Last update: May 24, 2018
Corso 281 srl and its affiliated companies consider you our guests and recognize the importance of your privacy. We want to inform you about how we collect, use, and disclose your personal data.
This Privacy Policy describes the privacy practices adopted by Corso 281 srl for data collection through:
- • the website www.corso281.com, through which you can access this Privacy Policy;
- • the software applications we provide for use on PCs and mobile devices (the "Apps");
- the social media pages we control, through which you can access this Privacy Policy (collectively referred to as our "Social Pages");
- • HTML-formatted email messages that we send containing a link to this Privacy Policy and those we receive;
- • your visit to or stay at our property or other types of offline interaction.
Collectively, the website and our Social Pages are referred to as "Online Services," and "Services" if offline channels are included. By using these Services, you accept the terms and conditions set out in this Privacy Policy.
- • Collection of Personal Data
- • Methods of Collecting Personal Data
- • Collection of Other Data
- • Methods of Collecting Other Data
- • Use of Personal and Other Data
- • Disclosure of Personal and Other Data
- • Other Uses and Disclosures
- • Entities Not Affiliated with Corso 281 srl
- • Third-Party Advertising
- • Security
- • Preferences, Access, and Storage
- • How to View, Modify, or Delete Personal Data
- • Data Retention
- • Sensitive Data
- • Use of Services by Minors
- • Updates to This Privacy Policy
- • How to Contact Us
- • Additional Information
- • Privacy Preferences
COLLECTION OF PERSONAL DATA
"Personal Data" means information that personally identifies you or allows someone to identify an individual.
At every point of contact throughout your journey, we collect your Personal Data in accordance with legal provisions, such as:
- • Name
- • Gender
- • Postal address
- • Phone number
- • Email address
- • Credit/debit card number or other payment information
- • Financial information under certain circumstances
- • Language preference
- • Date and place of birth
- • Nationality, passport, visas, or other government-issued identification data
- • Important information such as birthdays, anniversaries, and special occasions
- • Employer information
- • Information regarding travel itinerary, tour group, or activities
- • Previous stays or guest interactions, goods and services purchased, special services and requests
- • Geolocation information
- • Social media account ID, profile photo, and other public or available information from your social media
In more limited circumstances, we may also collect:
- • Data about family members and partners, such as names and ages of children
- • Biometric data, such as digital images
- • Images, video, and audio through surveillance cameras located in public areas of our property, such as entrances and hallways
- • Preferences and personalized data ("Personal Preferences"), such as interests, activities, hobbies, food and beverage preferences, services and amenities you requested or that we learned about during your visit
By providing us or our service providers with Personal Data about other individuals (e.g., if you make a reservation on behalf of someone else), you represent that you are authorized to do so and permit us to use such information in accordance with this Privacy Policy.
METHODS OF COLLECTING PERSONAL DATA
We collect Personal Data in various ways.
- • Online Services We collect Personal Data when you make a reservation, purchase goods and services from our Website, send us messages, contact us, post on social media, subscribe to a newsletter, or participate in surveys, contests, or promotional offers.
- • Visits to the property and offline interactions We collect Personal Data when you visit our property or use our Concierge to book third-party services, such as restaurants, wellness centers, tours, childcare, and spas. We also collect Personal Data when you attend or we participate in promotional events hosted at our property or when you provide your Personal Data to promote an event.
- • Customer support centers We collect Personal Data when you make a phone reservation, send us an email or a fax. These communications may be recorded to ensure quality and staff training.
- • Strategic business partners We collect Personal Data from companies we work with to provide you with goods, services, and offers based on your experiences at our property or that we believe may be of interest to you ("Strategic Business Partners"). These include travel partners, car rental providers, and booking platforms. Strategic Business Partners are independent of Corso 281 srl.
- • Other sources We collect Personal Data from other sources, such as public databases, joint marketing partners, and other third parties.
- Internet-connected devices We collect Personal Data from Internet-connected devices available at our property (Manet Mobile).
- • Location-based and mobile services We collect Personal Data when you use our Manet mobile devices. For example, we may acquire the precise location of your Manet device using satellites, cell towers, Wi-Fi signals, and other technologies.
COLLECTION OF OTHER DATA
"Other Data" refers to information that does not reveal your specific identity or does not directly relate to a person. If Other Data does reveal your identity or relates to an individual, we will treat such information as Personal Data. Other Data includes:
- • browser and device data
- • data collected through cookies, pixel tags, and other technologies
- • demographic data and other data provided by you
- • aggregated data
METHODS OF COLLECTING OTHER DATA
We collect Other Data in various ways.
- • Browser or device Through your browser or automatically via your device, we collect certain information, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Online Services you use (e.g., Apps). We use this information to ensure the Online Services function properly.
- • Pixel tags and similar technologies Data is collected via pixel tags (also known as "web beacons" and "clear GIFs") used in connection with certain Online Services for various purposes, including tracking users’ actions (including email recipients), measuring the success of our marketing campaigns, and compiling usage statistics for the Online Services.
- • Analytics We collect information via Google Analytics and Adobe Analytics, which use cookies and other technologies to collect and analyze usage data from the Services. These services also collect data regarding the use of other websites, apps, and online resources. To learn more about Google's practices, visit www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout. To learn more about Adobe and how to opt out, visit http://www.adobe.com/privacy/opt-out.html.
- • Adobe Flash technology (e.g., Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies. We collect information through Flash LSOs and other technologies on certain websites for various purposes, including collecting and storing information regarding your use of the Online Services. If you do not want Flash LSOs stored on your computer, you can adjust your Flash Player settings to block Flash LSOs using the tools provided in the Website Storage Settings Panel at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also manage them via the Global Storage Settings Panel at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and follow the instructions provided (which include how to delete existing Flash LSOs, prevent their storage without your permission, and (for Flash Player 8 and later) block LSOs not being delivered by the operator of the current page). Please note that limiting Flash LSOs may affect the functionality of some Flash applications, including those used in connection with our Online Services. For more information, visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
- • IP address The IP address is a number automatically assigned to your computer by your Internet Service Provider (ISP). It is automatically identified and logged in our server log files whenever a user accesses the Online Services, along with the time of the visit and the pages visited. We use IP addresses to calculate usage levels, diagnose server issues, and manage the Online Services. We may also use your IP address to approximate your geographic location.
- • Aggregated data We may aggregate the collected data, which does not identify you or any other user.
USE OF PERSONAL DATA AND OTHER DATA
We use Personal Data and Other Data to provide you with Services, develop new offerings, and protect Corso 281 srl and our guests as outlined below. In some cases, we may ask you to provide your Personal Data and Other Data directly to us. If you do not provide the requested data or prohibit us from collecting such information, we may not be able to provide the requested Services.
We use Personal Data and Other Data for our legitimate business interests, including the following.
- • Provision of Requested Services We use Personal Data and Other Data to provide you with the requested Services, including:
- • to facilitate bookings, process payments, send administrative messages, confirmations or pre-arrival messages, assist you with meetings and events, and provide other relevant information about the location and property of your stay;
- • to complete your reservation and stay, such as processing payment, ensuring your room is available, and providing relevant assistance;
- • to support our e-receipt program. When you use an email address to make a reservation, we use that address to send you a copy of your invoice. If you make a reservation for another person using your email address, that person's invoice will also be sent to your email address. You can opt out of receiving invoices by email and request a printed copy instead by contacting the front desk. We will use Personal Data and Other Data to manage the contractual relationship established with you, as it is in our interest and/or to comply with legal obligations.
- • Personalization of Services Based on Your Preferences We use Personal Data and Other Data to personalize Services and enhance your experience, including when you contact our front desk, visit one of our properties, or use our online Services, in order to:
- • customize your experience based on your preferences;
- • offer promotions tailored to your preferences.
- • We will use Personal Data and Other Data to deliver personalized Services based on your preferences, either with your consent or because it is in our legitimate interest to do so.
- • Communication About Products and Services Based on Preferences We use Personal Data and Other Data to:
- • send you marketing communications, promotional offers, market research, and periodic customer satisfaction or quality surveys. We will use Personal Data and Other Data to communicate with you with your consent, to manage the contractual relationship, and/or because it is in our legitimate interest to do so.
- • Lotteries, Initiatives, Events, and Promotions We use Personal Data and Other Data to allow you to participate in sweepstakes, contests, and other promotions and to manage these activities. Some of these activities may have additional rules containing further information on how we use and disclose your Personal Data. We recommend reading those rules carefully. We use Personal Data and Other Data for these purposes with your consent, to manage the contractual relationship, and/or because it is in our legitimate interest to do so.
- • Business Purposes We use Personal Data and Other Data for the following activities: data analysis, auditing, security monitoring, fraud prevention (including CCTV, electronic keys, and other security systems), developing new products and services, improving or modifying our services, identifying usage trends, measuring the effectiveness of our promotional campaigns, and managing and expanding our business activities. We use Personal Data and Other Data for these purposes with your consent, to manage the contractual relationship, to comply with legal obligations, and/or because it is in our legitimate interest to do so.
DISCLOSURE OF PERSONAL DATA AND OTHER DATA
Our goal is to offer you hospitality and services of the highest quality, and in doing so, we share Personal Data and Other Data with the parties listed below.
- • Corso 281 srl We disclose Personal Data and Other Data to other companies for the purposes described in this Privacy Notice, including providing and customizing services, communicating with you, promoting our services, and achieving our business objectives. Corso 281 srl is responsible for the joint use of Personal Data. We share your Personal Data and Other Data used to make a reservation with the relevant property to complete the reservation.
- • Strategic Business Partners We disclose Personal Data and Other Data to selected Strategic Business Partners who provide goods, services, and offers that enhance your experience at our properties or that we believe may be of interest to you. Sharing data with these partners allows us to deliver personalized services and unique travel experiences. For example, sharing data enables third-party spas, restaurants, wellness centers, and concierges to provide services to you. Sharing also allows us to offer bundled packages including travel services such as flights, car rentals, or vacation packages.
- • Service Providers We disclose Personal Data and Other Data to third-party service providers for the purposes described in this Privacy Notice. These providers include companies offering web hosting, data analysis, payment processing, order fulfillment, IT and infrastructure services, customer service, email delivery, marketing, auditing, and other services.
- • Linked Accounts and Promotional Activities We work with selected third parties that allow you to sign up for their services or participate in their promotions. These include airlines and car rental providers. We will only disclose your Personal Data and Other Data to third parties after you have enrolled in their services.
- • Business Reorganization We may disclose or transfer your Personal Data to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of Corso 281 srl’s business, assets, or stock (including in the event of bankruptcy or similar proceedings).
OTHER USES AND DISCLOSURES
We will use and disclose Personal Data when we deem it necessary or appropriate:
- • to comply with applicable laws, including laws outside your country of residence;
- • to comply with legal processes;
- • to respond to requests from public and government authorities, including authorities outside your country of residence, and to meet national security or law enforcement requirements;
- • to enforce our Terms and Conditions;
- • to protect our operations;
- • to protect the rights, privacy, and safety;
- • to allow us to pursue available remedies or limit damages we may sustain.
We may use and disclose Other Data for any purpose, except where not permitted under applicable law. In some cases, we may combine Other Data with Personal Data (e.g., your name with your location). When we do so, we treat the combined data as Personal Data as long as it remains combined.
ENTITIES NOT AFFILIATED WITH CORSO 281 SRL
This Privacy Policy is not intended for, and we are not responsible for, the privacy, data, or other practices of entities not affiliated with Corso 281 srl, including strategic business partners or third parties that operate websites or services linked to our Services, payment services, or websites that redirect to landing pages of high-speed internet service providers in our facility. The inclusion of a link on our online Services does not imply our endorsement of the linked site or service. We have no control over and are not responsible for the collection, use, and disclosure of your Personal Data by any third party.
We are also not responsible for the collection, use, disclosure, or data security policies and practices of other companies such as Facebook, Apple, Google, Microsoft, RIM, or any other app developers, app providers, social media platform providers, operating system providers, wireless service providers, or device manufacturers, including with respect to Personal Data you disclose to such other organizations through or in connection with our Social Media Pages.
THIRD-PARTY ADVERTISING
We may use third-party advertising companies to serve advertisements about goods and services that may be of interest to you when you access and use our online Services and other websites or online services. These companies may place or recognize a unique cookie on your browser (including through the use of pixel tags) to do this. To learn more about this practice and your choices, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/. You can opt out by downloading the AppChoices app from www.aboutads.info/appchoices.
SECURITY
We are committed to taking all appropriate organizational, technical, and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you believe that your interaction with us is no longer secure (for example, if you feel your account has been compromised), please notify us immediately using the contact methods below under “Contact Us.”
PREFERENCES, ACCESS AND STORAGE
You can express your preferences on how we manage your data, and we want to provide you with all the information necessary to make the best choice for you.
If you no longer wish to receive marketing emails, you may unsubscribe by
sending an email to suites@corso281.com
We will try to comply with your request as soon as possible. If you opt out of receiving marketing emails, we may still send you important administrative messages, which you cannot opt out of.
HOW TO ACCESS, MODIFY OR DELETE PERSONAL DATA:
If you would like to review, correct, update, suppress, restrict, or delete the Personal Data you previously provided to us, or if you would like to receive an electronic copy of your Personal Data for the purpose of transmitting it to another company (to the extent this right to data portability is provided by law), you may contact us at suites@corso281.com or via postal mail:
Corso 281 srl
Via del Corso 281, 00186
Rome - Italy
Please clearly specify in your request which Personal Data you would like to have changed, whether you want your Personal Data to be removed from our database, or otherwise let us know what limitations you would like to put on our use of your Personal Data. For your protection, we will only implement requests with respect to the Personal Data associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (For example, when you make a purchase or a reservation, or participate in a promotion, you may not be able to modify or delete the Personal Data provided until that purchase, reservation, or promotion is completed). There may also be residual information that remains in our databases and will not be removed. Additionally, there may be information that we are not permitted to allow you to review for legal, security, or other reasons.
RETENTION
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
The criteria used to determine our data retention periods are as follows:
- • how long we have had an ongoing relationship with you by providing our Services (for example, since you started using our Services);
- • whether we are subject to a legal obligation (for example, certain laws require us to retain your transactions for a certain period of time before we can delete them);
- • whether retention is advisable considering our legal position (such as with respect to statutes of limitations, litigation, or regulatory investigations).
SENSITIVE DATA
Unless specifically requested, we ask that you do not send or disclose sensitive Personal Data via the Services or by any other means (such as social security numbers, national ID numbers, information about racial or ethnic origin, political opinions, religious or philosophical beliefs, health, biometric or genetic characteristics, criminal background, union membership, administrative or criminal proceedings or sanctions).
USE OF SERVICES BY MINORS
The Services are not intended for individuals under the age of sixteen (16), and such individuals should not provide Personal Data through the Services.
UPDATES TO THIS PRIVACY POLICY
The "LAST UPDATED" caption at the top of this page indicates the date of the last revision of this Privacy Policy. Changes will become effective when the updated Privacy Policy is posted on our online Services. Your continued use of the Services following these changes means that you accept the revised Privacy Policy. If you wish to review the version of the Privacy Policy that was in effect prior to the revision, please contact us at suites@corso281.com.
HOW TO CONTACT US
If you have any questions about this Privacy Policy, please contact us by email at suites@corso281.com, or by mail at:
Corso 281 srl
Via del Corso 281, 0018
Rome - Italy
OTHER INFORMATION
You may also:
PRIVACY PREFERENCES
Corso 281 srl respects your privacy and provides you with information and choices. The options below allow you to express your preferences regarding the content shared with you and how and when we communicate with you.
OTHER PREFERENCES
If you wish to communicate other preferences or exercise your individual rights under the General Data Protection Regulation (GDPR), please contact us by email at suites@corso281.com or by mail at the following address:
Corso 281 srl
Via del Corso 281, 00186
Rome – Italy
We look forward to providing you with an experience that exceeds your expectations, both online and at our property. For security reasons, we may require you to verify your identity before processing your request.
