RHA TERMS & CONDITIONS AND RHA PRIVACY POLICY

RHA Terms and Conditions

These RHA Terms and Conditions (“RHA T&C” or “T&C“) apply to users/visitors of the RHA Site and the Social Web and, in general to current and potential customers (“Guests“) of Roman Holiday Accommodation by Paolo Marroccu (“RHA“). T&C are accepted by Guests when they use/make use of the RHA Services.

ANIMALS.

Pets and animals are not allowed inside the RHA Holiday Homes.

WEAPONS.

No weapons are allowed inside the RHA Holiday Homes. Here is a non-exhaustive list of what can be considered a weapon: firearms, air guns, fake firearms and any mechanism that can be used to shoot a bullet, daggers, self-defense devices or deterrents like taser or pepper spray, ammunition of any kind, bombs and explosives.

RHA EQUIPMENT.

Guests are required to use the diligence of the good father with reference of the household appliances, linen, pots and other equipment made available during the stay (appliances, linens, pans, etc. jointly “RHA Equipment” and separately “Equipment RHA “). In case of theft, breakdown, damage, loss of the RHA Equipment, we will be obliged to charge the cost of the relative repair / replacement to the Guests to which it is attributable, without prejudice to the greater damages. At this regard please read carefully the List of RHA Equipment.

RHA HOLIDAY HOME.

Your RHA Holiday Home is located in a historic building that houses other families (“Historic Building“); Guests are therefore required to respect it and treat it as you would take care of their own home and that of relatives and friends, to ensure a serene, orderly and peaceful coexistence with everyone. Any activity that could damage the RHA Holiday Home, the Historic Building and/or disturb the condominium and/or third parties is forbidden. The RHA Staff reserves the right to access the RHA Holiday Home by prior arrangement with the Guests, or at any time and without notice in case of imminent risk, danger, maintenance, requests of the Police or the condominium administrator. Guests are required to lock the RHA Holiday Home when they leave and during night time.

CHECK-IN.

At check-in it is requested the payment of the eventual balance of the RHA Services and of the Tourist Tax (see the relative entry here below). You can pay the balance in cash or by credit card, bank transfer or PayPal. The Tourist Tax can only be paid in cash. The following information must be communicated no later than one week before the date of arrival:

estimated arrival time at the apartment
how you arrive in Rome: train, car, plane, etc.
if you arrive by plane, please provide the flight details: air company, flight numbers, arrival and departure time and airport
if you arrive by train, please provide: arrival and departure train station and time, arrival train station and time,
if you arrive by ship, please provide: the arrival port and time, the name of the ship and the shipping company
details on how you arrive from the station to the apartment (bus, metro, taxi, on foot, etc)

In case of failure to provide the information above we may not be able to receive you at the RHA Holiday Home and deliver you the keys at your arrival.

Check-in and key collection takes place directly at the RHA Holiday Home. Self-check-in can be arranged in some circumstances. You are required to contact RHA at least 2 hours before your arrival to arrange an appointment for the check-in unless you have arranged your arrival through a Third Party Service. The person in charge of the reception will go to the apartment only after receiving your call/message.

Check-in is any time after 2:00 p.m of the arrival day. It may occasionally happen that the RHA Holiday Home is available after 14.00 (e.g. because of strikes, demonstrations or in case a particular cleaning is required). If the RHA Holiday Home is not ready and available, you can leave your luggage inside the RHA Holiday Home or other neighboring place (see Luggage Storage Service) and take possession of the RHA Holiday Home at the agreed time.

Early Check-in: where the RHA Holiday Home is available in advance, it is possible to book and guarantee a check-in time before 2.00 pm according to the Comfort Plus Services.

CHECK-OUT.

Check-out time is any time before 10:00am of the departure day.

Early/Late Check-out: where the RHA Holiday Home is available, it is possible to book and guarantee a later check-out time at 10 a.m. according to the Comfort Plus services. If necessary, you can leave your luggage in the RHA Holiday Home or in a different location (see Luggage storage service) and retrieve them from Monday to Friday (weekdays) with the following timetables: 10.00 am -13.00 and 16.00-18.30. The recovery of luggage at different times or on Saturdays, Sundays and holidays must be previously agreed with RHA.

KEYS.

When you leave, do not forget to leave the keys in the appropriate container inside your RHA Holiday Home. In case of loss, failure return, breakage of a key, an amount of € 10.00 will be charged for each broken/lost/not returned key.

NOTICES.

Guests may address all notices and communications to RHA as follows:
Roman Holiday Accommodation di Paolo Marroccu

via Labicana, 80- 00184 Roma, Italia

E-mail: info@romanholiday.it
RHA may respond to Guests by letter, fax or e-mail. All notices and communications provided electronically will be considered as communications in writing.

ELECTRICITY.

It is strictly forbidden to use electrical equipment in the RHA Holiday Home. In case of not complying with this ban, the Guests will be held liable for any damages. Electric razors and phone, PC/MAC chargers compliant with CE standards are excluded from the ban.

EXSPULSION.

RHA, come anche previsto delle vigenti leggi della Repubblica Italiana, ha diritto di espellere senza preavviso chiunque non rispetti i presenti T&C o si comporti in modo da creare danno o disturbo, salvo il risarcimento dei danni subiti.

Devono essere altresì rispettate tutte le indicazioni specifiche riportate nei cartelli posti nella Casa delle Vacanze RHA.

RHA, in line with Italian laws, has the right to expel without notice Guests who does not respect these T&C or behaves in such a way as to create damage or disturbance, without prejudice to compensation for damages.

Guests shall also comply with all the specific indications given in the signs displayed in the RHA Holiday Home.

SMOKE.

Smoking is not allowed in all areas of the Historical Building. There is no smoking also inside the RHA Holiday Homes as most of our Guests are non-smokers and families with children. If you wish to smoke, you can do it outside the windows and in areas outside the Historical Building. It is forbidden to throw the cigarette ends on the floor.

FIRE.

It is not allowed to smoke, light candles, burn incense, etc. inside the RHA Holiday Home, in the elevator, in the stairs and in general inside the Historical Building.

COMPLAINTS AND DAMAGE.

Guests shall immediately report any issues related to the RHA Services.

Guests are liable for and shall compensate any damages caused by them or caused by persons or animals for which they are responsible.

APPLICABLE LAW, LANGUAGE AND JURISDICTION. FAILURE TO COMPLY WITH T&C.

Italian law applies to this T&C and agreements between RHA and Guests. In cases of disputes arising from or related to them, the Court of Rome is competent. The original text of these T&C is in Italian but it may have been translated into other languages. The translated version is unofficial and for illustrative purposes only, therefore without legal value -and in the event of disputes or inconsistencies or discrepancies between the Italian text and translations into the other languages of these T&C, the Italian text prevails- unless it is the only copy signed/executed by the Guest. The terms that are not defined in the T&C (for example “RHA Services”) have the meaning indicated in the RHA Mission document.

These T&C and the RHA Mission document, the RHA Equipment List, the RHA Privacy Policy, the RHA Iubenda Privacy Policy and RHA Iubenda Cookie Policy here mentioned, which are to be considered all as attachments that are an integral and substantial part of these T&C (defined, jointly with the T&C as “Contractual Documentation“), apply from 24 May 2018. RHA reserves the right to change over time the Contractual Documentation, whose updated version is published on the RHA Site and made available in the RHA Holiday Home. Please keep the documents signed and stamped by RHA applicable to you in order to avoid future disputes. At any time it is possible to request further copies of the Contractual Documentation from RHA.

Failure to comply with T&C, the provisions contained therein and with the Contractual Documentation in general, may result in termination of the agreement with the relevant economic and legal consequences, so please read them carefully. Some T&C are summarized for your convenience in an illustrative brochure in each RHA Holiday Home.

MINORS.

Parents (or those who legally exercise parental responsibility) are jointly liable for acts performed by their minor children within the RHA Home Holiday and are required to supervise them and to ensure that they maintain polite and respectful behavior towards others, under their own direct responsibility and, in particular, regarding the obligation to respect the silence, the correct use of the bathrooms and RHA Equipment.

OVERBOOKING ET SIMILIA.

In the event of overbooking, force majeure and/or whenever RHA is forced to cancel the reservation of a specific RHA Holiday Home, RHA undertakes to promptly notify the Guest and provide a similar or higher accommodation than that for which the reservation was made. Where this is not possible, RHA undertakes, as required by art. 1385 c.c., to repay up to twice the amount paid as a deposit. Nothing else can be requested by Guests as compensation.

CANCELLATION POLICY.

Hospitality Service:

If the reservation is made DIRECTLY with RHA and if it is canceled or modified by the client, the following penalties apply:

from the moment of reservation until 90 days before check-in: 10% of the total amount
from 89 until 60 days before check-in: 20% of the total amount
from 59 until 20 days before check-in: 30% of the total amount
from 19 until 1 days before check-in: 50% of the total amount
check-in day or in case of no-show of the client: 100% of the total amount

Arrivals after the check-in date or check-outs before the scheduled date are not refunded. If the reservation is made through an OTA the Cancellation Policy applies the penalties the clients agrees on that OTA.

Third Party’s Service:

The terms and conditions of cancellation (penalties, payments due, etc.) of the Third Party Services are set by the Third Party providing the service.

In case of cancellation of the Third Party Services, RHA does not apply penalties (as the service is provided by the Third Party), except for the reimbursement of any costs incurred for the management of the reservation.

RESERVATION.

Once the reservation of the Hospitality Service is made, the Guest will receive a written confirmation with the address of the RHA Holiday Home where the stay is fixed and the telephone to call to arrange check-in. After confirming the reservation it is important to communicate the expected arrival time and any request for a Booking Service of a transfer service to the RHA Holiday Home.

PRICES.

Prices are in Euros and VAT is included.

PRIVACY AND COOKIE POLICY.

The data you provide will be processed in compliance with the (EU) Regulation 2016/679 (“GDPR”) and Legislative Decree no. 196/2003 as amended by the GDPR. By signing this T&C, the Guest declares to have read and specifically accepts the RHA Privacy Privacy and the RHA Iubenda Privacy and RHA Iubenda Cookie Policy (for the Social Web) which are part of the Contractual Documentation.

REGISTRATION.

According to the Art.109 of the TULPS (Consolidated Text of the Laws of Public Security), the operators of the accommodation facilities have the obligation to communicate, at the territorially competent Police Headquarters, the presence of people housed. Therefore, Guests are requested to provide the following information at the check-in:

a) Reservation holder: NAME, SURNAME, PLACE OF BIRTH, DATE OF BIRTH, COMPLETE ADDRESS OF RESIDENCE, TAX CODE, TYPE OF DOCUMENT (PASSPORT, IDENTITY CARD, LICENSE), NUMBER OF DOCUMENT, DATE OF DOCUMENT ISSUE, PLACE OF DOCUMENT ISSUE, NATIONALITY
b) Other guests: NAME, SURNAME, PLACE OF BIRTH, DATE OF BIRTH, NATION OF RESIDENCE, NATIONALITY

LIABILITY.

Within the constraint of the law (art. 1229 c.c.), RHA SHALL NOT BE LIABLE FOR ANY DIRECT OR INDIRECT DAMAGE THAT GUESTS MAY SUFFER –E.G. WITH REFERENCE TO LOSSES, THEFTS, DELAY IN ARRIVAL OR DEPARTURE, ILLNESS OR ACCIDENTS- OCCURRING DURING THE STAY IN OR DURING TRANSPORTATION TO AND FROM THE RHA HOLIDAY HOME. Without prejudice to the exclusions and limitations of liability provided by these T&C and to the extent permitted by law, the liability of RHA, its owner and RHA Staff towards Guests is limited to direct and immediate damages actually incurred and paid by the Guest attributable to failure to comply with RHA’s contractual obligations and THE TOTAL COMPENSATION FOR DAMAGES SUFFERED BY THE GUESTS FOR A SINGLE CIRCUMSTANCE OR FOR A SERIES OF CIRCUMSTANCES DURING THE STAY is however limited to the cost of the RHA Services actually paid by the Guests and in any case SHALL NOT EXCEED THE AMOUNT OF THE RELATIVE RESERVATION, AS SHOWN IN CONFIRMATION E-MAIL OF THE RHA SERVICES. By way of example, RHA, its owner and the RHA Staff will not be held responsible for (i) punitive, special, indirect or consequential damages, loss of production, profit, income or contract losses, injury or damage to good name and reputation, (ii) products or services offered or provided by Third Parties, (iii) physical injury, death, theft, property damage (iv) strikes, force majeure or any other event outside our control. We suggest you to subscribe a travel insurance covering such events.

WASTE.

In the area of the RHA Holiday Homes, separate waste collection is active on the street, with the separation of food waste and organic waste, non-recyclable waste, glass, plastic, metal, paper and cardboard. Specific instructions are given to Guests upon arrival. Separate waste collection is regulated by community, national and municipal legislation which provides for penalties of up to € 500 for those who do not use the appropriate containers, leave the waste on public land or on private spaces visible or damage the urban decorum.

Therefore, the Guests are required to collect the garbage in the appropriate collection containers inside the RHA Holiday Homes and to throw them in the appropriate containers on the street. Guests will be liable to and refund any fines charged as a result of incorrect waste management by the same.

NOISE.

Please note that other people and families live inside the Historical Building and avoid making noise in your RHA Holiday Home, in the stairs and in the elevator after 10.00 p.m.

PAYMENT SERVICES.

RHA provides Guests with the possibility to make payments for RHA Services and any deposits to guarantee/reservation deposits in the manner they prefer, whether they are managed directly by RHA (cash payment), or systems managed by third parties (by bank transfer, POS, via PayPal, etc.), also in connection with and through the RHA Site or through OTAs (“Payment Services“). RHA reserves the right to improve, optimize, modify, delete or introduce new Payment Services. The availability of the Payment Services or some services or functionalities thereof may be limited where maintenance is required.

Where the Payment Services make use of systems managed by third parties (“External Payment Services“) they are subject to terms and conditions, including privacy, established by the third parties themselves and Guests are required to read them carefully. RHA is not responsible for the availability or accuracy of the External Payment Services or for the contents, products or services provided by them. In the event of any conflict between these T&C and the terms and conditions applicable to a specific Payment Service, the latter will prevail. Links to such External Payment Services posted on the Social Web can not be construed as and/or be deemed as endorsement by RHA or imply a liability of the latter in connection with such External Payment Services.

The Guest can not use the Payment Services differently from what is established by the applicable laws.

TOURIST CITY TAX.

The amount of the Tourist City Tax is 3.50 Euro per night per person. Children up to the age of 9 are exempt from paying this tax. The payment of the Tourist City Tax is to be made upon arrival and strictly in cash. It is not possible to pay the Tourist City Tax by credit card or PayPal.

VALUES AND SECURITY.

For Guests’ convenience any RHA Holiday Home is equipped with a combination safe. Please notify RHA of the discovery or loss of items in the RHA Holiday Home. RHA is not liable/responsible for any theft and personal injury to the Guests, nor for the loss of cash, documents, objects (of value or not), left within the RHA Holiday Home and/or the Historic Building. We suggest you to subscribe a travel insurance covering such events.

VISITORS NOT DECLARED.

Any people housed in the RHA Home Holiday, but not declared at the time of reservation or upon arrival, will be charged to the reservation holder with an increased rate of 40% on the daily price, with prejudice to the right of RHA to report to Police Authority all unauthorized persons, found inside the RHA Holiday Home.

For the purposes of security and privacy, visits by family, friends or acquaintances must be previously authorized by RHA.

RHA PRIVACY POLICY

Summary: 1. Preamble; 2. Personal Information RHA collect; 3. How we ask and collect data; 4. Legal basis for processing and data processing purposes; 5. Sharing and disclosure; 6. Security; 7. Changes to Privacy Policy 8. Your rights; 9. Data controller; 10. Contact Us.

1. Preamble

This Privacy Policy is given according to UE Regulation 2016/679 and Italian Legislative Decree 196/2003 and illustrates how Roman Holiday Accommodation di Paolo Marroccu (hereinafter, “RHA”) collect, use, process, and disclose information -including personal information- of our Guests for legitimate business purposes and to better serve the needs of our Guests in conjunction with the offer and use of RHA Services and access and navigation on Social Web, according to our applicable general terms and conditions (“RHA T&C” or “T&C”).

By visiting our website or otherwise interacting with RHA by, for example, using RHA Services, you acknowledge the processing activities undertaken by RHA which are described in this Privacy Policy, RHA Mission, RHA T&C and any other related documents referenced herein/therein.

Please note that websites other than Social Web not managed by RHA but that may be below or linked to our websites or may offer RHA Services (e.g. Airbnb, Booking.com, HomeAway, Flipkey/TripAdvisor, Facebook, ecc., hereinafter also, “OTA Web”) are subject to their own privacy notice to which we refer you.

The original text of this RHA Privacy Policy is in Italian, but it may have been translated into other languages. The translated versions are unofficial and are for illustrative purposes only, therefore without legal value. In the event of disputes or inconsistencies or discrepancies between the Italian text and translations into other languages, the Italian text prevails.

If you see an undefined term in this Privacy Policy (such as “RHA Services”, “RHA Holiday Home”, etc.), it has the same definition as in the document RHA Mission.

2. Personal Information RHA collect

RHA may collect the following general categories of information:

2.1. Information that are necessary for the reservation and/or purchase and answering of info requests as for the Core Services and Comfort Plus Services and to comply with UE and Italian legislation (“Necessary Data for Your Stay”).

When you contact RHA in order to reserve, obtain information about or request Core Services and Comfort Plus Services, we ask you and collect the following personal data:

Contact and First Identity Verification Data. It refers to certain information such as your first name, last name, email address, phone numbers, possible whatsapp, messenger, wechat, viber, skype, i-message, Apple face-time accounts, etc., preferred languages and date of birth.
Information that are necessary for the enjoyment of Core Services and Comfort Plus Services. It refers to information on the dates for which you request the Core Services and Comfort Plus Services, on the composition (e.g. number and age) of the group of persons for whom you request the Core Services and Comfort Plus Services, on the check-in and check-out time and any other similar relevant information (e.g.time, identification code, origin and airline of your flight).
Other Identity Verification Information.RHA is legally bound to collect identity verification information (e.g. information of your government issued ID, passport, national ID card, or driving license,) of Guests who stay at an RHA Holiday Home and to send such information to the Italian Police within 24 hours of arrival (for further information we recommend consulting the Italian Police website and in particular the following pages: https: //www.poliziadistato.it/article/23001/ and https://alloggiatiweb.poliziadistato.it/PortaleAlloggiati/). RHA also retains authentication information to help create and maintain a trusted environment within RHA Holiday Home. In particular, please note that in order to speed-up the check-in process you may agree to send us images of your government issued ID, passport, national ID card, or driving license, via e-mail, web, whatsapp, ecc. before or on your arrival, provide that the verification of the original document is necessary.
Billing and Payment Information. To allow booking and payment of Core Services and Comfort Plus Services we may ask you to provide us with (and collect) certain information such as your billing address, information related to your payment transactions, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, security number (i.e. “codice fiscale”, required for Italian citizen only), your address, guarantee and deposit information to secure your reservation and other related transaction details. This information is necessary for the adequate performance of the contract between you and RHA and to allow the provision of the Payment Services.
Information that are necessary for the Collection and Remittance of the Tourist City Taxes. RHA is legally bound to collect and settle the Tourist City Tax as described in the T&C. To this end, Guests expressly grant RHA permission, without further notice, to disclose Guests’ data and other information relating to them or to their transactions, bookings, accommodations, stay and Tourist City Tax to the Municipality of Rome and relevant competent authorities (e.g. tax authority), including, but not limited to, the Guest’s name, transaction dates and amounts, the amount of taxes received (or due) by RHA from Guests, and contact information.
Information about e-mail you send us, including its content and the e-mail itself.
Spontaneous Data.It refers to additional information, non requested or solicitated by RHA, You may decide to provide us as useful for your better fruition Core Services and/or Comfort Plus Services.

You are under no obligation to provide this information, but without it, we may not be able, in whole or in part, to: (i) process your request reservation or cancellation of the Core Services and Comfort Plus Services, (ii) answer to your enquiries, remarks, complain and other questions on Core Services and Comfort Plus Services, (iii) to comply with laws and legal obligations (e.g. anti-terrorism communication to the Police, collection and remittance of the occupation taxes, keeping of accounts), including tax laws, or orders from the Authority, (e.g. relevant to anti-money laundering), in brief, “ex Lege” obligations, (iv) comply with our pre-contractual, contractual and legal obligations (in brief, “ex Iuris Vinculum” obligations) and (v) exercise the rights of RHA and Data Controller, (e.g. management of receipts and payments, right to defense in court and right to image, honor and reputation) in brief, “ex Iure” actions and, in general, (vi) provide you with the Core Services and Comfort Plus Services you require.

RHA retains the information above provided by you for the entire duration of your stay and will delete it within 30 working days from the day of your departure, without prejudice to retention of data necessary to fulfil actions and obligations ex Lege, ex Iure, and/or Iuris Vinculum, within the limits and time period provided for applicable legislation and obligation performance/right exercise (in brief “Ex lege Retention”).

2.2. **Voluntary Information you may provide to enjoy the Extra Services and, in general, to upgrade your experience as RHA Guest (“Voluntary Information for the Extra Services”)**

In order to offer you the Extra Services and to make your stay at RHA Holiday Home more enjoyable, we ask and collect personal data about your tastes, habits, preferences and interests, duration and frequency of trips, profession, etc. (e.g. we may ask you if you are a smoker or non-smoker, if you have difficulty climbing stairs, which are your favorite newspapers/magazines, sports, cultural interests and so on).

In addition, we may collect and process additional information not requested by us that you may independently provide as useful for your better use of Extra Services or however, should you require on-site Support Services, you may provide us with the information necessary to provide you with better assistance (e.g. contents of lost baggage, reasons for which you need medical care, etc.).

You are under no obligation to provide this information, but without it, we may not be able nor to provide you, in whole or in part, with the Extra Services or to do our best to make your stay at RHA Holiday Home more enjoyable.

RHA retains the information you provide to receive Extra Services and to improve your experience as an RHA Guest for the duration of your stay and deletes it within 30 working days from the day of your departure, without prejudice to Ex Lege Retention.

2.3. **Voluntary Information you may provide to enjoy Promo Services and Social Web Services and, in general, to stay in touch with us (“Voluntary Information for Promo and Social Web Services”)**

We are a family business and we chose this job for passion, after our first trips abroad when we decided accommodation day by day following the directions of paper guides, often local publications, and we met special people with whom we are still in touch, who have opened us their home and made us know the beauties and traditions of their countries, well before the multinationals of tourism reduced the choice of a holiday to few clicks on the web.

We therefore like to think that during your stay you become for us something more than a customer and we become for you something more than a supplier of accommodation and ancillary services.

With your consent, you can choose to subscribe to the Promo and Social Web Services and so we can stay in touch with you, update you on our progress and receive news by you and, if you want, receive our newsletters (no more than three per year) and any commercial information and be contacted to respond to surveys and participate in prize draws or promotions.

To this end we ask you to provide us with the following information:

Contact and First Identity Verification Data.It refers to certain information such as your first name, last name, email address, phone numbers, preferred languages and date of birth.
Spontaneous Data. You may decide to provide additional unsolicited information you deem important to better enjoy Promo Services and Social Web Services (e.g. preferences on the apartment, special needs, tastes, habits, preferences and interests, duration and frequency of trips, profession, composition of your family, a personal description).
Other information. You may choose to provide us with other information when you fill out a form, do a search, answer to surveys, post content on the Social Web, participate in promotions, or use other Social Web features.
Information about e-mail you send us, including its content and the e-mail itself.
Reviews on RHA that you will leave can be published on the Social Web. For more information, you may contact us at: info@romanholiday.it.

You are under no obligation to provide this information, but without it, we may not be able, in whole or in part, nor to provide you with the Promo Services and Social Web Services or, in general, to stay in touch with you.

RHA retains the information you provide in relation to the Promo and Social Web Services for the period of 1 year unless you specified a different period in the consent form (e.g. 3, 5 or 10 years … we know it is a long period but you do not know what pleasure we feel when, over the years, we remain in contact with our Guests, sharing memories, experiences or suggestions for each other’s travels or when a guest comes back or sends his children or friends to us and this would no longer be possible without the release of the express consent from you).

RHA will contact you for the Promo and Social Web Services exclusively by e-mail, unless you have expressly given your consent to be contacted by additional means.

Keep in mind that at any time you can withdraw the consent you gave sending a request to privacy@romanholiday.it and we will delete all data concerning you within the technical times required as soon as reasonably possible, without prejudice to Ex Lege Retention.

With reference to your interaction with the Applications, also in connection with the Promo and Social Web Services and as for log data, cookies, etc., it is necessary that you also take note of the specific privacy policy available here (which must be considered an integral and substantial part of this RHA Privacy Policy) and the cookie policy available here both generated by Iubenda (respectively “RHA Iubenda Privacy Policy” and “RHA Iubenda Cookie Policy” and, jointly, “RHA Iubenda Policies“). The RHA Iubenda Policies provide further information on aspects related to interaction with Guests via the web. It is however important that you know that browsers and mobile devices allow the Guest to control or disable certain options (eg. use of cookies, localization, etc., in the relevant settings menus and that RHA does not control or supervise social media platforms and in general the work of third parties (eg. Google Analytics, Google AdWords) with which some of your personal data may be shared, therefore any question concerning how your personal data are processed by the latter must be addressed to the supplier in question, see also section 5.5 below.

2.4. Necessary Data if you require Booking Services of Third Parties Services (“Necessary Data for Booking Services”).

When you request Booking Services of Third Party Services we request/collect the following data in order to transmit them to the Third Party providing the service:

Contact and First Identity Verification Data.It refers to certain information such as your first name, last name, email address, phone numbers, preferred languages and date of birth.
Data for the use of Third Party Services. It refers to certain information on the dates and times for which you request the booking/cancellation of Third Party Services, on the composition (e.g. number and age) of any group of persons for whom you request the Third Party Services and any other similar and relevant information (e.g. time, identification code, departure airport and airline of your flight).
Spontaneous Data. You may decide to provide unsolicited additional information you deem important to better enjoy Third Parties Services.
Information about e-mail you send us, including its content and the e-mail itself. Please note that RHA store and may forward to the Third Parties the e-mails with which you request the booking / cancellation of Third Party Services.
Billing and Payment Information. To allow booking and payment of Third Party Services it may be necessary RHA transfer on your behalf to the Third Parties certain information such as your billing address, information related to your payment transactions, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, guarantee and deposit information to secure your reservation and other related transaction details. This information is necessary for the adequate performance of the contract between you and the Third Parties and to allow the provision of the Third Party Services and Payment Services. Once transferred to the relevant Third Partie(s) RHA will delete your billing and payment Information received as per this paragraph as soon as reasonably possible.

You are under no obligation to provide this information, but without it, we may not be able to, in whole or in part: (i) to process your requests for reservations or cancellation of Third Party Services, (ii) to answer to or forward your requests for information, observations, complaints and other questions about Third Party Services, (iii) to comply with regulatory obligations (e.g. tax), or orders of the Authority (e.g. on anti-money laundering), (v) act in accordance with our pre-contractual, contractual and legal obligations and exercise the rights of RHA and the Data Controller (e.g. the right of defense in court) and, more generally (iv) to provide you with the Booking Services of Third Party Services that you may request.

3. How we ask and collect data

3.1. Information You Give to Us.

Information as per Section 2 above may be asked and/or collected by communicating with RHA, via email, telephone, SMS, whatsapp or other means, you may insert it in forms we ask you to fill, by sending an “enquiry”, booking or cancelling or ordering RHA Services. Some information may be provided while your navigation or uploading information on Social Web, even automatically (cfr. RHA Iubenda Policies).

3.2. Personal data of children, Group Reservations, Reservations through Intermediary, Reservations through OTA and, in general, information we collect from third parties.

RHA does not knowingly collect personally identifiable information from any person we actually know is a person under the age of 18. We may collect personally identifiable information from persons under the age of 18 as part of the Guests reservation and registration processes, but always received by or in any case with the consent of such person’s parent or guardian.

RHA may collect data, including your personal information, that third parties provide to us about you when they request information about or book RHA Services or use the Social Web. This may happen, for example, in the case of reservations made by one person for a whole group of people, e.g. bookings made by the householder for himself and his family members, or by a professor for himself and his students (“Group Reservations“) or when the RHA Services are booked by one of your representatives, by your employer, from your company, your university, etc. (“Reservations through Intermediary“).

If you are providing data on behalf of another person, you warrant to us that you are entitled to (you have been authorised by that person), and that information you enter is accurate and correct. If any non-compliance by you with respect to this provision results in any loss or damage being incurred by us, you may be required to compensate us in respect of such loss.

If you book RHA Services through a third party or third-party’s sites/services, e.g. Airbnb, Booking, HomeAway, Flipkey, tripAdvisor, Google, Facebook, WeChat etc. (“Reservations through OTA“), such third party/site/service can send us information such as, for example, your registration data and your user profile on the site/service of the third part. The data sent to RHA may vary and are controlled by the third party and the site/service that refers to it or depend on the permissions you have issued to the third party’s site / service in the relevant privacy settings.

We do not control, monitor or respond to the processing of your personal data by such third parties, therefore any request for information regarding the communication of your personal information must be forwarded directly to such third parties.

RHA may combine the information obtained from third parties with the information we collects directly.

4. Legal basis for processing and data processing purposes

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop RHA Services and Social Web, create and maintain a trusted and safer environment and comply with our legal obligations.

With reference to data processing our actions are based on the following purposes:

4.1. **Comply with “ex Lege” obligations, comply with pre-contractual, contractual and legal obligations “ex Iuris Vinculum” and exercise “ex Iure” actions.**

4.2. Provide, Improve, and Develop RHA Services and Social Web.

Given our legitimate interest in improving Guest’s experience, RHA Services, the Social Web and, where it is necessary, for the adequate performance of the contract with you, RHA process information collected in order to:

enable you to communicate with RHA and RHA Staff
operate, protect, improve, and optimize RHA Services, our Guests experience (e.g. organize search results or profiling based on spoken language and / or state of residence)
guarantee the proper execution of the agreement between us and the Guest
provide customer service
send you service or support messages, updates, security alerts, and notifications as for your stay
enable you to access and use the Social Web
to operate, protect, upgrade, and optimize Social Web and your experience (eg. organize search results or profiling based on your interactions with the Social Web, spoken language and / or state of residence, your profile information and preferences, and other content you submit to the Social Web).

If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for Reviews, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.

4.3. Develop a Trusted and Safer Environment.

Given our legitimate interest in protecting RHA business and Social Web, to measure the adequate performance of our contract with Guests, and to comply with applicable laws we process information collected to:

comply with our legal obligations.
detect and prevent fraud, spam, abuse, security incidents, and other harmful activity
resolve any disputes with any of our Guest and enforce our agreements with third parties
enforce our T&C and other RHA policies.

verify information or identifications provided by you

4.4. Advertising and Marketing.

Given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest RHA will process your personal information for the purposes:

send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about RHA or its commercial partner’s campaigns and services) and social media advertising via mail (also via dedicated platforms, e.g. MailChimp) o through social media platforms (e.g. Facebook, Google, Instagram)
personalize, measure, and improve our advertising.
administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by RHA or its commercial partners.
organize search results or profiling based on your characteristics and preferences (e.g. spoken language and / or state of residence) based on the information you provide to us, your interactions with the Social Web, information obtained from third parties, to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.

4.5. Purpose in the Use of the Payments Data.

Given its legitimate interest in improving the Payment Services and where it is necessary for the adequate performance of the contract with Guest and to comply with applicable laws, RHA process payment data in order to:

Enable you to access and use the Payment Services.
Detect and prevent fraud, abuse, security incidents, and other harmful activity.
Comply with legal obligations (such as anti-money laundering regulations).
Enforce the Payment Terms and other payment policies.

5. Sharing and disclosure

5.1. With Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Social Web account (where applicable) and information or when you participate in promotional activities conducted by RHA partners or third parties or when you require us Booking Service of Third Party Services.

5.2. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

RHA may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against RHA or RHA Staff, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose RHA, you, RHA Staff, or any other of our Guests to legal liability, (iv) to enforce and administer our T&C, or other agreements with RHA Service Providers, Third Parties or members of the public, or (v) to protect the rights, property or personal safety of RHA, RHA Staff, RHA Service Providers, Third Parties or members of the public.

Where appropriate, we may notify Guests about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon RHA’s property, Guests, , RHA Service Providers, Third Parties or members of the public. In instances where RHA comply with legal requests without notice for these reasons, we will attempt to notify that Guest about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

5.3. RHA Services Providers.

RHA may use third party service providers to help us in management of the RHA Holiday Homes or to provide RHA Services (e.g. cleaning services or check-in services) as well as in the management of the Social Web or the Payment Services (“RHA Services Providers”).

In order to ensure the adequate performance of our contract with you, we will need to share with them your information, including personal information (e.g. date and time of check-in and check-out, name and telephone number) with such third-party suppliers. In some cases, RHA Services Providers may have access to or collect some of your data.

For example, RHA Services Providers may help us: (i) with reference to technical assistance, maintenance and development of the Social Web and RHA’s IT tools, (ii) verify your identity or authenticate your identification documents (e.g. for the anti-terrorism communication to the Police), (iii) allow the provision of the RHA Services through third party platforms and software tools (e.g. through the integration with our APIs), or (iv) provide advertising, or payments services. Some RHA Services Providers have limited access to your information to perform these tasks on our behalf.

Current RHA Service Providers are based in Italy and in Europe and USA.

However, we do not exclude that in the future some RHA Services Providers in the context of the Social Web and the management of IT tools may have – or in the continuation of the report, notify us that they need to move (e.g. their servers referable to RHA) outside of the European Economic Area (“EEA”), in countries such as India, Asia Pacific and North and South America. Where RHA Services Providers are located outside EEA, we evaluate the activation/continuation of the relationship with them taking into account the guarantees of security, management and data protection in accordance with European standards (e.g.Privacy Shield Principles, contractual clauses, etc.) that will be provided to us.

Upon request, we are available to provide additional information on the RHA Services Providers.

Consult the “Contact us” section for the addresses to send us these requests.

RHA will not sell your personal information to third parties (e.g. for direct marketing purposes), In general, please remember that you can avoid communication for direct marketing purposes (even through third parties platform etc.) by not giving your consent.

5.4. Public Information.

Social Web lets you publish information, including personal information, that is visible to the general public.

Based on our legitimate interest to promote RHA, we may display (e.g. on RHA commercial partner websites) parts of the Social Web, including, for example, parts of your public profile page, content you submit, your Reviews, etc, using technologies such as widgets or APIs.

In some cases we may report slightly modified extracts of your reviews for the optimization of search engine output; in this case the reference will show only your first name and not your surname.

Information you share publicly on the Social Web may be indexed through third party search engines. In some cases, you may opt-out of this feature in your account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

5.5. Social Web e OTA WEB.

Where permissible according to applicable law, we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to the Social Web or otherwise promote our products and services or the Social Web. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by RHA. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

Please note that you may, at any time ask RHA to cease processing your data for these direct marketing purposes by sending an e-mail to privacy@romanholiday.it.

Social Web may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Other Third Parties”). RHA doesn’t own or control these Other Third Parties and when you interact with them, you may be providing information directly to the Other Third Parties, RHA, or both. These Other Third Parties will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

Parts of the Social Web use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5.6. RHA business transfer

If RHA undertakes or is involved in any merger, acquisition, reorganization, succession, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

5.7. Aggregated Data

We may also share aggregated information (information about our Guests that we combine together so that it no longer identifies or references an individual Guest) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

6. Security

We are continuously improving and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are antivirus and information access controls.

If you know or have reason to believe that your information or RHA account credentials (where applicable) have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use thereof, please contact us following the instructions in the Contact Us section below.

7. Changes to Privacy Policy

This is version 3.0 of RHA Privacy Policy, is entered into force and published on RHA Website on 24, May 2018.

RHA reserves the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will make the revised Privacy Policy available to the public (e.g. we will post it on the RHA Website). We will also provide you with notice of the modification by email where you give us previous consent to sending you e-mail. In case of your continued access to or use of the Social Web, and/or RHA Services, such access/use will be subject to the revised Privacy Policy.

8. Your rights

You may exercise any of the rights described in this section before RHA and the Data Controller by sending an email to privacy@romanholiday.it. Please note that we may ask you to verify your identity before taking further action on your request.

8.1. Managing Your Information.

You may access and update some of your information by sending an email to privacy@romanholiday.it or, where possible, through your account settings. If you have chosen to connect your Social Web account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your account settings. You are responsible for keeping your personal information up-to-date.

8.2. Rectification of inaccurate or incomplete information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself on the Social Web).

8.3. Data Access and Portability.

Within the limits of applicable law, you may request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

8.4. Data Retention and Erasure.

RHA generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you don’t want us to further use your information, you can request that we erase your personal information and close your RHA account (if applicable). Please note that if you request the erasure of your personal information:

we may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
we may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, RHA may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g. Reviews, forum postings) may continue to be publicly visible on the Social Web, even after your information/account is cancelled. Additionally, some copies of your information may remain in our database, but are disassociated from personal identifiers.
because we protect RHA from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

8.5. Withdrawing Consent

Where you have provided your consent to the processing of your personal information by RHA you may withdraw your consent at any time by sending us a communication specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, within the limits of your rights under applicable law you may limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to following paragraph 9.6.

and pending the verification whether the legitimate grounds of RHA override your own.

8.6. Objection to Processing

Where applicable law entitle you to require RHA not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest, if you object to such processing RHA will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask RHA to cease processing your data for these direct marketing purposes by sending an e-mail to privacy@romanholiday.it

8.7. Complaints

You have the right to lodge complaints about the data processing activities carried out by RHA, as RHA is located in Italy, the competent data protection authority is the Italian Data Protection Authority with registered office in Rome (Italy), Piazza di Monte Citorio, 121 – 00186.

9. Data controller

With reference to this Privacy Policy the RHA data controller is RHA, with registred office in Rome (Italy), via San Giovanni Laterano 210, 00184, in person of Paolo Marroccu.

10. Contact Us

Should you have any questions or complaints about this Privacy Policy or RHA’s information handling practices, please don’t hesitate to contact us at privacy@romanholiday.it

Please note that you may, at any time ask RHA, inter alia, to cease processing your data for direct marketing purposes by sending an e-mail to privacy@romanholiday.it

All your enquiries will be received during Italian office hours and we will aim to respond to your enquiry as soon as reasonably possible.

Terms and Conditions and RHA privacy policy