Privacy policy

This page describes how to manage the site in relation to the processing of the personal data of the users who consult it. This policy is also provided pursuant to art. 13 of the EU Regulation 2016/679 applicable from 25 May 2018 – General Regulation for the Protection of Personal Data (below referred to as GDPR) to those who interact with the web services of the The Yard Hotel  in Milan accessible at:

https://www.theyardplaces.com/the-yard-milan/

The policy is provided only for the https://www.theyardplaces.com/the-yard-milan/ website and not for other websites that may be consulted by the user via links and complies with Recommendation n. 2/2001 concerning the minimum requirements for online data collection in the European Union, adopted May 17, 2001 by the Article 29 Working Group.

DATA CONTROLLER

Under art. 4 paragraph 7) of GDPR 2016/679, Data Controller is THE YARD S.r.l. with registered office in Piazza XXIV Maggio, 8 – 20123 Milan and headquarters at the The Yard Hotel located in Piazza XXIV Maggio, 8 – 20123 Milan.

DATA PROCESSOR

Under art. 28 of GDPR 2016/679, Nexteam S.r.l. based in Via San Francesco d’Assisi, 33 66100 – Chieti Scalo is in charge of processing reservations through the booking expert platform. 

DATA PROCESSING LOCATION

Processing related to the web services of this site take place at the headquarters of the owner and of the person in charge of the processing. No data deriving from the web service is provided to third parties or disclosed. Using third-party cookies, processing may also take place outside the European community by Google and third-party cookie companies. In this regard, please refer to the Cookie Policy.

TYPES OF DATA PROCESSED

Navigation data

Computer systems and software procedures used to operate this website acquire, in the course of 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 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 connecting 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 numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user’s computer environment. This data is used only to obtain anonymous statistical information on the use of the site and to check its correct functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site: except for this eventuality, data on web contacts is not kepst for more than thirty days.

Data provided voluntarily by the user

Optional, explicit and voluntary sending of e-mail to the addresses listed on this site entails the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other personal data included in the message. The interested party is prompted to read this privacy policy by filling in the data acquisition forms on the website.

PROCESSING METHOD

Personal data is processed with automated tools for the time it takes to achieve the purposes for which it was collected. Specific security measures are in place to prevent data loss, unlawful or incorrect data uses and unauthorized access.

PURPOSE, LEGAL BASIS AND NATURE OF COLLECTION

The Personal Data you provide through the Website will be processed by THE YARD S.r.l. for the following purposes:

1. Book hotel rooms. Consent Not required. The legal basis is based on Article 6 par. 1(b) of GDPR 2016/679 that is processing is necessary for the execution of a contract of which the interested party is a party or to carry out pre-contractual measures taken at the request of the same;
2. subscription to the company’s newsletter. Consent Required. The legal basis is based on the consent of the interested party under Article 6 part.1 (a) GDPR 2016/679.evaluation of possible job applications by acquiring resumes via email or online ads. Requires explicit consent.
3.   The legal basis is under Article 111 b of D. Lgs.196/2003;any profiling purposes through third-party cookies; Consent required as per Cookie Policy. The legal basis is based on art. 6 par. 1 (a) of GDPR 2016/679 in compliance with the 2009/136/CE Directive of 25 November 2009;
4. research and statistical analysis on anonymous aggregated data, aimed at measuring the functioning of the Site, measuring traffic and assessing usability and interest to make it more functional and performing; Consent not necessary as it does not entail the processing of personal data.
5. purposes relating to the compliance with laws and regulations; Consent Not Required The legal basis is based on Article 6 par. 1 c) of the GDPR 2016/679;
6. purposes necessary to ascertain, exercise or defend a right in a court of law or whenever the judicial authorities exercise their jurisdictional functions. Consent Not Required The legal basis is based on Article 6 par. 1 f) of GDPR 2016/679 that is processing is necessary for the pursuit of a legitimate interest of the owner;

MANAGING CVS

We do not acquire curricula or personal data for job selection through this website, however we have decided to integrate this section into the privacy policy for any searches or job advertisements on specialized portals in order to redirect the interested party to the privacy policy in hand.

THE YARD S.r.l. reserves the right to evaluate the CVs received via email or through online job advertisements in accordance with this privacy policy.

Curricula considered “interesting” will be stored for 24 months and will be processed in compliance with the security measures of the EU Regulation 2016/679. 

At the end of the 24 months the curricula will be destroyed or the person concerned may be contacted to request authorization to receive an updated curriculum.

Resumes will not be disclosed to third parties.

However, we kindly invite the candidates to respect the following rules when submitting their CVs:

• writing the resume in European format;
• submitting the resume in pdf format;
• avoiding to add to the resume specific data as per article 9 of the EU Regulation 2016/679 (concerning, in particular, to health, religious, philosophical or political beliefs) that are not relevant in relation to the job offer;
• by providing consent to the processing of specific categories of personal data relevant to the establishment of a employment relationship (for example belonging to protected categories Law 68/99).

The Company will provide appropriate information pursuant to art. 13 of EU Regulation 2016/679 during any interviews with candidates.  The purpose of the processing related to the management of the curricula will involve activities strictly related to the evaluation, recruitment or selection of personnel, with objectives of collaboration, temporary or permanent employment, of internships, or to allow the chosen candidate to prepare his / her own thesis degree at the Company’s headquarters.

TRANSFERS OF PERSONAL DATA TO THIRD COUNTRY OR INTERNATIONAL ORGANIZATIONS

Under no circumstances, personal data is transferred outside the European Community.

In case third-party cookies are used to allow the identification of the interested party’s IP address (please refer to the Cookie Policy), some of your Personal Data may be transferred to Recipients that could be outside the Community European. In this case THE YARD S.r.l. ensures that the electronic and paper-based processing of your Personal Data by the Recipients takes place in compliance with the Applicable Law which has a legal scope of application outside the EU.

Otherwise, transfers alternately rely on an adequacy decision or the Standard Model Clauses approved by the European Commission as well as in compliance with the Privacy By Shield principles in case of transfers to the USA. 

DISCLOSURE OF PERSONAL DATA

Personal data acquired through the website may be disclosed to:

• The Yard S.r.l.’s employees authorized for processing;
• Nexteam S.r.l. external manager Nexteam S.r.l. for the management of the booking platform;
• Otelia S.r.l., the company owner of the IT platform for customer management as website bookings are integrated with the dedicated hospitality management software;
• companies providing the management and technical support services of THE YARD S.r.l.’s IT infrastructure;
• Public bodies or offices according to legal and/or contractual obligations;
• debt collection companies and to banks for the management of receipts and payments resulting from the execution of the stay;
• any consultants and external companies specifically appointed to carry out tax and tax consultancy activities on our behalf;
• employees or service providers when such communication is necessary for the use of the hotel services by the interested party;
• third-party companies that install profiling cookies;

The updated list of external managers appointed under Article 28 of GDPR 2016/679 can be requested from the Data Controller.

DATA RETENTION

THE YARD S.r.l. will hold your Personal Data for the time strictly necessary to achieve the objectives stated in this policy and up to the time allowed by Italian law to protect its interests (Art. 2947(1)(3) c.c.).

The user will remain subscribed to the company’s newsletter until they exercise the right of deletion that can be exercised with a simple click directly from the received email.

AUTOMATED PROCESSING

THE YARD S.r.l. does not carry out processing based on an automated decision-making process, including profiling that produce legal effects or that can significantly affect those who interact with the website.

For details ABOUT cookies installed by the external technology manager and their interaction with social networks, see the site’s Cookie Policy.

RIGHTS OF THE INTERESTED PARTIES

The user can freely exercise the rights referred to in articles 15 and subsequent of the GDPR 2016/679 or:

• withdraw consent at all times. Users may withdraw their previously expressed consent to the processing of their personal data;
• oppose the processing of their data. Users may object to the processing of their Data when it occurs on a legal basis other than consent;
• access their data. Users are entitled to obtain information about the data processed by the Data Controller, con certain aspects of the processing and to receive a copy of the Processed Data;
• verify and ask for the amendment. Users can verify that their Data is correct and request that it be updated or corrected;
• obtain processing restriction. When certain conditions apply, users may request to restrict the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than to retain them;
• obtain the cancellation or removal of Personal Data. When certain conditions apply, the user may request that the Data Controller delete their Data;
• receive their Data or have them transferred to another Data Controller.  The user has the right to receive his/her data in a structured, commonly used format that is readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another Data Controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the user’s consent; on a contract to which the User is a party, or on contractual measures connected to it;
• make a complaint. The User may make a complaint to the relevant personal data protection authority or take legal action.

HOW TO EXERCISE YOUR RIGHTS

For the exercise of the rights mentioned above, the interested party may contact the company’s management at privacy@theyardmilano.com

UPDATE AND REVIEW

This privacy policy has been updated on 11-10-2019 to Review 1 and may be subject to future reviews.