CARDO ROMA and affiliates and providers:
In order to provide multiple access points to the services and products we offer, CARDO ROMA operates directly, or through its affiliates or service providers, many web sites, including without limitation www.cardohotels.com. Any third party, which is an affiliate or provider of CARDO ROMA, will only be allowed to collect personally identifiable information (hereinafter: “PII”) on behalf of CARDO ROMA when such is explicitly mentioned on their website. Any one of these web sites may ask for and collect in order to enhance your experience and provide you with relevant information.
TYPES OF INFORMATION WE COLLECT:
Information may be collected as part of: (i) fulfilling reservation or information requests, (ii) purchasing products, (iii) registering for program membership, (iv) submitting a job application, or (v) responding to communications from us (e.g., surveys, promotional offers, or reservation confirmations). We endeavour to collect information only with your knowledge and with your permission if necessary. The types of PII that we collect may include your name, home, work and e-mail addresses, telephone and fax numbers, credit card information, date of birth, gender, and lifestyle information such as room preferences, leisure activities, names and ages of children, and other information necessary to fulfil special requests (e.g., health conditions that require special room accommodations).
CARDO ROMA may also collect non-PII about you, such as your use of our web sites, communication preferences, travel habits, aggregated data relative to your stays, and responses to promotional offers and surveys.
PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE:
Collection & Use
CARDO ROMA is fully committed to providing you with information about the collection and use of PII furnished by, or collected from, visitors while using our web sites, products, and services. It is our practice not to ask you for information unless we need it or intend to use it. Some of the primary purposes for collecting your PII are as follows:
Providing services such as processing a transaction (e.g., making a reservation, fulfilling a request for information, or completing a product order) marketing and communications with you in relation to the products and services offered by CARDO ROMA, our strategic marketing partners, and other trusted third parties performing market research via surveys to better serve your needs, improve the effectiveness of our web sites, your hotel experience, our various types of communications, advertising campaigns, and/or promotional activities;
You will always be offered the choice not to submit your PII or to decide what communications you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing a name will prevent the processing of reservations.
Processing and Disclosure
In most cases, the information you provide is added to a local or global database. In the course of processing your information, it may be necessary to transfer your PII to CARDO ROMA affiliates, properties within the CARDO ROMA system and/or third party service providers located in the country where the system is located and throughout the world for the purposes outlined within this Privacy Statement. As a general practice, CARDO ROMA does not sell, rent, or give physical possession of your PII to unaffiliated third parties outside the CARDO ROMA system. Situations in which CARDO ROMA may disclose your information to others include:
when we have received your consent to do so in situations where sharing or disclosing your information is required in order to offer you products or services you desire (e.g., a vacation package)
when companies or services providers that perform business activities on behalf of CARDO ROMA require such information (e.g., credit card processing, customer support services, market research administration or database management services) when a hotel or other property leaves the CARDO ROMA system and access to your PII is necessary to facilitate business operations or meet contractual obligations in the event CARDO ROMA is merged or acquired by another company to comply with legal or regulatory requirements or obligations in accordance with applicable law or court order in case of emergency such as to safeguard the life, health, or property of an individual;
If information is shared as mentioned above, we seek to limit the scope of information that is furnished to the amount necessary for the performance of the specific function. Unless otherwise precluded by legal process, we require third parties to protect your PII and abide by applicable privacy laws and regulations.
CONSENT:
As part of our commitment to keep you informed, we may mail, e-mail, telephone, or contact you by other means to notify you of new CARDO ROMA products and services, or upcoming CARDO ROMA special offers, events, enhancements, or other relevant information that may be of interest to you. You may also receive mailings or other communications from carefully selected third parties. We always offer you the option to decline any or all of these communications by following the directions included in our e-mails or other communications, or by contacting CARDO ROMA directly.
If you are member of a CARDO ROMA loyalty program, you may also change your communication choices by updating your e-mail preferences in your individual membership profile.
We would like to keep all of our guests and visitors informed and equally able to take advantage of the benefits offered by CARDO ROMA and its strategic marketing partners. However, depending on the country where you live, certain data privacy regulations may require us to obtain your permission before we send you information that you have not requested from us.
GOOGLE ANALYTICS ADVERTISING AND REMARKETING FEATURES
If you’ve enabled any Google Analytics Advertising features, you are required to notify your visitors by disclosing the following information in your privacy policy:
THE GOOGLE ANALYTICS ADVERTISING FEATURES YOU’VE IMPLEMENTED
How you and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
How visitors can opt-out of the Google Analytics Advertising Features you use, including through Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI’s consumer opt-out).
We also encourage you to point users to Google Analytics’ currently available opt-outs for the web.
EUROPEAN UNION USER CONSENT POLICY
When using Google Analytics Advertising Features, you must also comply with the European Union User Consent Policy.
INTEREST-BASED ADVERTISING
If you’ve enabled interest-based advertising, including Remarketing, with Google Analytics in connection with other Google services, you must follow the policies applicable to those Google services (like the Google Ads Policy for Personalized advertising and its sensitive category restrictions, and the Platform Program Policies).
If you use Google Analytics to collect sensitive information about your visitors, as described in the Google Ads sensitive category restrictions, you may not use Google Analytics to collect data for the purpose of interest based advertising.
DATA TRANSFERS ACROSS INTERNATIONAL BORDERS:
We endeavour to provide you with the same outstanding service in all locations. To achieve this goal, we have established or endeavouring to establish a global network comprised of properties, offices, data centres, trusted marketing partners, service providers, customer contact centres, and trained associates around the globe. The nature of our business and our operations require us to transfer your information, including PII, to other group companies, properties, centres of operations, data centres, or service providers that may be located in countries outside of your own. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, CARDO ROMA will take appropriate steps to ensure that your PII is protected and handled as described in this Privacy Statement.
ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION:
To ensure that your PII is accurate and up to date, we encourage you to regularly review and update your information as appropriate (e.g., in the event your home or e-mail address changes, or you wish to add an additional method for us to communicate with you). If you are member of a CARDO ROMA loyalty program, you can review and update your individual membership profile on-line or with the assistance of a CARDO ROMA customer service representative. Please note that in an effort to prevent the unauthorized disclosure of your PII, you may be asked to provide proof of identity (or other authentication materials) together with the completed access request form.
If, upon review, you wish to deactivate your CARDO ROMA loyalty program member profile, or update your PII, we will endeavour to do so in a timely manner. Occasionally, information that you request to be removed will be retained in certain files for a period of time in order to properly resolve disputes or to troubleshoot problems. In addition, some types of information may be stored indefinitely on “back up” systems or within log files due to technical constraints, or financial or legal requirements. Therefore, you should not always expect that all of your PII will be completely removed from our databases in response to your request.
SECURITY SAFEGUARDS:
CARDO ROMA recognizes the importance of information security, and is constantly reviewing and enhancing our technical, physical, and logical security rules and procedures. All CARDO ROMA owned web sites and servers have security measures in place to help protect your PII against loss, misuse, and alteration while under our control. Although “guaranteed security” does not exist either on or off the Internet, we safeguard your information using both procedural and technical safeguards, including password controls, “firewalls” and the use of up to 128-bit encryption based on a Class 3 Digital Certificate issued by VeriSign, Inc. This allows for the use of Secure Sockets Layer (SSL), an encryption method used to help protect your data from interception and hacking while in transit.
In some cases your permission will be implied from the nature of the service requested or transaction undertaken. For example, CARDO ROMA may collect and use PII that you volunteer, or behavioural data or information collected in the aggregate. In addition, your permission will be deemed given for communications from us that are necessary to fulfil transactions and services that you request.
In certain circumstances, we will seek your express permission when we collect information that is regarded under certain data privacy regulations to be sensitive in nature (e.g., information revealing racial or ethnic origin, political opinions, or health conditions).
ON-LINE TECHNOLOGIES:
CARDO ROMA may use cookies, invisible pixels, and web beacons to obtain information about you while visiting our web sites. A cookie is a very small text file that is sent to your browser from a web server and stored on your computer’s hard drive. It assigns the computer with a unique identifier, which in turn, becomes your identification card whenever you return to a CARDO ROMA web site.
Cookies are designed to save you time because they help us to provide you with a customized experience without you having to remind us of your preferences each time you return to our web pages. CARDO ROMA cookies are not designed to damage your files, nor can they read information from other files on your computer hard drive.
Cookies can also help us provide you with a personalized on-line experience in the following ways:
- they remember your user name and password for future visits so log-in is easier and faster
- they ensure you are provided with the appropriate frames and content
- they ensure you obtain all requested information
- they help us deliver communications that are relevant and responsive to your interests and location
CARDO ROMA cookies are limited to our web sites only, and are not designed to follow you when traveling on the Internet after leaving CARDO ROMA owned web sites. We track the usage of our web sites in order to better meet your needs and to help make it easier for you to find information in the future. Please note that in addition to CARDO ROMA cookies, various third parties may also place cookies on your computer’s hard drive. CARDO ROMA is not responsible for the presence or absence of third party cookies, or for the technological capabilities or practices employed by third parties in connection with third party cookies.
If you would prefer not to have the benefits of cookies, your Internet browser can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our web sites and our ability to recognize your browser from one visit to the next.
CARDO ROMA also uses invisible pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain PII. CARDO ROMA may use this information to improve marketing programs and content.
LINKS TO OTHER WEB SITES:
In order to anticipate your needs, CARDO ROMA provides links to other web sites for your convenience and information. CARDO ROMA are not responsible or liable for any content presented by or contained on any independent web site, including, but not limited to, any advertising claims or marketing practices. Please note that while CARDO ROMA will protect your information on CARDO ROMA owned and operated web sites, we cannot control and will not be responsible for the privacy policies of third party web sites, including web sites owned or controlled by independent franchisees, third party owners of hotel, resort, interval ownership, or residence properties that may use the name of a CARDO ROMA brand, or web sites not controlled or authorized by CARDO ROMA. Third party web sites that are accessed through links on our web sites have separate privacy and data collection practices, and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their web sites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any PII. We recommend that you review the privacy statements and policies of linked web sites to understand how those web sites collect, use and store information.
MINORS:
CARDO ROMA does not seek to obtain nor does it wish to receive PII directly from minors; however, we cannot always determine the age of persons who access and use our web sites. If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from future CARDO ROMA marketing communications.
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Larimar Rome Hotel Operations
Vicolo San Giovanni sul Muro 9
20121 Milano, Italy
VAT: IT10171560963
Info.roma@cardohotels.com