Subject: On this page the procedures are described for the management of this Internet site with regard to the processing of the personal data of the users who consult it.

This informative note is issued pursuant to art. 13 of Lgs. Decree No. 196/2003 – the personal data protection code – for the users of the services of our site which are available via Internet.

The informative note is not valid for other web sites that the user may consult through our links.

The informative note is based on Recommendation No. 2/2001 that the European Supervisory Authority on the protection of individuals with regard to the processing of personal data, represented by the Working Pary instituted pursuant to art. 29 of Directive 95/46/EC, adopted on 17^th May 2001 for the identification of certain minimum requisites for the on-line collection of personal data and, in particular, the procedures, timing and nature of the information that the Data Processor must provide to the users when these link up to the web page, regardless of the purpose of the connection.

THE DATA PROCESSOR
Following consultation of this site, data relative to identified or identifiable persons could be processed.

The Data Processor is the company

Gardaqui S.r.l.
Via S.Nazzaro,2
I-38066 Riva del Garda (TN)
ITALY

PLACE OF DATA PROCESSING
The processing involved with the web services of this side is carried out at the Data Processor’s head office by employees or collaborators of the aforesaid company who are assigned with the task of the processing and by any person charged to carry out occasional maintenance operations.

TYPE OF DATA PROCESSED

Surfing data
The computerised systems and the software procedures used for the functioning of this web site acquire, in the course of their normal use, certain personal data, the transmission of which is implicit in the use of the Internet communications protocols.

The said data are not collected for the purpose of being associated to the identified persons concerned, but could, by their very nature, through the processing and association with data held by third parties, allow for the identification of the users.

This category of data includes the IP addresses or the domain names in the computer used by the users who link up to the site, the addresses entered in the URI (Uniform Resource Identifier) of the requested resources, the time of the request, the method used for presenting the request to the server, the size of the file obtained in reply, the numeric code indicating the state of the reply given by the server (successfully transmitted, error, etc.) and other parameters relative to the user’s operating system and computer environment.

These data are used only for the purpose of acquiring anonymous statistical information on the use of the site and to control its correct functioning. The data could be used in order to ascertain responsibilities in the case of hypothetical information technology crimes to the damage of the site.

Data provided voluntarily by the user
In this site, the User may provide voluntarily and in a facultative manner his/her own personal data, including his/her e-mail address, in order to:
· acquisition and the entry of the user’s data and e-mail address into automated databases;
· send general requests, requests to the help desk, and for intervention and commercial purposes. Filling in the forms that are on the site involves the acquisition of the data necessary to answer the requests made. These data shall, in any case, be eliminated from the databases once the User’s requests have been dealt with, except in cases that are clearly specified by means of special informative sheets and subject to the User’s approval.
· send curricula or requests for employment. The compilation of the curriculum involves the acquisition of personal data in order to perform the procedures involved in the search for personnel;
· send an inquiry relative to availability or a booking request to selected hotels. The acquisition of the data of such inquiries and requests and the sender’s e-mail address is necessary in order to respond to the request made. Such data will, in any case, be eliminated from the databases once the User’s requests have been dealt with, except in cases that are clearly specified by means of special informative sheets and subject to the User’s approval;
· manage his/her request for general information and/or booking in order to provide him/her with the relative information;
· provide contents, services and personalised instructions to the user on the basis of his/her language preferences, the post code, the country, and any other content and preference specified;
· invite the user to take part in surveys relative to products, services, news and events.

Specific summarised information is given or visualised on the site page prepared for the compilation of the eventual request or registration with the site.

Cookies
A cookie is a very short text file saved from a Web site on the computer hard disk to allow for memorising personal information or the preferences provided by the user.

The Data Processor reads the cookies only for the purpose of facilitating access to the site and surfing on the part of the user.

The use of session cookies (which are not permanently memorised on the user’s computer and which disappear when the browser is closed) is strictly limited to the transmission of the session IDs (composed of random numbers generated by the server), which are necessary to allow for the safe and efficient exploration of the site.

The session cookies used in this site avoid the need to take recourse to other information technology techniques that represent potential risks for the confidentiality of the user’s surfing and which do not allow for the acquisition of the user’s personal identification data.

The Data Processor uses cookies every time a LogIn is carried out, memorising on the hard disk the user’s unique identifier, the time of access, and the date. Such a cookie allows for moving from one page to another without having to repeat the access procedure each time. When the browser is closed, the cookies are eliminated by the computer being used.

Logfiles
All the events generated by the interaction of the web site with the external environment are memorised in sequence by the webserver in a special filed called a logfile.

This information allows for us to understand whether our site is really an effective instrument for supplying the services that it offers and is used solely for statistical purposes.

THE FACULTATIVE NATURE OF THE GRANTING OF THE DATA
Apart from what is specified regarding the data for surfing, the user chooses freely whether to supply his/her personal data to request the services offered by our company. The refusal to grant the data, however, may make it impossible to obtain what has been requested.

PROCESSING MODALITIES
The personal data are processed by automated instruments and on hard copy for the time strictly necessary for performing the purposes for which they were collected.
Specific security measures are observed in order to prevent the loss of the data, the illegal or incorrect use of the same, and unauthorised access.

RIGHTS OF THE DATA SUBJECT
According to the prescriptions of art. 7 of Lgs. Decree No. 196/2003, the person concerned may:
· obtain the rectification, updating, erasure, anonymization, or blocking of data that have been processed unlawfully;
· obtain a certification to the effect that the aforesaid operations have been notified to the entities to whom the data were communicated within the limits indicated by art. 7, paragraph 3, letter c) of Lgs. Decree 196/2003;
· object, on legitimate grounds, to the processing of data concerning him/her or to the processing of data concerning him/her, where it is carried out for the purpose of sending advertising material or for the performance of market or commercial communications surveys by writing to:

Gardaqui S.r.l.
Via S.Nazzaro,2
I-38066 Riva del Garda (TN)
Or
info@gardaqui.com