Privacy Policy
This Privacy Policy applies to personal data processed at acamea Holiday Home. Please, read it carefully because it contains important information about your personal data processing and legal rights.
Compulsory fields of our forms shall be fulfilled to process your request.
1. WHO IS YOUR PERSONAL DATA CONTROLLER?
The Company who operates the acamea holiday home where you stay (hereinafter, the acamea), whose contact details are as follow:
red Architettura SA, with UID: CHE-462.402.378, with address at via San Gottardo 96, 6648 Minusio, Switzerland, being the scope of the respective responsibilities of the red Architettura SA the following:
The acamea is responsible for its management necessary customers data processing, i.e. Administrative and accounting operations, managing of bookings and stays, contracted service provision and claims customer care.
acamea is liable for holiday home management personal data processing including:
The holiday home management control and business data analysis.
The acamea quality assurance and improvement.
Commercial management of customers personal data for sending of commercial communications, management of loyalty programs, preparation of commercial profiles or services personalization.
For more information about your personal data processing or your legal rights exercise regarding it, you may send an e-mail to the acamea Data Protection Officer: info@acamea.ch
2. PURPOSE AND LEGAL BASIS FOR THE PERSONAL DATA PROCESSING
Personal data will be processed for:
2.1.- Reservations management and provision of the requested services.
The categories of data collected by the acamea for those purposes are the following:
Identification data and contact details of the reservation holder.
Reservation data or request for service (stay dates, number of guests, customer´s age, requested service).
Payment methods data.
Goods and services transactions data.
These data are obtained directly from you or the person who made the reservation or requested the service on your behalf.
The processing of such data is required for the execution of accommodation contract, the provision of the requested services or the application of precontractual measures requested by the data subject.
The economic data and goods and services transactions data will be processed for accounting and administrative management purposes and the acamea compliance with its legal obligations.
All the collected data will be in the acamea Holiday Home database.
2.2.- Traveller´s record and control.
In accordance with the current traveller´s control law, acamea must register guests information. This information is included at the check-in form fulfilled by the guest, retained by the acamea and made available to the competent authorities.
Which data are processed for this purpose?
Name and surname (s), sex, date of birth, nationality, identity card type, number and date of issue, date of entry, signature.
If necessary, by the health regulations in force, the acamea will provide a record of people that Access the acamea.
2.3. Activities recording.
Activities or entertainment organized by the acamea could be photographed or recorded for internal dissemination. You will previously be asked for your consent. Your consent does not condition participation in the activities or entertainment. Your consent may be revoked by contacting the acamea Data Protection Officer: info@acamea.ch
2.4. Quality control.
The acamea may conduct satisfaction surveys. These surveys are completed anonymously and are not compulsory.
However, if identification data were provided, acamea may contact you. This processing is based on the acamea legitimate interest in assessing its services and products quality and improve its customer attention.
How has this interest been weighed with regard to your rights?
The processing is compatible with the customer reasonable expectations who has willingly provide his identifying data and contact details.
The impact of the processing on customer privacy is limited because its only purpose is resolve complaints and discuss suggestions, improving our service quality and customer attention.
2.5. Advice and complaints service.
Data provided on your queries or complaints will be processed to manage your requests and complaints. This processing is necessary for the performance of the lodge contract, to take pre-contractual measures with regard to your request or to defence against unjustified customer claims.
2.6. Customer´s data consolidation.
Data provided by customers, together with data gathered during your stay, are consolidated in data bases owned by acamea Holiday Home.
Which data are consolidated?
– IIdentification data: Name, surname (s), identification document (kind, number, date of issue), country of residence, postal address, shipping address, billing address, e-mail, telephone.
– Personal details: Sex, date of birth, country of birth, nationality, family data (kids, date of birth, couple), language.
– Booking details: dates, services, and consumptions.
-Advice and complaints data.
– Goods and services transactions data.
– Financial and insurances data.
– Butler service data.
These data are consolidated in the acamea Holiday Home´s systems, in order to have a customer record, standardize formats, codify information and allow centralized management, i.e. authorities entry reports. This consolidation is based on GDPR 48th recital, that recognises companies legitimate interest in sharing customers personal data for internal administrative purposes.
How has been balanced this legitimate interest regarding your rights?
– Data processing is compatible with the reasonable expectations of the parties, being the customers parties of the acamea.
– The impact of the treatment on the privacy of the parties is limited, having into account purposes, data limited storage time and technical and organisational measures adoption to avoid the use of those data with commercial purposes without express consent.
Consolidated data are also used for the following purposes:
2.7. Non personalised commercial communications sending and distribution lists management (segmentation)
acamea Holiday Home process customers identification and contact data, together with the rest of data, for sending non personalised commercial communications regarding the acamea products and services and distribution lists management.
This information consolidation is based on the acamea legitimate interest in operating a commercial database for direct marketing purposes.
How has been balanced this legitimate interest regarding your rights?
– GDPR 47th recital considers that personal data processing for direct marketing purposes is considered legitimated. GDPR 48th recognizes the legitimate interest of companies in sharing customer personal data for internal administrative purposes.
– Data processing is compatible with the reasonable expectations of the parties, being previously the parties customers of the acamea.
– The impact of the treatment on parties privacy is limited, having into account that you object to the processing when data are collected or through commercial communications.
You can decide, at any time, to cancel your registration on distribution lists, through the link at our commercial communications or by sending an e-mail to: info@acamea.ch
To manage distribution lists, the acamea classifies the recipients by language or home market. This processing is based on the acamea legitimate interest in segmenting recipients.
How has been balanced this legitimate interest regarding your rights?
– The processing is compatible with customers reasonable expectations because it is secondary to commercial communications sending, allowing to be received in a suitable format and with the appropriate language.
– The processing is not a privacy significant threat, because it is a ranking based on objective criteria that do not support new information about customers; Technical and organizational measures have been taken to avoid commercial profiling, predictions, or individualized behavioural analysis without express customers authorisation. Customers can decide, at any time, to object to the processing for receiving commercial communications.
2.8. Commercial profile elaboration to personalize acamea Holiday Home services and commercial communications.
Which data are included in the profile?
– Identification and contact data: Name, surname (s), country of residence, postal address, e-mail, telephone.
– Personal data: Gender, country of birth, date of birth, nationality, family, language.
-Goods and services transactions data: Booking data (dates, number and age of guests, services included) and consumptions (purchases, services, use of the facilities).
-Preferences expressed during the stay (i.e., a special pillow)
-Claims, complaints, and surveys data.
Health data or another special category of data, such as religion or payment means, will never be incorporated to your profile.
acamea Holiday Home will use you profile for:
-Personalise our offering regarding your consumption; This profile is used to make special offers regarding your Booking frequency, contracted products and amounts spent.
Although individualised decisions having legal effects are not taken based on this profile, you have right to object that decision making according to GDPR article 22nd.
This processing is based on your consent. Do not give your consent or withdraw it does not condition your booking or your contracted services. You can revoke your consent at any time by sending an e-mail to info@acamea.ch.
3. HOW LONG ARE YOUR DATA KEPT?
In general terms, customers data will be kept for the duration of the acamea relationship and, in any case, during the required time for dealing with any liabilities arisen from the processing. Your data will be cancelled when they are no longer necessary for the purposes for which they were collected, specifically:
– The acamea will keep your stay economic and goods and services transactions data during the accounting and tax current regulation required time.
– The acamea will keep the guest registry as required by Lear.
– Health data provided for special needs attention, will be daily cancelled for non-hosted customers or hosted ones once they have finished their stay.
– Butler service chats will be cancelled once the customer has finished its stay.
– Consolidated customer data management tool (PMS, Property Management System) will be kept during six (6) years.
– Data processed for commercial purposes, including commercial profiles, will be kept unless you oppose or request its suppression. The means including your consent will be kept for the processing whole duration and applicable prescription terms.
– Data processed for control and business data analysis purposes will be kept without time limit. Data from customers who did not consent for profiling will be anonymized once the conservation period at the PMS expires.
4. WHICH ARE YOUR RIGHTS?
You have right to obtain confirmation about if we are processing your personal data and to access to them. You can equally ask for rectify your data if not accurated or completed, as well as ask for its erasure if they are not needed for the purposes for which they were collected.
In certain circumstances, you will be able to ask for the data processing limitation. In such case, we will only process your data for complaints or protection of rights of others. In certain cases, you might be able to object to the processing of your personal data; If this is the case, we will not process your personal data except for compelling legitimate grounds that prevail over your rights, or for complaints.
Moreover and, under certain conditions, you will be able to ask for the portability of your data to be passed to another data controller.
You can revoke your consent for certain purposes without invalidating the lawfulness of the processing based on your previous consent.
You can revoke your consent anytime or oppose to your data processing with direct marketing purposes, including commercial profiling; In that case, we will not process your personal data for those purposes. You can equally oppose to automated individual decisions that affect you, according to GDPR, article 22nd.
To stop receiving commercial communications you can use the ad hoc link or send an e-mail to info@camea.ch
To delete your commercial profile, you can send an e-mail to info@camea.ch