Privacy Policy

PRIVACY NOTICE PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679 (GDPR) AND ITALIAN LEGISLATION (LEG. DECREE 196/2003, AS AMENDED)

This privacy notice is provided pursuant to Article 13 of Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018. It applies to all users interacting with the web services of Sogetur Sicilia S.r.l., accessible online at www.hotelvillaromana.com.

Data Controller

Sogetur Sicilia S.r.l.
Registered office: Via Umberto I, No. 9 – 92014 Porto Empedocle (AG), Italy
VAT Number: 02803430848
E-mail: sogetursicilia@gmail.com

Data Protection Officer (DPO)

The company has appointed Mr. Salvatore Patti as Data Protection Officer (DPO).
DPO contact: sogetursicilia@gmail.com

Purposes and Legal Basis for Processing

Personal data are processed for the following purposes:

• Managing contact or booking form requests: processing is necessary for pre-contractual or contractual measures (Art. 6(1)(b), GDPR);
• Managing hotel bookings and related services: contractual performance and legal obligations (Art. 6(1)(b) and (c));
• Compliance with accounting and tax requirements: legal obligation (Art. 6(1)(c));
• Use of technical and functional cookies: legitimate interest of the controller (Art. 6(1)(f));
• Use of profiling/statistical cookies (e.g., Google Ads, Booking.com, Expedia): user’s consent (Art. 6(1)(a)).

Categories of Personal Data

• Identifying data (name, surname)
• Contact details (email, phone number)
• Booking data (dates, preferences, number of guests)
• Billing and tax data
• Browsing data and cookies (see Cookie Policy)

Providing personal data is mandatory for contractual and legal purposes. It is optional for profiling/statistical purposes.

Data Processing Methods

Data will be processed using manual and electronic tools, with appropriate technical and organizational security measures in accordance with Article 32 GDPR.

Data Retention Periods

• Booking and accounting data: 10 years
• Data submitted via contact forms (without contract): up to 12 months
• Cookies: as specified in the Cookie Policy

Data Recipients

Data may be disclosed to:

• Authorized staff of the Data Controller
• External processors (e.g., booking engine providers, channel managers, IT providers)
• Public authorities where required by law (e.g., tax authorities)

An updated list of external processors is available upon request.

Transfers to Non-EU Countries

Some services (such as Google Ads, Booking.com, Expedia) may transfer data to non-EU countries. Such transfers are based on Standard Contractual Clauses (SCC) approved by the European Commission.

Data Subject Rights

You have the right to:

• access your personal data (Art. 15 GDPR)
• request rectification or erasure (Art. 16 and 17 GDPR)
• restrict processing (Art. 18 GDPR)
• object to processing (Art. 21 GDPR)
• receive your data in a structured, commonly used format (Art. 20 GDPR)
• withdraw your consent at any time (Art. 7(3) GDPR)
• lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it)

How to Exercise Your Rights

You may exercise your rights by sending an email to: sogetursicilia@gmail.com

Automated Decision-Making and Profiling

No automated decision-making or individual profiling is performed.
Statistical/profiling cookies are described in the Cookie Policy.

Last update: June 2025