Privacy Policy

This Privacy Policy has been published on 21/06/2019 and become effective for new users of websites and offline activities of Hotel Delfino Lugano on 21/06/2019.

Hotel Delfino Lugano Privacy Policy

Effective: 21/06/2019

IMPORTANT NOTICE

At Hotel Delfino Lugano, our mission is taking care of our guest to make enjoyable every moment of their stay in harmony with our “smart&friendly” style. That mission covers our offline and in-store activities, and extends to our online community as well through our websites, products and services (which we collectively refer to in this Privacy Policy as the “Services”). Our Privacy Policy describes how we collect and process your Personal Data through our websites (e.g., including, but not limited to, hoteldelfinolugano.ch (“Websites”)).

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY. END USERS FROM OUTSIDE THE US ARE ENCOURAGED TO.
Note to Residents of the European Union: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.

– Who We Are –
We are Hotel Delfino Lugano.

– Information About Your Personal Data-
This Privacy Policy relates to data about you, and your interaction with our Services.
“Personal Data” is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number and certain cookie.
Hotel Delfino Lugano collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business; for marketing.
We may create de-identified or anonymous data from Personal Data by excluding data components (such as your name or email address) that makes the data personally identifiable to you, through obfuscation, or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

– How We Collect and Use Personal Data –
We collect your Personal Data in a number of ways and for various purposes, including:
1. When you interact with our Services.
We collect Personal Data when you use or interact with our Services. This Personal Data may include name, address, phone number, email address, date of birth. We also use this data for internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
2. When you communicate with us or sign up for promotional materials.
We collect Personal Data when you communicate with us or sign up to receive promotional materials or information via email, or text messages – including email address, mobile number, etc.
If you consent to such messages, we may use your Personal Data and other information to communicate with you about the Hotel Delfino Lugano. products or Services you have purchased or used; provide you with promotional messages; to notify you of other products; to notify you of Services we think may be of interest to you; and, for other marketing purposes. You can manage your communication preferences by directly calling us or sending us an email.
Please note that regardless of your email settings, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to products or Services you have purchased or use.
We may use your Personal Data to respond to your requests for technical support, online services or to any other communication you initiate. This includes accessing your account to address support requests. We may also use your Personal Data to address your requests, inquiries, and complaints.
3. When we leverage and/or collect cookies.
We may collect certain Personal Data using cookies and other technologies such as web beacons and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.
4. When we aggregate or centralize data.
We aggregate and centralize Personal Data for purposes of analytics, innovation, and to provide enhanced services to our customers and end-users.
5. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes (Country/Region-Specific Disclosures may apply).
We may use Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

– How We Disclose Personal Data –
We may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy, in the Country/Region-Specific Disclosures section, and in the following ways:
1. To Social Network Providers.
With social network providers when we use social network widgets, buttons, or plug-ins in our Services
2. For Certain Analytics and Improvement
With certain companies for purposes of analytics and improvement of the Services.
3. For Legal Compliance, Law Enforcement, and Public Safety Purposes (Country/Region-Specific Disclosures may apply).
With law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.
4. In the event of an actual or contemplated sale. (Country/Region-Specific Disclosures may apply).
With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
Residents of the European Economic Area. Our disclosure is limited to situations where we are permitted to do so under applicable European and national data protection laws and regulations.

– Types of companies with whom we share data. –
Types of companies with which Hot. it shares the personal data of the users:
– Marketing and advertising operations: we share personal data with third parties for marketing and advertising purposes, eg, Facebook, Inc. (United States), to enable them to assist Hotel Delfino Lugano. in the promotion of our services inside and outside the platform for current and future customers through targeted advertising.
– Customer Service: These third-party systems and solutions enable us to provide support to respond to complaints and solve customer technical problems.
– We may request your consent to collect accurate location data. You may need to request this information to provide information on how to reach our company. In addition, we may request your consent to share your precise location data with third parties (Google through Google Maps) for viewing the map and calculating the route to reach our company

– Legal Basis for Processing –
This section addresses the legal basis for processing your data if you reside outside the Switzerland. Some processing is addressed in multiple sections because more than one legal basis may apply depending on the circumstances or service.
For the purposes of applicable data protection laws, Hotel Delfino Lugano is the controller of the Personal Data you provide to us (“Data Controller”). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Personal Data, or if you have questions regarding this Privacy Policy.

We collect and process your Personal Data for a variety of purposes outlined in this Privacy Policy. In certain cases, separate consent is not required, including:
1. For the performance of a contract
To perform our contractual obligations to you, including booking registration, fulfilling booking or booked you have made (including processing of payment), contacting you in relation to any issues with your order, in relation to the provision of the Services, where we need to collect Personal Data from third party sources and when you access third party products and services, where we collect data from third parties or publicly-available sources, or to aggregate and centralize data for the performance of the Services.
2. To meet legal obligations
To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.
For Legitimate Interests
To operate our business and provide the Services, other than in performing our contractual obligations to you for Hotel Delfino Lugano. “legitimate interests” for the purposes of applicable law – except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.
For example, the following areas include processing covered by Legitimate Interests, subject to applicable law:
Communication. To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms and also to address your requests, inquiries, and complaints. We may send strictly necessary communications, including emails, even if you have opted out of receiving other Hotel Delfino Lugano emails or communications. These types of communications do not require consent. We also process your Personal Data for our legitimate interests when you communicate with us, including when you sign up for promotional materials and we have not asked you for your consent in that regard.
Respond to Your Requests. To respond to your requests for technical support, online services, service information or to any other communication you initiate.
Promotional Messages. We process your non-sensitive Personal Data to provide you with promotional messages and personalized marketing, including: when you communicate with us or sign up for promotional materials; when we aggregate and centralize data; and when we share Personal Data with companies or ventures that are owned or controlled by Hotel Delfino Lugano. and with our service providers and vendors.
Surveys. To send you surveys in connection with our Services, unless commercial in nature. In those cases, a survey request may be sent to you if you have given us your consent to receive marketing from us.
Compliance with Law and Public Safety. To assist in the investigation of suspected illegal or wrongful activity. To protect and defend our rights and property, or the rights or safety of third parties.
Improvement and Development. To develop, provide, enhance, and improve our Services and your experience, including to enable you to use the full range of our Services. For internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
Enforcing Terms and Notice. To enforce our Terms or this Privacy Policy, or agreements with third parties.
Merger or Acquisition. (Country/Region-Specific Disclosures may apply). To support a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.

– Consent as a Basis for Processing –

In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when providing us with your Personal Data through our Services or a form (including enrolling in Promotions)
Managing Sharing Preferences
The information you share about our Services across Social Networks are subject to the Privacy Policy of that Service.

– Managing Preferences and Withdrawing Consent –

You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising and your communication settings. Depending on the Service, collection and use of Personal Data may be required for the Services to work.

We provide you several ways to manage your preferences:
1. Cookie Use and Controls
Cookies serve a wide variety of purposes. Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. Cookies are used to personalize your web experience and for security, analytics, marketing, and interest-based advertising. Our cookies are placed and read by our web servers, while other cookies are placed and read by other companies’ web servers. You can block and control cookies using the information noted in the Cookie Policy section. If you block all cookies, certain functionality on our website will not work.
The following settings will control our use of browser cookies, the use of IP address for tracking, and the collection and use of data for cookie-based, interest-based advertising.
[ IN ] Required Cookies: These strictly necessary cookies are used for core functionality, and recognize when you are signed in, remember things such as shopping carts and text entered, are necessary for security, and enforce your privacy preferences. Without these cookies, some functionality on our websites will fail. You can block these cookies in your browser preferences.
[ IN / OUT ] Functional Cookies: These cookies help to improve the sites by allowing us to understand how the site is used and how the site performs. These cookies include analytics and measurement.
[ IN / OUT ] Advertising Cookies: These cookies help us and other parties personalize ads that are shown to you on our sites and Services, as well as on other sites. If enabled, these cookies will allow third parties engaged in interest-based advertising on our site to recognize your browser software on other sites too.
2. IP Address Use
An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Privacy Policy, include “public” IP addresses, such as the IP address for a home router that is visible to the Internet, as well as “local” IP addresses, which are IP addresses assigned to computers and mobile devices “behind” a router (such as a home router). Our advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency.
You can choose not to have IP address used for purposes of advertising or analytics by using the cookie controls for “Advertising Cookies,” and “Performance/Analytics,” above.
3. Web Pixels
Pixels are extremely small image files that, when loaded by your web browser, cause the browser to make a network request to the party corresponding to the pixel. If that party’s cookies are currently stored in your browser, those cookies will be transmitted with the request.
4. Social Network Interaction and Widgets
Social network widgets, buttons, and plug-ins on our websites passively transmit data regarding a social network’s members to that social network, even when a button is not clicked. These technologies may allow a social network (such as Facebook, Twitter or YouTube) to personally identify its members and to know the web pages its members have visited. This is true wherever social network buttons are embedded, regardless of whether a button is “clicked” or “pressed.” If you belong to a social network or use these categories of web services, you should review the privacy policies of those services to understand the nature of the data that they collect and what, if any, options the service offers to control how data is collected and used. If you disable advertising cookies, the passive tracking associated with these buttons will be blocked on our sites.
5. Change Consent Settings for Communication Preferences
Consent for Email Communication: After signing up for email communications, you can choose to unsubscribe using the unsubscribe link in any commercial email we send. If you use more than one Service, then unsubscribing from the emails relating to that Service will not stop you from receiving emails from other Services. Please note that if you unsubscribe from “all emails” this means “all emails other than strictly necessary emails.” You will still receive email communications from us if they are strictly necessary to provide the Hotel Delfino Luygano. service or to confirm or validate a transaction, recover accounts, etc.

– Transfers of Your Personal Data to Other Countries –
The Personal Data Hotel Delfino Lugano processes, and all associated Services and systems, including registration, is housed on servers in the Switzerland. If you are located outside of the Switzerland, please be aware that Personal Data we collect will be processed and stored in Switzerland (the data protection and privacy laws in Switzerland may offer a lower level of protections than in your country/region).
By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in Switzerland. Where and as required, we will seek your explicit consent as outlined in this Privacy Policy

– Data Retention –
We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems. Where permissible, we will also delete your Personal Data upon your request. Information on how to make a deletion request can be found here.
If you have questions about our data retention practices, please contact us at info@hoteldelfinolugano.ch.

– Security –
We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

– Links to Other Websites –
Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide a link or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third Party Sites with that you interact with.
Children.
We do not knowingly collect Personal Data online from children under 16 (note that the minimum age may vary based on country/region, and on local law). If you become aware that a child has provided us with Personal Data without parental consent, please contact us through our Support Team. If we become aware that a child under 16 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel the child’s account.

– How to Contact Us –
If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us at info@hoteldelfinolugano.ch or write to us at:

Hotel Delfino Lugano
Privacy Office
Via Casserinetta 6
CH-6900 LUGANO

Lugano, 21/06/2019