Privacy & Cookies

PRIVACY POLICY & COOKIE POLICY

1. Data Controller

The data controller responsible for the processing of personal data in connection with this website is:

ALEA Garda Lake Suite S.r.l.
Via Narzelle n. 14 – 38062 Arco (TN), Italy
Tel.: +39 333 681 9962
Email: info@alea-suite.com
VAT No.: 02437350222
CIN: IT022006B4KHS5MIUE

For any questions regarding the processing of personal data or to exercise the rights described below, users may contact the data controller at the email address indicated above.

2. Place of Data Processing

Data processing relating to the web services of this website takes place at the data controller's premises and/or with external service providers appointed to provide technical and organisational services for the operation of the website, the management of enquiries and bookings, and the analysis of website usage.

Data is processed by duly authorised personnel and service providers. Where required, external service providers are appointed as data processors in accordance with Article 28 GDPR.

3. Types of Data Processed

3.1 Browsing Data

The IT systems and software procedures used to operate this website collect certain personal data during their normal operation. The transmission of such data is inherent in the use of internet communication protocols.

This information may include IP addresses or domain names of the devices used, URI addresses of requested resources, the time and method of the request, the size of files received, server response codes, and information relating to the user's operating system and technical environment.

This data is processed to ensure the proper operation and security of the website, identify technical issues and, where applicable, compile statistical information on website usage. Where possible, such data is processed in aggregated or anonymised form.

3.2 Data Voluntarily Provided by Users

When users complete contact forms, send enquiries, request information or make a booking through the website, personal data necessary to handle the relevant request may be collected.

This may include, in particular, first and last name, email address, telephone number, requested stay dates, number and composition of guests, and any further information voluntarily provided by the user.

Such data is processed to respond to enquiries, prepare offers, manage bookings and provide the requested services.

Providing data marked as necessary is required to process the relevant request or provide the requested service. Failure to provide such data may make it impossible to handle the request.

3.3 Booking-Related Data

For online bookings, ALEA uses the external booking system Booking Expert, a solution provided by Zucchetti Hospitality S.r.l., Piazza Mino Zucchetti 1, 26900 Lodi (LO), Italy.

When users make a reservation or start the booking process, the personal data required for this purpose may be processed through the external booking system. This may include identification and contact details, stay information, guest details, booking information and, where applicable, payment-related information.

The processing is carried out to take pre-contractual steps, fulfil the booking contract and manage the stay. Depending on the specific arrangements, Booking Expert may act as a technical service provider and data processor or may have its own independent data protection responsibilities for certain processing activities.

Further information about data processing by Booking Expert and the Zucchetti Group companies is available at:
https://bookingexpert.com/privacy

3.4 Special Categories of Personal Data

The data controller does not generally intend to collect special categories of personal data within the meaning of Article 9 GDPR through this website.

If users voluntarily provide such information, it will only be processed where legally permitted and necessary for the relevant purpose.

4. Purposes and Legal Bases for Processing

Personal data is processed for the following purposes, in particular:

responding to contact and information requests;
preparing offers and handling booking enquiries;
making and managing reservations and stays;
taking pre-contractual steps and fulfilling contractual obligations;
complying with legal obligations, particularly tax and accounting requirements;
ensuring the technical functionality and security of the website;
analysing and statistically evaluating website usage through Google Analytics;
measuring the effectiveness of advertising activities and creating advertising audiences through Meta Pixel;
protecting the data controller's legitimate interests, for example, establishing, exercising or defending legal claims.

Depending on the purpose, processing is based on one or more of the following legal grounds under Article 6 GDPR:

Article 6(1)(a) GDPR – Consent: in particular, for non-essential analytics and marketing cookies and similar tracking technologies.
Article 6(1)(b) GDPR – Contractual necessity or pre-contractual steps: for example, handling enquiries and processing bookings.
Article 6(1)(c) GDPR – Legal obligation: for example, complying with statutory record-keeping and reporting requirements.
Article 6(1)(f) GDPR – Legitimate interests: for example, ensuring the security and proper functioning of the website and protecting legal claims, provided that the interests and fundamental rights of the data subject do not override those interests.

Any consent given may be withdrawn at any time with effect for the future. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

5. Cookies and Other Tracking Technologies

Cookies are small text files that a website may store on a user's device. These files can be accessed again when the user visits the website at a later time.

In addition to cookies, similar technologies may be used, such as pixels, tracking scripts or other tools capable of collecting information about website usage.

5.1 Strictly Necessary Cookies

These cookies are required for the operation of the website and to provide the functions expressly requested by the user. They may, for example, enable basic navigation, store certain settings or technically support enquiry and booking processes.

Strictly necessary cookies do not require the user's prior consent.

5.2 Functional Cookies

Functional cookies allow the website to remember certain user preferences, such as language settings or other individual choices.

Where these cookies are not strictly necessary for the operation of the website, they are only used with the user's consent.

5.3 Analytics and Statistics Cookies – Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, to evaluate website usage and improve its content and functionality.

For this purpose, information about website usage, technical device information, IP addresses and other browsing data may be processed and transmitted to Google. The specific processing depends on the Google Analytics configuration in use.

Analytics cookies and similar technologies are activated only after the user's prior consent, unless a legal exemption applies.

Further information about Google's data processing:
https://policies.google.com/privacy

5.4 Marketing and Tracking Technologies – Meta Pixel

This website uses the Meta Pixel, a tracking and analytics tool provided by the Meta group of companies.

The Meta Pixel enables actions performed by users on the website to be recorded, the effectiveness of advertisements on Facebook and Instagram to be measured, and audiences to be created for advertising activities. For example, it can help determine whether users visit the website or perform certain actions after clicking on an advertisement.

For this purpose, information relating to website visits, pages viewed, actions performed, IP addresses, device and browser information, as well as cookies and online identifiers, may be transmitted to Meta. If users are also logged in to Facebook or Instagram, Meta may be able to associate the information collected with their respective accounts.

The recipient of data collected through the Meta Pixel is, in particular, Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Further processing by Meta Platforms, Inc. in the United States cannot be excluded.

The Meta Pixel is activated, and the related processing of personal data for marketing and tracking purposes takes place, only after the user's prior consent.

Further information about Meta's data processing:
https://www.facebook.com/privacy/policy/

Information about Meta Business Tools:
https://www.facebook.com/legal/terms/businesstools

5.5 Cookies and Technologies Used by External Booking Services

In connection with the booking function, the external booking system Booking Expert may use its own cookies or similar technologies that may be necessary to provide and technically manage the booking process.

Further information about the technologies actually used and their storage periods depends on the technical configuration of the booking system and the information provided by the relevant provider.

5.6 Managing Cookie Preferences

When users first visit the website, a cookie banner is displayed, allowing them to give or refuse consent to the different categories of cookies and tracking technologies.

Users may select their preferences and change or withdraw previously given consent at any time with effect for the future. Consent can be managed through the cookie settings function available on the website.

Strictly necessary cookies cannot be disabled through this function, as they are required for the operation of the website.

Disabling certain cookies may result in some website functions becoming unavailable or operating with limitations. Cookies may also be managed or deleted through the settings of the user's internet browser.

6. Voluntary Nature of Providing Data

Except for technically necessary browsing data, users are generally free to provide or withhold their personal data.

However, failure to provide certain data may make it impossible to respond to an enquiry, prepare an offer or complete a booking.

Consent to non-essential analytics and marketing technologies is voluntary. Refusing such technologies must not prevent users from accessing the essential functions of the website.

7. Data Processing Methods and Retention Periods

Personal data is processed using appropriate technical and organisational measures to ensure its security and confidentiality and to protect it against loss, unlawful use, unauthorised access or improper disclosure.

Retention periods depend on the relevant processing purpose:

Contact and information requests are retained for as long as necessary to handle them and, where appropriate, for any further period justified by documentation requirements or the protection of legitimate interests.
Booking and contractual data is retained for the duration of the contractual relationship and subsequently in accordance with statutory retention requirements.
Tax and accounting data is retained in accordance with applicable statutory retention periods.
Browsing and technical data is retained for the period necessary to ensure the security and proper operation of the website.
Analytics and marketing data is processed in accordance with the consents given, the settings of the services used and the retention periods established by those services.

After the relevant retention periods have expired, data is deleted or anonymised unless further retention is required by law or justified by legitimate grounds.

8. Disclosure of Data and Recipients

Personal data collected may be disclosed, to the extent necessary for the purposes described above, to the following categories of recipients:

employees and authorised personnel of the data controller;
IT, hosting and technical service providers;
website and booking system providers, particularly Booking Expert and Zucchetti Hospitality S.r.l.;
analytics and tracking service providers, particularly Google in connection with Google Analytics;
Meta Platforms Ireland Limited and, where applicable, other companies within the Meta group in connection with the Meta Pixel;
communication, email and administrative service providers;
tax advisers, legal advisers and other professional consultants;
banks and payment service providers, where necessary to process payments;
public authorities and institutions where required by law.

These recipients receive only the data necessary to provide their respective services or perform their duties.

Where required, external service providers are contractually appointed as data processors in accordance with Article 28 GDPR. Personal data is not publicly disclosed.

9. Transfers of Personal Data to Third Countries

When using external services, particularly Google Analytics and Meta Pixel, personal data may be processed or transferred outside the European Economic Area (EEA), particularly to the United States.

Such transfers are carried out in compliance with the requirements of Articles 44 et seq. GDPR, for example on the basis of an adequacy decision of the European Commission, certification under the EU-U.S. Data Privacy Framework or appropriate safeguards such as Standard Contractual Clauses, where applicable to the specific circumstances.

Further information about relevant transfers may be found in the privacy notices of the respective providers or requested from the data controller.

10. Rights of Data Subjects

Under Articles 15 et seq. GDPR, data subjects have the following rights, in particular:

Right of access (Article 15 GDPR): the right to obtain confirmation as to whether personal data is being processed and, where applicable, access to such data and a copy thereof.
Right to rectification (Article 16 GDPR): the right to have inaccurate or incomplete personal data corrected.
Right to erasure (Article 17 GDPR): the right to request the deletion of personal data under the conditions provided by law.
Right to restriction of processing (Article 18 GDPR): the right to request the restriction of processing in the cases provided for by law.
Right to data portability (Article 20 GDPR): the right to receive certain personal data in a structured, commonly used and machine-readable format or request its transfer to another controller.
Right to object (Article 21 GDPR): the right to object to certain processing activities on grounds relating to the user's particular situation. Users may object at any time to the processing of personal data for direct marketing purposes.
Right to withdraw consent: the right to withdraw consent at any time with effect for the future.

To exercise these rights, users may contact the data controller:

ALEA Garda Lake Suite S.r.l.
Via Narzelle n. 14 – 38062 Arco (TN), Italy
Email: info@alea-suite.com

Data subjects also have the right to lodge a complaint with the competent data protection supervisory authority. In Italy, this is:

Garante per la protezione dei dati personali
Website: https://www.garanteprivacy.it/

11. Data Security

The data controller implements appropriate technical and organisational security measures to protect personal data against loss, destruction, unlawful or unauthorised processing and unauthorised access.

Security measures are determined taking into account the nature of the data processed, the relevant risks and the state of the art, and are updated where necessary.

12. Links to External Websites

This website may contain links to external websites or online services operated by third parties.

The processing of personal data on such external websites is the sole responsibility of the respective operators and is governed by their own privacy notices.

Users are therefore advised to consult the privacy notices of the relevant providers before using their services.

13. Changes to This Privacy Policy

The data controller reserves the right to update this Privacy Policy where necessary, particularly in response to legal, organisational or technical changes.

The latest version will be published on this website.

14. Contact

For any questions regarding the processing of personal data or to exercise the rights provided by applicable law, users may contact the data controller: