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Hotel Clarofonte  Via lungo Canali, n° 2   38054 Primiero - San Martino di Castrozza (TN) Italy +39 0439 62347  info@clarofonte.it

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HD Group © 2025  |  VAT No. IT10487350968   |   Legal notes   |   Privacy  |  Cookies

PRIVACY POLICY


In the following chapters you will find information regarding the methods of processing your personal data, data that may be collected during your Internet browsing of our site as well as as a consequence of the services we offer. In order for you to use all the services offered by our website, it is necessary for us to collect and process personal data relating to you. The processing of personal data relating to you may be, by way of example but not limited to, any type of activity regarding the collection, organization, storage, analysis, interpretation, modification, selection, comparison, use, linking, blocking, communication, deletion, and destruction of data. The processing of personal data relating to you takes place in compliance with the principles of lawfulness and fairness in accordance with the legal provisions in force and EU Regulation 2016/679 of the European Parliament and Council. In this privacy notice, it is our duty to inform you about the data we collect, why this is necessary, and what your rights are regarding the processing of your data.

Data Controller
The data controller of the personal data collected by this site is:

Hotel Clarofonte Via lungo Canali, n° 2 - 38054 - Primiero - San Martino di Castrozza 

Tel.: +39 0439 62 347 r.a. E-Mail: info@clarofonte.it  VAT No.: IT10487350968 
Registered with the Milan Chamber of Commerce - REA No. 2535035  
Internet: www.clarofonte.it

Purpose of processing
We process the data for the following purposes:

Type of processing
Your personal data is processed manually but also electronically, mainly thanks to the use of automated means and processes that are refined according to the set objectives. In this case, databases and IT platforms are particularly used, which can be managed either by us or by third parties. Each type of processing ensures the respect and confidentiality of the data processed. This data and general information are saved in databases and as log files on servers. In order to guarantee you unique browsing experiences, it is necessary to collect technical data essential for operation such as

  • type and version of the browser used

  • operating system

  • the website from which the system accesses our website (the so-called referrer)

  • the sub-websites that the system accesses from our website

  • date and time of the visit to our website

  • IP address

  • other data and similar information

The legal basis for this type of processing is Art. 6 of the GDPR. When you connect to the website, the IT systems and management software automatically and indirectly detect and/or manage all this series of data and information. The detection of this data in anonymous form is processed by us firstly in a static form and subsequently in order to process it with the aim of improving the level of protection.

Data retention period
In compliance with current laws, the data controller must observe different data retention periods regardless of the use made:

Use of Cookies
To constantly improve navigation on our website, we use Cookies. Cookies are pieces of text information that, while browsing a website, are stored on the computer through the browser used. The storage of this data serves to recognize accesses. You can delete at any time, through the settings of the browser used, the Cookies that are stored and at the same time set the browser so that Cookies are no longer stored in the future. If you choose this option, we cannot guarantee normal use of our site and some services and functions may no longer be available. Further information about Cookies and their use can be found here or by consulting the dedicated section.

Contact form
If you have decided to contact us through the contact form on our website, it is necessary to provide some personal data in order for us to process your request. This is also the reason why the respective fields of the contact form are marked with an asterisk or in another way as mandatory fields. The entry of additional personal and/or sensitive data, however, remains your choice. If you fail, even partially, to enter the required data marked with an asterisk or a similar character, it may result in our inability to fulfill the requested service and services. Sending the request via the contact form also constitutes acceptance of the processing of the personal data sent. The data you provide will be processed and stored for a period strictly necessary, and no longer, for the processing of the request sent to us.

Newsletter
The sending of a newsletter containing commercial information is subject to your prior consent or a legal provision. Our Newsletter contains information about the company's activities, our services, offers and news (for example, new communication platforms, suggestions, advice and travel offers, offers complementary to your trips, gift vouchers, prize draws as well as information on participation in the Community). Such communications may also come from business partners. The frequency of sending our Newsletter depends on the topics covered. In any case, before sending a Newsletter, we make sure to have obtained your prior consent using a system called Double Opt-In as required by current regulations in Art. 6 paragraph 1 letter b) of the GDPR. The recipients' data are communicated for the sending of the Newsletter to our technical partner. This collaboration is regulated by a Sub-Processor contract for the processing of personal data as required by the GDPR. In compliance with current regulations, it is our duty to monitor and store the consent received for sending the Newsletter. To this end, we record the time of subscription and confirmation to the Newsletter; the personal data provided on this occasion are used solely for the personalization and addressing of the Newsletter and recipients can unsubscribe at any time using the tools provided within the Newsletter itself. The retention of data corresponds exclusively to the period of use and subscription to the service.

Profiling
Profiling is any type of automated processing of personal data that consists of using such personal information to evaluate, analyze, and predict certain aspects relating to a natural person. For this type of marketing, we have entered into agreements with third parties.

Collaborations with third parties
When we work with our suppliers and use third-party services, we ensure that they are contractually obliged to use the same privacy/security standards that we use and we make sure that these are respected. Such third parties acting as data processors guarantee that the data received will not be stored or used for purposes other than those contractually agreed upon. In the context of these technical agreements, the email addresses made available to them are encrypted using technology such as Hashing so that third parties are unable to trace the original addresses. It may happen that we are forced to transfer your data to third parties located in non-European (EEA) countries. The EEA (European Economic Area) is composed of the countries of the European Union, Switzerland, Iceland, Liechtenstein, and Norway. These countries guarantee the same rules regarding the security of personal data processing. The transfer of data may occur when the servers (that is, the physical location where the data is stored) or the headquarters of our suppliers are located in a country outside the EEA. In the event that we are forced to transfer data to a country outside the European Economic Area (EEA), we assume responsibility that the data will be processed with adequate security standards.

Data dissemination
The personal data processed are mainly not disseminated. Only and exclusively in certain cases, personal data may be communicated to the following requesters:

  • Subcontractors for technical analysis and checks, payments, identification and delivery services, analysis providers or credit insurance agencies

  • The public administration and Authorities, in the event that there is a legal obligation

  • Credit institutions with which we have business relationships for the management of credits/debts and with financial intermediation

  • any natural or legal person, public and/or private (legal, administrative and tax consultancy, courts, chambers of commerce, etc.) if the forwarding of data is necessary or relevant for the performance of our activity

Rights of the data subject
The rights of the data subject outlined above may be exercised by the data subject and/or by a person appointed by them by sending a written request via registered mail with return receipt and by email to the data controller of Hotel Clarofonte. The data subject has the right to obtain a copy of the data in our possession, which will be made available to them within the time limits provided by the applicable law.
In certain cases, we reserve the right to store some information for legal purposes (such as suspected fraud and violation of the general terms and conditions). If you believe that your rights have been violated, you have the right to contact the competent authorities for personal data protection as well as to take legal action.

Below we summarize the rights of the data subject:

Location of personal data processing
The processing of personal data you provide mainly takes place at our facilities and in the departments where the data controller may be found. The agreed contractual services will take place exclusively in one of the Member States of the European Union or in a State that is part of the European Economic Area agreement.
Any partial or total transfer of the contracted service to a third country requires the prior consent of the customer and can only take place if the special data guarantee and security conditions set out in Art. 44 et seq. of the GDPR are met (such as the Commission's adequacy decision, EU standard data protection clauses, approved codes of conduct).
For further information, please contact us at the addresses indicated in the "Publishing" section.

Google Analytics
This website uses Google Analytics, an analysis tool and advertising efficiency service from Google Inc. ("Google"). Google Analytics uses so-called "Cookies", small text files that are saved on your computer and allow an analysis of your use of the website. The information about your navigation on our website collected through the use of Cookies (including your IP address) is sent to a server in America where it is then stored. Google will use the information received to analyze your navigation on our website, compile reports for website operators on activities carried out on the site itself, and provide further services related to website activities and Internet usage. In certain cases, Google may also transfer this information to third parties, for example if required by law or regarding third parties who process this data on behalf of Google. Your IP address can in no case be used by Google for purposes other than those indicated above. By using the services of this website, the registered user consents to Google processing their data in the manner and for the purposes indicated above. You can prevent the installation of Cookies with appropriate settings on the browser used for navigation; in this case, we must warn you that disabling Cookies may limit the quality of your website navigation as well as its use. To prevent Google from collecting and processing data in the ways described above, you must download and then install the following browser plugin https://tools.google.com/dlpage/gaoptout?hl=it. Further information on the terms of use and data protection by Google Analytics can be found at the link https://www.google.com/analytics/terms/it.html as well as https://support.google.com/analytics/answer/6004245?hl=it. The website uses Google Analytics with IP-Masking mode in order to ensure that the collection of IP addresses takes place in an anonymized manner. We consider it appropriate to specify that we use Google Analytics to evaluate and analyze AdWords data for statistical purposes and Double-Click-Cookies. If you do not like this setting, you can disable it at any time by visiting the link https://adssettings.google.com/?hl=it.

Google Fonts
This website uses Web Fonts for a correct display of graphic characters that are made available by Google. When our website is loaded, your browser loads the necessary web fonts into the browser's cache so that the graphic characters are displayed correctly.
For this purpose, the browser you have chosen must necessarily connect to Google's servers, which will thus become aware that your IP address has loaded our website. The use of Google Web Fonts is a consequence of the desire to offer a clean and attractive browsing experience. This also represents a legitimate interest according to the content of Art. 6 paragraph 1 letter f) of the GDPR. Further information on the use of Web Fonts can be found at the following link https://developers.google.com/fonts/faq or by consulting Google's data processing information notice at the link https://www.google.com/policies/privacy/.

SSL Certificate
We process the personal data collected on the website using IT tools. Personal data is protected through encryption with Secure Socket Layer (SSL) technology. This technology protects the user from the risk of inadvertently revealing their personal data by using an unsecured connection.
The user is notified when accessing the secure connection by the appearance of a padlock icon. By clicking on the padlock symbol, it is possible to verify that the SSL certificate is valid and up to date.

  1. for the fulfillment of legal obligations

  2. for the fulfillment arising from contractual obligations

  3. to be able to provide you with the requested information and provide the agreed services

  4. for the examination of the system's efficiency

  5. for the implementation of marketing activities such as sending commercial information, advertising material, and market research

  6. to protect obligations (for example, payments)

  7. for the detection of the degree of satisfaction regarding the quality of the products and services offered

  1. With regard to the management and response to your questions about products and activities, your personal data will be kept for a period of time strictly necessary to process your request.

  2. With regard to the management of activities related to browsing our website, your personal data will be kept for a period of time strictly necessary to fulfill the requests you have submitted.

  3. With regard to the management and exercise in compliance with legal obligations (as far as the retention periods of invoices, administration, and tax data are concerned), your personal data will be processed for a period equal to the deadlines provided by law.

  4. With regard to the management of disputes and litigation, your personal data will be kept for as long as strictly necessary to pursue these purposes and, in any case, no longer than the applicable statute of limitations.

  • Right to confirmation of data processing
    Every data subject has the right to request the data controller to confirm whether their personal data is being processed. If a data subject wishes to exercise this right to confirmation, they can contact us at any time.

  • Right to information
    Every data subject has the right to obtain, free of charge and at any time, information on the processing of data relating to their person. The communication must contain the following information:

    • the purposes of the processing

    • the types of personal data being processed

    • the recipients and/or categories of recipients to whom the processed personal data may or may not be disclosed, with particular reference and attention to recipients located outside the EEA or to international organizations. Furthermore, regarding disclosure to non-EEA countries, the data subject has the right to receive additional information regarding the security guarantees offered for the processing

    • the retention period provided for the processing and storage of personal data

    • the possibility of filing a complaint with the competent authorities regarding personal data protection

    • in the event that the personal data was not collected and managed by the company, the possibility of obtaining adequate information about their source and origin

    • the possibility that automated decisions may occur, including those provided for by Art. 22 paragraphs 1 and 4 of the GDPR regarding profiling of personal data, and in this case to obtain adequate and supported information regarding the decision-making logic involved and the possible consequences that such a choice may have for the protection of the data subject's rights.

  • Right to rectification of personal data
    Any person concerned by the processing of personal data has the right to request the immediate correction of inaccurate personal data concerning them.

  • Right to erasure
    Any person concerned by the processing of personal data has the right to request the data controller to immediately erase the personal data concerning them, provided that at least one of the following reasons is met and that the processing of personal data is not required:

    • The personal data has been collected or otherwise processed and is no longer necessary.

    • The data subject withdraws the consent to processing granted pursuant to Art. 6 paragraph 1 letter a) of the GDPR or Art. 9 paragraph 2 letter a) of the GDPR, but also in the event that the processing should be in conflict with further data protection regulations.

    • The data subject objects to the processing pursuant to Art. 21, paragraph 1, of the GDPR and demonstrates that there are no legitimate grounds for the processing.

    • In the event that the personal data should be processed in a non-compliant manner

    • The erasure of personal data is required to fulfill a legal obligation under Union or national law to which the data controller is subject.

    • The personal data has been processed in relation to the request for services by minors in compliance with the provisions of Art. 8 paragraph 1 of the GDPR.

  • Right to restriction of processing
    Any person affected by the processing of personal data has the right to request the data controller to restrict processing if one of the following conditions applies:

    • The accuracy of the personal data is contested by the data subject. The restriction applies for a period enabling the controller to verify the accuracy of the processed personal data.

    • The processing does not comply with the applicable legal regulations, the data subject refuses to delete the personal data and instead requests the restriction of the use of the personal data.

    • The data controller no longer needs the personal data for processing purposes, but the data subject needs them in order to assert, exercise or defend their rights in legal proceedings.

    • The data subject has objected to the ongoing processing pursuant to Article 21 paragraph 1 of the GDPR and it has not yet been clarified whether the legitimate reasons of the relevant data controller prevail over those of the data subject.

  • Right to data portability
    Any person affected by the processing of personal data has the right to receive, in a structured, commonly used, and machine-readable format, the personal data relating to the data subject and provided by them to the data controller. The data subject also has the right to transfer these data to another data controller without any hindrance from the transferring controller.
    Furthermore, pursuant to Article 20, paragraph 1 of the GDPR, the data subject affected by the processing of personal data has the right to require that the data be transferred by the transferring controller directly to the new receiving controller, as long as it is possible to identify a common technical solution between the parties and in compliance with the freedoms and rights of any third parties involved in the process.

  • Right to object
    Any data subject has the right to object at any time to the processing of their personal data for reasons arising from their particular situation.
    This principle also applies to profiling based on the provisions listed here.
    In the event of an objection to data processing, we will cease processing personal data, unless we can demonstrate valid reasons to continue processing, reasons that override the interests, rights, and freedoms of the data subject, or if the processing serves the establishment, exercise, or defense of legal claims.
    If we use the processing of personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for direct marketing purposes. This provision also applies to profiling, when it is used for direct marketing purposes.

  • Automated decisions including profiling
    Any data subject has the right to object to a decision based solely on automated processing, including profiling, which has legal consequences and effects on them and which significantly affects them, unless the decision is made to conclude or fulfill a contract between the data subject and the data controller.
    If the decision to conclude or fulfill a contract between the data subject and the data controller is required or has been made with the explicit consent of the data subject, we will take reasonable measures to safeguard the rights and freedoms of the data subject.

  • Right to object to consent for data processing
    Every individual concerned by the processing of personal data has the right to withdraw at any time the consent given to the data controller.

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