Privacy Policy and Cookie Policy


Version 2.0 (valid from 09.03.2020)

HOLIDAY SERVICE s.r.l. (henceforth “HS” or “Data Controller”), the company operating RESORT TENUTA PRIMERO, is constantly implementing measures to guarantee the privacy of its online users. This policy statement has been written in compliance with art. 13 of Regulation (EU) 2016/679 (“Regulation”) and the Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018 (henceforth collectively “Applicable Law”) in order to inform you about our privacy policy and about how your personal data is handled when visiting our website (; henceforth “Website”). Where necessary and/or appropriate, the statement shall allow you to express your informed consent to the processing of your personal data.
The information and details you provide or which are otherwise acquired through your use of HS’s services (for example, booking requests, enquiries, the purchase of services or products or accessing certain areas of the Website; henceforth “Services”) will be handled in compliance with the stipulations of the Applicable Law and the appropriate confidentiality obligations. In compliance with the Regulation, personal data is handled by HS in accordance with the principles of lawfulness, fairness, transparency, purpose and retention time limitation, data minimization, accuracy, integrity and confidentiality.


  • 1. Data controller
  • 2. Processed personal data
  • a. Web navigation data
  • b. Data provided voluntarily by the data subject
  • c. Cookies
  • 3. Purpose of processing the data
  • 4. Legal basis and compulsory or optional provision of personal data
  • 5. Who may receive your Personal
  • 6. Transmission of personal data
  • 7. Data retention times
  • 8. Rights of data subjects
  • 9. Amendments

1. Data controller
The subject entrusted with processing data through the Website is HS, as defined above. For any information on how your personal data are being processed by HS – including a list of the appointed data processors – you can contact the Data Controller at:

2. Processed personal data
Following access to the Website, we inform you that HS will process personal data, which may comprise identifying data such as your name, an identification number, an online username or one or more elements distinguishing your physical, physiological, mental, financial, cultural or social identity, which may lead to the data subject being identified or made open to identification (“Personal Data”). The Personal Data processed through the Website are as follows:

  • a. Web navigation data
    The IT systems and software used to run the Website automatically acquire certain Personal Data, as transmission of the same is implicit to the use of Internet communication protocols. This type of information is not gathered for the purpose of linking it to identified subjects, but, by its nature, if processed and linked to data held by third parties, could lead to the user being identified. This category comprises data such as IP addresses or the domain names of the computers used by the users connecting to the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to make the request of the server, the size of the file sent in response to the request, the numerical code indicating the state of the response made by the server (complete, error, etc.) and other parameters pertaining to the user’s operating system and type of device being used. These data are used exclusively to obtain anonymous statistical information about Website use and to ensure the site is working properly, as well as making it possible to pinpoint any anomalies or improper use of the site; they are deleted immediately after processing. In the event of unlawful attacks against either the Website or related third parties, these data may be used to identify the guilty party/ies; excepting these cases, the data regarding web contact are deleted within a few days of creation.
  • b. Data provided voluntarily by the data subject
    The voluntary sending of your Personal Data by means of contact forms and requests for availability or reservation trough the Site or via e-mail to addresses indicated on the Site entails the subsequent acquisition of the data communicated to the sender (including your name, surname, e-mail address, any mobile number) as well as the conferral of your consent to receive any reply messages to your requests. The Personal Data supplied in this way are used by HS for the sole purpose of providing the Services, as well as to respond to the requests transmitted and are communicated to third parties only if necessary for that purpose.

    When availing of certain Services offered by the Website, it may happen that you forward third-party data to HS. In this event, you act as independent data controller, and shall be responsible for all the duties and liabilities foreseen by law. As such, on this point you grant us the fullest possible exemption from any protest, claim, request for damages from data processing, etc. that may be made against HS by third parties whose Personal Data have been processed through your using the Website functions in violation of the applicable legislation on personal data protection. NotwitGLtanding this, in the event of you providing or otherwise handling the Personal Data of any third party when using the Website, you hereby declare – and take full legal responsibility for the declaration – that there is a sound legal basis for doing so, in accordance with art. 6 of the Regulation legitimizing processing of the information in question.

    c. Cookies

    Definitions, characteristics and application of the legislation

    Cookies are small text files that the websites visited by the user send and record on their computer/mobile device, so that they can be resent to the same sites the next time the user logs on. It’s precisely thanks to cookies that a website can remember the user’s actions and preferences (such as login details, preferred language, font size, other visual settings, etc.) so that the user doesn’t have to set these preferences again the next time they visit the website, or even when they move to a different page on the same website. Therefore, cookies are used for authentication purposes, to monitor sessions and to memorize the data regarding user activities when browsing a website. They may contain a personal identification code that makes it possible to track the user’s activities within the website for statistical or advertising purposes. While navigating on a website, the user’s computer may receive cookies from websites or web servers other than those used by the website being visited (so-called “third-party cookies”). Some operations may be impossible to perform without the use of cookies, as in some cases they are vital to the technical functioning of the website.


    Various types of cookie exist, with different characteristics and functions, and they may remain on the user’s device for varying length of time: “session cookies”, which are automatically deleted as soon as the browser window is closed, and “persistent cookies”, which stay on the user’s computer until a previously established length of time has elapsed. According to Italian legislation, for cookies to be used, it is not always necessary for the website user to give their express consent. In particular, “technical cookies” – i.e. those used for the sole purpose of completing the transmission of information on an electronic communication network, or to the extent that is strictly necessary to provide a service explicitly requested by the user – are used without express consent. In other words, technical cookies are those which are vital to allow the website to function or in order to carry out the user’s requests.


    Among the technical cookies that do not require express consent in order for websites to make use of them, the Italian Personal Data Protection Regulator (see the edict ‘Identification of Simplified Methods for Informing Users and Obtaining Consent to the Use of Cookies’ published on 8 May 2014 and the subsequent clarifications regarding the same; henceforth simply “Edict”) lists:

    • “analytics cookies”, when they are used directly by the website administrator to gather aggregated statistical information about the number of hits and how users browse the site;
    • navigation or session cookies (for authenticating users);
    • technical cookies, which allow the user to navigate on the site according to a series of selected criteria (e.g. language, products selected for purchase) in order to improve the service provided to the same user.

    For “profiling cookies” on the other hand – i.e. cookies designed to create a profile of the user that are used in order to send commercial messages in line with the preferences shown by said user when surfing the web in general – the express consent of the user must previously be obtained.


    Types of cookies used by the Website and option to (de)select

    The Website uses the following cookies that may be deselected, except for the third-party cookies: for these you will have to refer directly to the relative methods of selection and deselection for each cookie, for which we provide the relevant links:

    • Navigation or session technical cookies which are strictly necessary either to allow the Website to function or to allow you to access content and avail of the requested services.
    • Functional cookies, i.e. those used to activate specific Website functions as well as a series of selected criteria (for example, language) in order to enhance the service provided.

    N.B.: by turning off technical and/or functional cookies, you may render the Website unusable, or certain services or functions provided by the Website may become unavailable or fail to function correctly, therefore forcing you to modify or manually insert certain information or preferences each time you visit the Website.

    • Third-party cookies, i.e. cookies from websites and web servers other than HS’s, used for the purposes of the same third parties. We would like to point out that these third parties, listed below with the respective links to their privacy policies, are generally independent data controllers for the data gathered through the cookies they serve; therefore, you will have to refer to their data processing policies, notices and consent forms (selection and deselection of their respective cookies), as stipulated in the aforementioned Edict. We furthermore inform you that HS does everything in its power to trace cookies on its own Website. These cookies are regularly updated on the table below, where we state with total transparency which cookies are sent directly by HS and what their respective purposes are. As for the third parties who send cookies through our Website, we have provided links to their respective privacy statements below: as mentioned before, the responsibility to inform users and obtain their consent is theirs, as foreseen by the Edict. This responsibility is not only for the cookies sent directly by the third parties, but also to any cookies sent through our Website during utilization of services said third parties avail of. Concerning these cookies, which are sent by service providers to the aforementioned third parties, HS has no control over them, and does not know either their characteristics or purposes.


    Below are the links to the relevant information on third-party cookies:

    A detailed table of the cookies sent by HS through the Website is presented below:

    Cookie settings

    You can block or remove technical and functional cookies (either wholly or partially) by using specific functions provided by your browser. Nevertheless, we inform you that, if you do not authorize the use of technical cookies, it may be impossible for you to utilize the Website, view all the contents and make use of the available services. Blocking technical cookies could lead to certain services or functions provided by the Website being unavailable or failing to work correctly, and you may be forced to amend or manually insert either information or preferences every time you visit the Website.


    The choices you make regarding the cookies used by the Website will in turn be recorded on a specially designated cookie. In certain circumstances, however, this cookie may not work correctly; if this happens, we recommend that you delete or block the unwanted cookies through your browser. If you subsequently use a different device or browser to access the Website, you will have to reset your cookie preferences.


    How to view and make changes to cookies using a browser

    Every browser has functions allowing you to authorize, block or remove cookies (either wholly or partially). For more information on how to set your cookie preferences through your preferred browser, you can consult the relevant instructions below:

    Nome Fornitore Scopo Scadenza Tipo
    CookieConsent Cookiebot Memorizza lo stato del consenso ai cookie dell'utente per il dominio corrente 1 anno HTTP Cookie

    Statistiche (3)

    I cookie statistici aiutano i proprietari del sito web a capire come i visitatori interagiscono con i siti raccogliendo e trasmettendo informazioni in forma anonima.

    Nome Fornitore Scopo Scadenza Tipo
    _ga Google Tag Manager Registra un ID univoco utilizzato per generare dati statistici su come il visitatore utilizza il sito internet. 2 anni HTTP Cookie
    _gat Google Tag Manager Utilizzato da Google Analytics per limitare la frequenza delle richieste 1 giorno HTTP Cookie
    _gid Google Tag Manager Registra un ID univoco utilizzato per generare dati statistici su come il visitatore utilizza il sito internet. 1 giorno HTTP Cookie

    Marketing (4)

    I cookie di marketing vengono utilizzati per tracciare i visitatori sui siti web. La finalità è quella di presentare annunci pubblicitari che siano rilevanti e coinvolgenti per il singolo utente e quindi di maggior valore per editori e inserzionisti di terze parti.

    Nome Fornitore Scopo Scadenza Tipo
    _p_hfp_client_id Elfsight Utilizzato per l'implementazione di piattaforme social sul sito. Consente il tracciamento dell'utente, assegnando un ID specifico all'utente stesso. 1 giorno HTTP Cookie
    ads/ga-audiences Google Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. Session Pixel Tracker
    EappsInstagramFeedCache#Items Elfsight Utilizzato da Instagram per raccogliere informazioni su quali prodotti/eventi potrebbero interessare all'utente, al fine di ottimizzare la rilevanza della pubblicità. Persistent IndexedDB
    eapps-instagram-feed-red-like-time Necessario per l'implementazione della galleria di immagini di Instagram sul sito. Persistent HTML Local Storage

    Non classificati (11)

    I cookie non classificati sono i cookie che sono in fase di classificazione, insieme ai fornitori di cookie individuali.

    Nome Fornitore Scopo Scadenza Tipo
    cookiebar In attesa 29 giorni HTTP Cookie
    eapps-39d69746-aec0-4b16-9e9c-15bd9b76cd08-view-expiration Elfsight In attesa Persistent HTML Local Storage
    IASWGHFVVAUIW Seekda In attesa 1 giorno HTTP Cookie
    KLJIQWJ38ASK Seekda In attesa 1 giorno HTTP Cookie
    kognitiv_session In attesa Persistent HTML Local Storage
    SDLKJWIUDKIJS Seekda In attesa Session HTTP Cookie
    smts.istouch In attesa Session HTML Local Storage
    smts_entrypage In attesa 6 giorni HTTP Cookie
    smts_referrer In attesa 6 giorni HTTP Cookie
    ULTZCTLUCKO67 Seekda In attesa 1 giorno HTTP Cookie
    vmts.istouch In attesa Session HTML Local Storage

    3. Purpose of processing the data
    The reasons for processing your data, with your express consent where necessary, are as follows:

  • a. to allow us to provide our Services;
  • b. to comply with any legal, accounting or taxation obligations.
  • c. sending of promotional and marketing communications, including the sending of newsletters and offers, through automated (email, etc.) and non-automated means (paper mail, telephone with operator, etc.); Please note that the Controller collects a single consent for the marketing purposes described herein, in accordance provision of the Italian Data Protection Supervisory Authority "Linee guida in materia di attività promozionale e contrasto allo spam" of July 4th 2013. At any time you can oppose to the processing of your Personal Data for marketing purposes, and revoke your consent by contacting the Controller at the contact indicated in this statement, without prejudice to the lawfulness of the processing based on consent prior to revocation.

    4. Legal basis and compulsory or optional provision of personal data
    The legal basis for processing your Personal Data for the purposes stated in section 3.a is art. 6(1)(b) of the Regulation, inasmuch as it is necessary to process your data in order to provide our Services and/or to reply to your queries. Providing Personal Data for these purposes is optional, but failure to do so will make it impossible for us to provide our Services.
    The purposes stated in section 3.b constitute legitimate processing of Personal Data under the terms of art. 6(1)(c) of the Regulation. Once you have conferred your Personal Data, GL must process them in order to comply with legal obligations to which it is subject.
    The legal basis of the data processing for the purposes set out in section 3.c is art. 6(1)(a) of the Regulation (the data sub’s consent). For the processing carried out for the same purposes that involve the direct sending of own advertising materials or for the fulfillment of own market research or commercial communications in relation to products or services of the Controller similar to those purchased by the data subject in the past, the Controller may use, even without the subject’s consent, e-mail addresses and post addresses, pursuant to and within the limits permitted by art. 130, paragraph 4 of Legislative Decree 196/2003 and the provision of the Italian Supervisory Authority of 19 June 2008. In such case, the legal basis for the processing of Personal Data is art. 6(1)(f) of the Regulation.
    5. Who may receive your Personal Data
    For the purposes stated in section 3 above, our Personal Data may be shared with:
  • a. a. (i) subjects, who typically act as autonomous data controllers, such as freelancers or firms who provide professional assistance and advice regarding the provision of the Services; (ii) subjects, which act as external data processors and with whom it is necessary to interact for the provision of the Services (for example: hosting providers, cloud services, etc.), or for accessory services, such as accounting management, labor consultants etc. (iii) delegates to perform technical maintenance activities, including maintenance of network equipment and electronic communications networks; (collectively "Recipients");
  • b. b. natural persons, organizations or authorities to whom we must forward your Personal Data in order to comply with the relevant legislation or with specific orders;
  • c. c. individuals authorized by HS to process Personal Data when strictly necessary in order to provide the Services; these individuals have previously committed to maintain confidentiality or have a legal obligation to maintain confidentiality (e.g. employees of GL).
    6. Transmission of Personal Data
    Your Personal Data will not be shared with any Recipients outside the European Economic Area

    7. Data retention times
    The Personal Data processed for the purposes stated in section 3.a will be stored for the necessary time it takes to complete the requested operations. As this data processing concerns the provision of Services, HS also retain your Personal Data for the time permitted under Italian Law for the defense of own rights (art. 2946 Code of Civil Law).
    The Personal Data handled for the purposes stated in section 3.b will be stored for the time permitted by the specific disposition or applicable law.
    Personal Data processed for the purposes referred to in section 3.c will be retained until the revocation of the consent by the subject, or in the absence of such revocation, for a maximum time considered appropriate by the Controller.
    You can request further information on data retention times and the criteria adopted to establish these times by writing to the following address:

    8. Rights of data subjects
    Under the terms of articles 15 onwards of the Regulation, you have the right to ask HS at any time to allow you to access your Personal Data, to make amendments to or delete them wholly or in part, object to their being processed; also the right to request restrictions to their processing in the cases foreseen by art. 18 of the Regulation, and to obtain the data pertaining to you in a structured, commonly recognized and legible form from an automatic device in the cases foreseen by art. 20 of the Regulation. At any time, you may revoke, the consent already given according to art. 7 of the Regulation, without prejudice to the lawfulness of the processing carried out prior to the withdrawal of consent. Requests of can be sent to the following address:
    In any case, you always have the right to file a claim with the relevant Supervisory Authority (in Italy: Garante per la protezione dei dati personali), under the terms of art. 77 of the Regulation, in the event that you believe your Personal Data have been processed in violation of the Applicable Law.

    9. Amendments
    HS reserves the right to amend or simply update the contents of its privacy policy, either partially or entirely, for reasons which may include changes to the applicable legislation. You will be informed of any such changes through publication on the Website. Therefore, HS invites you to consult this section regularly in order to familiarize yourself with the most recent and up-to-date version of the privacy policy; this way you will always be adequately informed about the data gathered and how they are used.

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. 
To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin. 
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 an adequacy decision taken by the European Commission (“Privacy Shield”) or on data processing agreements.

On our website you have the possibility to buy vouchers. To process your purchase and to save and store your data 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 an adequacy decision taken by the European Commission (“Privacy Shield”) or on data processing agreements. 

The data you provide is required to fulfil the contract or to carry out pre-contractual measures. Without this data we cannot conclude a contract with you. The data will not be transferred to an outside third party, except for your credit card data which will be transferred to the payment provider and to our tax accountant to fulfil our tax obligations.

The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) and/or lit b (processing necessary for the performance of a contract) of the GDPR.