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Privacy

Declaration made in accordance with Art. 13 of EU Regulation 2016/679 issued by the European Parliament and Council on 27 April, 2016 concerning the protection of natural persons as regards the processing of their personal data , as well as the free circulation of such data, and which abrogates Directive 95/46/EC (General Regulations for the protection of data).
In accordance with the EU General Regulations for the protection of data (Regulation 2016/679 issued by the European Parliament and Council), please be informed that:

NAME AND CONTACT DETAILS OF THE CONTROLLER
The data controller is the company:

Europa Splendid Hotel SRL
Corso della Libertà 110
I-39012 Merano (BZ)
00100340215
info@imperialart.it
www.imperialart.it


PERSONAL DATA AND SPECIAL CATEGORIES OF DATA
The following are considered as being your personal data:
- personal data (surname, name, address, e-mail, telephone number, fax number, date of birth)
as well as your language and the license plate of your vehicle
- the data shown in your passport or identity card
- data relative to the method of payment or otherwise connected with your payments (e.g. bank coordinates, details of credit card)
- date of arrival and length of stay

Special categories include data relative to health and specific personal needs.

 

COOKIES
Information about the use of cookies on this website can be found in our cookie declaration.


MOTIVES FOR THE PROCESSING OF PERSONAL DATA AND LEGAL GROUND FOR THEIR PROCESSING
The data provided will be processed for the following purposes:

- For compliance with legal obligations
- For the implementation of pre-contractual and contractual requirements relative to the guest's visit (booking, period of stay, departure etc.)
- Forwarding of communications and telephone calls directly to the guest
- Memorization of the data for the purpose of future bookings and requests
- Forwarding of information, special offers and new features offered by the company and the other associated company by e-mail, ordinary mail, and other means of communication concerning the company, the local area and any local events etc.
- Forwarding of information, special offers and new features offered by the company and the other associated companies by e-mail, ordinary mail, and other means of communication concerning the company, the local area and any local events etc.

Legal ground for the processing of your data:
- compliance with legal and judicial obligations
- compliance with obligations and pre-contractual and contractual requirements
- your consent
- legitimate interests: Delivery of advertisment emails (newsletter) to improveme our client service and our contacts with the clients


RECIPIENTS OF THE PERSONAL DATA
In most cases, your personal data will not be provided to third parties. In special circumstances, however, the data may:
- be forwarded to other departments within the company, subject to the limits of legitimate use;
- be forwarded to the following to third-party subjects, when necessary to meet your requests or in order to provide specific services: please see the section "third-party subjects" of this text.

The recipients listed above are required by us to comply with all current norms and standards governing the protection of data.


DURATION OF CONSERVATION OF DATA
The duration of the conservation of the data is calculated on the basis of the obligations for the conservation of the data and the requirements contemplated by the law. If your personal data are processed in order to comply with a legal requirement or a contractual obligation, they will be kept only for the time that is strictly necessary for their processing. If the data are processed with your consent, they will be kept until that consent is revoked.


RIGHTS OF THE DATA SUBJECT
Right of access by the data subject:
In accordance with art. 15 of the GDPR, you are entitled to be informed of the personal data processed, their provenance, nature, possible forwarding to third parties (in such case identifying the same) and their utilization.

Right of rectification and erasure:
In accordance with art. 16 of the GDPR, you may at any time require the rectification or completion of your personal data. Similarly, in accordance with art. 17 of the GDPR, you are entitled to require the erasure of the data. In the presence of published data, you also enjoy the "right to be forgotten", i.e. to request that the measures necessary to erase all the links, copies, replications and similar.

Right to object:
You may at any time exercise your right to object as described in art. 21 of the GDPR and modify or entirely revoke your consent for the future.

Right of restriction (or blocking) of processing:
In accordance with art. 18 of the GDPR, you may require the restriction of the processing of your personal data. The relevant data may be processed only subject to specific prior consent, i.e. their processing will be effectively limited.

Right to data portability:
In accordance with art. 20 of the GDPR, you are entitled to request and receive the personal data provided by yourself in a structured, commonly used and machine-readable format, and you have the right to require their transmission to another controller.

In accordance with art. 77 of the GDPR, you have the right to lodge a complaint with the supervisory authority.


CHARACTERISTICS OF CONSENT
Your personal data will be processed in accordance with the contract and with current legislation, as set forth in the provisions of EU Regulation 679/2016 (GDPR).
Consent for the processing of personal data included in special categories is given on a voluntary basis. In the absence of such consent, the personal data cannot be processed for any future bookings.
Consent for the processing of personal data as regards the forwarding of information, special offers and new features offered by the company, too, is voluntary. If the personal data are not provided, then offers and other information shall not be supplied.


THIRD-PARTY SUBJECTS
Google Analytics
Google Analytics may be integrated within our online offer. Google Analytics is a web analysis service offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
The information collected by Google Analytics about your use of this website is generally transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymisation on these websites, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.
You can prevent the collection by Google Analytics by downloading and installing the browser plug-in available under the following link: Browser add-on to disable Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=en).
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). For more information on Google's use of data, settings and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

 

ADDITIVE+ LANDINGPAGE -  Online Marketing and Landing Pages
Beside our website we do also operate optimized landing pages for means of hotel online marketing. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”), our partner in the field of hotel digital marketing. The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
You can prevent the data collection connected to your use of our online services through cookies and the processing of this data by Google, by installing the browser-plugin available at the following link:
https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence. Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. If you continue using the website or click on the respective button you consent to the use of cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.

 

Facebook Pixel
We use Facebook Pixel from Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook") on our website. Facebook Pixel is an analytics tool that enables us to measure the effectiveness of our advertising on Facebook and optimize our advertising campaigns.
When you visit our website, Facebook Pixel automatically connects to Facebook's servers. This means that Facebook is informed that you have visited our website and what actions you have taken on our website. The data collected is anonymous and does not allow us to identify you personally.
The processing of your personal data by Facebook is carried out within the framework of Facebook's privacy policy. You can find information on your rights and options for protecting your privacy there.
You can object to the use of Facebook Pixel at any time. To do so, you can set an opt-out cookie or change the settings in your Facebook account: https://www.facebook.com/settings/
Further information on Facebook Pixel and data protection can be found in Facebook's privacy policy at https://www.facebook.com/policy.php.

 

ADDITIVE+ NEWSLETTER
On our website you have the possibility to subscribe to our newsletter. For the subscription we need your email address and your consent to receive our newsletter through ADDITIVE, our provider for hotel e mail marketing. To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin  in our hotel newsletter tool.
After signing up for our newsletter you will receive an email containing a link to confirm the subscription.
Your subscription can be cancelled any time by clicking on the cancellation link in the respective newsletter.
To process your subscriptions and to send our newsletters we use software provided by ADDITIVE Srl, 39011 Lana (BZ), Italy (“ADDITIVE”). Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.

 

Processing of personal data through the KOSMO virtual assistant

An interactive virtual assistant Ai Kosmo Chatbot (hereinafter, the “Chatbot”) is active on our website to assist you during navigation, provide information about our services, and answer your questions. This service is developed by AI KOSMO S.r.l., which acts as Data Processor pursuant to Article 28 of the GDPR, on the basis of a specific agreement governing its tasks and responsibilities. The Data Controller of the data you provide through the Chatbot remains Europa Splendid Hotel SRL.

The Chatbot uses artificial intelligence systems based on Large Language Models (LLMs) to understand your requests and provide relevant responses.

a. Categories of data processed

The processing concerns the following categories of personal data:

  • Data actively provided by the user: any information that you voluntarily type into the chat window, such as questions, requests for information, first name, last name, contact details, or stay preferences.
  • Session-related technical data: IP address, browser type, operating system, and other technical data necessary to ensure the proper technical functioning of the chat.
  • Conversation content: the full text of your interactions with the Chatbot.

b. Purposes and legal basis of the processing

Your personal data are processed for the following purposes:

  • Provision of chat-based assistance and support services: to respond to your requests, assist you during navigation, and provide you with the necessary information about our services. The legal basis for this processing is the legitimate interest of the Data Controller in providing efficient and immediate customer support. In the case of pre-contractual requests (e.g. quotations or booking availability), the legal basis is the performance of pre-contractual measures.
  • Service improvement and training of artificial intelligence algorithms: to analyse conversations (in aggregated and anonymised form where possible) in order to improve the accuracy of the Chatbot’s responses and the effectiveness of the service. The legal basis for this processing is the legitimate interest of the Data Controller and the Data Processor in improving the technology and the quality of the service offered, provided that your interests or fundamental rights and freedoms do not prevail.

The provision of data for purpose no. 1 is optional but necessary in order to use the Chatbot service. For purpose no. 2, you may object at any time, without prejudice to your ability to continue using the chat service.

c. Processing methods and security measures

The processing is carried out using IT and telematic tools. In accordance with the principles of data protection by design and by default (Article 25 GDPR), appropriate technical and organisational measures are adopted to ensure a level of security appropriate to the risk. This includes, where possible, the pseudonymisation or anonymisation of data, particularly for the purposes of training the algorithms.

d. Data retention period

Your personal data will be retained in accordance with the principle of storage limitation:

  • For assistance purposes: conversation logs will be retained for the time strictly necessary to manage your request and, in any case, for a period not exceeding 6 months from the closure of the chat session, unless the emergence of a dispute justifies further retention.
  • For algorithm training purposes: personal data will be retained in a form that allows your identification only for the time strictly necessary for analysis and extraction of information useful for improving the model. After this period, they will be irreversibly anonymised or deleted. In any case, this period will not exceed 90 days.

e. Data disclosure and transfers

The data collected through the Chatbot are processed by our provider AI KOSMO, appointed as Data Processor. AI KOSMO may use sub-processors (e.g. cloud service providers) for the provision of the service, in compliance with the obligations set out in Article 28 of the GDPR.

The use of such services may involve the transfer of your personal data outside the European Economic Area (EEA). Such transfers will take place only where appropriate safeguards are in place, such as adequacy decisions of the European Commission or the execution of Standard Contractual Clauses.

f. Use of artificial intelligence systems

The Chatbot service makes use of artificial intelligence technologies, in particular Large Language Models (LLMs). In line with the transparency principles set out in the European AI Act, the GDPR, and national Law No. 132/2025, we provide you with the following information:

  • Transparency obligation: we inform you that you are interacting with a system that uses AI components. This system has been designed to assist Hotel staff in interpreting and routing your requests.
  • Operation and system logic: the AI system analyses the text of your requests in order to understand their content and purpose and to route them to the competent department.
  • Human oversight and absence of automated decision-making: we guarantee that the AI system operates as a support tool for our staff. No decision producing legal effects or similarly significantly affecting you (pursuant to Article 22 GDPR) is taken in a solely automated manner. Any complex request, charge, or relevant decision is subject to review and validation by a human operator.
  • Fairness and non-discrimination: AI systems have been developed and are periodically monitored to minimise the risk of errors and discriminatory effects, in line with best practices and regulatory requirements.

g. Data subject rights in relation to the use of AI

In addition to the general rights provided for by the GDPR (access, erasure, restriction of processing, data portability, and objection), you are also guaranteed specific rights in relation to the use of artificial intelligence systems, in line with the guidance of supervisory authorities:

  • Right to rectification: if you find that the information generated by the Chatbot concerning you is inaccurate, you have the right to request its correction.
  • Right to erasure: if the correction of inaccurate data is not technically possible, you have the right to obtain their erasure.
  • Right to object: you may object at any time to the processing of your data for the purpose of algorithm training based on legitimate interest.

To exercise your rights, you may contact Europa Splendid Hotel SRL using the contact details provided in this privacy notice.