Privacy Policy
Introduction
This privacy policy describes how Hub Ospitalità Digitale collects, uses, and protects the personal data you provide when using our online platform and services related to distribution channel integration, revenue management, booking engines, central reservation systems, OTA connectivity, pricing automation, and reservation synchronization.
Data Controller
The data controller responsible for your personal data is Hub Ospitalità Digitale, located at 345 Via Tiburtina, Piano 3, Rome, Lazio, 00159, Italy.
Data We Collect
We may collect various types of information, including:
Identity and Contact Data: Information you provide when you interact with our service, such as your name, company name, job title, physical address, and other contact details.
Service Data: Information related to your use of our services, including account details, configuration settings, usage patterns, transaction data, and information necessary for integrating with third-party platforms.
Technical Data: Information automatically collected when you access our online platform, including internet protocol (IP) addresses, 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 site.
Usage Data: Information about how you use our site and services, including the pages you visit, the features you use, and the time spent on our site.
Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
How We Collect Your Data
We collect data through various methods:
Direct Interactions: You provide data when you register for an account, use our services, fill out forms, communicate with us, or provide feedback.
Automated Technologies: As you interact with our site, we may automatically collect Technical and Usage Data using cookies, server logs, and similar technologies.
Third Parties: We may receive personal data about you from third parties, such as integration partners or service providers, necessary for providing our services.
Purpose of Processing
We process your data for the following purposes:
To provide and maintain our services.
To manage your account and provide customer support.
To process transactions and service requests.
To improve and optimize our online platform and services.
To understand how you use our services and develop new features.
To communicate with you about updates, services, and offers, where permitted by law or with your consent.
To ensure the security and integrity of our site and services.
To comply with legal obligations and enforce our terms and policies.
Legal Basis for Processing (GDPR)
We process your personal data based on the following legal grounds:
Performance of a Contract: Where processing 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 (e.g., providing our services).
Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided your fundamental rights do not override these interests (e.g., improving our services, preventing fraud, direct marketing where permitted).
Legal Obligation: Where processing is necessary for compliance with a legal obligation we are subject to.
Consent: Where you have given consent for specific processing activities (e.g., certain marketing communications, placement of non-essential cookies). You have the right to withdraw consent at any time.
Data Security
We have implemented appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorized way. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Data Sharing and Disclosure
We may share your personal data with:
Service Providers: Third-party vendors and service providers who perform services on our behalf (e.g., hosting, analytics, customer support). These providers are contractually bound to protect your data and use it only for the purposes for which we disclose it to them.
Integration Partners: Third parties with whom you authorize us to integrate our services (e.g., OTAs, property management systems) as necessary to provide the requested functionality.
Legal Requirements: If required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
Business Transfers: In connection with or during negotiation of any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
We ensure that any third parties we share data with provide adequate protection for your data.
International Data Transfers
Your data may be transferred to, and stored at, destinations outside of the European Economic Area (EEA). Where we transfer your data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: transferring data to countries that have been deemed to provide an adequate level of protection by the European Commission, using specific contracts approved by the European Commission which give personal data the same protection it has in Europe, or transferring data to US based providers under the Privacy Shield (though this mechanism is subject to change and alternatives like Standard Contractual Clauses are now primary).
Your Data Protection Rights
Under GDPR and other relevant laws, you have rights regarding your personal data. These rights include:
The right to access: You have the right to request copies of your personal data.
The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
The right to erasure: You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right to withdraw consent: Where our processing is based on your consent, you have the right to withdraw that consent at any time.
The right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state where you reside, work, or where the alleged infringement occurred.
To exercise any of these rights, please contact us in writing at the physical address provided below. We may ask you to verify your identity before responding to such requests.
Cookies
Our site uses cookies and similar tracking technologies to collect information about your browsing behaviour. For detailed information on how we use cookies, the types of cookies we use, and how you can manage your cookie preferences, please refer to our separate Cookie Policy, which is available on our online platform.
Children's Privacy
Our service is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will take steps to delete such information.
Changes to This Privacy Policy
We may update this privacy policy from time to time. We will notify you of any changes by posting the new policy on this page. We encourage you to review this policy periodically for any changes.
Contact Us
If you have any questions about this privacy policy or our data practices, please contact us by writing to:
Hub Ospitalità Digitale
345 Via Tiburtina, Piano 3
Rome, Lazio, 00159
Italy