational data and the use of particular precautions to protect the data pertaining to the credit card, which is provided during on-line reservations.

PROCESSING ARRANGEMENTS

Personal data is processed with automated means for no longer than is necessary to achieve the purposes for which it has been collected. Specific security measures are implemented to prevent the data from being lost, used unlawfully and/or inappropriately, and accessed without authorisation.

DATA SUBJECTS' RIGHTS

Data subjects are entitled at any time to obtain confirmation of the existence of personal data concerning them and be informed of their contents and origin, verify their accuracy, or else request that such data be supplemented, updated or rectified (Section 7 of Legislative Decree no. 196/2003). The above Section also provides for the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data. All requests should be emailed to or sent to ower address.