Informativa sul trattamento dei dati personali
pursuant to art. 13 Legislative Decree no. 196 of 30 June 2003 (“Privacy Code”)
Nature of the data being processed and purposes of processing
This information has been prepared in accordance with art. 13 of the Privacy Code by Joinbed s.r.l.s., in relation to personal data provided by users during access or registration on the www.joinbed.com website (“Site”)
1.1. The Data Controller
After consulting this Site, data relating to identified or identifiable persons may be processed.
The “Controller” of the data processing is Joinbed s.r.l.s. with registered office in Corso d’Italia 11, Rome. Registered in the Rome Companies Register under REA number – RM 1401413 tax code/VAT no. 14157021008 e-mail: info@Joinbed.com. In this document, Joinbed s.r.l.s. will be referred to as “Joinbed”, which is the brand name under which it exercises the services provided on the Site.
1.2 The place where data processing is carried out
The processing operations connected to the web services of this Site take place at Joinbed’s office and are handled only by its technical personnel. In case of need, the data connected to the newsletter service can be processed by the Company personnel who maintain the technological part of the www.joinbed.com website at the Company’s headquarters.
Purposes of processing
Joinbed will process the personal data provided by users for the following purposes̀:
(b) for administrative and accounting purposes related to registration on the Site and online bookings, as well as to fulfil legal obligations;
(c) subject to the user’s express consent, for Joinbed to send information and promotional communications relating to the services offered on the Site – including the newsletter informing new beds on the Site, promotional campaigns, discount vouchers and special offers, in relation to own or third-party services, as well as to carry out market research to assess the degree of customer satisfaction, by email and/or the postal service (so-called “marketing” purposes).
(d) limited to the e-mail coordinates provided by the user in the context of the services offered on the Site or, to allow the direct sale of similar products or services without the need for the user’s express prior consent (as provided for by art. 130, paragraph 4 of the Privacy Code) and on condition that the user does not exercise the right of opposition in the ways described in art. 6 d) et seq. (so-called “soft spamming “).
(e) subject to the user’s express consent to processing by Joinbed of their commercial profile, through (i) analysis of information relating to the user, their interests and/or composition of their family unit, voluntarily provided by the user to Joinbed or at the time of registration on the Site and/or other Sites powered by Joinbed and/or through the “Profile” section of these sites or through other initiatives of the same and (ii) frequency and type of purchases made online, in order to display to the user on the Website personalised offers, provided by the Company or by third parties, as well as, in the event that the user has given consent to processing their personal data for marketing purposes, also for Joinbed to send informative and/or advertising material of specific interest to the user, by e-mail and/or the postal service (so-called “profiling” purposes).
2.1 Credit card data
To make a payment on the Website by credit card, the user must enter confidential credit card information (card number, cardholder, expiration date and security codes). These data will be acquired by the payment service provider who will act as an independent data controller, without passing through the Joinbed server which will therefore not process this data in any way. The data will be acquired in encrypted format and according to the security requirements provided by the Payment Card Industry (PCI) certification. The user can ask through the Site for such data to be saved, but it will be saved directly by the payment service provider and will not be acquired by Joinbed, which will only keep track of the last four digits that make up the credit card number and exclusively to prevent fraud in online payments. The payment service provider uses the Secure Sockets Layer (SSL) protocol.
2.2 Data provided as part of the “Invite a Friend” service
Registered users can pass on information about one or more beds to their friends/contacts by entering their e-mail address. Users must be aware that Joinbed will not store such data after sending the e-mail, except for the time strictly necessary to document that it has carried out the user’s request. To take advantage of this service, users must be able to use the data of their friends/contacts legitimately.
2.3 Sensitive data
Joinbed does not process any sensitive or judicial data of users.
2.4 Data security
The user’s Joinbed account information is protected by a password to guarantee the privacy and security of the user. Joinbed takes all of the security measures and applies the physical, electronic and organisational procedures required by current legislation. In some areas of its website, Joinbed uses standard SSL encryption systems to increase data transmission security. Even if Joinbed does everything reasonably possible to protect your personal data, it cannot guarantee complete security of the data transmitted by users during communication, so Joinbed warmly invites you to take all precautionary measures to protect your personal data when you surf the Internet. For example, users are asked to change their password often, using a combination of letters and numbers and making sure that they use a secure browser.
2.5 IP addresses and log files
Browsing the Joinbed site takes place anonymously, unless the user has previously specified that they want Joinbed to remember the identifier with which they registered and the related password. Joinbed does not collect any user data automatically, including e-mail addresses. Joinbed records the user’s IP address (Internet Protocol, which is the Internet address of the user’s computer) to give an idea of the area of the site that the user visits and the duration of the visit, in compliance with the current legislation on the protection of personal data. However, Joinbed does not link the user’s IP address with other personal information relating to the same person, unless they have been duly informed of its processing and has obtained consent to the processing, and only with respect to registered users of the Joinbed site. Like many other websites with character and content aimed at services, the Joinbed website can use a standard technology called “cookies” to collect information on how the site is used by the user. For more information, the user is invited to consult the following “Cookies” section.
2.7 Data relating to the composition of the family unit
The Host user must provide Joinbed with certain data relating to the composition of their family unit, in particular, the name, gender and date of birth of the spouse or partner and their children. These data will be processed by Joinbed for the purposes referred to in point (a) and (e) of this article.
Provision of data and the consequences of failure to consent to processing
The provision of data for the purposes referred to in points (a) and (b) of art. 2 above is optional. However, since this treatment is necessary to allow registration on the Site and use of the services offered by Joinbed, any refusal by the user to provide the data in question will make it impossible to register on the Site and make use of online services.
With reference to the purposes of the processing referred to in points (c) (so-called “marketing” purposes) and (e) (so-called “profiling” purposes) of art. 2 above, giving consent to the processing of personal data is optional. Failure to give consent will not have any consequence in terms of registering on the Site and/or entering beds and property in the database, or in terms of making reservations on it. It will only have the following consequences:
– failure to consent to the processing of personal data for the purposes referred to in art. 2 (c) above (so-called “marketing” purposes), will make it impossible to receive from Joinbed information and promotional communications relating to the services offered on the Site, including the newsletter for information on new beds, in the case of discount vouchers and special offers, in relation to its own or third-party services, as well as for carrying out market research, also to assess the degree of customer satisfaction, via email and the postal service;
– failure to consent to the processing of personal data for the purposes referred to in art. 2 (e) above (so-called “profiling” purposes) will make it impossible for Joinbed to process the user’s business profile by analysing the information relating to the user, their interests and/or the composition of their family unit, given on a voluntary basis by the user to Joinbed through the Site and/or acquire habits and user preferences, based on detection of the frequency and type of purchases made on the Site, in order to show the user personalised offers, of its own or of third parties, as well as, in the event that the user has given consent to the processing of their personal data for marketing purposes, also for the purpose of sending specific informative and/or advertising material of specific interest to the user.
The user may in any case revoke any consent given for the purposes described in points (c) (“marketing” purposes) and (e) (“profiling” purposes) of art. 2, or oppose processing for the purposes referred to in letter (d) (“soft spamming”) by contacting Joinbed at the address indicated in art. 1 above.
Furthermore, only for the purposes described in point (c) (“marketing” purposes) and (d) (“soft spamming”) of art. 2 above, users can also object to the processing of data concerning them through a special link at the bottom of any promotional e-mail sent by Joinbed. The objection expressed in these ways also extends to sending communications via the postal service.
Scope of data communication
The personal data provided by the user for the purposes described in art. 2 above may be made known to or communicated to the following subjects:
– to the company that sends the newsletters on behalf of Joinbed and other information communications transmitted on behalf of Joinbed;
– to the subjects that manage online payment transactions;
– to all those public and/or private subjects, physical and/or juridical persons (legal, administrative and fiscal consultancy offices), if the communication is necessary or functional for correct fulfilment of the contractual obligations assumed in relation to the services provided through the Site, as well as the obligations deriving from the law;
– to all those subjects (including Public Authorities) who have access to the data pursuant to legislative or administrative provisions.
All personal data provided by users in connection with registration on the Site and/or booking through the Site are not subject to disclosure.
User data will only be stored for the time necessary to guarantee correct provision of the services offered.
In the event of termination of the Website account on the user’s initiative, the data contained therein will be stored for administrative purposes for a period not exceeding three months, subject to any specific legal obligations on the conservation of accounting documentation or for the purpose of public security. In order to close the account, the user must access the “Personal data and password” page of the “Profile” section and select the link in the “profile deletion” paragraph.
In any case, it is understood that personal data will be stored and processed for the purposes referred to in letters (c) (“marketing” purposes) and (e) (“profiling” purposes), referred to in art. 2 above, for the period of time permitted by law and by the provisions of the Italian Data Protection Authority. At the end of this period, Joinbed may ask the user to renew their consent to the processing of their data for these purposes or to make them anonymous and keep them only for statistical purposes.
Right to access personal data
Pursuant to art. 7 of the Privacy Code, the user has the right to:
- a) obtain confirmation of the existence or not of personal data concerning the user and its communication in an intelligible form;
- b) obtain information:
– on the origin of the personal data, on the purposes and methods of processing, on the logic applied in the case of processing carried out with the aid of electronic instruments;
– on the identification of the Data Controller;
– on the subjects or categories of subjects to whom the data may be communicated or who may become aware of the data as a designated representative in the territory of the state, managers or appointees;
- c) obtain:
– updating, correcting or supplementing data about the user;
– the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those which need to be kept for the purposes for which the data was collected or subsequently processed;
– attestation of the fact that the operations referred to in the preceding points have been brought to the attention also as regards their content, to those to whom the data have been communicated or disseminated, except in the event that this is impossible or involves the use of manifestly disproportionate means with respect to the right being protected;
- d) object, in whole or in part:
– for legitimate reasons, to the processing of data concerning the user, even if pertinent to the purpose of the collection;
– to the processing of personal data concerning the user, provided for the purposes of commercial information or the sending of advertising material or direct sales or for carrying out market research or commercial communication.
The above rights may be exercised by request to the Data Controller, at the addresses indicated in art. 1.1. The data subject’s right to object to the processing of personal data for the purposes referred to in art. 2 (c) (“marketing” purposes) carried out through automated methods of contact (email) also extends to traditional ones (post), without prejudice to the possibility for the interested party to exercise this right in part, pursuant to art. 7, paragraph 4 b) of the Privacy Code, i.e. opposing, for example, just the sending of promotional communications through automated tools.
Minors and Privacy
The Joinbed website is not intended for use by anyone under the age of 18. This is why Joinbed asks users for their age when registering.
Third Party Sites
The Joinbed website contains links to other sites. Joinbed does not share users’ personal data with these sites and is not responsible for their practices in relation to the protection and processing of personal data. Joinbed invites users to view the privacy policies of such sites to learn how such third party websites process and collect personal data.
Questions or Suggestions
In the event of questions or concerns regarding the collection, use of the data, or the communication or dissemination of personal data, users can send an e-mail to the following e-mail address: firstname.lastname@example.org
This document was last updated on 05/04/2017