Privacy Policy

The Data Controller, pursuant to Article 4(7) of the GDPR, is COBRA S.R.L., with registered office in Ardara (SS), via Vittorio Emanuele 110, VAT no. 01788140901, registered in the Companies Register under R.E.A. no. 125788 SS, in the person of its pro tempore Legal Representative Vittoria Biddau.

For any communication, request or exercise of rights relating to data protection, the Controller may be contacted through the following official channels:

• Postal address: Via Vittorio Emanuele 110, 07010 Ardara (SS), Italy
• Telephone: (+39) 327 546 3087
• Email: info@milenasuiteapartments.it
• Certified email (PEC): termostaticobra@legalmail.it

The personal data processed by the company's website fall into three main categories:

• A) Browsing data and technical metadata: The IT systems and software procedures responsible for the operation of this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of internet communication protocols (e.g. IP addresses, connection times, pages visited, technical metadata of the browser and operating system used). Although collected in anonymous or pseudonymous form, such data could allow indirect identification of the user if combined with information held by third parties.
• B) Data voluntarily provided by the user: This refers to the identification and contact data (first name, surname, email address, telephone number, payment details) that the user actively enters by filling in the 'Book now' form, sending requests through the 'Contacts' section, or sending direct communications to the property's email addresses.
• C) Cookies and tracking tools: Small text files that the site sends to the user's device, where they are stored and then retransmitted on the next visit. For specific usage, please refer to the dedicated section.

In full compliance with the ruling of the Italian Data Protection Authority (Garante) and the European EDPB guidelines, our web portal adopts a transparent and proactive cookie management system:

• Technical (Essential) Cookies: Used solely to enable browsing or to provide the service requested by the user (e.g. saving the booking session). They do not require the user's consent but are listed in the full cookie policy available on the site.
• Profiling and Third-Party Cookies: Used for marketing or personalised tracking. They may only be installed after the user's active, explicit and unambiguous consent.
• The Cookie Banner: On first access to the site, a banner of adequate size is displayed containing: (1) a quick-close command (e.g. an 'X' in the top right) that allows the user to reject all non-essential cookies and continue browsing with default settings only; (2) a brief and transparent notice; (3) a link for analytical and granular cookie choices; (4) a button for global acceptance.
• Consent Rules: Please note that scrolling the page, silence or user inactivity do NOT in any way constitute valid consent under privacy law. Preference boxes are never pre-ticked or pre-selected. The user may withdraw or change their choices at any time, free of charge, through a dedicated command or graphic symbol that is always visible in the site footer.

The presence on the site of social network buttons or widgets (e.g. Facebook, Instagram) entails the automatic transmission of certain browsing data (such as the IP address) to the relevant third-party platforms, even if the user does not directly click on the element. COBRA S.R.L. blocks such scripts in advance until consent is given via the cookie banner.

Personal data is stored on servers located in Italy or within the European Union. Should some technical providers (such as cloud invoicing systems or newsletter platforms) store data in non-EU third countries, the Controller guarantees the accuracy of the information and the adoption of adequate safeguards pursuant to Chapter V of the GDPR (e.g. Standard Contractual Clauses or adequacy decisions).

In accordance with Articles 15, 16, 17, 18, 20, 21 and 22 of the GDPR, the user has the right to request at any time:

• Right of Access (Art. 15): To obtain confirmation as to whether processing is taking place and to receive a copy of their data.
• Right to Rectification (Art. 16): To obtain the update or completion of inaccurate or incomplete data.
• Right to Erasure / To Be Forgotten (Art. 17): To request the deletion of data no longer necessary or unlawfully processed.
• Right to Restriction (Art. 18): To request the temporary suspension of the processing of personal data.
• Right to Data Portability (Art. 20): To obtain their data in a structured format and transfer it to another controller.
• Right to Object (Art. 21): To object to processing on legitimate grounds or for marketing and profiling purposes.
• Right to Withdraw Consent: To withdraw consent at any time without affecting the lawfulness of previous processing.

The exercise of these rights is entirely free of charge. The Controller undertakes to provide a comprehensive response and to facilitate requests without undue delay, and in any case within one month of receipt of the request. The user also has the right to lodge a formal complaint with the supervisory authority (the Italian Data Protection Authority - www.garanteprivacy.it).