Dear User



These rules and guidelines, together with the Legal Notice of the website bemahotel.com (the "Site") set out the basis for the way personal data will be porcessed and collected from you within the scope of delivering the services provided through the Site (the ?Service?).

Please, read the following carefully to understand the practices regarding your personal data and how it will be treated.

The Website bemahotel.com is operated and managed by Terry Thompson (the "Manager") and is hosted on servers under the supervision of GH Fresh s.r.l., which is a service provider of the Manager.

The Manager will collect and process all data (including Your personal data) that will be uploaded on the Website with the aim of storing, organising and processing them in a database accessible via Internet (the "Database").
Since the Manager hosts the Website and the Database in Italy, Your personal information and data will be dealt with in accordance with Italian legislation of transposition of EU directives 95/46/EC and 2002/58/EC, that is on the basis of the Privacy Code referred to in Legislative Decree no. 196, 30 June 2003.

1. Minors.

   
   Users under the age of 18 (?Minors?) are not eligible to use the Site and must not attempt to register with and/or submit any personal information to us unless verifiable parental consent is obtained (?Parental Consent?). A Minor may enter his/her parent(s)? email address in the required field during their registration and an automatic email will be sent to the parent(s) requesting his/her approval. Only when this Parent Consent is obtained will be Minor have validly registered with us. We do not knowingly collect personal information from any person who is under the age of 18 or allow them to register without Parental Consent. If it comes to our attention that we have collected personal data from a person under the age of 18 without the Parental Consent, we will delete this information as quickly as possible.



2. The type of information we collect.

   
   In order to deliver the Service, we will use data (including personal data) concerning you (such as name, address, phone number). This is information that you yourself give us orally, in written form, electronically via email or by direct insertion of data by yourself.


3. IP address, cookies, and links. We may collect information about your computer, including where available your IP address, operating system abd browser type, for system administration and to report aggregate information for statistical purposes. This is statistical data about our Users? browsing actions and patterns, and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer?s hard drive. They help us to improve the Site and to deliver a better and more personalised service. They enable us:
   
   • mainly to recognise you when you return to the Site;
   • to estimate our audience size and usage pattern;
   • to store information about your preferences, and so allow us to customise our site accordng to our individual interests;
   • to speed up your searches.
   
   You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to the Site.



4. Where do we store your personal information.

   
   By submitting your personal data, you agree to the transfer of your personal data to the Manager and the controlling, storing and processing of your personal data by the Manager through GH Fresh s.r.l. in Italy. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. All data you provide is stored on secure servers located in Italy under the Manager and GH Fresh s.r.l. control. Where you have been given a password which enables you to access certain parts of the Site, you need to keep this password confidential. You are not allowed to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will take reasonable steps to protect your personal data, se cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.


5. 
   

   Purpose and method of the processing to which the data are assigned.

   
   The personal data you give us that will be used by the Manager for supplying the Service will be reported to and used by the Manager?s employees and/or co-workers and/or freelance workers, as well as by GH Fresh s.r.l., a company located in Italy, in Piazza San Francesco 8, 40122 Bologna,for the sole purpose of carrying out the Service (including hosting and electronic maintenance activities related thereto) and conducting some statistical research with anonymized data and under its control. The personal data you give us will be used by the Manager for the provision of the Service and to comply with the resulting legal obligations. The Manager may also use your personal data for other purposes, including the following: direct marketing and newsletters. Your data will be processed electronically, and will in any event always be protected by suitable and constantly updated security systems and deposited in a secure and controlled environment.


6. Optional nature of providing data. Providing data is always optional, although any refusal on your part to provide data may make it impossible for us to carry out your request for receiving the Service or to adeuqtely review the information you have provided.


7. 
   

   Length of the processing.

   
   The data you give us will be kept throughout your subscription to the Service. Your personal data will also be used for a period of 24 months follwoing expiry of your subscription to the Service for the purposes stated in Section 5 above.


8. 
   

   Your rights. Identifying details of the Controller and, if designate, of the Data Processor.

   
   The Manager is the Data Controller of the processing of Your Data. You may address to him for the exercise of the rights under Art. 7 of the d.lgs. 196/2003. You have the right to ask the Manager not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevetn such processing by checking or unchecking certain boxes on the forms we use to collect your data. You have the right to access information held about you. Your right of access can be exercised in accordance with the Privacy Code. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you. Your rights entitle you (on email application) to: a. Obtain the statement of the origin of your personal data, ther purposes and methods of procesing, the logic for any electronic processing, thedetails ofthe processor,the subjects or categories of subjects to whom the personal data may be givne or who may be informed of the data; b. Update, correct or add to your data; c. Cancel, maeke anonymous or block any of your data that is processed in breach of the applicable laws, including data that need not be kept in relation to purposes for which your data was collected or subsequently processed; d. Ask for details of ow your data has been processed, including regarding its content, those to whom your data has been given or reported (except in cases where the fulfilment of such request is found to be impossible or involves the use of means cearly disproportionate in respect to the right protected); e. Contest, for legitimate reasons, the processing of personal data concerning you, even if they are relevant to the purpose of the collection, or to the processing of personal data conerning you in order to send advertising or direct sales material or for carrying out market research studies or sending commercial notices. External Data Processor limited to web-hosting of the database and provision of the Service on behalf of the Manager is GH Fresh s.r.l..



9. Changes of this privacy policy.

   
   Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.



10. Contacts.

    To send a complaint or obtain information relating to the purposes or procedure of management of Your data related to the Service you can also write to the e-mail: support@freshcreator.com.