LAST UPDATED: May 2018
Passione Panino is committed to protecting your privacy and wants you to be familiar with how we collect, use, and disclose Personal Information (as defined below).
PERSONAL INFORMATION WE COLLECT
BLU Srl may collect "Personal Information" from you, meaning information that identifies you as an individual or from which you may be identified. For example, we may collect:
- contact information, such as your name, mailing address, e-mail address, and telephone number;
- credit card number or other payment account number, billing address, and other payment and billing information (“Payment Information”);
- records and copies of your correspondence if you contact us;
- information necessary to fulfil special requests (e.g., health conditions that require specific accommodation);
- guest stay information, including the hotels where you have stayed, date of arrival and departure, and goods and services purchased;
- information collected through the use of closed circuit television systems, card key and other security systems; and
- in limited cases, information relating to the credit of customers.
We may collect Personal Information from a variety of sources including:
- through the Site;
- through reservation and call centers;
- through social media and brand channels (e.g. Facebook, Twitter);
We may also combine Personal Information we collect with publicly available Personal Information and Personal Information we receive from others or cross-reference with others. The collection and use of Personal Information, whether separately or combined, is done in accordance with and for the purposes described in this Policy
If you voluntarily share "Sensitive Information" (e.g., Personal Information related to your health) with us, that information will only be used as necessary to fulfill special requests (e.g. health conditions that require specific accommodations). For example, if you voluntarily convey a health-related need to us, we may store and use that information in order to provide a room with appropriate amenities. We do not collect or store Sensitive Information unless it is voluntarily provided by you. By providing such Sensitive Information, you expressly consent to our collection, processing and storage of that information in accordance with the terms of this Policy.
HOW WE USE THE PERSONAL INFORMATION WE COLLECT
Passione Panino collects Personal Information about guests, visitors to the Site, and others, so that we can provide an experience that is responsive to the needs of such individuals. BLU srl may collect, use, and disclose Personal Information for one or more of the following purposes:
- Fulfillment of Reservation or Information Requests. To fulfill your requests such as completing a credit card transaction or booking a reservation at any Licensed Hotel worldwide through our central reservation system, or responding to your requests that we send marketing, informational or other newsletters to you (and to personalize such newsletters and the Site to your preferences). For example, when you make a reservation through Passione Panino web site, we may collect Payment Information from you, and may use and disclose such Payment Information to fulfill your reservation. Administrative and Other Communications. To send you important information regarding the Site, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your travel reservations, such as reservation confirmations and pre-arrival communications). We may also use your Personal Information to determine whether you are eligible for and/or inform you, if you have provided your consent, to send marketing communications or tell you about products, programs, enhancements, events, special offers, and services of Passione Panino . For more information, see the “Your Choices” section of this Policy below
- Customer Care. To track, process, and respond to customer care inquiries and to enhance and improve the customer’s experience. We may also transmit your Personal Information to third party service providers, to allow those third parties to track, process, and respond to customer care inquiries.
- Internal Business Purposes. For our internal business purposes, such as data analysis, audits, developing new products, enhancing the Site, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our Promotions, and meeting contractual obligations.
- Our Legal Duties. To comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process.
- E-mails to Friends. To permit you to forward information about our products, services, to another individual, such as a friend or co-worker. If you wish to use this feature, you may be required to provide to us, and we may use, the applicable individual's name and e-mail address to facilitate your sending of such messages to such individual (and any Personal Information ‒ such as your name and your email address ‒ provided in connection with sending such information, will be disclosed to such individual). By using this functionality, you affirm that you are entitled to use and to provide to us the recipient's name and e-mail address for this purpose. We will not seek to use the recipient’s Personal Information for any purpose other than to allow the e-mail to be sent, unless we disclose such other purpose to you at the time that you provide such Personal Information to us or unless we have separately collected such Personal Information through other means.
- Additional Uses. We may also use your Personal Information in other ways as described when you provide such information to us or for other purposes with your consent.
HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION - Third-Party Service Providers. BLU Srl relies on third-party service providers to provide certain products and services on our behalf, including reservation services, credit card/payment processing and billing, IT services, customer care, e-mail delivery services, text messaging services, communication and delivery of promotional and marketing materials via e-mail, direct mail, and text message, administering guest surveys and Promotions, administration, data analysis, and other similar services. When we do outsource the processing of your Personal Information to third parties or provide your Personal Information to third party service providers, we require those third parties to protect your Personal Information with reasonable security measures and to limit their use only to the purposes for which we have disclosed it to them.
- Social Networking Forums. Passione Panino may make available interactive services (e.g., message boards, forums, and blogs) through which you may post information and materials on the Site. Please note that any information you disclose through such services becomes public information and may be available to visitors to the Site and to the general public. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, through these services. If you choose to voluntarily disclose your personal Information through such a forum it may be available to the public and might be used by others for any purpose.
- Credit Authorization. When you apply for a credit card, your Personal Information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether you are eligible for the credit card and whether the card issuer will grant and/or maintain a line of credit to you.
- Responsibility When Information Is Transferred. If a service provider that receives Personal Information from us about an EU data subject or Swiss data subject takes an action that is contrary to the principles of the EU-US Privacy Shield or Swiss-US Privacy Shield, we shall be liable for those actions unless we prove that we are not responsible for causing them.
BLU Srl may also collect “Non-Personal Information,” meaning aggregated and/or anonymized information, demographic information, and any other information that does not reveal your specific identity. Because Non- Personal Information does not personally identify you, we may use and share such information with other third parties for any purpose, including without limitation to facilitate and improve your ongoing access to and use of our Site, to best tailor our services to suit personal interests, to analyze visiting patterns, enhance and improve customer service, and for our other business purposes. As you navigate the Site, we may collect certain Non-Personal Information such as your computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version using automatic data collection technologies.
DO NOT TRACK
Your web browser may let you choose your preference as to whether you want to allow websites to collect information over time about your online activities across different websites or online services. At this time, the Site does not respond to such “Do Not Track” or similar preferences you may have configured in your web browser, and the Site may continue to collect information in the manner described in this Policy. However, as stated in the “Non- Personal Information” section above, we do allow you to exercise some choice in the information collected by adjusting your browser’s cookie settings.
SECURITY & INTEGRITY
Because the security of your Personal Information is important to us, we have implemented security measures that provide reasonable precautions against the unauthorized access, disclosure, alteration, or destruction of Personal Information. The Personal Information we collect from you online is stored by us and/or our service providers and protected through a combination of physical and electronic access controls, firewall technology, and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, access, misuse, or alteration of Personal Information. Where required by law, we will notify you of any such loss, access, misuse, or alteration of Personal Information that may affect you, so that you can take the appropriate actions to protect your rights. We may decide to notify you by mail, email, or telephone where permitted by law.
Please do not send us your Payment Information or Sensitive Information through e-mail or any undesignated area (e.g., submission of your credit card number in a "comment" field). If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the alleged problem by contacting us..
You may always choose what Personal Information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected. For example, we cannot take a reservation without a name, and if we cannot disclose your Personal Information to our partners, we may be unable to provide you with all or certain reservation services, other services.
If you do not wish for us to use your contact information to promote our own or third parties' products or services, you can opt-out of any or all such promotional communications or withdraw your previous consent by contacting us to firstname.lastname@example.org . If you have received a promotional e-mail from us and no longer wish to receive such e-mails going forward, you may opt-out by using the unsubscribe function in the e-mail you have received from us. Please note that when you unsubscribe from receiving promotional e-mails from us, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the accounting programs database according to the Italian tax law.
ACCESS, DELETION, & MODIFICATION
BLU Srl may allow you to review certain Personal Information through the Site or through other online means. Information about the availability of online means for reviewing your Personal Information is generally available at the Site or on the printed materials where such type of Personal Information was first submitted.
Pursuant to applicable law, you may have the right to request access, deletion or changes to the Personal Information we maintain about you and, where appropriate, request that we update such Personal Information you believe is incomplete, inaccurate or out of date. You can also inquire whether we maintain Personal Information that relates to you. Although Passione Panino will attempt in good faith to respond to your request, we may not be able to provide, delete, or change your Personal Information in all circumstances. For example, Passione Panino may not be able to change, provide, or delete Personal Information about you if it would impose an undue burden or expense, or require Passione Panino to also change information relating to another person. In addition, in some circumstances pursuant to applicable law, you may have the right to request that we cease using Personal Information about you on the grounds that such Personal Information was acquired by unjust means or used in violation of law. Passione Panino will honor such requests as required and within the time specified by applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to your request.
To make one of the requests listed above, please write to email@example.com
DATA RETENTION & MINIMIZATION
Passione Panino only collects Personal Information that it believes is necessary to perform the services that you seek from Passione Panino and to exercise its rights and comply with its obligations as otherwise outlined in this Policy. We will keep your Personal Information only as long as we need it for the purposes for which we collect it or as otherwise permitted by law.
If you have any questions regarding this Policy, or would like to update your information or modify your communication preferences, please contact us by e-mail at firstname.lastname@example.org by phone at 0039 011 4018700 or write to us at the following address:
Via Torino 154
10093 Collegno – To - Italy
Please note that e-mail communications will not necessarily be secure; accordingly, you should not include Payment Information or Sensitive Information in your e-mail correspondence to us.
CHANGES TO THE POLICY
Passione Panino reserves the right to change, modify, or amend this Policy at any time. The date this Policy was last revised is at the top of this page. If we make a material change to this Policy, we will indicate on the Site that our privacy practices have changed and will provide a link to the new policy. If we make material changes to how we use your Personal Information, we will notify you by e-mail to the e-mail address specified in your account (if applicable) and/or through a notice on the Site’s home page, and we will provide you with an opportunity to opt-out of such new or different use. Any changes to the Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect.