**What is the Privacy Policy**
This page describes the management methods of the site regarding the processing of personal data of users who consult it.
This information is also provided pursuant to Article 13 of Legislative Decree no. 196/2003 – Code regarding the protection of personal data for those who interact with the web services of AMERICAN HOTEL SRL, accessible electronically from the address: www.americanhotelnapoli.it/
This information is provided only for the website of AMERICAN HOTEL SRL, the Data Controller, and not for other websites that may be consulted by the user through links.
The information complies with European Community regulations and more precisely with Recommendation no. 2/2001 which the European authorities for the protection of personal data, gathered in the Group established by Article 29 of Directive no. 95/46/CE, adopted on May 17, 2001, to identify certain minimum requirements for collecting personal data online, and, in particular, the methods, timing, and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purpose of the connection.
**THE “DATA CONTROLLER”**
Pursuant to Article 28 of Legislative Decree 196/2003, the Data Controller is AMERICAN HOTEL SRL with headquarters in Riv. di Chiaia, 256 – 80121 Napoli
**THE “DATA PROCESSORS”**
Pursuant to Article 29 of Legislative Decree 196/2003, the Data Processor is AMERICAN HOTEL SRL.
Pursuant to Article 29 of Legislative Decree 196/2003, the external Data Processor for the management of the website and the acquisition of personal data during the booking phase is D-EDGE, 66 Rue des Archives 75003 Paris France, owner of the hotel booking engine (www.d-edge.com) integrated into this website.
**DATA PROCESSING LOCATION**
The site is hosted on machines managed by an external company; however, communications are transmitted to the data controller to respond to user requests and ensure booking.
The processing connected to the web services of this site takes place at the offices of the data controller and the external data processors for areas of relevance.
No data deriving from the web service is communicated by the two companies to third parties unless strictly pertinent to the purpose of the processing or imposed by laws or regulations.
**PURPOSE OF THE PROCESSING**
The personal data voluntarily and optionally provided by users who submit requests to receive information about hotel services (prices, room availability, etc.), or simply submit job applications by sending electronic resumes, are used solely to perform the service or provision requested and are not communicated to third parties unless the communication is imposed by legal obligations or is strictly pertinent and necessary to fulfill the requests.
Specifically, the personal data voluntarily provided by the subjects will be collected and processed, including by electronic means directly and/or through third parties (companies providing email services, companies hosting the website) for the following purposes:
– Verify the availability of the requested room based on information entered in the booking form;
– Allow and confirm the booking by providing identifying data and credit card information as a guarantee;
– Activate any promotional and commercial activities in accordance with Article 130, paragraph 4 of Legislative Decree 196/2003;
– Comply with current administrative, accounting, and tax obligations, as well as comply with laws and regulations;
– Provide answers about our hotel services (room availability, prices, conference rooms, catering, etc.);
– Register for the newsletter to receive periodic commercial or promotional communications;
– Evaluate any resumes received in line with potential internal needs;
– For the defense by the Data Controller in court or in preparatory phases to its potential establishment, from abuses resulting from an illegal use of the website or related services by the user;
– Statistical purposes in anonymous form (to evaluate the number of accesses, etc.).
**BOOKINGS**
Personal data related to bookings will be processed electronically and on paper solely to guarantee the room reservation under the agreed conditions.
The booking platform is owned by D-EDGE, the external data processor, which will communicate the data of the subject to the accommodation facility for normal activities related to hospitality management.
The data will be recorded in our electronic databases accessible to duly authorized personnel trained in data security and confidentiality.
To confirm the booking, a credit card provided as a guarantee will be required, although the customer may decide to pay in cash at the end of the stay.
**MANAGEMENT OF RESUMES**
This information, prepared in accordance with Article 13 of Legislative Decree 196/2003, can also be used by AMERICAN HOTEL SRL for any job advertisements published on websites or portals not directly managed by AMERICAN HOTEL SRL.
The company will process the resumes received by email or through third-party recruiting companies (published on portals, etc.) to evaluate potential candidates within the company or for future opportunities.
Processing is done electronically, except for resumes received by regular mail.
Resumes considered “interesting” will be kept at the company’s headquarters for a period not exceeding one year and will be processed in full compliance with the minimum security measures provided by Articles 33, 34, and 35 of Legislative Decree 196/2003.
Resumes deemed not relevant or those exceeding the 12-month retention period will be discarded.
Resumes will still be stored at the company’s headquarters and will not be communicated to unauthorized third parties.
They may be evaluated by employees or collaborators of the company appointed as data processors (pursuant to Article 30 of Legislative Decree 196/2003).
Applicants are invited to follow these rules when sending electronic resumes:
– Complete their resume in European format;
– Send the resume in PDF format;
– Avoid including sensitive data (related, in particular, to health status, religious, philosophical, or political beliefs) not relevant to the job offer;
– Provide consent for processing.
The company reserves the right to discard resumes that do not comply with the above requirements.
The company will provide appropriate information pursuant to Article 13 of Legislative Decree 196/2003 during any interviews with candidates.
The purpose of processing related to resume management will involve activities strictly related to evaluating, recruiting, or selecting staff, with collaboration, fixed-term or permanent employment, internships, or to allow the selected candidate to prepare their thesis at our headquarters.
**COMMERCIAL EMAIL COMMUNICATIONS**
AMERICAN HOTEL SRL reserves the right to send promotional and commercial emails in accordance with Article 130, paragraph 4 of Legislative Decree 196/2003:
“If, in the context of a sale of a product or service, the Data Controller uses the customer’s email address, the same address can be used to send commercial and promotional material without prior consent provided the customer is properly informed with each promotional and commercial material sent and that they can easily and freely exercise their right to stop such processing.”
In this case, the recipient, after receiving the first promotional message, will have the option to unsubscribe from the hotel’s newsletter with a simple click.
Sending these messages is entrusted to a third-party email service provider.
**COMMUNICATION AND DISCLOSURE OF DATA**
Personal data acquired from the website in question may be processed only by personnel officially appointed and trained in confidentiality and security of personal data.
The communication of personal data may refer to:
– Public entities or offices based on legal and/or contractual obligations;
– D-EDGE company;
– External data processors, including companies or consultants who carry out instrumental activities on behalf of the Data Controller for the proper functioning of the website and the management of information acquired through it;
– Postal Police for determining any harmful activities for the company’s website;
– Collaborators or service-providing companies when the communication is necessary for the user to use the hotel’s services.
Personal data will not be disclosed.
**NAVIGATION DATA**
The software applications aimed at the functioning of this website acquire, during their normal operation, some personal data whose transmission is implicit in the Internet communication protocol IP.
This information is not collected to be directly associated with identified subjects, but by their nature, they could, through processing and association with data held by third parties (providers), allow the identification of users.
This category of data includes IP addresses or domain names of the computers used by users who connect to the site, the date and time of the request, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the size of the file obtained in response from the server, the numerical code indicating the status of the response given by the server (ok, error, etc.) and other parameters related to the user’s operating system and computer environment.
These data are used solely to obtain anonymous statistical information on site usage and to check its proper functioning and are deleted immediately after processing.
This site may reveal personal data that, if required in accordance with the law, may be communicated to the judicial authority for purposes of defense of the State or for prevention, verification, or repression of crimes, act to ensure the protection of personal data of those using the site’s online services, for any defensive investigations pursuant to Law no. 397 of December 7, 2000, or, in any case, to assert or defend a legitimate right and interest of the Data Controller in judicial proceedings, always in compliance with the principles of relevance and not excess in relation to the purpose of the processing.
**OPTIONAL NATURE OF DATA PROVISION**
Apart from what is specified for navigation data, the user is free to provide personal data to make an online reservation.
The progress of the online booking procedure implies the implicit consent of the subject to the processing of their personal data according to the privacy policy of this website.
The acquisition of other personal data through dedicated forms (for example, newsletter registration) will require the explicit viewing of the information by the subject as authorization to process their personal data.
The failure to provide the personal data required by the website may make it impossible to obtain what is requested.
The optional, explicit, and voluntary sending of emails to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other
