Owner and Data Controller
Luxury Hotels & Resorts Sagl
P.IVA: CH237.312.363
6962 Via al Fiume 6
Viganello - CH
Owner contact email: info@san-marco-hotels.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Usage Data; Tracker; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; first name; last name; phone number; country; email address; various types of Data; ZIP/Postal code; city; physical address; number of Users; session statistics.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Displaying content from external platforms, SPAM protection, Contacting the User, Analytics, Marketing, Advertising and Remarketing and behavioural targeting.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
-
Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Website.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Google Ads conversion tracking (Google Ireland Limited)
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
-
Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
-
Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorises this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: country; email address; first name; last name; phone number; various types of Data.
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: city; country; email address; first name; last name; physical address; ZIP/Postal code.
-
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Vimeo video (Vimeo, LLC)
Vimeo is a video content visualisation service provided by Vimeo, LLC that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Google Maps widget (Google Ireland Limited)
Google Maps is a maps visualisation service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
-
Marketing
Reguest Messenger
Description of Service
This is a communication tool in the form of an online chat. It provides its customers to communicate with their guests.
Processing Company
ReGuest GmbH
Kuperion Street 34, 39012, Merano, Italy
Data Protection Officer of Processing Company
Below you can find the email address of the data protection officer of the processing company.
info@reguest.io
Data Purposes
This list represents the purposes of the data collection and processing.
- Functionality
- Analytics
Technologies Used
This list represents all technologies this service uses to collect data. Typical technologies are Cookies and Pixels that are placed in the browser.
- Cookies
Data Collected
This list represents all (personal) data that is collected by or through the use of this service.
- Browser information
- First name
- Last name
- E-mail address
- Telephone number
- Address
- Date of birth
- Payment information
- Contact information
Legal Basis
In the following the required legal basis for the processing of data is listed.
- Art. 6 para. 1 s. 1 lit. f GDPR
Location of Processing
This is the primary location where the collected data is being processed. If the data is also processed in other countries, you are informed separately.
- European Union
Retention Period
The retention period is the time span the collected data is saved for the processing purposes. The data needs to be deleted as soon as it is no longer needed for the stated processing purposes.
- The data will be deleted as soon as they are no longer needed for the processing purposes.
Data Recipients
In the following the recipients of the data collected are listed.
- ReGuest GmbH
Click here to read the privacy policy of the data processor https://www.reguest.io/en/information/privacy-policy/5-0.html
Click here to read the cookie policy of the data processor https://www.reguest.io/en/information/cookies/6-0.html
Storage Information
Below you can see the longest potential duration for storage on a device, as set when using the cookie method of storage and if there are any other methods used.
- Non-cookie storage: no
This service uses different means of storing information on a user’s device as listed below.
__utma*
This cookie provides information on when you first visited the website, on the number of visits and on the last visit.
Type: cookie
Duration: Session
__utmb*
This cookie contains a hash value of all the here mentioned UTM Cookies.
Type: cookie
Duration: Session
__utmv*
This cookie is dedicated to individual contents. Being an empty cookie, it serves to store visitor-level custom-variable data.
Type: cookie
Duration: Session
__utmx*
This cookie contains values of the Google Website Optimizer.
Type: cookie
Duration: Session
__utmz*
This cookie contains information on the visitor traffic source that explains how the user reached the site. It may store information on search engines and the entered search terms, or where the IP address of the visitor is located.
Type: cookie
Duration: Session
__utmt*
Shows the type of request made. (It could be an event, transaction, itemoro custom variable. If there is no specification given it is a pageview.)
Type: cookie
Duration: Session
_ga, _gid
This cookie is used to identify users.
Type: cookie
Duration: Session
_gat
Used to create tracker objects.
Type: cookie
Duration: Session
_gac_
Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out.
Type: cookie
Duration: Session
1P_JAR
These cookies are used to support Google's advertising services.
Type: cookie
Duration: Session
AID
Google also use cookies named "AID", "DSID" and "TAID" which are used to link your activity across devices if you’ve previously signed in to your Google Account on another device. We do this to coordinate the ads you see across devices and measure conversion events. These cookies may be set on the domains google.com/ads, google.com/ads/measurement, or googleadservices.com.
Type: cookie
Duration: Session
APISID
Google uses cookies like the PREF, NID or SID cookie to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
CONSENT
These cookies are used to support Google's advertising services. DSID, Google, performance, stay active: 2 years. This cookie by doubleclick.net is used by Google to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
HSID
Google use cookies called "SID" and "HSID" which contain digitally signed and encrypted records of a user’s Google account ID and most recent sign-in time. The combination of these two cookies allows Google to block many types of attack, such as attempts to steal the content of forms that you complete on web pages.
Type: cookie
Duration: Session
DSID
This cookie by doubleclick.net is used by Google to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
IDE
This cookie by doubleclick.net is used by Google to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
NID
Google uses cookies like the PREF, NID or SID cookie to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
PREF
Google uses cookies like the PREF, NID or SID cookie to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
SAPISID
Google uses cookies like the PREF, NID or SID cookie to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
SID
Google uses cookies like the PREF, NID or SID cookie to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
SSID
Google uses cookies like the PREF, NID or SID cookie to individually adjust advertisements in Google products like the Google search. The cookies are used to capture, for instance, the Google newest searches, your former interaction with advertisements or the search results and your visits on websites of an advertiser. This way you receive individually customised advertisement on Google.
Type: cookie
Duration: Session
GPS
Registers a unique ID on mobile devices to enable tracking based on geographical GPS location.
Type: cookie
Duration: Session
YSC
Registers a unique ID to keep statistics of what videos from YouTube the user has seen.
Type: cookie
Duration: Session
_fbp
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
Type: cookie
Duration: Session
fr
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
Type: cookie
Duration: Session
vuid
Collects data on the user's visits to the website, such as which pages have been read.
Type: cookie
Duration: Session
_hjid
This cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the random user ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.
Type: cookie
Duration: Session
_hjClosedSurveyInvites
This cookie is set once a visitor interacts with a Survey invitation modal popup. It is used to ensure that the same invite does not re-appear if it has already been shown.
Type: cookie
Duration: Session
_hjDonePolls
This cookie is set once a visitor completes a poll using the Feedback Poll widget. It is used to ensure that the same poll does not re-appear if it has already been filled in.
Type: cookie
Duration: Session
_hjMinimizedPolls
This cookie is set once a visitor minimizes a Feedback Poll widget. It is used to ensure that the widget stays minimizes when the visitor navigates through your site.
Type: cookie
Duration: Session
_hjDoneTestersWidgets
This cookie is set once a visitor submits their information in the Recruit User Testers widget. It is used to ensure that the same form does not re-appear if it has already been filled in.
Type: cookie
Duration: Session
_hjMinimizedTestersWidgets
This cookie is set once a visitor minimizes a Recruit User Testers widget. It is used to ensure that the widget stays minimizes when the visitor navigates through your site.
Type: cookie
Duration: Session
_hjIncludedInSample
This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels.
Type: cookie
Duration: Session
_hjShownFeedbackMessage
This cookie is set when a visitor minimizes or completes Incoming Feedback. This is done so that the Incoming Feedback will load as minimized immediately if they navigate to another page where it is set to show.
Type: cookie
Duration: Session
ASPSESSIONID*
System cookie, used to keep the user session up
Type: cookie
Duration: Session
PageConfig.HttpFirstReferrerLink
Origin URL is attached to e-mails.
Type: cookie
Duration: Session
Page_*
Used to save actions performed by the visitor
Type: cookie
Duration: Session
sImageMode
Used to determine if the user accesses the website from a desktop, tablet or mobile device.
Type: cookie
Duration: Session
bCookieBarClosed
This cookie indicates whether or not the cookie banner is being displayed on the webpage.
Type: cookie
Duration: Session
RG_Messenger_Token
Device token for switching between offer area and website
Type: cookie
Duration: Session
RG_Messenger_Token_*
Additional cookie for guest area identification (Re:Guest Messenger), so that logout and new registration work correctly
Type: cookie
Duration: Session
-
Remarketing and behavioural targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
In order to understand Google's use of Data, consult Google's partner policy.
Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
-
SPAM protection
This type of service analyses the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.
Google reCAPTCHA (Google Ireland Limited)
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie
Policy.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Website, if not stated otherwise within this document.