Make a request - Family Two Bedroom Duplex Carrara
Sweetguest Travel Privacy Notice
Last update: 26 June 2020
Thank you for choosing Sweetguest Travel! Your trust is important to us and we are committed to protecting the privacy and security of your personal information. The information that is shared with us helps us to provide a quality experience with Sweetguest. This Privacy Notice describes how we collect, use, process and disclose your personal information in connection with your access to and use of the Sweetguest Travel Platform of Payment Services, and related services.
1.1 WHAT IS MEANT BY "DATA PROCESSING"?
The processing of personal data means (as indicated in the EU Regulation on data protection number 679/2016 Article 4 point 2) any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, even if not recorded in a database, such as collecting, recording, organising, structuring, storing, processing, selecting, blocking, adapting, modifying, retrieving, consulting, using, notifying by disclosing, disseminating or any other form of making available, comparing or interconnecting, restricting, erasing or destroying.
1.2 DATA CONTROLLER
Sweetguest SpA. Registered office: Corso Cristoforo Colombo 10, 20144 Milan (MI). email@example.com
1.3 APPLICABILITY TO PAYMENTS
This Privacy Notice also applies to the Payment Services provided to you by Sweetguest Travel in accordance with the General Terms and Conditions. When you use the Payment Services, you will provide your data, including personal data, to one or more companies of Sweetguest SpA or partner companies for payment services, which will also act as Data Controller.
2. TYPES OF DATA WE COLLECT
Sweetguest Travel collects three general categories of data.
2.1 Information you provide directly to us
2.1.1 Information required to use the Sweetguest Travel Platform
When you use Sweetguest Travel, we request and collect the following personal information. This information is necessary for the proper performance of the service and enables us to act in accordance with our legal obligations. Without this information, we may not be able to provide you with all the services you require.
● Guest data: when you make a booking or send a request for information, we ask you to provide certain data such as your first and last name, email address and telephone number.
● Payment information: to use certain features of Sweetguest Travel, we may ask you to provide certain payment information (such as your bank account details or credit card details) to facilitate payment processing.
2.1.2 Information necessary for the use of the Payment Services
In order to comply with the applicable law (e.g. anti-money laundering rules) and to properly perform contractual duties, the Data Controller needs to collect the following information. Without it, you will not be able to use the Payment Services:
● Payment information When you use Payment Services, the Data Controller requires certain payment details (such as your bank account details or credit card details) to process payments and comply with applicable law.
2.1.3 Information that we automatically collect from your use of Sweetguest Travel and the Payment Services
When you use Sweetguest Travel and the Payment Services, we automatically collect personal data relating to the services and how they are used. This information is necessary for the proper performance of the service and to enable us to act in accordance with our legal obligations and based on our legitimate interest in being able to improve and offer you the functionality of the Sweetguest Travel Platform and Payment Services.
● Location information. When you use certain features of the Sweetguest Travel Platform, we may collect information about your exact or approximate location, determined through information such as your IP address or the GPS of your mobile device, to provide you with a better user experience. Most mobile devices allow the user to control or disable the use of location services for applications in the device settings menu. Information on use. We collect information regarding your interactions with the Sweetguest Travel Platform, including, for example, the pages or other content you view, your ad searches, bookings made and other actions you take on the Sweetguest Travel Platform.
3. HOW WE USE THE DATA WE COLLECT
Sweetguest Travel may use, store and process personal information to (1) provide, understand, improve and develop the Platform, (2) create and maintain a reliable and more secure environment (such as to fulfil our legal obligations and ensure compliance with Sweetguest's Policies) and (3) provide, customise, evaluate and enhance advertising and marketing.
3.1 Provide, improve and develop the Sweetguest Travel Platform. We may use your personal information to provide, improve and develop the Sweetguest Travel Platform, for example:
● allow you to access and use the Sweetguest Travel Platform
● allow you to communicate with other Members
● manage, protect, improve and optimise the Sweetguest Travel Platform and our users' experience, including, for instance, conducting analysis and research activities
● help customers
● send you service or support messages, such as, for example, updates, alerts, and booking notifications if you provide us with your contact information, we may process this information for: (i) the facilitation of your referral invitations, (ii) the sending of requests for references, (iii) the detection and prevention of fraud, and (iv) any purpose authorised by you at the time of collection
● manage, protect, enhance and optimise the Sweetguest Travel Platform our users' experience, as well as customise your experience (such as by organising search results, displaying advertisements based on your search), and facilitate claims with our Host Guarantee, Host Protection Insurance and Experience Insurance Cover, or other similar host protection programmes
● enable you to use our products
We process the personal information you provide for these purposes based on your legitimate interest in improving our Sweetguest Travel Platform and experience, and where necessary to ensure the proper performance of the service.
3.2 Create and maintain a more reliable and secure environment. We may use your personal information to create and maintain a reliable and secure environment such as, for example:
● to detect and prevent fraud, spam, abuse, security incidents and other harmful activities
● to carry out safety investigations and risk assessments
● to verify or authenticate the information or identifications you provide (e.g. verify the address of your Accommodation)
● to perform checks by cross-checking with databases and other sources of information, including background checks, to the extent permitted by applicable law and with your consent when applicable
● to fulfil our legal obligations
● to resolve any disputes with our Members and enforce our rights against third parties
● to ensure the application of our General Conditions and other policies
● in connection with the activities described above, we may perform profiling based on your interactions with the Sweetguest Travel Platform, other content you submit to the Platform and information obtained from third parties.
We process personal information for these purposes based on our legitimate interest in protecting our Sweetguest Travel Platform, measuring the proper performance of the contract between us and you and complying with applicable laws.
3.3 Provide, customise, evaluate and improve our advertising and marketing. We may use your personal information to provide, customise, evaluate and improve our advertising and marketing, for example:
● by sending you promotional messages, marketing information, advertising and other information that may be of interest to you based on your preferences (including information about campaigns and services from Sweetguest Travel or a partner) and social media advertising through social media platforms (such as Facebook or Google)
● by customising, evaluating and improving our advertising
● by managing referral programmes, prizes, surveys, sweepstakes or other promotional activities or events sponsored or managed by Sweetguest Travel and our partners, such as catering services, home delivery services, transportation services and tourism services
● by carrying out profiling based on your characteristics and preferences (based on the information you provide, your interactions with the Sweetguest Travel Platform, information obtained from third parties and your booking and search history) in order to send you promotional, marketing, advertising and other information that we believe may be of interest to you.
We will process your personal information for the purposes listed in this section because of our legitimate interest in engaging in marketing activities to offer you products or services that may be of interest to you.
3.4 Methods of use of the data collected by the Data Controller
We may use your personal information as part of the Payment Services, for example, for:
● enabling you to access and use the Payment Services.
● detecting and preventing fraud, abuse, security incidents and other harmful activities.
● carrying out safety investigations and risk assessments.
● performing checks by making comparisons with databases and other sources of information.
● complying with our legal obligations (such as anti-money laundering regulations).
● ensuring the application of our Terms of Service and other payment policies.
● With your consent, we will send you promotional messages, marketing information, advertising and other information that may be of interest to you according to your preferences.
The Data Controller processes the information provided on the basis of a legitimate interest in improving the Payment Services and the experience of its users, as well as to ensure the proper performance of the contract with the user where necessary and to comply with applicable laws.
3.6 Your choices
You have options on the promotional messages you choose to receive.
● You can limit the information you give Sweetguest. Participation in promotions and marketing programmes is voluntary.
● You can limit the messages Sweetguest sends you.
○ To opt-out of marketing emails, click the "unsubscribe" link at the bottom of any marketing email we send you
○ Please note that even if you opt out of marketing messages, we may still need to contact you for important transaction or booking information.
3.7 What happens if personal data are not provided by Users?
Apart from what has been specified above with regard to browsing data, the personal data that must be provided by the Users are normally made up of the Users' first and last names, their email addresses and payment details to complete the purchase. The conferment of any other personal data required in the forms for access to the service is therefore optional and entirely left up to Users to issue them.
Any refusal to provide personal data for the purposes set out in points 2.1.1 and 2.1.2 above will make it impossible for Users to register with the Site, to make requests and to receive the services.
With reference to the purposes of the processing referred to in point 3.3, consent to the processing of personal data is merely optional and may be expressed by ticking the box on registration on the Site.
3.8 Retention period of Users' personal data
Users' personal data will be retained only for the time necessary to ensure the correct provision of the services offered by Sweetguest.
In order to send the newsletter, personal data (name, surname and email address) will be kept until the Users have sent their wish to unsubscribe and in any case for a period of 36 months from the date of the last interaction with Sweetguest.
Personal data relating to Users' preferences will be retained and processed for the purposes set out in point 3.3 above for a maximum period of 36 months.
In any case, at the end of the retention period, data will be deleted, aggregated or anonymised.
More information about the retention period of Users' personal data and the criteria used to determine this period can be requested by writing to: firstname.lastname@example.org.
4. SHARING AND DISCLOSING
4.1 Advertising and social media; sharing with your consent
Where you have given your consent, we may share your data, including personal data, as described when we have obtained your consent, for instance when you participate in promotional activities conducted by Sweetguest partners or third parties.
Where permitted under applicable law, we may use certain limited personal information about you, such as your email address, to hash and share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Sweetguest Travel platform. These processing activities are based on our legitimate interest in undertaking marketing activities in order to offer you products or services that may be of interest to you.
Sweetguest does not control or supervise the social media platforms with which your personal information may be shared. Therefore, any questions regarding how your personal data are processed by the social media provider should be directed to the provider in question.
We remind you that, at any time, you can request Sweetguest to stop processing your data for marketing purposes by sending an email to email@example.com.
4.2 Compliance with the law, response to requests from public authorities, prevention and protection of our rights
Sweetguest Travel may disclose your data, including personal data, to courts, public authorities, government authorities, tax authorities or authorised third parties if and to the extent we are required or authorised to do so by law or where such disclosure is reasonably necessary: (i) to comply with our legal obligations (ii) to comply with a valid legal request or to respond to claims made against Sweetguest Travel, (iii) to comply with a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity likely to expose us, yourself or any of our other users with legal responsibilities, (iv) to manage and enforce our Terms of Service, Terms of Payment, (v) to protect the rights, property or personal safety of Sweetguest, its employees, customers or the general public. Such information may be necessary to comply with our legal obligations, to protect your or another person's vital interests or for the protection of our or third parties' legitimate interest in keeping the Sweetguest Travel platform secure, prevent damage or crime, enforce or defend rights or prevent damage, facilitate tax collection and prevent tax fraud or damages.
4.3 Aggregated data
We may also share aggregate data (information about our users that we combine together in a way that does not identify or trace back to an individual user) and other anonymous information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5. OTHER IMPORTANT INFORMATION
5.1 Partners and third-party integrations
The Sweetguest Travel Platform may contain links to third-party websites or services, such as third-party integrations, co-branded services or third-party branded services ("Third-Party Partners"). Sweetguest Travel does not own or control such third-party partners and when you interact with them, information about you may be provided directly to the third-party partners, Sweetguest Travel or both. These third-party partners have their own rules regarding the collection, use and disclosure of data. Please read the Privacy Notice of the other sites you visit carefully.
6. YOUR RIGHTS
In accordance with applicable law, you may exercise any rights described in this section against the Data Controller and the Payment Processor applicable to you.
6.1 Data retention and deletion
In general, Sweetguest Travel stores your personal data for the time necessary to perform the service and to fulfil our legal obligations, and in any case for a period of 36 months from the date of your last interaction with Sweetguest.
We remind you that if you decide to request the deletion of your personal data:
● we may retain some of your personal data for as long as necessary to satisfy our legitimate business interests, such as preventing and detecting fraud and promoting security. we may retain some of your personal data to the extent necessary to fulfil our legal obligations.
6.2 Withdrawal of consent and limitation of the data processing
Where the processing of your personal data is based on consent, you may revoke this consent at any time by sending us a notice specifying which consent you wish to revoke at firstname.lastname@example.org. Please note that the revocation of consent does not affect the legitimacy of any processing activity based on it prior to its revocation.
6.3 Submission of complaints
You have the right to complain about our data processing activities to our Data Protection Officer, who can be reached via the email address email@example.com.
You have the right to lodge a complaint as a natural person concerned with the Data Protection Supervisor, following the procedures and instructions published on the Authority's official website at www.garanteprivacy.it.
Sweetguest Travel constantly implements and updates administrative, technical and physical security measures to help protect your data from unauthorized access, destruction or alteration. Some of the security measures we use to protect your information are firewalls, encryption and information access controls.
9. CHANGES TO THIS PRIVACY NOTICE
Sweetguest reserves the right to change this Privacy Notice at any time in accordance with this section. If there are any changes to this Privacy Notice, we will post the updated version on the Sweetguest Travel Platform and update the "Last Updated" date at the top of this document. We will also provide you with notice of changes made by email
10. CONTACT US
If you have any questions or complaints regarding this Privacy Notice or Sweetguest Travel's data processing practices, you can send us an email at firstname.lastname@example.org.