Welcome to Simply Dolomiti privacy policy

THIS PRIVACY POLICY WILL REGULARLY BE UPDATED TO REFLECT THE WAY WE PROCESS YOUR PERSONAL DATA OR ANY CHANGES IN THE APPLICABLE LAWS

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1.    WHO WE ARE

1.1. Simply Dolomiti Ltd.
1.2. Our contact detail is as follows: Simply Dolomiti, 107a Milton Road, Cambridge, CB4 1XE, England
1.3. Data Privacy Officer: Mogens Kristensen: Tel: +442081331979, Email: mogens@simplydolomiti.com

2.    OUR PRIVACY STATEMENT
2.1. Simply Dolomiti respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we protect the personal data we process and control relating to you (“personal data”) and tell you about your privacy rights. We want to ensure you are aware of our practices for processing your personal data.
2.2. This privacy statement applies to personal data we collect about you, when contact Simply Dolomiti.
2.3. The following sections provide further details on how we protect your personal data:

1.    FOR WHICH PURPOSE WE COLLECT YOUR PERSONAL DATA AND WHICH LEGAL BASIS
2.    WHICH CATEGORIES OF DATA WE COLLECT ABOUT YOU
3.    DO WE USE THIRD-PARTY LINKS TO WEBSITES AND PROGRAMS
4.    HOW YOUR PERSONAL DATA IS COLLECTED
5.    HOW WE USE COOKIES
6.    HOW WE USE YOUR PERSONAL DATA WHEN YOU VISIT OUR RESORTS AND HOTELS
7.    HOW WE USE PERSONAL DATA FOR MARKETING PURPOSES
8.    WHAT YOUR RIGHTS ARE IN RESPECT OF MARKETING COMMUNICATIONS
9.    WHO THE INTENDED RECIPIENTS OF YOUR PERSONAL DATA ARE
10.   HOW LONG WILL WE USE YOUR PERSONAL DATA FOR
11.   TRANSFER OF YOUR PERSONAL DATA
12.   HOW WE PROTECT YOUR PERSONAL DATA
13.   WHAT RIGHTS DO YOU HAVE IN RESPECT OF THE PROCESSING OF YOUR PERSONAL DATA
 
PERSONAL DATA GLOSSARY
Applicable laws means for the purpose of this Privacy Policy in respect of European Union citizens, the law of the country of their residence for the purpose of the GDPR (as defined below);
Biometric data means any personal data relating to the physical, physiological or behavioural characteristics of an individual which allow his unique identification, including facial images or dactyloscopy data;
Consent means any freely given specific, informed and unambiguous indication of the wishes of a data subject, either by a statement or a clear affirmative action, by which he signifies his agreement to personal data relating to him being processed.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Direct marketing means the communication of any advertising or marketing material which is directed to any particular individual.
Encryption means the process of transforming data into coded form;
GDPR means the European Union General Data Protection Regulation, which came into force in 25 May 2018;
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interest. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interest against any potential impact on you in respect of specific activities by contact us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Processing means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information and the additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed;
Third party means a person or public body other than a data subject, a controller, a processor or a person who, under the direct authority of a controller or processor, who or which is authorised to process personal data;
Traffic data means any data relating to a communication by means of a computer system and generated by the system that form part in the chain of communication, indicating the communication’s origin, destination, route, time, date, size, duration, or type of underlying service.

 
1.    FOR WHICH PURPOSE WE COLLECT YOUR PERSONAL DATA AND WHICH LEGAL BASIS
1.1.    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
1.1.1.    Where we need to perform the contract we are about to enter into or have entered into with you.
1.1.2.    Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
1.1.3.    Where we need to comply with a legal or regulatory obligation.
1.2.    We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

IMPORTANT: Except for certain information that is required by law, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data, or you fail to provide that data when requested. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Privacy Policy, in particular, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services available at our Resorts). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

1.3.    We will not use your personal data for purposes that are incompatible with the purposes for which we collected it, and of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
1.4.    We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. For example, in order to prevent fraud and other illegal activity, and for verification process of any online transaction or payment.
1.5.    We use your personal data only where required for specific purposes. See below for (i) a list of the purposes for which we use your personal data and (ii) an overview of the legal basis for each such purpose.

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2.    WHICH CATEGORIES OF DATA WE COLLECT ABOUT YOU  
2.1.    We collect personal data of Simply Dolomiti employees, potential employees, customers, suppliers and service providers, and website users. If the data we collect are not listed in this Privacy Policy, we will give individuals (when required by law) appropriate notice of which other data will be collected and how we will be using them.
2.2.    If you provide us with personal data of another person (other than a child), you are responsible for ensuring that such person is made aware of the information contained in this Privacy Policy and that the person has given you his/her consent for sharing the information with us.
2.3.    The personal data we collect includes and are grouped together as follows:
2.3.1.    Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2.3.2.    Contact Data includes billing address, delivery address, email address and telephone numbers.
2.3.3.    Financial Data includes bank account and payment card details.  We do not store any credit card details.
2.3.4.    Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
2.3.5.    Technical Data (if applicable) includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
2.3.6.    Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
2.3.7.    Usage Data includes information about how you use our website and services.
2.3.8.    Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.4.    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
2.5.    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Policy.
2.6.    We do not collect ‘sensitive personal data’ also known as Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.7.    In limited cases where we do seek to collect sensitive data (for example your food preference, allergies, health conditions, current medication, any physical conditions that affect your mobility) we will do so in accordance with data privacy law requirements and/or ask for your explicit consent.

IMPORTANT: This website is not intended for children and we do not knowingly collect data relating to a child under the age of 18. By law, parents or guardians of the child have the obligation to provide data related to the child. In this case, we shall make every reasonable effort to verify using any reasonable means (including but not limited to any written supporting evidence) that the express consent has been given or authorised.

2.8.    The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). Such third parties include our affiliates, public authorities, public websites and social media, suppliers and vendors.

IMPORTANT: It is important that the personal data we hold about you is accurate and current. Please keep us informed and click here, if your personal data changes during your relationship with us.

3.    DO WE USE THIRD-PARTY LINKS TO WEBSITES AND PROGRAMS
3.1.    The use of our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
3.2.    We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy/statement of every website you visit.

4.    HOW YOUR PERSONAL DATA IS COLLECTED   
4.1.    We use different methods to collect data from and about you including through:
4.1.1.    Direct interactions:
4.1.1.1.    You may give us your personal data when you fill in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: (i) book a holiday; (ii) request brochures or newsletters to be sent to you; (vi) enter a competition, promotion or survey;
4.1.1.2.    If you contact us, we may keep a record of that correspondence;
4.1.1.3.    Any postings, comments or other content that you upload or post to on websites.
4.1.2.    Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns, traffic data. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
4.1.3.    Third parties or publicly available sources. We may receive personal data about you from a third party.

5.    HOW WE USE COOKIES  
5.1.    If using our website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
5.2.    If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
5.3.    For more information about the cookies we use, click here

6.    HOW WE USE PERSONAL DATA FOR MARKETING PURPOSES
6.1.    The source of our marketing data relates to the data and information collected through our direct interactions with you.
6.2.    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

7.    WHAT YOUR RIGHTS ARE IN RESPECT OF MARKETING COMMUNICATIONS
7.1.    You can exercise your right to prevent us from using your personal data for direct marketing by ticking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you.

IMPORTANT: Your explicit consent will be required if you do not wish to receive any of our promotional offers and marketing communications from us.

7.2.    In each case, you have not opted out of receiving that marketing, you will receive promotional offers from us. We may then use your Identity Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide, which services and offers may be relevant for you.
7.3.    You will also receive marketing communications from us if you have requested information from us or purchased or made a booking with us, or if you provided us with your details when you entered a competition or registered for a promotion.

IMPORTANT: You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our database at any time by contacting us. In such cases, we will retain minimum personal data (for example, personal data provided to us as a result of a booking or previous service experience at our Resorts) to note that you opted out in order to avoid contacting you again.
 
8.    WHO THE INTENDED RECIPIENTS OF YOUR PERSONAL DATA ARE
8.1.    We do not share your personal data with any company outside Beachcomber for marketing purposes, but should this be the case, we will get your express opt-in consent before we proceed.
8.2.    In relation to the purposes for which we collected your personal data, we may have to share your personal data to:
8.2.1.    Internal third parties such as our preferred service providers (such as IT systems suppliers and support, and other service providers)  from whom we require (i) to respect the security of your personal data, and to treat it in accordance with the law, and (ii) not to use your personal data for their own purposes, and (ii) only to process your personal data for specified purposes and in accordance with our instructions.
8.3.    We may require to share your personal data to external third parties:
8.3.1.    Our professional advisors that is our accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all countries where Simply Dolomiti operates;
8.3.2.    Any public or enforcement authority in Italy or elsewhere, or in case of a court, administrative or governmental order to do so.
8.3.3.    Third party suppliers who look after you whilst on holiday for example, ground handlers, airlines and hoteliers.

9.    HOW LONG WILL WE USE YOUR PERSONAL DATA FOR
9.1.    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2.    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9.3.    By law we have to keep basic information about our customers (including Identity Contact, Financial and Transaction Data) for ten (10) years or such number of years according the applicable laws, after they cease being customers for tax and other judicial purposes.
9.4.    Please contact us for  further details on retention periods for different aspects of your personal data.
9.5.    In some circumstances, you can ask us to delete your personal data: see Request erasure below for further information.
9.6.    In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10.    TRANSFER OF YOUR PERSONAL DATA
10.1.    When sharing your personal data within Simply Dolomiti, whether this involves transferring your data outside the countries where Simply Dolomiti operates, we ensure your personal data is protected as per the applicable law requirements.
10.2.    Whenever we transfer your personal data, we ensure a similar degree of security and protection is afforded to it. For further details, please contact us.

11.    HOW WE PROTECT YOUR PERSONAL DATA
11.1.    We maintain organisational, physical and technical security measures (i) to prevent your personal data from unauthorised access, alteration, disclosure, accidental loss, and destruction, and (ii) based on the nature of the personal data, to protect your personal data from the harm that may result in unauthorised access, alteration, disclosure, destruction of the data and its accidental loss.
11.2.    In particular, our preventive and protective measures include (i) the pseudonymisation and encryption of personal data; and (ii) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services through our disaster recovery management procedure.
11.3.    We limit access to your personal data to those employees, agents, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
11.4.    We maintain procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

IMPORTANT:
You should understand that the open nature of the internet is such that information and personal data flows over networks connecting you to our systems without security measures and may be accessed and used by people other than those for whom the data are intended.

12.    WHAT RIGHTS DO YOU HAVE IN RESPECT OF THE PROCESSING OF YOUR PERSONAL DATA
12.1.    You have the right to, in the circumstances and under the conditions, and subject to the exceptions, set out in applicable laws:
12.1.1.    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
12.1.2.     Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
12.1.3.    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
12.1.4.    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
12.1.5.    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
12.1.6.    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
12.2.    Right to lodge a complaint If you have any complaints regarding this privacy policy or the way that we use your personal information, you may also contact the UK Information Commissioner at telephone number 0303 123 1113 or https://ico.org.uk/.

12.3.    IMPORTANT:
•    If you wish to exercise any of the rights set out above or need any clarification thereon, please contact us.
•    We would appreciate the chance to deal with your concerns before you approach the DPC, ICO or CNIL, so please contact us in the first instance.
•    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12.4.    Pursuant to the GDPR, and if you are an EU Citizen, you have the right of portability that is the right to receive your personal data, which you have previously provided in a 'commonly use and machine readable format' and have the right to transmit that data to another controller, for so long as such rights do not violate any third party fundamental rights and freedom, and subject to such other exceptions set forth under the GDPR.