Information on the processing of personal data of users
Articles 13 and 14 of Regulation 2016/679 / EU (hereafter also "GDPR")

Why do we collect information?
LO.AN. Srl (hereinafter also referred to as "LO.AN." or "Controller") is committed to respecting and
protecting your privacy and wishes you feel safe both during the simple browsing of the site and in case
you decide to register by providing your personal data to use the services made available to its Users
and/or Customers. On this page LO.AN. and Jointes controllers as better indicated below intend to
provide some information on the processing of personal data relating to users who visit or consult the
website accessible by electronic means from the address http://www.hotelsantacostanza.it(the "Site").
The information is provided only for the website of the Controller not for other websites that may be
consulted by the user through links (for which reference is made to the respective privacy policies).
Reproduction or use of pages, materials and information contained within the Site, by any means and on
any medium, is not permitted without the prior written consent of LO.AN.. Copying and/or printing for
use only personal and non-commercial (for requests and clarifications, contact the owner at the
addresses indicated below).
Other uses of the content, services and information on this site are not permitted.
With regard to the content offered and the information provided, LO.AN. will ensure that the contents
of the Website are kept up-to-date and revised without offering any guarantee as to the adequacy,
accuracy or completeness of the information provided explicitly declining any responsibility for any
omission errors in the information provided on the Website.

Origin - Navigation data
LO.AN. informs you that the personal data you provide and acquired together with the request for
information and/or contact, registration on the site and use of services via smartphones or any other
instrument used to access the Internet, as well as data necessary for the provision of these services,
including the navigation data and data used for the eventual purchase of the products and services
offered by LO.AN. but also the data only "navigation" of the site by Users, will be treated in
compliance with applicable law. The computer systems and software procedures used for the operation
of this website acquire, during their normal operation, some personal data whose transmission is
implicit in the use of the Internet. This is information that is not collected to be associated with
identified interested parties, but which by their very nature could, through processing and association
with data held by third parties, allow users to be identified as navigators. This category of data includes
the "IP addresses" or domain names of the computers used by users who connect to the site, the
addresses in the URI’s (Uniform Resource Identifier) notation of the requested resources, the time of
the request, the method used in the submit the request to the web server, the file size obtained in
response, the numerical code indicating the status of the response given by the web server (success,
error, etc.) and other parameters related to the operating system and the computer environment of the
user. These data are used for the sole purpose of obtaining anonymous statistical information on the use
of the site and for checking the correct operation of the LO.AN. website. Please note that the
aforementioned data could be used to ascertain responsibility in the case of computer crimes. against the
site of the owner or to other sites connected to it or connected to it.

Origin - Data supplied by the user
LO.AN. collects, stores and processes your personal data in order to provide the products and services
offered on the Site, or for legal obligations. With regard to some specific Services, Products,
Promotions, etc. the Data Controller may process your data for commercial purposes. In such cases, a
specific, separate, optional and always revocable consent will be required with the methods and the
contact details indicated below. The optional, explicit and voluntary sending of emails to the addresses
indicated in the appropriate section of the Website, as well as the compilation of questionnaires (for
example form), communication via chat, push notification via APP, social networks, call centers, etc.,
involves the subsequent acquisition of some of your personal data, including those collected through the
use of Apps and related services, necessary to respond to requests. We also point out that when using
the mobile connection to access digital content and services offered directly by LO.AN. or by our
partners it may be necessary to transfer your personal data to such third parties. We point out that you
may access the Site or connect to areas where you may be able to publish information using blogs or
bulletin boards, communicate with others, for example coming from the web page of LO.AN. on
Facebook®, Google + ®, Twitter®, and other sites social networks, reviewing products and offers and
posting comments or content. Before interacting with these areas, please read the General Conditions of
Use carefully taking into account that, under certain circumstances, the information published can be
viewed by anyone with access to the Internet and all the information you include in your publications
can be read , collected and used by third parties. We may process data of a particular/sensitive nature as
defined by the GDPR provided by you voluntarily in the notes field of the booking form, because they
are instrumental to the provision of our services (food allergies, disabled people, health information,
etc.). Such data will be processed in accordance with the General Authorization of the Guarantor for the
protection of personal data n. 5 and will be treated by us in strict confidence and will not be
disseminated.

CONTACT USER - ADDRESS MANAGEMENT AND SENDING OF EMAIL MESSAGES:
Mailing List or Newsletter
This type of service allows us to manage a database of email, telephone or of any other type of contacts
data, used to communicate with the User.
These services may also allow us to collect data relating to the date and time the messages are displayed
by the User, as well as to the User's interaction with them, such as information on clicks on the links
inserted in the messages.

INTERACTION WITH SOCIAL NETWORK AND EXTERNAL PLATFORMS:
This type of services allow interactions with social networks, or other external platforms, directly from
the pages of this Application.
The interactions and information acquired by this Application are in any case subject to the User's privacy
settings related to each social network.
If an interaction service with social networks is installed, it is possible that, even if the Users do not use
the service, the same collect traffic data relating to the pages in which it is installed.
Like button and Facebook social widgets (Facebook, Inc.)
The 'Like' button and Facebook social widgets are services of interaction with the social network
Facebook, provided by Facebook, Inc.
Personal Data collected: Cookies and Usage
Data. Place of processing: USA - Privacy
Policy
+1 button and Google+ social widgets (Google Inc.)
The +1 button and Google+ social widgets are services for interacting with the Google+ social network,
provided by Google Inc.
Personal Data collected: Cookies and Usage
Data. Place of processing: USA - Privacy
Policy
Tweet button and Twitter social widgets (Twitter)
The Tweet button and Twitter social widgets are services of interaction with the Twitter social network,
provided by Twitter Inc.
Personal Data collected: Cookies and Usage
Data. Place of treatment: USA - Privacy Poli

Purposes of processing and legal basis
The data are processed for the purposes:
1) strictly connected and necessary to make a reservation on the website www.hotelsantacostanza.it, to
the services and/or Apps developed or made available by the Data Controller, to the use of the related
information services, to the management of contact requests or information,

2) for ancillary activities related to the management of User/Customer requests and sending the
feedback that may include the transmission of promotional material; for the refinement of the
reservation, including the aspects related to payment by credit card, the update on the availability of
rooms and services temporarily unavailable;

3) use the credit card issued as guarantee for any charge as a penalty in the event of cancellation after
the deadline to exercise the right of withdrawal defined in the booking confirmation, or in case of
failure to arrive at the agreed date (procedure of no show);

4) related to the fulfillment of obligations under EU and national regulations, the protection of public
order, the detection and prosecution of crimes and safeguarding the rights of LO.AN. as well as to
comply with current administrative, accounting and tax obligations;

5) direct marketing, namely sending of advertising material, direct sales, carrying out market research
or commercial communication of products and / or services offered by LO.AN.; this activity may also
concern products and services of Omnia Hotels Group companies and be performed by sending
advertising/ informative/promotional material an/or invitations to participate in initiatives, events and
offers aimed at rewarding users / customers, carried out using "traditional" methods (for example, paper
mail and/or calls from an operator), or through "automated" contact systems (for example SMS and / or
MMS, telephone calls without operator intervention, e-mail, fax, interactive applications), pursuant to
art. 130 c. 1 and 2 of Legislative Decree. 196/03 and s.m.i.;

6) direct marketing, namely sending of advertising material, direct sales, carrying out market research
or commercial communication of products and/or services offered by Fleming 2009 srl – Omnia Hotels
Group and be performed by sending advertising/informative/promotional material and/or invitations to
participate in initiatives, events and offers aimed at rewarding users/customers, carried out using
"traditional" methods (by way of exemplary paper mail and/or operator calls), or through "automated"
contact systems (for example SMS and / or MMS, telephone calls without operator intervention, e-mail,
fax, interactive applications), pursuant to art. 130 c. 1 and 2 of Legislative Decree. 196/03 and s.m.i..

The provision of data for the purposes referred to in points 1), 2), 3) and 4) connected to a precontractual and/or contractual phase or functional to a user's request or required by a specific regulatory
provision, is mandatory and, failing that, it will not be possible to receive the information and access the
services requested; with regard to point 5) and 6) of this Information, the consent to the processing of
data by the user/customer is instead free and optional and always revocable without consequences on the usability of
the products and services except the impossibility for the owner to keep updated on new initiatives or
on particular promotions or advantages available to users/customers. LO.AN. may send commercial
communications relating to products and/or services similar to those already provided, pursuant to
Directive 2002/58/EU, using the electronic or paper coordinates, indicated by you on such occasions to
which you may object in the manner and at the addresses indicated below.

Methods, treatment logics, storage times and security measures
The processing is also carried out with the aid of electronic or automated means and is carried out by
LO.AN. and/or by third parties of which LO.AN. may use to store, manage and transmit the data. The
processing of data will be carried out with the logic of organization and processing of your personal
data, including the logs originating from access and use of services made available via the web,
products and services used
related to the purposes indicated above and, however, so to guarantee the security and confidentiality of
data. The personal data processed will be kept for the time required by the legislation in the applicable
time.

Always with regard to data security, in the sections of the website set up for particular services, where
personal data are requested from the user, the data is encrypted using a security technology called
Secure Sockets Layer, abbreviated to SSL. The SSL technology encodes the information before it is
exchanged via the Internet between the user's computer and the central systems of LO.AN., making
them unintelligible to unauthorized parties and thus guaranteeing the confidentiality of the information
transmitted; moreover, the transactions carried out using electronic payment instruments are carried out
using the payment service provider's platform (PSP) directly and the Owner retains only the minimum
set of information necessary to manage any disputes. In particular with reference to the personal data
protection aspects, the user/customer is invited, pursuant to art. 33 of the GDPR to report to LO.AN.
any circumstances or events from which a potential "breach of personal data (data breach)" may occur
in order to allow an immediate evaluation and the adoption of any actions aimed at combating such
event by sending a communication privacy.hsc@omniahotels.com or by contacting Customer Service.
The measures adopted by LO.AN. do not exempt the Customer /User from paying the necessary
attention to the use, where required, of a password/PIN of adequate complexity, which will have to be
updated periodically, especially if he was supposed to be violated/known by third parties, as well as
carefully guard and make inaccessible to third parties, in order to avoid improper and unauthorized use.

Areas of communication and data transfer
For the pursuit of the aforementioned purposes, LO.AN. will be able to communicate and have the
personal data of users /customers deal with third parties with whom we have relationships, where these
third parties provide services at our request. We will provide these third parties with only the
information necessary to perform the services required by taking all measures to protect your personal
data. The data may be transferred outside the European Economic Area if this is necessary for the
management of your contractual relationship. In this case, the recipients of the data will be imposed
security and security obligations equivalent to those guaranteed by the Data Controller. In the case of
use of services offered directly by Partners we will provide only the data strictly necessary for their
execution. In any case, only the data necessary for the achievement of the intended purposes will be
communicated and, where required, the guarantees applicable to transfers of data to third countries will
be applied. We may also disclose personal data to our suppliers of commercial services, for marketing
reasons, for this purpose appointed external processors. In addition, personal data may be disclosed to
the competent public bodies and authorities for compliance with regulatory requirements or for
ascertaining responsibility in the case of computer crimes to the detriment of the site as well as
communicated to, or allocated to, third parties (as responsible or, in the case of providers of electronic
communication services, autonomous owners), who provide information and telematic services (for
example hosting, management and development of websites) of which LO.AN. makes use of tasks and
activities of a technical and organizational nature that are instrumental to the functioning of the website.
The subjects belonging to the above categories operate as separate Data Controllers or as Processor
appointed for this purpose by LO.AN..
Personal data may also be known by LO.AN. employees / consultants who are person acting under the
authority of the Controller or of the Processor specifically instructed and appointed as “Incaricato del
trattamento”.

Rights of the data subject
You can exercise at any time the rights that are recognized by law, including that: a) to access your
personal data, obtaining evidence of the purposes pursued by the Owner, the categories of data
involved, the recipients to whom they may be communicated, the applicable retention period, the
existence of automated decision-making processes; b) to obtain without delay the correction of
inaccurate personal data concerning you; c) to obtain, in the cases provided for, the deletion of your
data; d) to obtain the limitation of the treatment or to oppose it, whenever possible; e) to request the
portability, where applicable to processing, of the data you have provided to LO.AN., i.e. to receive
them in a structured format, commonly used and readable by automatic device, also to transmit this data
to another holder, within the limits and with the constraints envisaged by art. 20 of the GDPR;
Furthermore, you may propose a complaint to the Supervisory Authority pursuant to art. 77 of the
GDPR. For the treatments referred to in point 5) and 6) of the purposes, the Customer can always
withdraw the consent and exercise the right to oppose direct marketing (in "traditional" and
"automated" form). The opposition, in the absence of a contrary indication, will be referred to both
traditional and automated communications.

Data Controller
The data controller is LO.AN. SRL based in Viale XXI Aprile, 4 - 00162 Rome. The rights indicated
above may be exercised at the request of the interested party in the manner disclosed on the Company's
website or by using the following references: LO.AN.. -Ref. Privacy- Viale XXI Aprile, 4 - 00162
Rome, e-mail: privacy.hsc@omniahotels.com.
The use of the Website, including those intended for tablets and / or smartphones, by the Customer and
/ or the User implies full knowledge and acceptance of the content and any indications included in this
version of information published by the Owner in the when the site is accessed.
LO.AN. informs that this notice may be changed without prior announcement and therefore
recommends a periodic reading.

Jointes controllers
LO.AN. SRL uses, in the context of processing customer data, IT systems jointly with third parties, all
companies belonging to the Omnia Hotels Group, which therefore become "Jointes controllers" of the
processing pursuant to art. 26 of the GDPR and relations with them are governed by a specific contractual
agreement.
The text of the agreement of, joint control in its essential contents, is available at the headquarters of
FLEMING 2009 s.r.l., with address: Viale Pinturicchio, 84-00196 Rome and may be viewed and made
available upon written request to the address pec: fleming2009@legalmail.it

The list of joint owners and their respective identification details is indicated below:

- FLEMING 2009 s.r.l., with registered office in Viale Pinturicchio, 84 - 00196 Rome;

- ALFA HOTEL 2007 SRL, with registered office in Piazza Monteleone di Spoleto, 20 - 00191 Rome;

- BELLA HOTEL 2007 SRL, with registered office in Via Vittorio Veneto, 24 - 00187 Rome;

- DONNA LAURA 2011 S.r.l. with registered office at Lungotevere delle Armi, 21 - 00195 Rome;

- FA.PA. S.R.L. with registered office in Viale Algeria, 141 - 00144 Rome;

- LO.AN. S.r.l. with registered office in Viale XXI Aprile, 4 - 00162 Rome;

- ST. MARTIN S.R.L. with registered office in Viale Pinturicchio, 84 - 00196 Rome;

- DOUHET 2005 S.r.l. with registered office in Piazza Monteleone di Spoleto, 20 - 00191 Rome;

- SHANGRI 2019 S.r.l. with registered office in Viale Pinturicchio, 84 - 00196 Rome;

- GERI 2009 S.r.l. with registered office in Viale Pinturicchio, 84 - 00196 Rome;

- SAR 2009 S.r.l. with registered office in Via Ludovisi, 43 - 00187 Rome;

- S.I.A.G.A. S.p.a. with registered office in Via Boncompagni, 19 - 00187 Rome.

This privacy policy was updated on 25 November 2021.