VILLA VESUVIANA GLOBAL PRIVACY STATEMENT.

Last Updated: May 23, 2018

At Villa Vesuviana, we strive to deliver outstanding products, services, and experiences around the world. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you on this site, through written or verbal communications with us, when you visit one of our properties, or from other sources. While this Statement broadly describes the practices we have adopted across Villa Vesuviana globally, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require affirmative consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements. If you are a resident of the European Economic Area (EEA), please see Appendix A for additional information regarding Villa Vesuviana’s use of your personal information.

By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement.

Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, companies that organize or offer packaged travel arrangements, marketing partners, or corporate customers.

Villa Vesuviana is the entity that is the data controller for all guest data.

PERSONAL INFORMATION WE COLLECT

In addition to information collected directly from you, we may also collect information about you based on the information you provide us or other information we collect.

USE OF YOUR PERSONAL INFORMATION

We use your personal information in a variety of ways, for example to provide and customize the services you require and expect from Villa Vesuviana, to offer you the level of hospitality expected in the room and in the rest of our properties, to manage the Villa program Vesuviana Honors, to conduct direct marketing and sales promotions as described below in more detail. We will request your consent before processing your data, where required by applicable laws.

In order to process your booking, we are obliged to collect certain data, including your name, address, payment information and, in certain countries, information on the travel document. If you do not provide us with this information, we will not be able to process your booking.

OTHER INFORMATION

When you visit and interact with the Villa Vesuviana website, we collect other information that does not identify you directly about your use of the site, such as a catalog of the pages of the site visited and the number of visits to our sites ("Other information"). We use these other information, as well as data received from third parties, to provide you with advertising via e-mail, online (on our and other sites) and mobile. We may also use this Other Information to allow third-party partners to recognize you as a Villa Vesuviana partner when you visit the partner's website or app, or to identify yourself as one of their clients when you visit Villa Vesuviana's websites or apps, in so that they can provide you with more relevant offers.

We use cookies and other technologies (such as "pixel tags", "web beacons", "transparent GIFs", links in e-mails, JavaScript, device IDs assigned by Google or Apple or similar technologies) to collect this information. If you want to remove or block cookies on your device at any time, you can update your browser settings (see the "Help" menu of your browser to know how to remove or block cookies). Villa Vesuviana is not responsible for the settings of your browser. You can find valid and simple instructions on how to manage cookies on different types of browsers at www.allaboutcookies.org.

We may use information we have collected or aggregated, or anonymously received personal information received from third parties, to learn more about our users (for example, we may use aggregated information to calculate the percentage of our users with a particular area code). This includes demographic data, such as date of birth, gender and marital status, the commercial interests we collect, as favorite products or hobbies, and other information we may collect from you or third parties.

Since the Other information does not identify you personally, this information may be disclosed for any purpose where permitted by law. In some cases, we can combine the other information with personal information. If we combine personal information and other information, these data will be treated as personal information, as set forth in this Notice.

CONFIDENTIAL INFORMATION

The term "confidential information" means your information concerning race or ethnic origin, political opinions, religion or other creeds, union membership, health, life or sexual orientation, genetic information, criminal records and biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data and information contained in identity documents are also considered sensitive information.

We generally do not collect sensitive information unless it is voluntarily provided by you or if we are required to do so in accordance with applicable laws or regulations. We can use the data you have provided us about your health to provide you with a better service and meet your particular needs (for example, by providing special access measures to people with disabilities).

PERSONAL INFORMATION OF CHILDREN

We do not intentionally collect personal information from persons under the age of 18. The parent or legal guardian should not allow their child to enter personal information without their consent.

LINKS TO WEBSITES AND THIRD PARTY SERVICES

Our site and our mobile applications may contain links to third-party websites. Please note that Villa Vesuviana is not responsible for the collection, use, management, sharing or disclosure of data and information by the aforementioned third parties. If you provide information about, and use third-party sites, the privacy policies and terms of service use of the aforementioned sites will apply. We encourage you to read the privacy policies of the websites you visit before submitting personal information.

Villa Vesuviana can also collaborate with a limited number of Internet providers to offer Internet access to our guests. Your use of the Internet service at the property is subject to the terms of use and the privacy policies of the third-party Internet provider. You can access these terms and policies by using the links on the service login page or by visiting the Internet provider's website.

PROTECTION OF PERSONAL INFORMATION

Villa Vesuviana will take appropriate measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction and (ii) ensure that personal information is accurate and up-to-date. Should a security incident occur, Villa Vesuviana will inform the supervisory authorities and / or consumers, as required by applicable laws or regulations.

For your privacy, we remind you to NOT send us the numbers of your payment cards or any other confidential personal information by e-mail.

We will not contact you by phone, text message or e-mail to ask for your personal confidential information or payment card data. We will ask for your payment card details by phone only when booking a stay or a promotional package. If you receive this type of request, please do not reply. We also ask you to notify us at info@VillaVesuviana.it.

CONSERVATION OF PERSONAL INFORMATION

We retain personal information for the period of time necessary to fulfill the purposes indicated in this Notice, where a longer period of storage of information is not required or permitted by law. We retain personal information collected in order to process guest bookings for seven years after the end of the stay. We keep other personal information for shorter periods, if possible and where permitted by law.

CHANGES TO THE INFORMATION

Occasionally this information will be subject to change. When we make material changes to this Notice, we will post a link to the revised and corrected Notice on the homepage of our site; moreover, if you have registered for any of our products or services, we can also inform you through the communication channel provided by you. You can check the date of the last update of this Notice through the link and the date at the beginning of the Information. Any changes to our Notice will take effect after publication of the revised and corrected Information on the website. The use of the site and of our products and services and / or your consent to the updated information following these changes constitutes your acceptance of the revised and correct information then in force.

CONTACT

For any questions about our information or how Villa Vesuviana handles your personal information, or if you would like to send us a compliment or a complaint, please contact us via e-mail at info@VillaVesuviana.com or by mail at: Villa Vesuviana Viale Europa, 68, 80059 Torre del Greco NA. We will reply within 30 days or sooner if possible.

APPENDIX A

ADDITIONAL PROVISIONS APPLICABLE TO THE TREATMENT OF
PERSONAL INFORMATION OF RESIDENTS IN THE EEA

For people resident in the EEA, this Appendix sets out some additional information that Villa Vesuviana is obligated to provide you with, as well as certain rights you have with regard to the processing of your personal information in accordance with applicable local laws. Where they conflict with one of the provisions contained in the main body of the Notice, the provisions of this Appendix shall prevail.

Responsible for data processing: for more information on the Villa Vesuviana entities responsible for processing your personal information.

Data protection officer: The data protection officer of Villa Vesuviana can be contacted by e-mail at the address info@VillaVesuviana.it or at the following mailing address:

Attn: Villa Vesuviana Viale Europa, 68, 80059 Torre del Greco NA

Purposes and legal bases for processing: Villa Vesuviana treats your personal information for the purposes set out in Sections 4 (Use of your personal information) and 5 (Personal information that we share) of the main body of this Notice.

The legal bases for the treatment of Villa Vesuviana include the processing of information as required to comply with our contractual obligations, compliance with our legal obligations, the protection of the safety of our employees, guests and other persons, for our legitimate business interests and in accordance with your consent.

Specifically, the legal bases for the processing of your personal information are based on the purpose for which such information was provided or collected:

Surveys: participation in surveys is voluntary; We process information obtained from surveys based on your consent and for the pursuit of our business interests, including marketing purposes, service improvements and analysis.

Collection at the properties: When you make a reservation and stay at one of our hotel properties, we process your name, address, contact information, as well as details of your stay (day and time of arrival and departure, vehicle information and information on other people traveling or stay with you) based on our contractual relationship with you. In addition, we process such data for our business interests, including marketing purposes, service improvements, management of our electronic receipt program, conduct of analysis and customization of services, as described in Section 4 of our Global Privacy Notice (above) .

We collect some additional personal information during registration / check-in at our properties (such as national identity card or passport details), as required to comply with our legal obligations.

At our properties we use CCTV cameras and other security measures that can display or record images of guests and visitors in the common areas, as well as information about your location in our properties (through keycards and other technologies) in order to protect our staff, our guests and visitors of our properties.

We process personal information in connection with services at properties (such as concierge services, activities, equipment rental) in order to provide you with services and for our business interests, including marketing purposes, service improvements, management of our program of electronic receipt, conduct of analysis and customization of services, as described in Section 4 of our Global Privacy Notice (above).

Event profiles: we process the personal information obtained in relation to your event on the basis of our contractual relationship with you and for our commercial interests, including marketing purposes, service improvements, conduct of analysis and customization of services, as described in Section 4 of our Global Privacy Notice (above).

Social media: participation in activities and offers on social media sponsored by Villa Vesuviana is voluntary; we process information obtained through participation in social media on the basis of your consent and for the pursuit of our related business interests, including marketing purposes, improvements to service, conduct of analysis and customization of services, as described in Section 4 of our Information global privacy (above).

Promotions and competitions: participation in competitions and other promotional offers is voluntary; we process information obtained through this participation based on your consent and as required to manage the offer. In addition, we use certain data for our business purposes, including marketing purposes, service enhancements, management of our electronic receipt program, conduct of analysis and customization of services, as described in Section 4 of our Global Privacy Notice (above) .

Direct marketing: we use your personal information to send you marketing communications based on your consent. You can withdraw your consent to direct marketing communications at any time by contacting us at info@VillaVesuviana.it, following the instructions to unsubscribe contained in the marketing message.

Data holder rights: EEA residents have the following rights:

Requests for access, correction and cancellation: you have the right to:

ask us to confirm if we are processing your personal information

receive information on how we process your data

get a copy of your personal information

request us to update or correct your personal information

ask us to delete personal information in certain circumstances

Right to object to the processing: you have the right to request that Villa Vesuviana stop processing your personal information:

for marketing activities, including profiling activities

Right to limit processing: you have the right to request that Villa Vesuviana limit the processing of your personal information:

if Villa Vesuviana is considering or taking steps to respond to your request to update or correct your personal information

where this treatment is contrary to the law and you do not want Villa Vesuviana to delete your data

if Villa Vesuviana no longer requires such data, but wishes that we keep the data to ascertain, exercise or defend a right in court

if you have submitted an opposition to the processing on the basis of our legitimate business interests and await our response to this request

Should we limit the processing of your personal information in accordance with your request, we will inform you before engaging you again in such treatments.

Data portability requests: You have the right to request us to provide you or a third party designated by you with some of your personal information in a commonly used electronic format. However, we inform you that the data portability rights only apply to personal information we have obtained directly from you and only if our processing is based on consent or execution of a contract.

We will respond to all such requests within 30 days of receipt of the request, unless there are mitigating circumstances, in which case it may take up to 60 days for the response. We will inform you if we anticipate that it will take more than 30 days for our response. However, some personal information may be excluded from these rights under applicable data protection laws. Furthermore, we will not respond to any request unless we can adequately verify the applicant's identity. We may charge you a reasonable amount for subsequent copies of the data you request.

If you have any doubts about our data practices or the exercise of your rights, you can contact Villa Vesuviana at info@VillaVesuviana.it or the supervisory authority of your Member State of residence.

Right of withdrawal of consent: you have the right to withdraw your consent to any processing that we conduct exclusively on the basis of your consent (such as sending direct marketing materials to your personal email address). You can withdraw your consent to marketing activities by following the instructions given in any marketing e-mail or by contacting the address info@VillaVesuviana.it. For any other activity for which you have given your consent previously, you can write to info@VillaVesuviana.it to revoke this consent.

Segmentation (also known as profiling) and automated decisions: we use personal information to subdivide a large group of consumers into consumer subgroups (called segments) based on some types of shared characteristics, such as geographic area, behavior or demographic information.

With your consent, we make automated decisions, ie without human intervention, using segmentation and / or your specific personal information to offer you certain benefits based on your characteristics (for example discounted room rates or other special offers based on your geographical area, your behavior or your demographic information).