1. Contact Forms and Business Inquiries
The Data Controller processes personal data voluntarily provided by users through the contact forms available on the Website, including forms intended for the submission of accommodation properties, collaboration requests, requests for information, and any other communications sent voluntarily by the user.
Depending on the form completed, the categories of data processed may include: first and last name, property name, property type, location, website, email address, telephone number or WhatsApp number, as well as any additional information freely entered by the user in the message.
Such data are processed for the following purposes:
- responding to requests submitted by the user;
- providing information about the services offered by the Website;
- evaluating collaboration proposals, applications, or property submissions;
- initiating any pre-contractual or commercial contact.
The provision of data marked as required is necessary in order to submit the request and receive a reply. Failure to provide the requested data may make it impossible to follow up on the communication.
2. Booking Requests, Participation in Tours, Events and Experiences
The Data Controller also processes personal data provided by users in connection with requests relating to bookings, guided tours, events, experiences, stays, or other activities promoted, presented, or featured through the Website.
Depending on the specific case, the categories of data processed may include: first name, last name, email address, telephone number, country of origin, requested date, number of adult and child participants, any preferences or special requirements, as well as any other information voluntarily provided by the user.
Such data are processed for the following purposes:
- handling the user’s request and providing a reply;
- verifying availability, conditions, and organizational arrangements for the requested service;
- sending confirmations, operational communications, updates, or information related to the request;
- coordinating, where necessary, the request with accommodation properties, venues, partners, collaborators, or suppliers directly involved in managing the requested service;
- fulfilling any administrative, organizational, or contractual obligations connected with the management of the request.
Where the user requests information, availability, or bookings relating to services offered by third parties, the data may be disclosed to the parties strictly involved in handling the request, solely to the extent necessary to process it.
3. Newsletter and Informational or Promotional Communications
If the Website allows the user to subscribe to the newsletter or receive updates on content, events, experiences, selected properties, editorial news, or initiatives promoted by the Data Controller, the relevant personal data will be processed for the purpose of sending informational, promotional, or commercial communications.
Depending on the service, the categories of data processed may include first name, email address, and any additional data that may be requested by the subscription form.
The legal basis for this processing is the freely given consent of the data subject.
Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before the withdrawal, by using the unsubscribe link, where available, in the communications received, or by contacting the Data Controller using the contact details provided in this notice.
The provision of data for newsletter purposes is optional. Failure to provide such data does not in any way affect browsing of the Website or the possibility of sending requests through the other available forms.
Recipients of Personal Data
For the purposes indicated above, personal data may be processed by persons authorized by the Data Controller and by third parties acting on behalf of the Data Controller as data processors or, where applicable, as independent data controllers.
In particular, the data may be disclosed to the following categories of recipients:
- providers of technical, IT, and infrastructure services related to the operation of the Website;
- providers of hosting, maintenance, security, email management, data storage, and form management services;
- collaborators, consultants, professionals, or persons engaged by the Data Controller for administrative, organizational, tax, or legal activities, within the limits strictly necessary;
- accommodation properties, venues, partners, collaborators, or external suppliers involved in handling requests for availability, bookings, visits, events, or other services requested by the user;
- providers of newsletter services, communication tools, contact management systems, or organizational platforms used by the Data Controller.
Personal data will not be disclosed indiscriminately.
The updated list of any data processors may be requested at any time by contacting the Data Controller using the contact details provided in this notice.
Data Retention Period
Personal data are retained for no longer than is necessary to achieve the purposes for which they were collected, in compliance with the principles of data minimization, storage limitation, and proportionality.
In particular:
- data submitted through contact forms, requests for information, or business inquiries will be retained for the time necessary to handle the request and, in the absence of further developments, for a maximum period of 12 months from the last contact;
- data relating to collaboration requests, property submissions, or professional communications may be retained for a maximum period of 12 months from the last contact, unless a subsequent contractual or pre-contractual relationship is established;
- data relating to booking requests, visits, events, experiences, or similar services will be retained for the time necessary to handle the request and, subsequently, for a maximum period of 24 months, unless further retention is required due to legal obligations, documented organizational needs, or the protection of the Data Controller’s rights;
- data processed for newsletter or promotional communication purposes will be retained until consent is withdrawn and, in any event, for no longer than 24 months from the user’s last significant interaction, unless consent is renewed or another legal basis legitimizing the processing applies;
- data may be retained for a longer period where this is necessary to comply with legal obligations, comply with orders of authorities, or establish, exercise, or defend a legal claim.
Once the applicable retention period has expired, the data will be deleted or anonymized, except where their further retention is permitted or required by applicable law.
Nature of the Provision of Data
The provision of personal data requested in the forms available on the Website is generally optional. However, failure to provide the data indicated as necessary may make it impossible for the Data Controller to respond to the request, provide the requested information, follow up on a collaboration proposal, manage a booking, or allow access to specific services offered through the Website.
The provision of data for promotional or newsletter purposes is always optional and, where required, subject to the data subject’s consent.
Personal Data processed for the following purposes and using the following services
Traffic optimization and distribution
Google Hosted Libraries
Personal Data: Usage Data; Tracking Tools
Protection from spam and bots
Google reCAPTCHA
Personal Data: clicks; Usage Data; keypress events; motion sensor events; touch events; mouse movements; scroll position; responses to questions; Tracking Tools
Analytics
Google Analytics 4
Personal Data: Usage Data; number of Users; session statistics; Tracking Tools
Displaying content from external platforms
Google Fonts
Personal Data: Usage Data; Tracking Tools
Contact Information
Data Controller: Soluzioni Web di Olga Ilchenko
Piazza Castelnuovo 26/A
Palermo – 90141
Italy
Data Controller’s email address: info@sicilyluxury.com
