Privacy policy

PRIVACY INFORMATION SHEET FOR SHORT RENTALS

pursuant to and for the purposes of articles 13-14 of Regulation (EU) 2016/679 GDPR
(General Data Protection Regulation)

INTRODUCTION Klodge SRLs (hereafter "Klodge", "Agency"), is a professional real estate broker registered with the C.C.I.A.A. of Sassari in the Section of Real Estate Agents and agents for consideration, REA n. SS-213700. Our agency undertakes to protect the Privacy and confidentiality of the Personal Data it acquires and processes in the context of i) its activity as agent and property manager in the name and on behalf of the respective Owners / Lessors, ii) in the activity of agent and for real estate brokerage carried out towards its customers.

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This document illustrates the methods and purposes of the collection, use, consultation and processing of personal data operated by Klodge and the rights guaranteed to the interested parties by the current legislation on privacy.

DATA CONTROLLER (Data Controller)
The Data Controller is KLODGE SRLs, registered office in via Pescara 11, 07026 Olbia (SS) Italy, email info@klodgepm.com

DATA PROCESSING RESPONSIBLE
The Data Controller is INTERNET TOURISM SOLUTIONS S.L. - VAT B97090138 and registered office in C / CHARLES ROBERT DARWIN 5 - 46980 PATERNA (Spain). Email dpo.cliente@conversia.es, tel. +34 96 353 04 51

LAWFUL PRINCIPLE
The processing of personal data is carried out correctly and transparently, for lawful purposes and protecting the privacy and rights of the interested parties.

INTERESTED CATEGORIES
During and for the purpose of the proper conduct of its business, Klodge may collect, use, consult and more generally process Personal Data relating to the following Interested parties:
• Clients - natural persons who are the owners of the booking and the lease
• Clients - legal persons who are owners of the booking and the lease
• Guests (companions or family unit) - following the main customer

CATEGORIES OF PERSONAL DATA
During and for the purpose of the proper conduct of its business, Klodge may collect, use, consult and more generally process the following Personal Data of the Interested parties:
• Personal data: tax code and / or VAT number, name and surname, place and date of birth, registered residence, sex, relationship, general and extremes and photostatic copy of the identification documents; recognition photo
• Contact details: telephone number, e-mail address, residential address, home address
• Financial information: bank details, credit and debit card details provided as collateral and / or balance
• Information relating to the rental: date of arrival, date of departure, number of nights, means of transport used for the trip, time of arrival and departure

SOURCES OF PERSONAL DATA COLLECTION
Klodge, during and for the purpose of the proper conduct of its business, may acquire the personal data of the interested parties:
• directly by the interested parties during: (i) requesting information on the services offered; (ii) booking request sent by the interested party via the booking portal www.klodgepm.com, by email or telephone;
• by OTA intermediaries and online booking portals following a direct confirmation booking made by the interested party;
• by other real estate brokers in the context of requests for availability and cost estimates formulated in the name and on behalf of the interested party
It is understood that if the interested party is under 18 years of age, the related personal data will be communicated to Klodge by the parent / subject who exercises parental responsibility. Therefore, the latter will be responsible for the aforementioned obligations to provide the information and to collect consent.

CATEGORIES OF RECIPIENTS OF PERSONAL DATA
During and for the purpose of the proper conduct of its business, Klodge can transmit the personal data of the interested parties to the following categories of subjects:
• public Authorities (Police Headquarters), Supervisory Authority and Financial Administration
• public administrations (Regions and Municipalities)
• external subjects and collaborators in charge of supplying ancillary services
• owners / lessors for the performance of the operations envisaged in fulfillment of legal obligations
• other business agents in mediation (also companies) identified by the Data Controller in order to collaborate for the fulfillment of the assignment entrusted by the interested party
• employees and collaborators of the Agency, designated as responsible and / or in charge of the treatment, in relation to the performance of the tasks and duties assigned to each

PURPOSE AND LEGAL BASIS OF THE PROCESSING OF PERSONAL DATA
Klodge processes the personal data of the interested parties in accordance with the provisions of the GDPR and Legislative Decree 196/2003 and its subsequent amendments and additions. This section defines the purposes for which Klodge acquires, uses and more generally processes personal data, illustrates the methods for sharing the information collected and specifies the "legal foundations" on which the processing of information is based. If Klodge intends to further process Personal Data for purposes other than those for which they were collected, before such processing it will provide the Data Subject with information regarding these different purposes and any further relevant information required by the GDPR.

The data of the interested party will be used for the purpose and for the purpose of:

a) complete the assignment of mediation in the lease conferred by the interested party concerning the property requested or to satisfy, even before the beginning of the contract, specific requests made by him. In the case of transactions with a monthly fee equal to or greater than € 10,000.00, Personal Data may be communicated to the competent authorities in the field of Anti-Money Laundering. In this regard, it is specified that the processing of personal data in connection with the anti-money laundering obligations must be carried out by means of the specific procedures provided for non-financial operators pursuant to d. 231/2007 and related application laws. Any refusal to communicate the requested data precludes the provision of the requested services and the communication of the details of the operation to the competent supervisory authority;

b) acquire and confirm the booking of accommodation and ancillary services and to provide the requested services. The processing concerns general and contact details, tax code and / or VAT number, bank details, credit and debit card details provided as guarantee and / or balance, list of services and products requested and purchased, date of arrival and departure, etc. Since these are treatments necessary for the definition of the contractual agreement and for its subsequent implementation, the consent of the interested party is not generally required. In case of refusal to provide personal data we will not be able to confirm the reservation or provide the requested services. The treatment will cease on departure, but some Personal Data may or must continue to be processed for the purposes and in the manner indicated in the following points;

c) fulfill the obligation set out in the "Testo Unico delle leggi di pubblica sicurezza" (art. 109 RD 18.6.1931 n. 773) which requires us to certify the identity of the guests and communicate to the Police Headquarters, for public safety purposes, the details of the customers accommodated according to the methods established by the Ministry of the Interior (Decree of 7 January 2013). The provision of data relates to generality, details and photostatic copy of the identification documents, customer identification photos, date of arrival and nights of stay, family relationships; the provision is mandatory and does not require consent, in case of refusal to provide such data we will not be able to deliver the keys to the accommodation. The data acquired for this purpose are stored by us, your consent to storage as required in point d) is required;

d) fulfill the mandatory ISTAT communication obligation of the tourist movement and accommodation capacity (Legislative Decree 322/1989) for private rental properties that requires us to communicate as delegates of the lessor, through the SIRED service, dates of arrival and departure, general information and details of the identification document of the so-called 'group leader', general information of the other lodged. The treatment is carried out without the need to acquire consent. The data are processed by us and by our managers and agents and are communicated externally only in compliance with legal obligations. In case of refusal to provide the data necessary for the aforementioned obligations, we will not be able to provide the requested services. The data object of communication are not kept by us;

e) fulfill the obligation to collect, pay and report the tourist tax (art. 4 of Legislative Decree 23/2011) concerning real estate units not used as main homes and leased for tourism purposes pursuant to Art. 1, paragraph 2, lett. c of Law 431/98. The treatment relates to the number of subjects lodged and the nights, the age of the guests, the check-in and check-out date, the generality of the subjects exempt or who refused to pay the tax. The provision is mandatory and does not require consent, in case of refusal to provide such data we will not be able to provide the requested services. The data are communicated externally only in fulfillment of legal obligations and stored by us for the time required by the respective regulations (10 years, and even further in the case of tax assessments);

f) fulfill current administrative, accounting and tax obligations. For these purposes, general and contact details, tax code and / or VAT number, credit and debit card details provided, the services and products purchased listed in the account statements and tax documents will be processed. The treatment is carried out without the need to acquire consent. The data are processed by us and by our managers and agents and are communicated externally only in compliance with legal obligations. In case of refusal to provide the data necessary for the aforementioned obligations, we will not be able to provide the requested services. The data acquired for these purposes are kept by us for the time required by the respective regulations (10 years, and even more in the case of tax assessments);

g) perform the function of sending communications via messages and phone calls during the stay. For this purpose, the data relating to personal and contact information will be processed, consent is required. You can withdraw your consent at any time. However, the treatment will cease on departure;

h) speed up the procedures in case of subsequent contracts. For this purpose, after obtaining the revocable consent at any time, the data will be kept for a maximum period of five years and will be used when the interested party will be a customer again, for the purposes referred to in the previous points;

i) sending promotional newsletters and commercial offers. For this purpose, after obtaining consent, the data relating to personal data, postal and / or electronic addresses of the interested party will be kept for a maximum period of five years and will not be disclosed to third parties. The interested party may withdraw consent at any time.

CONSENT AND REVOCATION
Consent to the processing of such Data explicitly given authorizes the Data Controller to share such data with the Data Processing Manager and with any Data Controllers. The interested party can withdraw consent to the processing of such Data at any time, without prejudice to the lawfulness of the treatment based on the consent given before the revocation. Withdrawal of consent implies the impossibility for Klodge and its Data Processing Manager and any Data Controllers to fulfill their contractual obligations, with the simultaneous suspension of services.

AUTOMATED DECISION-MAKING PROCESSES, INCLUDING PROFILING
Pursuant to art. 22 of the GDPR, Klodge does not use automated decision-making processes. Should he use them in specific cases, he will directly inform the interested party, according to the provisions of current legislation on privacy, both national and European. Klodge does not process data for the purpose of evaluating some personal aspects (so-called profiling).

METHOD OF TREATMENT
In relation to the purposes of the processing, personal data will also be processed by a "manager", that is, the natural person or the company, also external to the agency, to whom specific and defined tasks of management and control of data processing may be entrusted, and by one or more "Representatives", who will process or use the Data materially on the basis of the instructions

RIGHTS OF THE INTERESTED PARTY
All interested parties, or the natural / legal persons to whom the personal data refer, have the following rights regarding the protection of personal data, which can be exercised against the owner, by writing to the following e-mail address: info @ klodgepm .com or by communication to be sent by ar at the registered office of Klodge, Via Pescara 11 07026 Olbia:
• the right of access (art. 15 GDPR, i.e. request on how to use and process personal data),
• the right of rectification (art. 16 GDPR, i.e correction of any inaccuracies in the Personal Data),
• the right to erasure (art. 17 GDPR, i.e erasure of personal data if there is no longer a legal basis that justifies its processing or if the interested party revokes consent),
• the right to limit the processing (art. 18 GDPR, i.e. the interested party disputes the accuracy of personal data and the limitation of the processing of personal data takes place for the time necessary to consider the request of the interested party),
• the right to portability (ie reception and transmission to another owner) of the personal data stored (art. 20 GDPR),
• the right to object (art. 21, co. 1 and 2, GDPR)
• the right to withdraw your consent to the processing of personal data, as better indicated in the previous paragraph "CONSENT AND REVOCATION".
These rights are subject to some exceptions in order to protect public interests (for example the prevention and detection of crimes). Klodge undertakes to respond to most requests to exercise the above rights within 30 days of their receipt at the addresses indicated in this statement. If Klodge is unable to provide an adequate response to a request for clarification or a complaint, the interested parties have the right to submit a complaint to the Guarantor Authority for the Protection of Personal Data (Public Relations Office, email: urp @ gpdp.it).