PRIVACY POLICY

(pursuant to Article 13 of EU Regulation 2016/679 – GDPR)

1. Data Controller

The Data Controller is:

Luxury House S.r.l.
Via Villalba 2, 95024 Acireale (CT) – Italy
Email: info@crossingcondotti.com
Tel: +39 06 69920633

2. Types of Data Processed

a) Data provided by the user

• First and last name
• Email address
• Phone number
• Booking-related data
• Billing and tax information

b) Booking data

Online bookings are managed through the platform provided by Zucchetti Hospitality S.r.l. (Vertical Booking), which processes data as a Data Processor pursuant to Article 28 GDPR.

c) Browsing data

During navigation, the following data may be collected automatically:

• IP address
• Date and time of access
• Browser and device type
• Pages visited

d) Data collected via Google Analytics

The website uses Google Analytics, a service provided by Google LLC and/or Google Ireland Limited, to collect anonymous statistical data on website usage (subject to user consent).

3. Purpose and Legal Basis of Processing

Personal data are processed for the following purposes:

a) Booking and stay management

Legal basis: performance of a contract (Art. 6(1)(b) GDPR).

b) Compliance with legal obligations

Including tax, accounting obligations and communication of guest data to Public Security Authorities (Alloggiati Web). Legal basis: legal obligation (Art. 6(1)(c) GDPR).

c) Responding to information requests

Legal basis: pre-contractual measures (Art. 6(1)(b) GDPR).

d) Website statistical analysis

Carried out through Google Analytics. Legal basis: user consent (Art. 6(1)(a) GDPR).

e) Website security and abuse prevention

Legal basis: legitimate interest of the Data Controller (Art. 6(1)(f) GDPR).

4. Methods of Processing

Data processing is carried out using electronic and IT tools, adopting appropriate security measures to ensure confidentiality, integrity, and availability of data, and, where necessary, through paper documents (e.g. booking records, receipts, courtesy invoices).

5. Data Recipients

Data may be disclosed to:

• Authorized personnel of the Data Controller
• Zucchetti Hospitality S.r.l. (Vertical Booking), as external Data Processor
• Altura Labs S.r.l., as hosting service provider
• Google LLC and/or Google Ireland Limited, for statistical analysis services
• Public authorities, where required by law

6. Credit Card Payments

Credit card data are collected through the platform provided by Zucchetti Hospitality S.r.l., acting as Data Processor pursuant to Article 28 GDPR.

Such data are made available to the Data Controller for booking management, including verification, pre-authorization, and possible charges, based on the performance of a contract (Art. 6(1)(b) GDPR).

Processing is carried out in compliance with applicable security standards and the protection systems adopted by the service provider.

7. Data Transfers Outside the EU

The use of Google Analytics may involve the transfer of data to non-EU countries. Such transfers are carried out in accordance with the safeguards provided for in Articles 44 et seq. of the GDPR.

8. Data Retention Period

• Booking and tax data: up to 10 years (legal obligation)
• Statistical data: up to 24 months
• Contact request data: up to 6–12 months

9. Links to Social Networks

The website may contain links to the Instagram profile “crossing_collection” on Instagram. Any interaction with this platform is governed by the privacy policies of the social network.

10. Data Subject Rights

Pursuant to Articles 15–22 of the GDPR, users may:

• Access their personal data
• Request rectification or erasure
• Restrict or object to processing
• Request data portability
• Withdraw consent at any time
• Lodge a complaint with the Garante per la Protezione dei Dati Personali

Requests can be sent to: info@crossingcondotti.com

11. Nature of Data Provision

Providing data for booking purposes is necessary for the conclusion of the contract. Providing data for statistical purposes is optional and subject to user consent.

COOKIE POLICY

(pursuant to EU Regulation 2016/679 and the Italian Data Protection Authority Guidelines)

12. Types of Cookies Used

The website www.crossingcondotti.com uses the following categories of cookies:

a) Technical cookies (necessary)

These are essential for the proper functioning of the website and booking system. They do not require user consent.

b) Analytical/performance cookies

The website uses Google Analytics, provided by Google LLC and/or Google Ireland Limited, to collect aggregated statistical information on website usage.

These cookies are activated only with the user's prior consent through the cookie banner. Users can accept or reject cookies via the initial banner and modify their preferences at any time. The IP address is anonymized where technically configured. No profiling or marketing cookies are used.

13. Legal Basis

• Technical cookies → legitimate interest of the Data Controller
• Analytical/performance cookies → prior user consent

14. Cookie Duration

Cookies may be:

• Session cookies (deleted when the browser is closed)
• Persistent cookies (stored until their expiration)

Data collected through analytical cookies are retained for a maximum period of 13 months.