Privacy Policy

Privacy Policy regarding the processing of personal data of website users
Articles 13 and 14 of Regulation (EU) 2016/679 (hereinafter also “GDPR”)

Why this notice: ST. MARTIN 2019 s.r.l. (hereinafter also “ST. MARTIN” or “Controller”) is committed to respecting and protecting your privacy and wants you to feel secure both during simple navigation of the site and in the event that 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 the Joint Controllers, as better indicated below, intend to provide information on the processing of personal data relating to users who visit or consult the website accessible electronically starting from the address http://www.shangrilaroma.it (the “Site”). This information is provided only for the Controller's website and not for other websites that may be consulted by the user via links (for which reference should be made to the respective privacy policies/notices). Reproduction or use of pages, materials, and information contained within the Site, by any means and on any support, is not permitted without the prior written consent of ST. MARTIN. Copying and/or printing is permitted for exclusively personal and non-commercial use (for requests and clarifications, contact the Controller at the addresses indicated below). Other uses of the content, services, and information presented on this site are not permitted. Regarding the content offered and information provided, ST. MARTIN will ensure that the Site content is kept reasonably updated and reviewed, without offering any guarantee on the adequacy, accuracy, or completeness of the information provided, explicitly declining any responsibility for any errors of omission in the information provided on the Site.

Origin - Browsing Data
ST. MARTIN informs that the personal data provided by you and acquired at the same time as the request for information and/or contact, registration on the site, and use of services via smartphone or any other tool used to access the Internet, as well as the data necessary for the provision of such services, including browsing data and data used for any purchase of products and services offered by ST. MARTIN, as well as the so-called “browsing” data of the site by Users, will be processed in compliance with applicable regulations. The computer systems and software procedures used to operate 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 its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes "IP addresses" or domain names of the computers used by users who connect to the site, URI (Uniform Resource Identifier) notation addresses of the requested resources, the time of the request, the method used in submitting the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (success, error, etc.) and other parameters relating to the user's operating system and IT environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check the correct functioning of the ST. MARTIN website. It should be noted that the aforementioned data could be used to ascertain responsibility in the event of computer crimes against the Controller's site or other sites connected or linked to it.

Origin - Data provided by the user
ST. MARTIN collects, stores, and processes your personal data for the purpose of providing the products and services offered on the Site, or for legal obligations. Regarding some specific Services, Products, Promotions, etc., the Controller may also process your data for commercial purposes. In such cases, a specific, separate, optional, and always revocable consent will be requested in the manner and at the contact details indicated below. The optional, explicit, and voluntary sending of e-mails to the addresses indicated in the appropriate section of the Website, as well as the filling out of questionnaires (e.g., forms), communication via chat, push notifications 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 inform you that when using a 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 could access the Site or connect to areas where you might be enabled to publish information using blogs or message boards, communicate with others, for example coming from the ST. MARTIN web page on Facebook®, Google+®, Twitter®, and other social network sites, review products and offers and publish comments or content. Before interacting with these areas, we invite you to carefully read the General Conditions of Use, keeping in mind that, in 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 special/sensitive nature as defined by the GDPR provided voluntarily by you in the notes field of the booking form, because they are instrumental to the provision of our services (food allergies, people with disabilities, health status information, etc.). The data in question will be processed in accordance with the General Authorization of the Data Protection Authority No. 5 and will be treated by us with the utmost confidentiality and will not be subject to dissemination. CONTACTING THE USER - ADDRESS MANAGEMENT AND SENDING OF EMAIL MESSAGES: Mailing List or Newsletter This type of service allows for the management of a database of email contacts, telephone contacts, or any other type of contact, used to communicate with the User. These services may also allow for the collection of data relating to the date and time messages are viewed by the User, as well as the User's interaction with them, such as information on clicks on links included in the messages.

INTERACTION WITH SOCIAL NETWORKS AND EXTERNAL PLATFORMS: This type of service allows for 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 for each social network. In the event that a social network interaction service is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages where it is installed. Facebook Like button and social widgets (Facebook, Inc.) The Facebook 'Like' button and social widgets are interaction services with the Facebook social network, 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 interaction services 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 interaction services with the Twitter social network, provided by Twitter Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing USA – Privacy Policy

Purposes of processing and legal basis
Data are processed for the following purposes:

1) strictly connected and necessary for making the reservation on the website www.shangrilaroma.it, for the services and/or Apps developed or made available by the Controller, for the use of related information services, for the management of contact or information requests;

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

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

4) related to the fulfillment of obligations provided for by EU and national regulations, the protection of public order, the assessment and repression of crimes and the safeguarding of the rights of ST. MARTIN 2019, as well as to fulfill current administrative, accounting, and tax obligations;

5) direct marketing, i.e., sending advertising material, direct sales, conducting market research or commercial communication of products and/or services offered by ST. MARTIN; this activity may also concern products and services of Omnia Hotel Group Companies and be carried out 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 (for example, 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 paragraphs 1 and 2 of Legislative Decree 196/03 and subsequent amendments;

6) direct marketing, i.e., sending advertising material, direct sales, conducting market research or commercial communication of products and/or services offered by Fleming 2009 srl – a company of the Omnia Hotels Group and be carried out 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 (for example, 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 paragraphs 1 and 2 of Legislative Decree 196/03 and subsequent amendments.

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 request or provided for by a specific regulatory provision, is mandatory and, failing this, it will not be possible to receive the information and access any services requested; regarding points 5) and 6) of this Policy, 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 products and services, except for the impossibility for the Controller to keep users/customers updated on new initiatives or particular promotions or advantages that may be available.

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 e-mail coordinates or paper addresses provided by you on such occasions, which you may oppose in the manner and at the contact details indicated below.

Methods, logic of processing, retention times, and security measures 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 that ST. MARTIN may use to store, manage, and transmit the data. The processing of data will be carried out with logic of organization and elaboration of your personal data, also relating to the logs originated from the access and use of the services made available via web, of the products and services used related to the purposes indicated above and, in any case, in such a way as to guarantee the security and confidentiality of the data. The personal data processed will be kept for the times provided for by the legislation applicable over time. Also regarding data security, in the sections of the website set up for particular services, where personal data is requested from the browsing user, the data