Privacy Policy

Dear User, pursuant to

– European General Data Protection Regulation No. 679/2016
– Legislative Decree No. 196 of June 30, 2003

we inform you that:

– The Data Controller is LG HOTELS COLLECTION S.R.L. (Europa Palace), hereinafter Europa Palace, with registered office at Via Roma 187, 18038 Sanremo, and operational headquarters at Corso Imperatrice 27, 18038 Sanremo.
The Data Controller’s Legal Representative and the Data Protection Officer (DPO) can be contacted at privacy@europapalace.it.

User privacy is important to Europa Palace. This privacy policy is intended to provide information to all customers who visit the website www.europapalacesanremo.com, other associated websites, or applications that are subject to this policy/Europa Palace.
Given that: By using any of our products or services and/or accepting this Policy, for example, when registering for one of our products or services, you consent to the collection and use of Personal Information as described in this Policy.
In every contact or interaction with guests and in all other aspects of our business, we may collect personal information.
We may request the details of companions, including names, and data necessary for legal identification. We may also collect information related to conversations, including recording or monitoring calls to Europa Palace and other communications, such as in-app messages and SMS, emails, and chats.

In addition to the information collected directly from you, we may also obtain information about you from third parties/services/marketing partnerships, including disclosure to third parties if necessary for the provision of the service. Providing and consenting to data collection is optional, and the user may deny or revoke consent at any time, even if already granted. Denying consent, however, may prevent the provision of certain services or impair the browsing experience.
“Personal data” is information relating to an identified or identifiable individual.

Surveys: We may request demographic or other personal information in guest surveys.
On-Property Collection: We collect additional personal information during registration/check-in at Europa Palace, including information required by local laws. At Europa Palace, we may also use CCTV and other security measures that can view or record images of guests and visitors in common areas, as well as information related to your location on our property (through cards and other technologies). We may also use CCTV and other technologies that can record audio or video to protect our staff, guests, and visitors to our property, where permitted by law. Additionally, we may collect personal information related to the services available on the property, such as concierge services, wellness centers, spas, activities, babysitting services, equipment rentals, and key card functionality.

Event Profiles: If you plan to organize an event with Europa Palace, we will record the event/meeting details, date, number of guests, guest room details, and, for corporate events, information about your organization. We also collect information about guests in your group/event. If you visit us as part of a group, we may request your personal information from the group and may send you marketing information following your stay with a group or event, based on your preferences and as required by law. If you visit us as part of an event, we may share your personal information with event planners as required by law. If you are an event planner, we may also share your event information with third-party service providers who may send you marketing information about event services as required by law.

Social Media: If you choose to participate in social media offers/activities/events sponsored by Europa Palace, we may collect certain information from your social media profiles, consistent with your settings within the social media service, such as location, check-in, activities, interests, photos, status updates, and friends list. We may also allow you to enter contests to provide photos, such as those of your stay with us, which you may share with your social media contacts to receive votes, shared offers, or other promotions.

Send/Invite a Friend: From time to time, we may offer a feature that allows you to send an e-card or message to a friend online, from a standalone kiosk, or from a mobile device, or via email with offers, promotions, or informational materials we’ve sent you.
If you choose to use this feature, we’ll ask you for the recipient’s name and email address, along with any text you choose to include in the message. By using this feature, you represent that you are authorized to use and provide us with the recipient’s name and email address for this purpose.

Security: Europa Palace uses your email address to send you important security information or material changes to this Privacy Policy. The name you provide is associated with your email address and is displayed when you submit comments or other materials.

WiFi Connection: Europa Palace uses the email address and name you used when registering to access the WiFi service. This information may subsequently be used by Europa Palace for marketing purposes, and the connection service provider may store this information for security purposes as required and protected by local regulations.

Marketing Consent: If you provide explicit consent to receive marketing information from Europa Palace, we will also process your email address to send you marketing information about potential promotions and offers. The legal basis for processing your email address for this purpose is your consent. You can withdraw your consent at any time by sending an email to privacy@europapalace.it.
Personal data processed when subscribing to the newsletter: When registering for the newsletter, you will be asked to provide your email address and name. You can choose to provide only your first name or a pseudonym instead of your full name if you wish. All this information is made available to Europa Palace by the social media provider due to the way your social media registration is configured. However, Europa Palace only stores and processes this information, including your email address. If you do not want your information shared with Europa Palace via your social media provider, simply log in to your social media account and adjust your privacy settings.

Personal data processed when you communicate with Europa Palace: When you interact with our customer service representatives via email, telephone, online, or in person, we may collect personal information, such as your name, postal address, telephone number, email address, and contact preferences, as well as information about Europa Palace offers and promotions. We may also create event logs and analyze any feedback you voluntarily provide through customer surveys.

Personal data processed when you purchase a stay, promotion, or event on the Europa Palace website: If you purchase a stay, promotion, or event on the Europa Palace website, Europa Palace will collect your name, email address, and telephone number.

Europa Palace may also collect information about you from third parties, including information from social media services consistent with your settings on those services, and from other third-party sources legally authorized to share your data with us. We use and share this information (and may combine this information with other information we already have about you) for the purposes set out in this Policy.

We use your personal information in a variety of ways, including to provide and personalize the services you request and expect from Europa Palace, to offer you the level of hospitality you expect from Europa Palace, and to conduct direct marketing and sales promotions, as described in more detail below:

Service Management: We use your personal information to manage the programs/events/promotions you participate in, for example, and the offers for which you are eligible; to ensure the provision of the services included in that program/event/promotion;
Meeting and Event Planning: We may use your personal information to communicate with you regarding the planning of programs/events/promotions.

Marketing and Communications: Where permitted, we may use your personal information to provide or propose newsletters, promotions, and special offers, as well as other marketing messages in accordance with any communication preferences you have expressed. We use your information to provide you with in-stay messages, account-related alerts, and booking confirmations; To send you marketing messages; and to conduct surveys, contests, prize draws, and other similar initiatives. We may provide these communications to you via email, regular mail, online advertising, social media, telephone, text messaging (including SMS and MMS), push notifications, in-app messaging, and other means (including communications at Europa Palace, such as your in-room TV). With your consent, we also use user-generated content, such as photographs, via social media services to provide on-screen advertising or on our websites and apps.

Service improvements: We may use your personal information to improve Europa Palace’s services and to ensure our website, products, and services are of interest to you. We also use your personal information to provide you with the level of hospitality you expect at our property. This may include providing you with the ability to control in-room technology via our website or apps from your personal devices.

Electronic receipt program: We may enroll you in our electronic receipt program and use your email address to email you your property bill. It is your responsibility to ensure that the email address we have on file is correct (and preferred). If you make a reservation for someone else using your email address, the electronic receipt for that person will be sent to your email address.

Data accuracy, analysis, and personalization: We may combine your personal information with data from third-party sources for information updating and analysis purposes. We also rely on third-party information to provide you with a better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personalized and social, or to share and use it as described elsewhere in this Policy.

In order to provide you with the expected level of hospitality and the best possible service, we may share your personal information with our service providers and other third parties as detailed below:

Electronic Billing Program: If you receive an electronic receipt/invoice via email, a summary of the goods and services provided to you during your stay will be sent to your payment card provider, and your payment card provider may forward this summary to your employer or any email address you provided when registering your card with your bank. All information will be managed and stored by your credit card provider/manager.

Group Events or Meetings: If you visit or are a guest at Europa Palace for an event or meeting, the information collected for the planning of that event or meeting may be shared with the organizers and, if appropriate, with guests organizing or attending the event or meeting.

Business Partners: We may partner with other companies to provide you with products, services, or offers based on your experiences at our properties and share your information with our business partners accordingly. For example, we may receive assistance from our business partners for equipment rentals or other services and share your personal information with them to provide you with the requested services. We may also share your personal information, such as your email address, with our travel/event partners to help them assess travel policy compliance or participation in special rate plans, or to implement co-branded marketing initiatives with our corporate and non-corporate travel partners.

On-Property Services: We may share personal information with third-party service providers at our properties.

Service Providers: We rely on third parties to provide services and products on our behalf, and we may share your personal information with them if necessary. Generally, our service providers are contractually committed to protecting your personal information and may not use or share it unless required by law. We may use service providers to deliver news and provide you with promotional and transactional materials on our behalf, including personalized online and mobile advertising, in accordance with your preferences and applicable law. Please see our Cookie Policy for more information. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists we have customized for you based on your preferences and third-party data.

Business Transactions: In the course of conducting our business, we may sell, buy, modify, or reorganize businesses or assets. In such circumstances, Europa Palace may transfer, sell, or assign the information collected, including, without limitation, Other Information (as described below) and personal information in connection with these business transactions, to one or more affiliated or unaffiliated third parties.

Other: Additionally, Europa Palace I may disclose personal information to:
– comply with applicable laws,
– respond to government or public authority requests,
– comply with valid legal process,
– protect the rights, privacy, safety, or property of Hotel Ramon, site visitors, guests, employees, or the public,
– allow us to pursue available remedies or limit the damages we may sustain,
– enforce the terms and conditions of our websites, and respond to an emergency.

When you visit and interact with Europa Palace websites and apps, we collect other information that does not directly identify you about your use of the site, such as the pages you visit and the number of visits to our site. We use this Other Information, as well as data received from third parties, to provide you with advertising via email, online (on our and other sites), and mobile, or to use the remarketing feature, recognizing you as a visitor to our site on other websites. We use cookies and other technologies (such as pixel tags, web beacons, clear GIFs, links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect this information. If you want to remove or block Cookies on your device at any time, you can update your browser settings (see your browser’s “Help” menu to learn how to remove or block Cookies). Europa Palace is not responsible for your browser settings. You can find simple, valid instructions on how to manage cookies on different browser types at www.allaboutcookies.org. We may use information we have collected or aggregated, or anonymized personal information received from third parties, to better understand our users (for example, we may use aggregated information to calculate the percentage of our users with a particular telephone area code). This includes demographic data, such as date of birth, gender, and marital status, inferred business interests, such as favorite products or hobbies, and other information we may collect from you or third parties. Because Other Information does not personally identify you, this information may be disclosed for any purpose where permitted by law. In some cases, we may combine Other Information with personal information. If we combine personal information and Other Information, this data will be treated as personal information, as set forth in this Policy.

The term “confidential information” means information about your race or ethnic origin, political opinions, religion or other beliefs, trade union membership, health, sexual life or orientation, genetic information, criminal history, and biometric data used for unique identification. We generally do not collect confidential information unless it is provided voluntarily by you. We may use the health data you provide to us to provide you with better service and meet your specific needs (for example, by providing special access measures for people with disabilities).

The Europa Palace websites and apps are not intended for children under 18 unless they are under the supervision of their parents or legal guardians. If Europa Palace becomes aware that it has collected personal information from users under 18, it will take steps to delete such information as soon as possible.

Europa Palace will take appropriate measures to: protect personal information from unauthorized access, disclosure, alteration, or destruction; ensure that personal information is accurate and up-to-date. We also seek to require affiliates and service providers with whom we share personal information to commit to maintaining the confidentiality of such information. For online transactions, we take reasonable technological measures to protect the personal information transmitted through our website. However, unfortunately, no security system or data transmission over the Internet can be considered completely secure.
For your privacy, we remind you not to send us your payment card numbers or any other sensitive personal information via email.
We will not contact you by mobile phone, text message, or email to request your confidential personal information or payment card details.
We will only ask for your payment card details over the phone when booking a stay or promotional package.

To the extent required by applicable laws, you may request to be informed about how we handle your personal information and, where appropriate, request that we update, correct, and/or delete the personal information we maintain in our active database. We will make all requested updates and changes within the timeframe specified by applicable laws and, if permitted by law.

Such requests must be sent in writing to privacy@europapalace.it

To protect your privacy, we will only respond to such requests through the email address you registered with or provided to us. Please be aware that if you make such a request, we may not be able to guarantee you the same quality and variety of services you are accustomed to.

We retain personal information for the period of time necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by applicable law. We will destroy your personal information as soon as practicable and in such a manner that the information cannot be restored or reconstructed. If stored in paper format, personal information will be destroyed securely, such as using a paper shredder or incinerator for paper documents or otherwise; if stored in electronic format, personal information will be destroyed using technical measures to ensure that the information cannot be restored or reconstructed at a later date.

If you reside in the European Union, under the General Data Protection Regulation, you have the right to request from Europa Palace access to, rectification, or erasure of your personal data, data portability, restriction of processing, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside the European Union, you may have similar rights under local laws.

To request access to, rectification, portability, or erasure of your personal data, please contact Europa Palace by email at privacy@europapalace.it