Cookie Policy

Introduction

This Cookie Policy explains what cookies are, how we use them, and the choices available to users regarding their use. This notice is drafted in accordance with EU Regulation 2016/679 (GDPR) and the ePrivacy Directive.

What are cookies?

Cookies are small text files that visited websites send to the user’s device (computer, smartphone, or tablet), where they are stored to be re-transmitted to the same sites during subsequent visits. Cookies allow websites to recognize users, improve their experience, and provide specific services.

Technical Cookies

Technical cookies are essential for the proper functioning of the site and do not require user consent. They allow us, for example, to:

  • Maintain an active browsing session;
  • Save browsing preferences;
  • Improve page loading speed.

Analytical Cookies (with anonymization)

These cookies help us collect aggregate information on the use of the site, such as the number of visitors, the most visited pages, and the time spent on the site. We use tools that anonymize IP addresses to ensure compliance with privacy standards.

Profiling Cookies

Profiling cookies track the user’s navigation to offer targeted and personalized advertising. These cookies require the user’s explicit consent.

Third-Party Cookies

Some external services (e.g., social networks, video platforms) may install cookies on the user’s device to provide additional functionalities. We invite you to consult the respective privacy policies of these third parties for further details.

Purposes of Cookies

We use cookies for the following purposes:

  • Ensuring the technical functioning of the site;
  • Improving the user’s browsing experience;
  • Analyzing user interactions with the site;
  • Providing personalized and targeted advertising, where permitted.

Managing Cookies via Browser

You can configure your browser to accept or reject all cookies, or to receive a warning before a cookie is stored. Each browser has different procedures for managing cookies:

  • Google Chrome
  • Mozilla Firefox
  • Safari
  • Microsoft Edge
  • Opera

Legal Basis for Processing

Technical cookies are used based on our legitimate interest in ensuring the functioning of the site. Other types of cookies are processed only with the user’s consent.

User Rights

Users have the right to:

  • Obtain information on the processing of personal data;
  • Withdraw consent at any time;
  • Request the deletion of data processed via cookies, where applicable.
  • To exercise your rights, you can contact us via our contact page.

Changes to the Cookie Policy

We reserve the right to update this Cookie Policy at any time to comply with current regulations or operational changes to our site. Users will be informed through notices on the site.

We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners. View more
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This website collects some personal data from its visitors.

Premise

Hotel Carmencita, with registered office at Viale Tommaso de Tommaso 4c - 80071 - Anacapri (NA) (hereinafter Hotel Carmencita), constantly strives to protect the online privacy of its users. This document has been drafted in accordance with Article 13 of EU Regulation 2016/679 (hereinafter: "Regulation") to allow you to understand our privacy policy, understand how your personal information is managed when you use our website (hereinafter "Site"), and to allow you to provide express and informed consent to the processing of your personal data. All information and data provided by you or otherwise acquired in the context of the use of information request services, technical assistance, promotion, sending of commercial newsletters, or other actions—such as accessing the reserved area of the Website—will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire Hotel Carmencita's activities. All activities aimed at processing the data of website users carried out by Hotel Carmencita are inspired by the principles of lawfulness, fairness, transparency, purpose limitation and storage limitation, data minimization, accuracy, integrity, and confidentiality, as required by the Regulation.

Definition of Personal Data

According to Art. 4 GDPR, personal data is defined as any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. All information acquired during navigation on the Site will be used for the pursuit of the purposes indicated and described in this Document. During navigation on the Site, Hotel Carmencita will process the data acquired as a result of the activities carried out by the user during navigation or those acquired as a result of the use of the services provided by the Site itself. The information processed may be entered manually by the User, collected automatically, or acquired through third parties. The User has the right to rectify their personal information at any time or to prevent, revoke, and/or oppose its processing.

Type of Data Processed

Contact Data This refers to personal data capable of identifying the User through the indication of information such as company name and VAT number, first and last name, tax code (codice fiscale), address, email address, fax, website, date of birth, telephone or mobile number for natural persons, and information provided during registration, as well as unique IDs used by advertising services (e.g., Google Ads). Data Acquired During Site Navigation The computer systems used to ensure the proper functioning of the Site acquire some Personal Data which is automatically processed during the use of normal Internet protocols. Although the information acquired during navigation is not collected to be associated with specifically identified data subjects, it could allow for the identification of users through association with other data held by third parties. List of Navigation Data IP addresses or domain names of computers used by users connecting to the Site; URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the numerical code indicating the status of the response given by the server (successful, error, etc.), the size of the file obtained in response, and other parameters relating to the operating system. All this data is used solely to obtain anonymous statistical information regarding the use of the Site, to monitor its correct functioning, and to detect any anomalies and/or misuse. The data acquired for these purposes is deleted immediately after processing. The data could also be used to ascertain responsibility in case of hypothetical computer crimes against the site or third parties. Some sections and features of the Site designed to acquire User Personal Data may require the release of Personal Data attributable to the categories referred to in Art. 9 of the Regulation, namely "[...] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation". Hotel Carmencita invites its users not to publish such data unless strictly necessary. In any case, the potential publication by the User of strictly personal information, even in the absence of a specific expression of consent to process such data, releases Hotel Carmencita from any liability. Hotel Carmencita cannot be exposed to disputes of any kind because, in this case, the processing of such data must be considered authorized following the free and informed choice of the data subject to make them manifestly public in compliance with the provision contained in Art. 9 (1) (e) of the Regulation. Data Voluntarily Released by the User In the event that the User, using certain Features of the Site, releases Personal Data belonging to third parties to Hotel Carmencita, the User assumes the position of Data Controller, with all the legal obligations and responsibilities deriving therefrom. Consequently, the User indemnifies Hotel Carmencita from any liability regarding any disputes, claims, requests for compensation for damages, etc., that may be received from third parties whose Personal Data have been processed in violation of the applicable personal data protection rules following the User's use of the features present on the Site.

Cookies

General Premises and Definition Cookies are files (metadata) that are stored on the devices used by users to browse the Site. These files are sent by the Site and recorded on the computer or mobile device used by the User to be re-transmitted to the same Sites during a subsequent visit. Cookies, therefore, allow the Site to memorize user actions and preferences (such as login data, chosen language, font size, other display settings, etc.) and eliminate the need to indicate, on each visit to the Site, the data already provided previously by the User. Once installed on the User's IT device, the activities carried out by cookies include:
    • Computer authentication;
    • Monitoring of Site sessions;
    • Storage of information regarding the activities of users accessing the Site;
    • Tracking user navigation within the Site for statistical and/or advertising purposes.
During navigation on the Site, the User may receive cookies on their computer from sites other than the one they are visiting. In this case, we refer to "third-party" cookies. There are different types of cookie files. Cookies can be processed to perform different functions and are, therefore, endowed with different characteristics depending on the functions performed. For example, we can distinguish:
    • Persistent cookies: destined to remain on the user's device until a predetermined expiration;
    • Session cookies: automatically deleted when the browser is closed;
    • Profiling cookies: aimed at creating user profiles based on information detected during navigation, in order to send advertising messages in line with their preferences.
The use of temporary cookies is limited to providing safe and efficient navigation on the Site, as well as identifying the User to ensure correct delivery of the service requested on this Site. For the proper functioning of the website, the User is required to enter all requested personal information. For this type of cookie, prior consent from the User is required. Current legislation in Italy does not always require express user consent to allow the Site Owner to use cookies. "Technical cookies", for example, do not require such consent as they are files indispensable for the correct functioning of the Site and are used solely to ensure the correct delivery of a service expressly requested by the User. These are necessary cookies that must be installed on the User's device to guarantee the completion of certain operations. In this case, we speak of "technical cookies" necessary for the functioning of the Site itself. Among the technical cookies used by this Site that do not require express consent for their use, the Italian Data Protection Authority also includes:
    • Navigation or session cookies necessary for User authentication;
    • "Analytics cookies" used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site;
    • Functional cookies, which serve to allow navigation based on predetermined criteria (e.g., language).
Types of Cookies Used by the Site The Site uses the following cookies:
    • Technical navigation or session cookies: Strictly necessary for the functioning of the Site or to allow the User to use the contents and services requested. N.B. If technical and/or functional cookies are deactivated, the Site may not function correctly and the User may be forced to modify or manually enter some information or preferences every time they visit the Site.
    • Functional cookies: Used to activate specific Site features and a series of selected criteria (e.g., language) to improve the service provided.
    • Non-technical cookies: Used to identify the User and track activities carried out on the Site. The purpose is to allow the display of relevant ads of interest to the User chosen by third parties (e.g., publishers and advertisers) based on their preferences.
    • Third-party cookies: Cookies from sites or web servers other than Hotel Carmencita's, used for the purposes of said third parties. It is noted that these third parties, listed below with relative links to privacy policies, are independent data controllers of the data collected through the cookies they serve and are independently responsible for their activities. The User must, therefore, refer to the privacy policies, information notices, and consent forms of the third parties.
Cookie Updates The cookie files used by Hotel Carmencita are regularly and constantly updated. Regarding third parties sending cookies via our Site, we provide links to their respective privacy policies below. Third parties are responsible for providing the notice and collecting User consent. Hotel Carmencita cannot perform any suitable control to guarantee compliance with legal requirements regarding these cookies. Below are the links to third-party cookie information: Cookie Settings It is possible to block, delete (in whole or in part), or modify cookie settings through the specific functions of the Browser used. The User is informed that not authorizing the installation of technical cookies may result in the malfunction of the Site. Limiting the installation of functional cookies may result in some services and/or functions of the Site being unavailable or not working correctly. Viewing and Modifying Cookies Users can authorize, block, or delete cookies through browser functions. Instructions for common browsers:

Legal References & Basis for Processing

Data processing occurs in compliance with the principle of lawfulness (Art. 6 GDPR), pursued through consent given by the User authorizing the Controller to perform activities necessary to achieve the purposes indicated. The need to process data may also be based on the execution of a contract, pre-contractual measures requested by the client, or legitimate interest (Art. 6(1)(a), (b), (f) GDPR). Data may be processed when:
    • The Controller needs to use it for their own ends and interest;
    • The Controller must comply with public interest requests, including from authorities;
    • Information is functional to the fulfillment of legal obligations;
    • It is necessary to fulfill contractual agreements.

Data Controller and Data Processor

    • Data Controller: Defined in Art. 4 GDPR as the natural or legal person who determines the purposes and means of processing. The Data Controller for this Site is Hotel Carmencita.
    • Data Processor: Defined as the natural or legal person who processes personal data on behalf of the controller. The Data Processor for this Site is: [Note: The source text leaves this blank].

Definition of Processing

According to Art. 4 GDPR, "processing" means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Profiling

According to Art. 4 GDPR, "Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. User personal data may be subject to profiling to identify preferences and display relevant ads.

Place of Data Processing

Data processing takes place at the Data Controller's corporate headquarters. Personnel in charge of processing participate in data processing. No information obtained via web services is communicated or disseminated unless strictly necessary for the requested service or legal compliance. Data may be transferred to another country (Art. 3 GDPR).

Retention of Personal Data

User personal data is stored respecting security parameters and the principle of proportionality. The duration of storage is strictly connected to the purpose of the processing. Information will not be processed longer than strictly necessary. Once the purposes are achieved, information will be deleted.

Purposes of Processing

User data is processed to ensure the correct provision of services, including:
    • Commenting;
    • Statistics;
    • Access to third-party services/APIs;
    • Chat services;
    • Payment management;
    • Contact requests;
    • Hosting;
    • Social network interaction;
    • Heat mapping;
    • Advertising/Targeting/Profiling;
    • Support management.

Recipients of Personal Data

User Personal Data may be shared with: a. Processors: Consultants, hosting providers, tool providers, technical maintenance staff. b. Authorities: Where mandatory by law. c. Authorized Persons: Employees of Hotel Carmencita or partners subject to confidentiality. d. Commercial Distributors: Via automated (email, SMS) and non-automated means.

Data Transfers

Some Personal Data may be transferred to Recipients outside the European Economic Area. Hotel Carmencita guarantees that processing by these Recipients complies with the Regulation.

Rights of Data Subjects

Pursuant to Articles 15 et seq. of the Regulation, the User has the right to request from Hotel Carmencita access to their Personal Data, as well as rectification or erasure of the same, or to object to their processing. The user also has the right to request restriction of processing (Art. 18) and data portability (Art. 20). Requests should be addressed in writing to Hotel Carmencita. N.B. The User has the right to lodge a complaint with the competent Supervisory Authority (Garante per la Protezione dei Dati Personali).

Changes

This privacy policy is effective from April 23, 2024. Hotel Carmencita reserves the right to modify or update it.

Details on Specific Services

Access to Third-Party Services Third-party services may require sharing information in your accounts to interact with them. Comments Users may leave comments (potentially anonymously). Users are responsible for content. Third parties may collect statistical data. Contacting the Visitor
    • Mailgun: Mailing list/newsletter management service (USA). Requires: Name, email, customization info.
        • Place of processing: USA – Privacy Policy.
Hosting
    • Google Cloud Storage: Cloud hosting by Google Ireland Ltd.
        • Place of processing: Ireland – Privacy Policy.
Social Networks Allows interaction with social networks via the user's profile.
    • Collected Info: User ID, username, image, friend lists, etc.
Geolocation Non-continuous geolocation. The site may access location info if not denied by the user via browser/device. Registration and Access Allows the visitor to have a profile on the website. Statistics
    • Flazio Stats: Analyzes visitor behavior.
        • Place of processing: Ireland – Privacy Policy / Opt Out.
Privacy Shield Note (Note: Transfers based on Privacy Shield refer to the EU-USA agreement. Data is transferred to subjects self-certified under this framework). Content and Graphics
    • Google Fonts: Managed by Google Ireland Limited.
        • Place of processing: USA – Privacy Policy.
    • Google Maps: Managed by Google Ireland Limited.
        • Place of processing: Ireland – Privacy Policy.
Visitor Profiling Information may be used to create a visitor profile to monitor preferences via automated tools. Users can contact the Controller to object.
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