Privacy

(personal data collected from the data subject)

We would like to inform you that the companies listed below, affiliated with the brand of the R Collection Hotels group, are joint data controllers pursuant to Article 26 of Regulation 2016/679/EU, also known as the “General Data Protection Regulation” (hereinafter “GDPR”), concerning the protection of individuals with regard to the processing of personal data and the free movement of such data:

- King Gestioni Alberghiere SPA – Via Varese, 5 – 20814 Varedo (MB) – VAT/Tax ID: 06967750966

- Marvel SRL - Via Morigi, 2 – 20123 Milano (MI) - VAT/Tax ID: 10468490155

- R.g.a. SRL - Via Piazza Garibaldi, 5 – 22063 Cantù (CO) - VAT/Tax ID: 03160920132

- Texunion SRL - Via San Francesco, 33/37 – 20826 Misinto (MB) – VAT/Tax ID: 00871140158

will process the information and data you provide or otherwise acquire in the context of the services offered, in compliance with the provisions and confidentiality obligations that guide our organization’s activities.

By "processing personal data," we mean any operation or set of operations, carried out with or without the aid of electronic means, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation, and destruction of data, even if not recorded in a database.

The purpose of this notice is to transparently inform you of the purposes for which we may use your data, how we will manage it, to whom it may be communicated, where it may be transferred (within or outside the EU), and what your rights are.

Who processes your data?

Your data will be processed by the aforementioned JOINT DATA CONTROLLERS. In addition to the JOINT CONTROLLERS mentioned above, we inform you that there are external data processors who have been properly mapped, recorded, contracted, and appointed by them in accordance with Article 28 of the GDPR. The list of external data processors is available at the headquarters of the Joint Controllers.

Why do we need your data?

The JOINT CONTROLLERS will use your data exclusively for the following purposes:

1. **Purposes related to the management of the contractual relationship and the provision of services.**

Your data will be processed for the following purposes: establishment, management, and termination of the contractual and commercial relationship; fulfillment of accounting and tax obligations; compliance with legal obligations regarding anti-money laundering controls; fiscal and accounting checks; management of disputes; provision, support, updates, and information regarding the services offered.

2. **Purposes related to marketing activities and newsletters.**

With your specific consent, your data will be processed for the following purposes: sending newsletters, advertising, informational, promotional materials, and updates on initiatives, promotions, and offers related to the R Collection Hotels brand.

3. **Purposes related to the processing of images through photos and videos.**

With your explicit consent, data concerning you (e.g., images, videos, and other material collected during events organized by the companies affiliated with the R Collection Hotels brand in which you participate) will be processed for promotional activities.

The JOINT CONTROLLERS will process your data:

- based on your consent;

- because it is necessary for the contractual obligations referred to in point 1;

- because it is necessary to comply with legal obligations to which you are subject or because processing is necessary for pursuing a legitimate interest (e.g., safeguarding corporate strategic interests and related commercial relationships).

It follows that the provision of personal data is strictly necessary for the purposes outlined in point 1. The failure to provide such data will result in the inability to achieve the previously indicated purposes and therefore to continue the contractual relationship. Purposes 2 and 3 do not arise from a legal obligation, and the provision of the related consent is optional. The extent and appropriateness of the provided data will be evaluated from time to time to determine subsequent decisions and avoid processing data exceeding the pursued purposes.

The JOINT CONTROLLERS are committed not to use your personal data for purposes other than those described in this notice unless informing you in advance and, where necessary, obtaining your consent.

How will we use your data?

The JOINT CONTROLLERS aim to protect the data of their clients, guiding their processing according to the principles of fairness, lawfulness, and transparency. Therefore, we inform you that your personal data will be processed using tools and procedures suitable for ensuring maximum security and confidentiality, through paper archives and supports, with the aid of digital means, IT, and telematic tools.

We would like to remind you that you have the right to exercise the right to object, which, in the absence of your contrary indication, will apply to both traditional and automated communications.

How long will we keep your data?

Your personal data will be retained for a period not exceeding that necessary to achieve the purposes for which they were collected and subsequently processed. Personal data will be maintained for the entire duration of the contract you entered into and also for a subsequent period according to the following criteria:

1. within the time limits set by current legislation;
2. within the time limits established by secondary legislation that requires data retention (e.g., tax declarations);
3. within the period necessary to protect the rights of the data controller in the event of disputes related to the provision of the service. In any case, the maximum retention period for data is estimated at 10 years from the termination of the relationship.

 
Will we share your data with other parties?

For the purposes indicated above (“Why do we need your data”), your data may be communicated to third parties to comply with obligations arising from laws, regulations, community standards, or for aspects concerning the management and execution of the contractual relationship.

The data will also be processed by internal resources of the companies affiliated with the R Collection Hotels brand JOINT CONTROLLERS, adequately trained, who operate as authorized personnel for data processing.

Access to stored data may only be made by public authorities in cases and ways provided for by current laws, in the event of legal disputes. Your personal data will not be subject to dissemination.

What are your rights?

At any time, you have the right to request:

- access to your personal data;

- their rectification in case of inaccuracies;

- deletion;

- limitation of their processing.

You also have:

- the right to object to their processing even if processed for the pursuit of a legitimate interest of the JOINT CONTROLLERS;

- the right to data portability, i.e., to receive in a structured, commonly used, and machine-readable format the personal data you have provided.

We will handle your request with the utmost commitment to ensure the effective exercise of your rights.

Finally, you have the right to lodge a complaint with the national supervisory authority (Data Protection Authority). For a complete understanding of all the data subject's rights, please refer to Chapter III of the GDPR.

Can you revoke your consent once given?

Yes, you can revoke your consent at any time, without this affecting:

- the lawfulness of processing based on consent before its withdrawal;

- further processing of the same data based on other legal grounds (e.g., contractual obligations or legal obligations to which the JOINT CONTROLLERS are subject).

The identifying details of the JOINT CONTROLLERS for the processing of the data you provided are as follows:

- King Gestioni Alberghiere SPA – Via Varese, 5 – 20814 Varedo (MB) – VAT/Tax ID: 06967750966

- Marvel SRL - Via Morigi, 2 – 20123 Milano (MI) - VAT/Tax ID: 10468490155

- R.g.a. SRL - Via Piazza Garibaldi, 5 – 22063 Cantù (CO) - VAT/Tax ID: 03160920132

- Texunion SRL - Via San Francesco, 33/37 – 20826 Misinto (MB) – VAT/Tax ID: 00871140158

to whom you can turn at any time to exercise the rights provided for by the GDPR and detailed above. You can also exercise the rights of the data subject by writing to the email address privacy@rcollectionhotels.com 

The JOINT CONTROLLERS of the Processing