Privacy Policy

This privacy statement (“Statement”) applies to all of the hotel brands owned or licensed by IPA srl – Immobiliare Positano Amalfi srl and its affiliates (collectively, the “IPA Group”) and it is provided pursuant to Legislative Decree no. 196/2003.

The data controller is IPA srl – Immobiliare Positano Amalfi srl, with registered office in Positano (SA), via Arienzo 30.

We have prepared this Statement to inform you of the privacy principles that govern our use of information we obtain from our customers, including information we obtain through our websites, including villatreville.it, villatreville.com and other websites owned or controlled by the IPA Group (collectively, the “Websites”). As used in this Statement, the term “Authorized Licensees” means certain companies that have entered into a license or similar agreement with a IPA Group company to sell products and services under a IPA brand.

Our Websites are available to visitors located throughout the world, and operated for different purposes. For instance, some may be specific to a hotel brand or property, and others may enable you to shop for travel-related products. Our Websites are generally operated from Italy in accordance with laws of Italy and visitors to our Websites should be aware that the laws of Italy may differ from those of your country of residence. Where we operate country-specific Websites, those Websites are operated in accordance with the laws of that specific country.

This Statement was updated on May 13, 2015, to describe how the privacy statement applies to all of the information we obtain from you and to update the privacy statement with respect to IPA’s Authorized Licensees, franchisees and certain other commercial partners set out below.

THE TYPES OF PERSONAL INFORMATION WE MAY COLLECT INCLUDE:

The types of personal information that we may collect include:
• Your name, gender, home and work contact details, business title, date and place of birth, nationality, passport and visa information;
• Guest stay information, including the hotels where you have stayed, date of arrival and departure, goods and services purchased, special requests made, observations about your service preferences (including room, holiday preferences, amenities requested, facilities or any other services used);
• Telephone numbers dialed, faxes sent/received or receipt of telephone messages when connected to the telephone services we may provide guests during their stay;
• Your credit card details, online user accounts details, profile or password details and any frequent flyer or travel partner program affiliation;
• Any information necessary to fulfill special requests (e.g. preferences that require specific accommodations, purchase of goods and services);
• Information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers;
• Information collected through the use of closed circuit television systems, card key and other security systems;
• Contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents or meeting and event planners).
• Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents or similar providers). For example, if we know your name and postal address, we may request your email address from your travel agent.

We may collect this information through a variety of ways, including from you directly, from our Authorized Licensees, from third parties with whom we do business (e.g., such as travel agents, airlines, event planners or similar providers).

Occasionally, you may be requested to provide personal information about others to us (for example, individuals for whom you are making a reservation). In such cases, we rely on you to obtain such other persons' consent for disclosing their information to us which we will use in accordance with the terms of this Statement.

You may always choose what personal information (if any) you wish to provide to us. If you choose not to provide certain details, however, some of your transactions with us may be impacted.

HOW WE USE PERSONAL INFORMATION

We may use personal information in a variety of ways, including through personal contact, via our Websites, through emails and correspondence, and through third parties, such as travel agents and other business partners. We use personal information for the purposes we have disclosed to you, or as permitted by law. In general, we use personal information in order to:
• Provide the services your request, such as to facilitate reservations, send a confirmation, send you a pre-arrival message and provide other information about the area and the hotel;
• Provide you with information about meeting, event or celebration planning and access to specific account information for administrative purposes;
• Send you periodic customer satisfaction, market research or quality assurance surveys;
• Service your account and services preferences;
• Send you offers and promotions from IPA and its Affiliates and Authorized Licensees concerning any IPA branded offers and promotions which we believe will be of interest to you including;
o those related to the IPA vacation club;
o Promotions and news such as your account information, exclusive offers, hotel openings;
o IPA loyalty programs and worldwide promotions;
o Hotel specials such as personalized destinations deals and packages, last minute rates;
o Partner offers such as financial products, car hire, club memberships, among others.;
• Ship products, information or provide services to our customers, including sending you goods or products ordered from any of the Shop IPA Websites;
• Understand your and other customers’ needs;
• Learn about our markets and improve our products and services;
• Comply with regulatory and legal obligations;
• Assist with the planning of meetings and events;
• Protect our rights and properties
Disclosure of Personal Information
We may disclose personal information in the following ways:
• Reservations
o The personal information you provide to us for making a reservation is made available to the applicable personnel for the purpose of meeting your reservation request.
o After your stay we retain your personal information including details of your stay, room/accommodation type and amenities used.

• Travel Related Services
o To provide you with a single source for purchasing packages that include other travel-related services such as airline tickets or rental cars, including those offered by Authorized Licensees, we have entered into agreements with select reputable third-party companies that sell IPA branded products which require them to secure your personal information and to use it only to execute the transactions you request or to market IPA branded vacation products.

Any personal information you provide to these third parties will be controlled by each of them and is subject to their respective privacy statements and practices.

THIRD PARTY SERVICE PROVIDERS/PROCESSORS

IPA uses the services of third party processors, such as market researchers, fulfillment houses, email service providers and mail houses that process mail and communications for the IPA Group, and including in some cases, for Authorized Licensees. These parties are contractually prohibited from using personal information for any purpose other than for the purpose IPA specifies.

We may disclose your personal information in relation to the reorganization, sale or disposal of all or a part of our business or assets, joint ventures and related business transactions, including in relation to audit or reporting and other regulatory requirements. Any successor or assign may use your personal information for the same reasons as set out in this Statement.
IPA will disclose personal information without your permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to IPA guests, visitors, associates, or property (including our Websites), or to others.

COOKIES AND IP ADDRESSES

This website does not use profiling cookies.
It may use technical cookies that, as permitted by the Italian Data Protection Authority, are used exclusively for the carrying out the transmission of a communication on an electronic communications network, or that are strictly necessary to provide the service. They are not used for any further purposes and are usually installed directly by the data controller or the website manager.

Technical cookies, as defined by the Italian Data Protection Authority, may include browsing or session cookies, which allow users to navigate and use a website (e.g. to purchase items online or authenticate themselves to access certain sections); analytics cookies, which can be equated to technical cookies insofar as they are used directly by the website manager to collect aggregate information on the number of visitors and the pattern of visits to the website; functional cookies, which allow users to navigate as a function of certain pre-determined criteria such as language or products to be purchased so as to improve the quality of service.

If you would like to know more about cookies, the following website provide useful information:
www.allaboutcookies.org

REQUEST FOR ACCESS TO PERSONAL INFORMATION / QUESTIONS OR COMPLAINTS

Data subjects are entitled at any time to obtain confirmation of the existence of personal data concerning them and be informed of their contents and origin, verify their accuracy, or else request that such data be supplemented, updated or rectified pursuant to Section 7 of Legislative Decree no. 196/2003.

The above Section also provides for the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data.

If after reviewing this Statement, you have any questions or privacy concerns please or would like to submit a request, send an email to the IPA Information Protection & Privacy department at privacy@villatreville.it or send a letter to:
IPA srl- Immobiliare Positano Amalfi
Via Arienzo 30- Positano (SA)
Attn: Privacy Dept.

You may also use the above email or postal addresses to request access to personal information held about you. Such requests will be processed in line with local laws, and there may be circumstances where we are unable to provide access where it is legally permissible to do so, including where the information contains legal privilege, is a security risk or would compromise others’ privacy or where it is commercially proprietary. You may also ask us to update information we hold about you where you believe it is incomplete, inaccurate or out of date.