Profiling policy

Updated on April 26, 2017

Introduction and General Terms

Profiling is the analysis and processing of information related to Users and Clients, in order to divide stakeholders into “profiles”, i.e. into homogeneous groups according to specific characteristics or behavior, with the aim of achieving unequivocal identification of an individual user (Authenticated Users) using a recognized Terminal and, hence through it, the profiles of one or more users of that device will be identified.

This categorization is instrumental to the provision of services which are progressively targeted and adapted to the specific needs of the user, as well as the provision for personalized advertising.

Authenticated and unauthenticated users

Users of the features under consideration can be distinguished according to:  whether the User has an account created as a result of a registration procedure for access to “authenticated” services (Authenticated Users), or for the use of the same features without prior authentication (Unauthenticated Users).

Halldis SpA performs exclusive profiling surveys of personal data related to unauthenticated users.

Profiling Policy

Personal data handling

Halldis SpA, the Data Controller, with an office in Milan, Piazza IV Novembre 7, applies to all third party methods, referring to the collection of personal data which is provided via the functions of the Halldis site through email, telephone, messages or paper correspondence, where the information is structured and organized in mainly automated databases.

Personal information processed
With prior consent, personal information that can be processed is as follows:

– Name and Surname;
– Email address/es;
– Title;
– Phone number;
– Language;
– Type of Property and City of interest;
– Characteristics of the property requests: terrace, swimming pool, pets, spa, number of rooms, if in close vicinity to the CBD, facing the sea etc.
– Reduced Mobility;
– Duration of stay: short, medium, long;
– Individual Trip with family, partners, with large group;
– If travelling with children;
– Interests: sport, lifestyle, wellness, culture, food and wine tours;
– The original website where the inquiry was created;
– Customer status, or if you are already our client;
– Customer type: individual, company or intermediary;
– Budget: low, medium, high.

Once you have received our Newsletter, we retrieve the following information regarding:

– Time and date of the opening of the Newsletter;
– Location data of the Users Terminal;
– The email reader program used;
– Time, date, number and position of clicks eventually made to the newsletter.

Methods and purpose of profiling
Upon your informed and specific consent, your personal identifiable information may be collected in the following ways:
in filling out specific forms, available on the site, contact and / or request information and / or via online bookings;
receiving emails or phone contacts aimed at providing information and / or bookings;
behavioral analytics software which indicates your interactions with the newsletter received.

The information will be processed in mostly automated manner in the following ways:
– Base CRM: A Customer Relationship Management Platform and potential customers;
– MailUp: Platform used for distribution and newsletter management;
– Magarental: Management Platform for Rental contracts of apartments.

In any event, your personal data will not under any circumstances be disclosed or distributed to third parties.

The purpose of profiling is to make services available that are increasingly targeted in order to meet the specific needs of the user, and to provide personalised advertising.

Acquisition Modes of consensus and the modulation of decisions

The request for the provision of User consent required for the purposes of profiling is carried out in your information gathering phase, namely: by compiling forms and booking information requests or, in in the event of contact using one of Halldis’ direct email addresses. If you have not consented to the requirement of profiling, you may be required to disclose your personal information to one of our telephonic operators.
Please note that the refusal of consent to profiling has no consequence, in relation to the provision of the requested service.
To learn more or to change your selections at any time regarding your consent to profiling, you are more than welcome to contact us at the following email address: privacy@halldis.com

Processing methods and data storage

In accordance with the principle of finality in the preservation of users’ personal data (article 11, paragraph 1, letter e), of the Code), the data processed for profiling purposes will be kept in a way or form which permits the identification of data for a period of time, not applicable to any other purposes but for which they were collected or subsequently processed.
A reasonable data retention period not exceeding to that of 36 months, is considered. Upon expiry of which, the data will be automatically deleted and/or anonymized permanently.

Information treated for profiling purposes may be transferred to a third-party country outside the European Union only in the event that that Country guarantees an adequate level of protection of personal data on the basis of a decision by the European Commission and subject to the appointment of the importer Subject as external Data manager. Data treated for profiling purposes may also be transferred and stored on the Servers of:

 

  • Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (US), protected by appropriate measures and security procedures guaranteed by the certification of Google, including Google Inc. and its 100% owned subsidiary companies in the United States, in adherence to the principles of the Privacy Shield.
  • Future Simple Inc., Mountain View, CA, 850 North Shoreline Blvd (US), protected by appropriate measures and procedures guaranteed by the certification of Future Simple Inc.  in adherence to the principles of the Privacy Shield.

 

Your Rights and Data Controllers
You can learn more about your rights and the information processed by Data Controllers by consulting our Privacy Policy.


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