1.PRIVACY POLICY

Privacy information pursuant to Article 13 of the General Data Protection Regulation EU 2016/679 (GDPR)

Voihotels S.p.A. with registered office in Turin, Via Lugaro 15 is constantly committed to protecting the online privacy of its users.

A) Source of personal data and Data Controller

This document was drawn up pursuant to art. 13 of EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to know our privacy policy. The general methods of processing the personal data of site users and cookies are described and how your personal information is managed when you use our site ww.voihotels.com (hereinafter “Site”) The information and data you provide or otherwise acquired in the context of the use of the services of Voihotels SpA such as: access to the reserved area of the Site, newsletters, etc. , hereinafter “Services” -, will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire the activity of Voihotels S.p.A.

According to the rules of the Regulation, the treatments carried out by Voihotels S.p.A. will be based on the principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.

The owner of the treatments carried out through the Site is Voihotels S.p.A. with registered office in Rome as defined above to which you can write for any information concerning the processing of personal data.

The Data Protection Officer (hereinafter, “DPO”) can be reached at the following address: DPO@voihotels.com

This information is provided only for this Site and not for other websites that may be consulted by the user via links. Please refer to any specific sections of the Site where you can find specific information and any requests for consent for individual treatments.

B) Types of Data

After browsing the Site, we inform you that Voihotels S.p.A. will process personal data (Article 4 (1) of the Regulation) hereinafter only “Personal Data”.

In particular, the Personal Data processed through the Site are as follows:

1. Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning (see the paragraph on cookies below), to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used by the competent authorities to ascertain responsibility in the event of hypothetical computer crimes against the site.

2. Data provided voluntarily by the interested party

Apart from what is specified for navigation data, the user is free to provide personal data contained in any request forms present on the website (eg. To activate newsletters, free registration, purchase, etc.). Failure to provide them could make it impossible to provide the service. In these cases, only the information necessary for the requested service will be requested (see the specific information in detail).

In the use of some Services of the Site, the processing of Personal Data of third parties sent by you to Voihotels S.p.A. may occur. With respect to these hypotheses, you act as an independent data controller, assuming all the obligations and responsibilities of the law. In this sense, it confers on this point the widest indemnity with respect to any dispute, claim, request for compensation for damage from treatment, etc. that should reach Voihotels S.p.A. by third parties whose Personal Data have been processed through its use of the functions of the Site in violation of the applicable rules on the protection of personal data. In any case, should it provide or otherwise process Personal Data of third parties in the use of the Site, it guarantees from now – assuming all related responsibility – that this particular hypothesis of treatment is based on an appropriate legal basis pursuant to art . 6 of the Regulation which legitimizes the processing of the information in question.

C) Purpose of the processing and legal bases

The processing of personal data that we intend to carry out, with your specific consent where necessary, has the following purposes:

Allow the provision of the Site Services;

The legal basis of the processing is the execution of pre-contractual measures adopted at the request of the same (Article 6 (1) (b) of the Regulation) as the processing is necessary for the provision of the Service.

The provision of Personal Data for these purposes is optional but failure to provide it would make it impossible to activate the Services provided by the Site.

D) Recipients of personal data

Your Personal Data may be shared, for the aforementioned purposes, with:

• persons authorized by Voihotels S.p.A. to the processing of Personal Data necessary to carry out activities strictly related to the provision of the Services, which are committed to confidentiality or have an adequate legal obligation of confidentiality (eg employees and system administrators).

• third parties possibly involved in the management of the site who typically act as data processors (the complete and updated list of data processing managers is present and available at www.voihotels.com

• subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data by virtue of the provisions of the law or orders of the authorities.

E) Transfers of personal data

Some of your Personal Data are shared with Recipients who could be found outside the European Economic Area. ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulations. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis.

F) I Suoi diritti privacy ex artt. 15 e ss. del Regolamento

Ai sensi degli articoli 15 e seguenti del Regolamento, ha il diritto di chiedere a Voihotels S.p.A., in qualunque momento, l’accesso ai suoi Dati Personali, la rettifica o la cancellazione degli stessi o di opporsi al loro

trattamento, ha diritto di richiedere la limitazione del trattamento nei casi previsti dall’art. 18 del Regolamento, nonché di ottenere in un formato strutturato, di uso comune e leggibile da dispositivo automatico i dati che la riguardano, nei casi previsti dall’art. 20 del Regolamento.

Le richieste vanno rivolte per iscritto al Titolare al seguente indirizzo privacy.VOI@alpitourworld.it ovvero al DPO (Data Protection Officer) al seguente indirizzo DPO@voihotels.com

In ogni caso hai sempre diritto di proporre reclamo all’Autorità di Controllo competente (Garante per la Protezione dei Dati Personali), ai sensi dell’art. 77 del Regolamento, qualora ritenga che il trattamento dei tuoi Dati Personali sia contrario alla normativa in vigore.

G) Changes

This privacy policy is effective from 25/05/2018. Voihotels S.p.A. reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation Voihotels S.p.A. will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on Sit Voihotels S.p.A. therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to be always updated on the data collected and on the use made of it by Voihotels S.p.A.

2.COOKIE POLICY

Information pursuant to Article 13 of the General Data Protection Regulation EU 2016/679 (GDPR)

This information is the extension of the information on the use of cookies and other technical identifiers provided to the interested party through the simplified information on the banner shown when accessing this website.

This page is addressed to users who consult the website accessible electronically at the following address: www.vretreats.com (the “Site”)

The Data Controller is VOIhotels SpA with registered office in Turin, Via E. Lugaro 15 (hereinafter the “Company” “Owner”) The Data Protection Officer (hereinafter, “DPO”) can be reached at the following address: dpo@voihotels.com

1. Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send and record on your terminal device (computer or mobile devices such as smartphones and tablets), to be then re-transmitted to the same sites on the next visit.

Thanks to cookies, a site remembers the user’s actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) so that they do not have to be indicated again. when the user returns to visit said site or browse from one page to another. Cookies, therefore, are used to perform computer authentication, session monitoring, facilitate the use of content and store information regarding the activities of users who access a site and may also contain a unique identification code that allows you to keep track of navigation. of the user within the site itself for statistical or advertising purposes.

a) Classification of Cookies

While browsing a site, in addition to the cookies stored directly by the visited site (so-called “first-party cookies”), the user can also receive on his computer cookies from sites or web servers other than the one he is visiting (so-called “Third party cookies”).

Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary for the site to function.

There are various types of cookies, depending on their characteristics and functions, and these can remain on the user’s computer for different periods of time: “Session cookies” or also referred to as “navigation cookies”, which are automatically deleted when the browser is closed; CD. “Permanent cookies”, which remain on the user’s device until a pre-established expiry date.

Then there are cookies, so-called “Analytics cookies”, used for the purpose of evaluating the effectiveness of an information society service provided, for the design of a website or to help measure its “traffic”, ie the number of visitors, even if they are shared by geographical area, time slot of the connection or other characteristics.

According to the legislation in force in Italy, the user’s express consent is not always required for the use of cookies. In particular, the so-called “technical cookies”, ie those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies that are essential for the functioning of the site or necessary to perform activities requested by the user, without which some operations could not be carried out or would be more complex and / or less secure.

Among the technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Cookie guidelines and other tracking tools of 10 June 2021 and subsequent clarifications, hereinafter only “Guidelines “) also includes:

· analytics cookies if through their use the possibility of reaching the direct identification of the data subject (so-called “single out”) is precluded, thus preventing the use of analytics cookies that may be direct and unique identifiers. Furthermore, their structure must provide for the possibility of referring them not to one but to several devices, in order to create a reasonable uncertainty about the computer identity of the subject who receives it (usually through the masking of portions of the IP address within the cookie itself as indicated in the Guidelines). Finally, to be identified as technical, analytics cookies must be limited to the sole production of aggregate statistics and which are used in relation to a single site / mobile application, so as not to allow tracking of the navigation of the person who uses different applications or browses in different websites;

· navigation or session cookies;

For the so-called “profiling cookies”, vice versa, ie those aimed at creating profiles relating to the user and used in order to modulate the provision of the service in a personalized way beyond what is strictly necessary for the provision of the service or to send targeted advertising messages in in line with the preferences expressed by the same in the context of surfing the net and / or carrying out analysis and monitoring of visitor behavior, a prior consent of the user is required.

2. Types of cookies used by the Site

The Owner has classified the cookies in use based on their type of use as follows.

Also for third party cookie suppliers the obligation to comply with the relevant legislation, we refer to the link of the web pages of the third party sites, in which the user can find the cookie consent collection forms and their related information .

3. Your decisions regarding cookies

You can select a feature according to which your computer will notify you whenever a cookie is set, or you can decide to disable all cookies. You can select these features through your browser settings. Each browser is slightly different, so we invite you to identify in the “Help” menu of your browser the most correct way to change the functionality relating to cookies. If you decide to disable cookies, you will not have access to many functions that make your experience on our site more efficient and some of our services will not work properly.

4. Privacy rights pursuant to art. 15 and ss. of the Regulation

Pursuant to articles 15 and following of the Regulations, you have the right to ask the Company, at any time, to access your Personal Data, to rectify or delete them, you have the right to object to the processing, you have the right to request the limitation of processing in the cases provided for by art. 18 of the Regulation, as well as having the right to obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation.

At any time you can revoke pursuant to art. 7 of the Regulation, the consent already given, without prejudice to the lawfulness of the processing carried out prior to the revocation of the consent.

Requests must be sent in writing to the Data Controller at the following address privacy.voi@alpitourworld.it or to the DPO (Data Protection Officer) at the following address dpo@voihotels.com.

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.