PRIVACY POLICY pursuant to Articles 13-14 of EU Regulation 2016/679 (GDPR)
1. Data Controller The Data Controller is R.E.R.S. S.R.L., Viale Bassani 87/G, 36016 Thiene (VI), Italy – VAT 04161180247 – PEC: rers@legalmail.it. For any matter regarding data processing, you may contact the Controller at the above details.
2. Types of data processed In connection with the activity of the “Cortile D’Annunzio” accommodation, we may process:
- Identification and contact data: first and last name, email address, phone number.
- Stay-related data: check-in/check-out dates, number and composition of guests (adults/children), preferred language, any requests.
- Payment data: for online card payments, data is collected and processed directly by Stripe Payments Europe Ltd. The Controller only receives confirmation of payment and a transaction identifier; it does not process or store card numbers. For bank transfers, the data needed to reconcile the payment is processed.
- Technical browsing data: IP address (partially anonymised for consent logging), date and time of form submission.
- Proof of consent: upon form submission, the date, time and anonymised IP of acceptance are recorded for accountability purposes.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Managing the availability request, booking and stay | Performance of a contract or pre-contractual measures (Art. 6.1.b) |
| Payment management (Stripe/bank transfer) | Performance of the contract (Art. 6.1.b) |
| Responding to contact form enquiries | Legitimate interest in handling requests (Art. 6.1.f) |
| Tax, accounting and administrative obligations | Legal obligation (Art. 6.1.c) |
| Mandatory reporting to authorities (e.g. guest registration, tourist tax) | Legal obligation (Art. 6.1.c) |
4. Nature of provision Providing the data marked as mandatory in the forms is necessary to handle the request and booking: failure to provide it makes it impossible to proceed. Providing optional data (e.g. phone number) is voluntary.
5. Processing methods Data is processed using IT and electronic tools, with security measures adequate to ensure confidentiality, integrity and availability, and to prevent unauthorised access. Access to data is limited to authorised personnel.
6. Recipients Data may be disclosed to:
- Stripe Payments Europe Ltd. as the online payment service provider;
- technical service providers (hosting, website maintenance), appointed as data processors under Art. 28 GDPR;
- professionals and consultants (e.g. accountant) for legal obligations;
- public and law-enforcement authorities, where required by tourist rental regulations. Data is not disseminated and is never transferred to third parties for marketing purposes.
7. Transfers outside the EU Some providers (e.g. Stripe, Google) may process data outside the European Economic Area. In such cases, transfers comply with Articles 44 et seq. of the GDPR, based on Standard Contractual Clauses approved by the European Commission or adequacy decisions.
8. Retention period Data is kept for as long as strictly necessary for the purposes for which it is collected:
- booking and stay data: for the duration of the relationship and thereafter for the period required by tax and accounting obligations (typically 10 years);
- contact enquiries not followed by a booking: for the time needed to handle the request and a reasonable subsequent period;
- proof of consent: for the time needed to demonstrate the lawfulness of processing. Afterwards, data is deleted or anonymised.
9. Your rights As a data subject, you may exercise at any time the rights under Articles 15-22 of the GDPR: access, rectification, erasure (“right to be forgotten”), restriction, objection, and data portability. To exercise these rights, write to [controller email/PEC]. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante – www.garanteprivacy.it).
10. Changes to this policy The Controller reserves the right to amend or update this policy, including as a result of regulatory changes. The updated version will always be published on this page.
Last updated: [06/25/2026]