Last review and version: 01/08/2018, ver. 1.00
According to the rules of the Regulation, the processings carried out by AdsHotel, a D-Business srl division will be based on the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality and accountability.
1. Who is the data controller of your personal data?
The Data Controller of the processings of personal data carried out through the Website is AdsHotel, a D-Business srl division, with registered offices in via Zandonai 6/6, 30174, Mestre (VE), Italy, in the person of its legal representative pro tempore, as defined above. For any information concerning the processing of personal data by AdsHotel, a D-Business srl division you can write at the following address: firstname.lastname@example.org
2. What is personal data and what data do we process?
“Personal data” means any information suitable of identifying, directly or indirectly, a physical person, as an example You who are using the Services offered by AdsHotel, a D-Business srl division.
In particular, we collect and process your personal data necessary for the provision of the requested services, such as:
- navigation data;
4. Why do we process your personal data?
First of all, we collect and process personal data that concern you and that are strictly necessary to follow up on your requests and the services you have signed for. In particular we process them for:
- Respond to assistance, information or estimate requests, either through the chat service, through the “contact us”;
- fulfill any legal obligations (eg accounting and tax)
In any case, we are committed at ensuring that the information collected and used is appropriate to the purposes described, and that this does not result in an invasion of your personal sphere.
5. Upon which Legal Basis do we process Personal Data?
The legal basis for the processing of personal data for the purposes referred to in Section 4(a) is art. 6(1)(b) GDPR as the processing since it is necessary for the provision of the Services and for the response of requests by the interested party. The provision of personal data for these purposes is optional, but failure to provide it would make it impossible to activate the Services provided by the Site, to find requests or to evaluate the CVs.
The legal basis for the processing of personal data for the purposes referred to in Section 4(b) and 4(c) is art. 6(1)(a) GDPR since the processings are subject to the acquisition of an explicit consent. The provision of data is optional.
The purpose referred to in section 4(d) represents a legitimate processing of personal data pursuant to art. 6(1)(c) GDPR. Once the personal data have been transferred, the processing is indeed necessary to comply with a legal obligation to which AdsHotel, a D-Business srl division is subject.
6. How do we process Personal Data?
Your personal data may be processed by means of manual or electronic or automated processes, according to logic strictly related to the purposes themselves or in any case in such a way as to guarantee the confidentiality and security of Personal Data (with particular regard to the use of communication techniques at a distance).
7. To whom do we communicate your data?
Your Personal Data may be shared, for the purposes referred to in Section 4 above, with:
- subjects that typically act as external data processors after appointment by AdsHotel, a D-Business srl division, namely: i) people, companies or professional firms that provide AdsHotel, a D-Business srl division assistance and advice in accounting, administrative, legal, tax, financial and credit recovery relating to the provision of the Services; ii) subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers and banking institutions) iii) or subjects delegated to perform technical maintenance activities (including maintenance of network equipment and communication networks);
- subjects, bodies or authorities to whom it is mandatory to communicate your personal data in accordance with the provisions of law or authorities’ orders;
subjects authorized by AdsHotel, a D-Business srl division to process Personal Data necessary to carry out activities strictly related to the provision of the Services, which are committed to confidentiality or have an appropriate legal obligation of confidentiality (eg. AdsHotel, a D-Business srl division employees).
8. Where do we transfer your data?
Normally we do not transfer your data outside the European Union. Should this happen, we make sure that the other party complies with the provisions of the Regulation, including the rules specifically set out for the transfer of personal data to third countries. In particular, we guarantee that said transfers take place on the basis of an adequacy decision or the signing by the data processor of contractual clauses of data protection type approved by the European Commission.
9. How long do we keep your data?
We keep your data only for the time necessary to perform the processing and for the purposes mentioned above.
In particular, we list below the main periods of use and storage of your personal data with reference to the different purposes of treatment
- with reference to the processings of personal data for recruiting purposes we will process your data up to 24 months from receipt of your CV;
- for the fulfillment of legal obligations, your data will be processed and stored as long as the need for processing persists to fulfill these legal obligations.
10. What are your Data Protection Rights (‘DPRs’)?
- Right of access: you have the right to obtain confirmation about the existence or processing concerning your data as well as the right to receive any information concerning the same treatment.
- Right to rectification: you have the right to have your data corrected if they are incomplete or inaccurate.
- Right to cancellation (so-called “right to be forgotten”): under certain circumstances, you have the right to obtain the deletion of your data in our archives (if they are not relevant for the continuation of the contractual relationship or necessary for law).
- Right to limit processing: when certain conditions are met, you have the right to obtain the limitation of processing, if it is not relevant for the purpose of continuing the contractual relationship or necessary due to the law.
- Right to portability: you have the right to obtain the transfer of your data in favor of a different holder.
- Opposition right: you have the right to object, at any time for reasons connected with your particular situation, to the processing of data concerning you based on the lawfulness of legitimate interest or the performance of a task of public interest or exercise of public powers, including profiling.
- Right of revocation of consent: you have the right to withdraw consent to the processing of your data at any time, while maintaining the lawfulness of the treatment based on consent before revocation.
- Requests regarding DPRs should be sent in writing to AdsHotel, a D-Business srl division at the following address: AdsHotel, a D-Business srl division, via Zandonai 6/6, 30174, Mestre (VE), Italy.
- The exercise of your rights as an interested party is free under Article 12 of the GDPR .In any case, you are always entitled to propose a complaint to the competent Supervisory Authority (in Italy: Garante per la Protezione dei Dati Personali), pursuant to art. 77 of the GDPR, if you believe that the processing of your Personal Data is contrary to the law.