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?
FA.PA. Srl (hereinafter also referred to as "FA.PA." 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 FA.PA. 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 FA.PA.. Copying and/or printing for use only personal and noncommercial (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, FA.PA. 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
FA.PA. 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 FA.PA.
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 FA.PA. 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
FA.PA. 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 FA.PA. 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 FA.PA. 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 FA.PA. 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 FA.PA.; 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. FA.PA. 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 FA.PA.
and/or by third parties of which FA.PA. 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 FA.PA., 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 FA.PA. 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.hsl@omniahotels.com or by contacting Customer Service. The measures adopted by FA.PA. 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, FA.PA. 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 FA.PA. 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 FA.PA..
Personal data may also be known by FA.PA. 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 FA.PA., 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 FA.PA. SRL based in Viale Algeria, 141 - 00144 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: FA.PA.. -Ref. Privacy- Viale Algeria, 141 - 00144 Roma, e-mail:
privacy.hsl@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.
FA.PA. informs that this notice may be changed without prior announcement and therefore recommends a
periodic reading.
FA.PA. and the other companies of the Omnia Hotels Group use the booking platform

Jointes controllers
FA.PA. 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.