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

Why do we collect information?

ST.MARTIN 2019 Srl (hereinafter also referred to as "ST.MARTIN" 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 ST.MARTIN 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.shangrilaroma.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 ST.MARTIN. 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, ST.MARTIN 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
ST.MARTIN 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
ST.MARTIN . 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 ST.MARTIN 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
ST.MARTIN 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 ST.MARTIN 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 ST.MARTIN 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 Policy

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.shangrilaroma.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 ST.MARTIN 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 ST.MARTIN; 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 pre-contractual
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. ST.MARTIN 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
ST.MARTIN and/or by third parties of which ST.MARTIN 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 ST.MARTIN, 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 ST.MARTIN 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 a
privacy.hsm@omniahotels.com or by contacting Customer Service. The measures adopted by ST.MARTIN
.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, ST.MARTIN 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 ST.MARTIN
.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 ST.MARTIN.
Personal data may also be known by ST.MARTIN 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 ST.MARTIN, 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 ST.MARTIN SRL based in Viale Pinturicchio 84 - 00196 Roma. 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: ST.MARTIN. -Ref. Privacy- Viale Pinturicchio 84 - 00196
Roma, e-mail: privacy.hsm@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.
ST.MARTIN informs that this notice may be changed without prior announcement and therefore
recommends a periodic reading.

Jointes controllers
ST.MARTIN 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.