Privacy

Privacy Statement and Cookie Policy

Brandnamic srl, having registered office in Strada Satzl 4 | Perara, IT-39042 Bressanone (hereafter Brandnamic srl) is committed to protecting the online privacy of users. Pursuant to art. 13 of EU Regulation 2016/679 (hereafter: "Regulation"), this statement was written to inform you on our privacy policy and how your personal data is handled when you visit our website (hereafter “Website”), as well as to enable you to give your specific and informed consent to the processing of your Personal Data, where applicable. Please be informed that parental consent is required for children under 16 years of age. The information and data provided by you, or otherwise acquired through use of our online services (hereafter "Services") on your part, will be processed in compliance with the Regulation and the Data Controller’s obligation to confidentiality.

Pursuant to the Regulation, Brandnamic srl shall process Personal Data based on the principles of lawfulness, fairness, transparency, limitation of purpose and retention, data minimisation, accuracy, integrity and confidentiality.

TABLE OF CONTENTS

1. Data Controller
2. Personal Data subject to processing
1. Browsing data
2. Special categories of Personal Data
3. Data volunteered by Data Subjects
4. Cookies
3. Purposes of data processing
4. Lawful basis and mandatory or optional nature of data processing
5. Disclosure of Personal Data
6. Transfer of Personal Data
7. Retention of Personal Data
8. Your rights
9. Additional services and external service providers
10. Changes

1. Data Controller

In relation to the data processing carried out through our website, the Data Controller as defined above is Brandnamic srl. For any information regarding the processing of Personal Data by the Data Controller, including the list of Data Processors, please write to the following address: info@brandnamic.com

2. Personal Data subject to processing

Please be informed that as a result of website browsing, the Data Controller will collect and process Personal Data that may consist of information like name and surname, identification number, online identifier, mail address, e-mail address, landline and/or mobile telephone number or information on one or more physical, physiological, psychological, financial, cultural or social features relating to an identified or identifiable person (hereafter “Personal Data”).

The following Personal Data is processed through our Website:

a. Browsing data

During normal operation, the computer systems and software used to operate our Website acquire some Personal Data the transmission of which is implicit in the Internet communication protocols. The collection of this information is intended to be associated with identified parties; however, the data collected might by its nature allow users to be identified through processing and association with data held by third parties. This category of data includes IP addresses or domain names of computers used by users who connect to the Website, URI (Uniform Resource Identifier) of requested resources, the time of request and method used to submit it to the server, the size of the file obtained in reply, the numerical code indicating the server response status (successful, error, etc.) and other parameters relating to the user's operating system and IT environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to ensure its correct functioning by identifying any anomalies and/or abuses, and are therefore deleted immediately after processing. The data could be used to ascertain responsibility in the event of possible computer crimes against the Website or third parties; except for this possibility, the data collected from the Website is removed within a short period of time.

b. Special categories of Personal Data

If you send us your application via e-mail or through our website, you might provide us with Personal Data that falls within special categories as set forth in art. 9 of the Regulation, namely: “[…] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and [...] genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation”. Please do not disclose this type of data unless it is strictly necessary. Please be informed that if you do choose to provide this type of data without giving your specific consent to the processing (e.g. by sending a CV), the processing on our part will relate to data made manifestly public by the Data Subject, as provided for by art. 9(1)(e) of the Regulation. Therefore, the Data Controller will be released from any liability or dispute whatsoever in connection with the processing of such data. As previously mentioned, explicit consent to the processing of special categories of Personal Data is fundamental if you do choose to disclose such information.

Please be also informed that the Data Controller may view any social media profiles made openly available on professional networking sites or platforms (e.g. LinkedIn).

c. Data volunteered by Data Subjects

We may process Personal Data of third parties that you send to the Data Controller when using certain services on our Website (e.g. the request/contact/booking forms). In these cases, you act as independent Data Controller, thereby assuming all the obligations and liabilities set by law. In this sense, you release the Data Controller from any and all responsibilities and obligations with respect to any dispute, claim, compensation for damages etc. that may be received from third parties whose Personal Data has been processed through the Website functions in violation of applicable data protection laws. In any case, if you provide or process Personal Data of third parties while using our Website, you warrant – assuming full liability – that processing has a lawful basis in compliance with art. 6 of the Regulation.

d. Cookies General information about cookies

Cookies are small text files which can be stored by a website, and with the help of the browser, on the hard drive of a client computer, to save smaller amounts of website information for a specific period of time. Generally, there are different types of cookies; some are essential for the functioning of the website, such as navigation or shopping cart cookies. Furthermore, there are so-called Analytics cookies, which collect information, for instance about the number of website visitors and the way they found the website. Function cookies allow the website to remember your selection (e.g. selected filter settings or automatic language setting of a website).

In addition, so-called profiling cookies record the user's preferences and actions. A user profile is created on the basis of this information. This serves to combine advertising messages with the interests of the user and thus enables more target-group-specific advertising. In many cases, cookies from third parties are used by the website operator to broadcast personalised advertising.

Compulsory consent for cookies

Website visitors must actively consent to the use of cookies, which are not essential for the functionality of the website, and also have the right to revoke their consent at any time.

This website uses a technology called CMP (Consent Management Platform) to administer this right. When you visit the website, a banner appears informing you about the use of cookies, giving you various options for accepting them (all cookies, individual categories of cookies, or each individual cookie separately), and providing detailed information about the various cookies. The CMP remembers the settings made by visitor and applies them the next time the user visits the website. Here the website visitor can exercise the right of withdrawal or adjust the settings.

How to block cookies in your browser settings
Firefox:

1. Go to Menu and then to Options.
2. Select the Privacy panel.
3. Set Firefox will to: Use custom settings for history.
4. Remove the check mark from Accept cookies from sites.
5. Click OK to close the Options window.

Click here for more details and information: https://support.mozilla.org/en-US/kb/block-websites-storing-site-preferences

Google Chrome

1. Click the Chrome menu on the browser toolbar and go to Settings.
2. Select „Show advanced settings“.
3. In the "Privacy" section, click the Content settings button.
4. In the "Cookies" section, select "Block sites from setting any data".
5. Click OK to conclude the action.

Click here for more details and information: https://support.google.com/chrome/answer/95647?hl=en-GB

Internet Explorer

1. Click Extras on the menu and select internet settings.
2. Select the Privacy panel.
3. To set what types of cookies are blocked or allowed, move the slider. Generally, if the slider is all the way up, all cookies are blocked; if the slider is down, all cookies are allowed.
4. Click OK to conclude the action.

Click here for more details and information: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Safari

1. Choose Safari Preferences, and then click Privacy.
2. In the “Block cookies” section, specify if and when Safari should accept cookies from websites. To see an explanation of the options, click the Help button (question mark).

Click here for more details and information: https://support.apple.com/kb/PH5042?locale=en_US

3. processing

If necessary and with your specific consent, we will process your Personal Data for the following purposes:

1. Provide the services you require;
2. Respond to requests for assistance, information or bookings;
3. View CVs and contact applicants;
4. Comply with legal and tax obligations;
5. Marketing purposes: the data provided may be used, subject to explicit and specific consent, for the sending of promotional and marketing communications, including newsletters and market surveys, using automated tools (SMS, MMS, e-mails, push notifications) and non-automated tools (paper mail, telephone calls by operators). The lawful basis for the processing of your data for these purposes is art. 6, paragraph 1, letter a) of the Regulation. The processing of data for direct marketing is optional and based exclusively on your free choice, and denying your consent for this purpose will not affect the use of services on your part.

4. Lawful basis and mandatory or optional nature of data processing

The lawful basis for the processing of Personal Data for the purposes referred to in section 3 (a-b-c) is art. 6(1)(b) of the Regulation (performance of a contract) as the data is necessary to provide the services required and/or to respond to requests from the interested party. Giving your Personal Data for these purposes is optional, but indispensable to activate the services provided by the Website, to answer requests or evaluate CVs. With specific reference to the purpose 3.c and the viewing of profiles on professional networking platforms made freely available on the Internet, as mentioned in section 2.b, the lawful basis is art. 6(1)(f) of the Regulation, i.e. the legitimate interest of the holder in verifying the candidate’s suitability for the open position and any potential risks.

For the purposes illustrated in section 3.d, the lawful basis is art. 6(1)(c) of the Regulation (compliance with legal obligations). Once provided, Personal Data must be processed for the Data Controller to comply with legal obligations.

Art. 6(1)(a) of the Regulation (your consent) is the lawful basis for the processing of data for the purposes referred to in section 3.e. In this respect, activities that involve the direct sending of advertising material, direct sales or market surveys and commercial communications in relation to products or services similar to those you purchased, the Data Controller may use your e-mail and mail addresses without your consent, in accordance with and within the limits allowed by art. 130, paragraph 4 of the Italian Data Protection Code and the by the Decision of the Italian Data Protection Authority of 19 June 2008. The lawful basis for the processing of your data for this purpose is Art. 6(1)(f) of the Regulation (legitimate interest).

5. Disclosure of Personal Data

For the purposes listed in section 3, your Personal Data may be shared with:

1. Parties who typically act as Data Processors, namely: i) persons and/or organisations providing us assistance and counselling services on marketing and communication; ii) persons and/or organisations who assist us in providing certain services (e.g. hosting providers) iii) persons and/or organisations who perform technical maintenance activities (including maintenance of network equipment and electronic communication networks); (collectively, “Recipients”);
2. Persons, entities or authorities to whom Personal Data must be disclosed by virtue of legal provisions or orders given by a competent authority;
3. Parties authorised by the Data Controller to perform activities that are strictly related to the provision of services or for the purposes listed in section 3, who have committed themselves to confidentiality or have legal obligation to confidentiality (e.g. employees).

6. Transfer of Personal Data

Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area. The Data Controller ensures that these Recipients process your Personal Data in compliance with the Regulation. Transfer of Personal Data may be based on an adequacy decision, on Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis. For further information please contact the Data Controller by sending an e-mail to: info@brandnamic.com

7. Retention of Personal Data

Personal Data processed for the purposes referred to in section 3(a-b) will be kept only for as long as strictly necessary to achieve those purposes. In any case, since data is used in order to provide services, the Data Controller will process the Personal Data up to the time allowed by Italian law (art. 2946 of the Italian Civil Code and subsequent amendments). With regard to any CVs submitted through the Website or by e-mail (see section 3.c), the Personal Data will be kept for as long as necessary for the purpose. The Data Controller may contact the candidate again shortly before the indicated deadline to ask for an extension of the retention period.

Personal Data processed for the purposes referred to in section 3(d) will be stored for as long as provided for by applicable laws and regulations.

Personal Data processed for the purposes referred to in section 3(e) will be kept until we have consent; if you do not withdraw your consent, your data will be stored for a time deemed appropriate.

For more information on our data retention policy and criteria, please contact: info@brandnamic.com

8. Your rights

Pursuant to Art. 15 and following of the Regulation, you have the right to obtain access to your Personal Data at any time. You have the right to request from the Data Controller rectification or erasure of your data, as well as to object to and restrict processing of your data in the cases provided for by Art. 18 of the Regulation. You have the right to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format in compliance with Art. 20 of the Regulation.

Requests must be submitted in written form and sent to:info@brandnamic.com

In any case, you also have the right to lodge a complaint with the competent Supervisory Authority (Italian Data Protection Authority) if you consider that the processing of your Personal Data infringes the applicable law, pursuant to Art. 77 of the Regulation.

9. Additional services and external service providers

DialogShift chat application on our website

Our website uses the chat application of DialogShift GmbH, Rheinsberger Str. 76/77, 10115 Berlin. This application processes and stores data for the purpose of web analysis, to operate the chat application and to answer queries.
For the operation of the chat function, the chat texts are stored and a cookie with a unique ID is set - this is used to recognise you as a customer.
A cookie is a small text file that is stored locally in the cache on your device. Using this cookie, our application recognises the device and can retrieve past chat logs. This cookie is stored for 90 days since last use. You can disable the storage of cookies in your browser settings. However, without the use of cookies, the chat function cannot be performed.
The possible disclosure of e.g. name, e-mail address or a telephone number is voluntary and with the consent to temporarily use and store this data for the purpose of contacting you until the end of the contact. This personal data is deleted after 90 days.
The legal basis for data processing is Article 6 (1) lit. F DS-GVO based on our legitimate interest in effective customer support, for statistical analysis of user behaviour and for optimisation purposes of our offers.
DialogShift offers at https://www.dialogshift.com/en/data-privacy for further information on the collection and use of data and on your rights and options for protecting your privacy.

Google Custom Match

Google Customer Match allows advertisers to import their customers’ e-mail addresses onto their AdWords account, and to encrypt them by means of an algorithm. Customer Match then compares the anonymised e-mail address lists in AdWords with the Google database of registered users. This way, targeted ads can be displayed in Google Search, YouTube and Gmail, allowing for the autonomous optimization of campaigns. Based on the uploaded user lists, Google may also monitor clients sharing similar interests.
The Customer Match function allows Google to create a central information source for retargeting purposes (which means that users are sourced on a website and targeted with tailored ads on other websites). As concerns the data supplied by the advertiser, the Customer Match guidelines apply: https://support.google.com/adwordspolicy/answer/6299717?hl=en.
For further information, please refer to the Google privacy policy: https://www.google.com/intl/de/policies/privacy/. Settings concerning personal data and privacy can be changed in Google in the “My account” section: https://myaccount.google.com/intro?hl=dit

Hotjar

When you visit our website, we store the name of your internet service provider, the website from which you accessed our website, the pages of our website you visit and the length of your visit, and information about the device (type of device, operating system, screen resolution, language, country in which you are located, and browser type) you are using during your visit. We collect and store your IP address only in abbreviated form. It is collected and stored anonymously by suppressing the last eight characters so that your full IP address never reaches our servers and we never have access to it.

We process this usage data to make it easier for you to access our services (e.g. to adapt our services to the device you are using) and to detect and prevent misuse. We also process anonymous usage data for statistical purposes and to improve our website.

When you visit a Hotjar-based website, you can opt out of Hotjar collecting your information at any time by going to our opt-outpage and clicking ‘Disable Hotjar’ or by activating ‘Do Not Track (DNT)’ in your browser.

Contact

Hotjar Ltd, Level 2
St Julians Business Centre,
3, Elia Zammit Street
St Julians STJ 1000, Malta, Europe
+ 1 (855) 464-6788
support@hotjar.com

Push Panda

This website uses push notifications from the provider PushPanda. Push notifications are messages that can be displayed on your terminal device without opening the web page or the relevant app.
No personal user data such as IP addresses or the like are stored, which could allow the user in question to be identified. When registering (opt-in) for the notification distribution, only an identification code and the geographical IP information (i.e. an anonymised IP address) of the user will be sent to and stored in the PushPanda.io database. This code is assigned by the respective browser provider (Google, Mozilla, Apple, etc.) and enables the notifications to be sent to the relevant browser later on. Notifications are sent by the browser provider itself. These processing operations are only carried out if consent is given in accordance with Art. 6(1)(a) DSGVO.
If the opt-in for push notifications is withdrawn (opt-out), all data stored at PushPanda will be deleted and the identification code will become invalid. For information about the opt-out process for push notifications, click here/. PushPanda.io is a service provided by Project K GmbH, located in Innsbruck, Austria.

ADDITIVE+ LANDINGPAGE - Online Marketing and Landing Pages

Beside our website we do also operate optimized landing pages for means of hotel online marketing. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”), our partner in the field of hotel digital marketing. The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
You can prevent the data collection connected to your use of our online services through cookies and the processing of this data by Google, by installing the browser-plugin available at the following link: https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence.
Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. If you continue using the website or click on the respective button you consent to the use of cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.

Guest Pass

• Purpose
  The personal data provided will be transmitted to the single coordinating body of the Guest Pass in order to enable the creation and use of the Guest Pass and to provide the associated services.
• Recipient
  In connection with the issue of the Guest Pass, your data will be transmitted to the Mobilitätskonsortium, VAT Nr. 02735170215, which acts as the cardholder and unified coordinating body and assumes the role of autonomous data controller in processing the transferred data. For further information regarding the processing to which the data will be subjected, you can send an email to privacy@moko.bz.it.
• Legal basis
  The legal basis for processing is Art. 6 (1) (b) of the GDPR.

ADDITIVE+ MARKETING AUTOMATION - Direct Marketing

In order to increase customer loyalty and to sell our services and additional services we use hotel online marketing software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”) within the field of hotel marketing automation.
Therefore your data, which we gather and process in connection with your request, reservation, order, activation, registration or the transmission of other contact forms on our website, will be analysed and used to provide you with automatically generated offers for our services and additional services. Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.
You can deny the use of your data for this purpose anytime by clicking on the “unsubscribe” link in the respective message.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the prevention of competitive disadvantages, the increase in brand awareness and the maximisation of our economic success through an optimal use of the acquired contacts.

Facebook Custom Audiences

Facebook Custom Audiences is a remarketing campaign, which by means of an algorithm, allows the advertiser to encrypt the e-mail addresses of its customers, independently sourced and collected, and to upload this non-personal checksum (hash) onto the Facebook server.
Facebook can thus compare such data with its list of encrypted user IDs, save the matches as "Customer Audiences" (custom target groups) into the advertiser's account, and target the audiences with tailored ads. Once the comparison process is completed, all hashes are deleted.
For further information about the scope of data collection, processing and use through Facebook Custom Audiences, please refer to Facebook’s privacy policy as well as to the following links: https://www.facebook.com/ads/website_custom_audiences/ and https://www.facebook.com/privacy/explanation. The terms of use of Custom Audiences are available at: https://www.facebook.com/ads/manage/customaudiences/tos.php. To withdraw your consent to data collection and use of information for the purpose of targeted online advertisement, please refer to this link: https://www.facebook.com/ads/website_custom_audiences/

Conversion measurement and Custom Audience with the Facebook Pixel:

The Facebook Pixel is a JavaScript code used for tracking and optimising conversions as well as for the definition of remarketing target groups (Custom Audience).
Conversion tracking allows following a user’s path on the website by means of a specific tracking code which is personalised on the basis of target indicators.
The Custom Audience is a targeting option by which the users who visited a website can be reached on Facebook. It is possible to automatically group these users through the specific actions on the website. Such information is forwarded to Facebook via tracking code.
During this process the Facebook ID is also detected. Please be informed that the personal data of each individual user are encrypted locally in the system and remain anonymous to us. Data are thus forwarded securely to Facebook, where they are stored and processed. However, Facebook may link them to your Facebook account and utilise them for its own promotional purposes, in compliance with Facebook’s privacy policy. For further information on Facebook’s data use policy, please visit: https://www.facebook.com/about/privacy/.
The encrypted data are used for matching purposes only; they are not shared with third parties or other advertisers and are deleted immediately upon completion of the matching process.
If you wish to deny your consent to the use of the Facebook Pixel, please visit: https://www.youronlinechoices.eu

ADDITIVE+ NEWSLETTER

On our website you have the possibility to subscribe to our newsletter. For the subscription we need your email address and your consent to receive our newsletter through ADDITIVE, our provider for hotel e mail marketing. To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin in our hotel newsletter tool.
After signing up for our newsletter you will receive an email containing a link to confirm the subscription.
Your subscription can be cancelled any time by clicking on the cancellation link in the respective newsletter.
To process your subscriptions and to send our newsletters we use software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”). Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.

10. Changes

This Privacy Policy takes effect on 09.11.2022. The Data Controller reserves the right to amend or update the content of this policy, in part or in full, especially in the case of changes in the applicable law. Since the content of our Website and Privacy Policy may be subject to change, we recommend you visit this section regularly for updates on how we collect and use Personal Data.