Privacy Policy
1. Data Controller
The Data Controller for the personal data collected through this website is:
Vicolo di Sorano - Susanna Camilletti
Via del Borgo 37, 58010 Sorano (GR), Italy
Email: info@vicolodisorano.it
CIN: IT053026C2ZGN6ZZIC
2. Data We Collect
a) Data provided through the booking form
Name, surname, email address, phone number (optional), requested stay dates, number of guests, and any additional message or request.
b) Identity document data
In compliance with Italian public security law, guests are required to provide a valid identity document prior to or at check-in. This data is collected via our secure payment/booking processor, Stripe, and is transmitted to the local police authority (Questura) through the official “Alloggiati Web” portal, as required by Article 109 of the Italian Public Security Law (Testo Unico delle Leggi di Pubblica Sicurezza). This data is not used for any other purpose.
c) Data collected automatically
Through Google Analytics, we collect aggregated statistical data about site usage (pages visited, time spent, traffic source, device and browser type) via cookies and similar technologies, only after your consent.
3. Purpose and Legal Basis of Processing
| Purpose | Legal Basis |
|---|---|
| Managing booking requests and pre-contractual communication | Performance of pre-contractual measures (Art. 6(1)(b) GDPR) |
| Guest identification and reporting to local police authorities | Legal obligation (Art. 6(1)(c) GDPR; Art. 109 TULPS) |
| Statistical analysis of website traffic (Google Analytics) | Consent (Art. 6(1)(a) GDPR) |
| Responding to general contact enquiries | Consent / legitimate interest |
4. Cookies
This website uses technical cookies necessary for its operation (e.g. language selection) and analytics cookies (Google Analytics), the latter installed only after you provide explicit consent via the cookie banner shown on your first visit. You may change or withdraw your consent at any time via the cookie settings link in the website footer.
5. Data Recipients
Your data may be shared with:
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- Technical service providers supporting the website (hosting: Hostinger; booking management plugin)
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- Stripe, Inc., for secure processing of identity document data and payments
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- Google LLC, as provider of the Google Analytics service (with data transfer to the US governed by EU-approved Standard Contractual Clauses)
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- Italian public security authorities (Questura), as required by law
6. International Data Transfers
Some services used (Google Analytics, Stripe) may involve transferring data to servers located outside the EU/EEA, including the United States. Such transfers are carried out on the basis of Standard Contractual Clauses approved by the European Commission.
7. Data Retention
Booking request data is retained for as long as necessary to manage your request and for subsequent legal obligations (e.g. tax purposes), generally up to 10 years for accounting records. Identity document data submitted to the Questura is retained only as long as required by Italian public security law. Website analytics data is retained according to the retention settings configured in our Analytics account (recommended: 14 months).
8. Your Rights
At any time, you may exercise the following rights under Articles 15–22 GDPR by writing to info@vicolodisorano.it:
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- Access to your data
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- Rectification of inaccurate data
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- Erasure (“right to be forgotten”)
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- Restriction of processing
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- Data portability
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- Objection to processing
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- Lodging a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali, www.garanteprivacy.it)
9. Changes to This Policy
This privacy policy may be updated periodically. We encourage you to review it regularly.
