Privacy Policy
This information is provided in accordance with GDPR 679/2016 “General Data Protection Regulation” and DPL “Federal Law on Data Protection”, containing provisions regarding the processing of Personal Data.
This Privacy Policy describes the privacy procedures adopted by LEOPOLDO HOTELS & RESTAURANTS SA for the collection of data:
• when you browse the website we operate, which links to this Privacy Policy (hereinafter referred to as Website);
• from the social media pages we control, which link to this Privacy Policy (hereinafter collectively referred to as Social Media Pages);
• from emails we send out that contain a link to this Privacy Policy or from online or face-to-face communication;
• when you visit or stay in our hotel.
Our Website and Social Media Pages are hereinafter referred to collectively as “Online Services”.
1. Data Controller
For the processing purposes detailed in point 3, the Data Controller is LEOPOLDO HOTELS & RESTAURANTS SA with registered office in DOT LIFE SA in Via Tesserete 10, 6900 Lugano.
2. Data Processed
Browsing Data
During normal operations, the computer systems and software procedures necessary for the running of this website collect Personal Data, transmission of which is implicit in the use of Internet communication protocols.
This category includes the IP addresses or domain names of the computers you use to connect to the Website, URI (Uniform Resource Identifier) addresses, time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to your operating system and computer environment.
These data are also necessary for use of the web service. These data are also used solely for the purpose of collecting anonymous statistical information about site use and to check its correct functioning.
a. Data collected from online or hotel check-in
From contact or compilation of forms on our Website, we may collect Personal Data that include: personal and contact details; payment details such as the number and other information on a credit card; information regarding other services/products provided.
During check-in at our hotel, we may collect further Personal Data by, for example, scanning ID (identity card/passport). In addition to the above information, we may also use CCTV cameras, viewing or recording images of guests and visitors in some public areas to ensure the safety of our guests, staff and hotel.
b. Data collected from Meetings & Events
We may collect Personal Data from information provided on these occasions such as name, surname, email, company (where applicable) and any further information that you enter in the “message” field.
c. Data collected from the “Book a table” section
We may collect Personal Data from information provided in this case such as name, surname, email, telephone number and any further information you enter in the “message” field, including information relating to intolerances and/or allergies.
d. Links to third-party websites and services
Our Website may contain links to third-party websites. LEOPOLDO HOTELS & RESTAURANTS SA is not responsible for the processing of Personal Data and information by these third parties. If you provide information on third-party websites, the Personal Data protection provisions and terms of use of the services on these third-party websites shall apply, which we encourage you to read.
This Privacy Policy does not, therefore, apply to the privacy, data or procedures not belonging to LEOPOLDO HOTELS & RESTAURANTS SA and we accept no liability in this regard.
Neither do we accept any liability regarding the collection, use, disclosure, or data security policies and procedures of other companies such as Meta, Google, or any other application developer or provider, social media platform provider, operating system provider service or wireless device provider, also including Personal Data you provide to other companies on our social media pages.
e. Personal data we collect from client service/email/telephone bookings and third parties
• We collect Personal Data when you make a telephone booking, send us an email or contact our booking service.
• We may also collect personal information about you from third parties, including our social media services in accordance with your service settings (e.g. WhatsApp, FB, Instagram, etc.) and from our partners (airlines, travel agencies, etc.).
• If you send or communicate the Personal Data of other people to us or to our suppliers (for example, if you make a booking for another person), you confirm you are authorised to do so and authorise us to use said data in accordance with this Privacy Policy.
• Online Services: we collect Personal Data when you interact with our Online Services, for example but not limited to, browsing, making bookings, purchasing goods and services from our Websites, sending us messages, contacting us or posting on social media, signing up for a newsletter or taking part in surveys, competitions or special offers.
• Internet-connected devices: we collect Personal Data (e.g. contact details) from devices connected to the internet in our hotel. For example, when you connect your device to the hotel Wi-Fi network.
3. Purposes of Processing
We use Personal Data in a variety of ways, as detailed below:
I. In order to comply with the Data Controller’s legal, administrative, accounting and tax obligations;
II. To manage and follow through online, telephone and email bookings;
III. To manage reception and services related to stays in our hotel: check-in and check-out, payment processing; personalised services in the hotel (spa, babysitting, etc.); concierge services, luggage storage and parking; arrangements with third parties on behalf of guests (e.g. taxis, car rental, restaurant reservations, etc.); Wi-Fi access, TV and other connectivity and entertainment services; room service; to handle guests’ dietary restrictions, food intolerances and disabilities; housekeeping and dry cleaning; clients’ complaints; to inform third parties of guests’ presence in the hotel to allow operators to forward messages and phone calls during their stay.
IV. To manage conferences and events;
V. To collect information about guests’ stays in our hotel and carry out statistical processing of the aggregate data;
To identify and assess your preferences, tastes, consumption choices and habits to help us deliver increasingly more personalised products and services tailored to your needs; we may take note of anniversaries or birthdays to provide you with a gift or special offer to mark these occasions; we might keep track of your preferred activities or regularly requested services, to make sure we can offer you similar experiences on your next visit;
VI. To send advertising, direct sales, market research and commercial communications using traditional means (postal services, operator calls) or automated means (SMS, MMS, automated calls, newsletters), direct marketing; Based on the regulations in force, the Data Controller may use the email details provided when acquiring one of our services and/or benefits to suggest similar services and benefits. However, should you wish not to receive this kind of communication, you may notify the Data Controller at any time, using the link in the emails received. The Data Controller will, in this case, immediately discontinue these notifications.
VIII. To handle guests’ requests, questions and complaints.
4. Communication and Transfer of Personal Data
Your personal data may be communicated to third parties who provide outsourcing services (e.g. web hosting, direct/booking, data analysis, emailing, marketing, etc.) to the Data Controller and who act as contracted or appointed Data Processors. You can request an updated list of Data Processors at any time.
Your data will only be processed for the purposes mentioned at point 3 above, by personnel officially authorised to process Personal Data who have undertaken an obligation of confidentiality.
5. Lawful Basis for Processing
Each processing of your Personal Data is justified by one of the following legal prerequisites:
Pre-contractual/Contractual: Processing is necessary to execute a contract between the parties.
Legal obligation: Processing is necessary to fulfil a legal obligation.
Legitimate interest: Processing is necessary for the pursuit of the legitimate interest of the Data Controller, provided that the interests or fundamental rights and freedoms of the User, which require protection of Personal Data, are not overriding.
Consent: Processing is only possible if you have given your consent for specific purposes. In this case, you may revoke your prior consent at any time by contacting the Data Controller as explained in article 7.
6. Data Processing and Storage Methods
When processing your Personal Data we follow continually updated technical and organisational security measures to prevent accidental loss, unauthorised use or access, alteration or disclosure.
Your personal data are retained only as long as is needed to fulfil the purposes for which they were collected and to satisfy any legal, accounting or reporting requisites.
Your Personal Data are retained for a maximum of 24 months, unless otherwise obliged by law.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the same, the potential risk or harm from unauthorised use or disclosure of the same, the purposes for which we process the personal data and whether we can achieve these purposes by other means and applicable legal requisites.
All the Personal Data are stored in electronic format on servers in Switzerland and the EU.
Should it be necessary, the Data Controller may transfer the data outside Switzerland and the EU. In this case, the Data Controller ensures with immediate effect that transfer of the data shall comply with any applicable legislation.
7. Data Subject Rights
Concerning the processing detailed above, you may request confirmation at any time as to whether or not your Personal Data is being processed and, in this regard, you have the right to:
• request access to the data to obtain information regarding the purposes of the processing, recipients to whom the data may be disclosed, the duration of the processing (where possible) and possible consequences of processing based on profiling.
• revoke your consent at any time, without prejudice to the lawfulness of processing based on consent given before the revocation;
• request rectification of your Personal Data should these be inaccurate or incomplete;
• request the deletion of your data should these no longer be needed by the Data Controller or be inadequate for the intended processing purposes, or if you have revoked your consent or the data have been processed illegally;
• request the limitation of data processing, in the cases provided for by law;
• request transfer of your data to another Data Controller, in a commonly used, machine-readable format, without impediment from the current Data Controller;
• object to the processing of your data and, specifically, you have the right to object to decisions concerning yourself if these are based solely on automated processing of your data, including profiling;
• contact the competent authority if you believe that processing of your Personal Data violates current data protection legislation.
To request further information on processing of your Personal Data or to exercise your rights you can:
• write to: LEOPOLDO HOTELS & RESTAURANTS SA, c/o DOT LIFE SA in Via Tesserete 10, 6900 Lugano
• by sending an email to: privacy@dotlife.swiss
8. COOKIES
For information regarding the use of cookies on this Website, please read our cookie policy.
9. Changes to this Privacy Policy
The Data Controller reserves the right to amend or simply update the content of this Privacy Policy, in part or in full, also as a result of changes in applicable legislation. These amendments will be binding as soon as they are published on the Website. If you continue to access or use the service after said publication, it will be assumed that you have accepted these changes. The Data Controller therefore invites you to visit this section regularly to ensure you are familiar with the most recent and updated version of our Privacy Policy, the data collected and how they are used by the Data Controller.
