PRIVACY INFORMATION GDPR REGULATION

EUROPEAN (EU) 2016/679 OF 27 APRIL 2016

Hotel Schuhmann srl is committed to protecting user privacy and declares itself responsible for the security of customer data. We will be clear and transparent on

information we collect and what we will do with that information.
This statement establishes the following:
What personal data of the user is collected and processed in relation to the relationship with us as a customer and through the use of our website, mobile applications and online services;
• Where we get the data;
• What we do with these data;
• How we store data;
• To whom we transfer / disclose such data;
• How we treat your data protection rights;
• And how we comply with data protection regulations.
All personal data are collected and processed in compliance with EU and data protection laws.

Holder of the treatment

Vincenzo Barlotti is the "owner of the treatment" of all personal information collected and used on customers Hotel Schuhmann srl which is a company with
registered office in Via Marittima, 1 - 84047 Capaccio Paestum (SA) e
P.Iva 05512550657

What personal data we collect

Personal data means all information relating to the user that allows us to identify him, such as name, contact details, reference number, payment details and information on his access to our website. Specifically, we may collect the following categories of information:

to. Name, home address, e-mail address, PEC, telephone number, passport number or ID card details, credit / debit card or other payment details;
b. Information on the use of our website and / or app;
c. Communications exchanged with us or addressed to us through letters, emails, chat services, phone calls and social media.
d. Location, including the real-time geographic location of your computer or device via GPS, Bluetooth, and IP address, along with crowd-sourced Wi-Fi hotspots and repeater locations, if the user uses location-based and active features geolocation services on your device and computer.

For what we use personal data, why and for how long

User data can be used for the following purposes:
to. Provide the requested products and services: we use the information provided by the user to carry out the requested services;

b. Contact the user in case of modification or cancellation of the service: we send the user communications on the services he has requested and on any changes to these services. These communications are not for marketing purposes and cannot be deactivated;

c. Administrative or Legal Purposes: We use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or to respond to a dispute or complaint. We may perform data profiling based on the information we collect from the user in order to use it in statistical and marketing analyzes. Any profiling activity will be carried out only with the prior consent of the user and making every effort to ensure that all data on which it is based is accurate. By providing any personal data, the user explicitly accepts that we may use them to carry out profiling activities in accordance with this Privacy Policy.

d. Communications with customer service: we use user data to manage our relationship as our customer and to improve our services and improve the user experience with us;
is. Provide tailor-made services: we use the user's data to provide information that we consider of interest, and to personalize the services we offer to the user, such as special offers;

f. Marketing: from time to time we will contact the user with information relating to ancillary products via electronic communications. However, you will have the option of accepting or not receiving such communications by indicating your preference. The possibility of indicating that you no longer wish to receive our direct marketing material is also given in every electronic communication that we send.

We will only process your personal data if we have a legal basis for doing so. The legal basis will depend on the reasons why we have collected and must use your personal data.
We may also process your personal data for one or more of the following reasons:

• Respect a legal obligation;
The user has consented to the use of their personal data (for example, for marketing purposes).

We will not store data for longer than necessary to fulfill the purpose for which it was processed. To determine the appropriate retention period, we take into account the quantity, nature and sensitivity of personal data, the purposes for which we process it and whether we can achieve those purposes by other means.

We must also take into consideration the periods for which we may need to store personal data in order to fulfill our legal obligations or to examine complaints, requests and defend our legal rights in the event of a compensation claim.

When we no longer need your personal data, we will safely delete or destroy it. We will also evaluate if and how we can reduce the personal data we use over time and if we can make the user's personal data anonymous so that they can no longer

be associated with or identify you, in which case we may use this information without notice.

Security of personal data

We follow strict security procedures in the storage and disclosure of personal data, to protect them against accidental loss, destruction or damage.

International transfer of data

Hotel Schuhmann srl does not currently operate outside the European Economic Area.

Sharing of personal data

We may also share your personal data with the following third parties for the purposes described in this Privacy Policy:
to. Government authorities, law enforcement agencies;
b. Trusted agents through whom you book the service;

c. Trusted service providers that we use to manage our business, cloud service providers and email marketing services that assist our marketing team in managing surveys and targeted marketing companies;
is. Legal consultants and other professionals, courts and law enforcement agencies in all the countries in which we operate in order to protect our legal rights in relation to our contract with the user;

Cookies and site tracking

This site uses cookies to allow us to improve our service and offer the user some useful features. This may include media and advertising partner cookies that are stored on your computer or device when you visit our website or app. Please visit our partners' websites for information on their cookie and privacy policy.

Cookies are small text files that are transferred to your computer's hard drive via the web browser to allow us to recognize your browser and help us monitor visitors to our site, thus allowing us to better understand the products and services that will be more suitable for users. A cookie contains contact information and useful information to allow the computer to be identified when visiting our site with the aim of helping the user to make a reservation. Most web browsers automatically accept cookies, but if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" menu of the toolbar on most browsers explains how to prevent the browser from accepting new cookies, how to make the browser notify you when a new cookie is received or how to completely disable cookies. If you choose to change these settings, certain features and functionality may not work as expected. The cookies used do not detect the information contained on the computer.

We use specific software to monitor site traffic and use, in order to improve the development of website design and layout. This software does not allow us to collect personal data in addition to the subjects indicated.

Data protection officer

The data protection officer is Vincenzo Barlotti
The user has the right to lodge a complaint at any time by sending an e-mail to the following address: info@hotelschuhmann.com

Data protection rights

In certain circumstances, by law you have the right to:
• Ask us if we have personal information about you and, if so, what that information is and why we process / use it.
• Request access to your personal information (commonly known as a "data access request"). This allows you to receive a copy of the user's personal information in our possession and to check its correct processing.
• Request the correction of your personal information in our possession. This allows the user to correct any incomplete or inaccurate information.
• Request the deletion of your personal information. This allows us to ask you to delete or remove personal information where there are no valid reasons to continue processing it. The user also has the right to ask us to delete or remove his personal information if he has exercised his right to object to the processing (see below).

For cancellation (right to be forgotten) send an e-mail to:

info@hotelschuhmann.com

• Oppose the processing of your personal data in which a legitimate (or third party) interest is invoked and there are elements relating to a specific personal situation that push you to oppose the processing. The user also has the right to object to the processing where his personal information is used for direct marketing purposes.

• Oppose the automated decision-making process, including profiling, which must not be subject to any automatic decision-making process on our part through the use of personal information or user profiling.

• Request the limitation of the processing of your personal information. This allows you to ask us to stop the processing of your personal data, for example if you want to check its accuracy or reasons. • Request the transfer of your personal information in electronic and structured form to the user or to another party (commonly known as the right to "data portability"). This allows you to take your data in our possession in an electronically usable format and transfer it to another party in an electronically usable format.

• Withdrawal of consent. In the limited circumstances where you may have given consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw it for that specific processing at any time. Once we receive the notification of withdrawal of consent, we will no longer process your information for the originally agreed purpose or purposes, except on the basis of another legitimate basis.

No costs will be incurred to access your personal information (or to exercise any of the other rights). However, if the request for access is clearly unfounded or excessive we may charge the applicant a reasonable cost. Alternatively, we may refuse to fulfill the request in such circumstances.

We may need to request specific information from the user, which will help us confirm his identity and guarantee his right of access to information (or to exercise any of the other rights). This is another security measure that can ensure that personal information is not disclosed to people who are not entitled to receive it.

Changes to the privacy policy

Our Privacy Policy may change from time to time and any changes will be communicated to you via an email or a notice on our website.