VALUEGUEST PRIVACY POLICY
Valueguest collects some Personal Data from its Users.

POLICY SUMMARY
DPersonal data collected for the following purposes and using the following services:

Contact the User
Contact by telephone and e-mail
Personal Data: telephone number and e-mail

Managing contacts and sending messages
Sendgrid
Personal data: email

Management of support requests and
Help Scout contact
Personal Data: various types of Data as specified in the privacy policy of the service

Hosting and backend infrastructure
Openshift Redhat
Personal Data: various types of Data as specified in the privacy policy of the service

Interaction with live chat platforms
Crisp Widget
Personal Data: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service

Interaction with data collection platforms and other third parties
Widget Typeform
Personal Data: city, surname, date of birth, email, User ID, address, billing address, country, name, telephone number, VAT number and company name

Registration and authentication
Direct registration
Personal Data: surname, email address, billing address, name, telephone number, VAT number, password and company name

Google Analytics Statistics
Personal Data: Cookies and Usage Data

Transfer of Data outside the EU
Transfer of Data from the EU and / or Switzerland to the United States on the basis of the Privacy Shield and Other legal basis for the transfer of Data to third countries
Personal Data: various types of Data

Displaying content from external platforms
Headway Widget
Personal Data: Cookies and Usage Data
More information on Personal Data

Personal data of third parties registered by the User
The User who records personal information of third parties who do not directly use Valueguest such as, by way of example and not limited to:
– guests staying at their accommodation facility
– owners of properties managed by the User
authorizes the Data Controller to process – according to the conditions set out in this document – the following personal data:
name, surname, date of birth, place of birth, country of nationality, number of the identity document, place of issue of the document of identity.

Additional data necessary for the performance of our service
The User undertakes and authorizes the Data Controller to process the following data: username and password of the login credentials to the AlloggiatiWeb Portal.

Sale of goods and services online
The Personal Data collected are used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to complete the payment may be those relating to the credit card, the current account used for the transfer or other payment instruments provided. The payment data collected by Valueguest depends on the payment system used.

Personal Data collected through sources other than the User
The Owner of Valueguest may have legitimately collected Personal Data relating to the User without his involvement, drawing on sources provided by third parties, in accordance with the legal bases described in the section relating to the legal bases of the treatment.
If the Owner has collected Personal Data in this way, the User can find specific information about the sources in the respective sections of this document or by contacting the Owner.

The Service is not aimed at children under the age of 13
Users declare that they are of age according to the legislation applicable to them. Minors may only use Valueguest with the assistance of a parent or guardian. Under no circumstances may children under the age of 13 use Valueguest.

Automated decision-making processes
When a decision that can produce legal effects for the User or can have a similarly significant impact on his person is taken exclusively with technological tools and without human intervention, there is an automated decision-making process.
As part of the purposes described in this document, Valueguest may use the User’s Personal Data to make decisions based completely or partially on automated processes. Valueguest uses automated decision-making processes to the extent that it is necessary to conclude or execute a contract between the User and the Owner or, if required by law, with the consent given by the User.
Automated decisions depend on technological tools provided by the Owner or by third parties and are generally based on algorithms that meet predefined criteria. The rationale behind the automated decision-making processes aims to:
• enable or improve the decision-making process;
• guarantee Users fair and impartial treatment;
• reduce the potential harm deriving from human error, personal bias or other similar circumstances that could lead to discrimination or imbalances in the treatment of individuals;
• reduce the risk of the User breaching the obligations of a contract.
To obtain further information on purposes, any third-party services and on the specific logic of the automated decision-making processes adopted by Valueguest, the User can refer to the respective sections of this document.

Effects of automated decision-making processes and rights of Users subject to them
Users subject to this type of processing may exercise specific rights aimed at preventing or limiting the potential effects of automated decision-making processes. In particular, Users have the right to:
• receive an explanation regarding each decision taken as a result of an automated decision-making process and express an opinion in this regard;
• challenge the decision by asking the Owner to reconsider it or adopt a new decision on a different basis;
• request and obtain from the Titoalre a human intervention in the treatment. To obtain further information on Users ‘rights and their exercise, the User can refer to the section of this document relating to Users’ rights.

Analysis of User Data and forecasts (“profiling”)
The Owner may process the usage data collected through Valueguest to create or update user profiles. This type of treatment allows the Owner to evaluate the choices, preferences and behavior of the User for the purposes specified in the respective sections of this document.
User profiles can also be created thanks to automated tools, such as algorithms, which can also be offered by third parties. To obtain further information on the profiling activity, the User can refer to the respective sections of this document.
The User has the right to object to this profiling activity at any time. To find out more about the User’s rights and how to exercise them, the User can refer to the section of this document relating to Users’ rights.

Contact information
Data Controller
ValueGuest sas., With registered office at 400 Avenue Roumanille, Biot France
Representative in the EU:
Silvia Stefanoni, Avenue Pierre Courie 3 Antibes, France. Email: silvia@valueguest.com
Data Protection Officer:
Silvia Stefanoni, Avenue Pierre Courie 3 Antibes, France. Email: silvia@valueguest.com
Owner contact email: privacy@Valueguest.com

COMPLETE POLICY

Data Controller
ValueGuest sas., With registered office in 400 Avenue Roumanille, Biot France
Representative in the EU:
Silvia Stefanoni, Avenue Pierre Courie 3 Antibes, France. Email: silvia@valueguest.com
Data Protection Officer:
Silvia Stefanoni, Avenue Pierre Courie 3 Antibes, France. Email: silvia@valueguest.com
Owner contact email: privacy@Valueguest.com

Types of Data collected
Among the Personal Data collected by Valueguest, either independently or through third parties, there are: Cookies, Usage data, name, surname, address, email, password, company name, VAT number, telephone number, address. billing, various types of Data, date of birth, country, User ID and city.
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using Valueguest.
Unless otherwise specified, all data requested by Valueguest are mandatory. If the User refuses to communicate them, it may be impossible for Valueguest to provide the Service. In cases where Valueguest indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which data are mandatory are encouraged to contact the owner.
Any use of Cookies – or of other tracking tools – by Valueguest or by the owners of third-party services used by Valueguest, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described. in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through Valueguest and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

Method and place of processing of the collected Data
Processing methods: The Data Controller adopts the appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of Valueguest (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting) may have access to the Data. providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the processing
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;
• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• the processing is necessary for the execution of a task of public interest or for the exercise of public authority vested in the Data Controller;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.
However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place
The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can check if one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning.

Retention period
The Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
• The Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• The Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the processing of collected data
The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Statistics, Interaction with live chat platforms, Displaying content from external platforms, Registration and authentication , Hosting and backend infrastructure, Contact management and sending messages, Payment management, Data transfer outside the EU, Contacting the User, Interaction with data collection platforms and other third parties and Management of support and contact requests.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data Personal
Data are collected for the following purposes and using the following services:

Contacting the User
Contact by phone (Valueguest)
Users who have provided their phone number may be contacted for commercial or promotional purposes related to Valueguest, as well as to satisfy requests for support.
Personal Data collected: telephone number.

Managing contacts and sending messages
This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
These services may also allow the collection of data relating to the date and time the messages are displayed by the User, as well as to the User’s interaction with them, such as information on clicks on the links inserted in the messages.
Sendgrid (Sendgrid)
Sendgrid is an address management and email message sending service provided by Sendgrid Inc.
Personal data collected: email.
Place of processing: United States – Privacy Policy.

Payment
management Payment management services allow Valueguest to process payments by credit card, bank transfer or other means. The data used for payment are acquired directly by the requested payment service provider without being processed in any way by Valueguest.
Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or notifications regarding payment.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.

Management of support and contact requests
This type of service allows Valueguest to manage support and contact requests received via email or through other tools, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and on the tool used for communication (for example the email address).
Help Scout (Help Scout)
Help Scout is a support and contact request management service provided by Brightwurks Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Hosting and backend infrastructure
This type of service has the function of hosting Data and files that allow Valueguest to function, allow their distribution and make available a ready-to-use infrastructure to provide specific Valueguest functions.
Some of these services work through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.
Heroku (Heroku, Inc.)
Heroku is a hosting service provided by Heroku, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; Germany – Privacy Policy. Subject adhering to the Privacy Shield.

Interaction with live chat platforms
This type of service allows you to interact with live chat platforms, managed by third parties, directly from the Valueguest pages. This allows the User to contact the Valueguest support service or Valueguest to contact the User while he is browsing its pages.
In the event that an interaction service with live chat platforms is installed, it is possible that, even if the Users do not use the service, it collects Usage Data relating to the pages in which it is installed. Additionally, live chat conversations may be recorded.
Crisp widget (Crisp IM SARL)
The Crisp Widget is an interaction service with the Crisp live chat platform, provided by Crisp IM SARL.
Personal Data collected: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: France – Privacy Policy.

Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the Valueguest pages in order to save and reuse data.
In the event that one of these services is installed, it is possible that, even if the Users do not use the service, it collects Usage Data relating to the pages in which it is installed.
Typeform widget (TYPEFORM SL)
The Typeform widget is a service that allows you to interact with the Typeform data collection platform managed by TYPEFORM SL
Personal Data collected: city, surname, date of birth, email, User ID, address, billing address, country, name, telephone number, VAT number and company name.
Place of processing: Spain – Privacy Policy.

Registration and authentication
By registering or authenticating, the User allows the Application to identify him and give him access to dedicated services.
Depending on what is indicated below, the registration and authentication services could be provided with the help of third parties. If this happens, this application will be able to access some data stored by the third party service used for registration or identification.
Direct registration (Valueguest)
The User registers by filling out the registration form and providing his Personal Data directly to Valueguest.
Personal Data collected: surname, email address, billing address, name, telephone number, VAT number, password and company name.

Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracing and examining the use of Valueguest, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the advertisements of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Data transfer outside the EU
The Data Controller may transfer Personal Data collected within the EU to third countries (i.e., all countries outside the EU) only in accordance with a specific legal basis. Therefore, such data transfers are performed according to one of the legal bases described below.
The User can request information from the Owner regarding the applicable legal basis concretely applicable to each individual service.

Transfer of Data from the EU and / or Switzerland to the United States based on the Privacy Shield (Valueguest)
When this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the United States takes place under the Privacy Agreement Shield EU – USA or Switzerland – USA.
In particular, the Personal Data are transferred to subjects who have self-certified under the Privacy Shield and therefore guarantee an adequate level of protection of the transferred Data. The services involved in the transfer of data are listed in the respective sections of this document. Among them, those who adhere to the Privacy Shield can be identified by consulting the relative privacy policy or by checking the status of their registration in the official Privacy Shield list.
The rights of Users under the Privacy Shield are described in an updated form on the website of the United States Department of Commerce. The transfer of Personal Data from the EU or Switzerland to the United States to subjects who are no longer registered in the Privacy Shield is admissible only according to another valid legal basis. Users can request information from the Data Controller regarding these legal bases.
Personal data collected: various types of data.

Other legal basis for the transfer of Data to third countries (Valueguest)
When no other legal basis is applicable, the Personal Data can be transferred from the EU to third countries only under one of the following conditions:
• the transfer is necessary to execute a concluded contract between User and Owner or pre-contractual measures adopted at the User’s request;
• the transfer is necessary to conclude or execute a contract stipulated in the interest of the User by the Owner and another natural or legal person;
• the transfer is necessary for reasons of public interest; * the transfer is necessary to ascertain, exercise or defend a legal claim;
• the transfer is necessary to protect the vital interests of the interested party or other persons, when the interested party is physically or legally unable to express consent. In such cases, the Data Controller will inform the User on the legal basis applicable to the actual transfer through Valueguest.
Personal data collected: various types of data.

Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Valueguest and interact with them.
In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages in which it is installed.
Headway Widget (Oskar Krawczyk / Piotr Zalewa) Headway
Widget is a content viewing service operated by Headway and Oskar Krawczyk / Piotr Zalewa.
Personal Data collected: Cookies and Usage Data.
Place of processing: Poland – Privacy Policy.

Further information on Personal Data

User rights
Users can exercise certain rights with reference to the data processed by the owner.
In particular, the User has the right to:
• withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.
• oppose the processing of their data. The User can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
• access their data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the processing and to receive a copy of the data processed.
• verify and ask for rectification. The User can verify the correctness of his / her Data and request its updating or correction.
• obtain the limitation of the processing. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose than their conservation.
• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
• receive their data or have them transferred to another owner. The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it.
• propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or act in court.

Details on the right to object
When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons related to their particular situation.
Users are reminded that, if their data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise the rights
To exercise the rights of the User, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Cookie Policy
Valueguest uses Cookies. To learn more and to read the detailed information, the User can consult the Cookie Policy.

Further information on the treatment

Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of Valueguest or related Services by the User.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

Specific information
At the request of the User, in addition to the information contained in this privacy policy, Valueguest may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System
logs and maintenance For needs related to operation and maintenance, Valueguest and any third party services used by it may collect system logs, which are files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track”
requests Valueguest does not support “Do Not Track” requests.
To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on Valueguest as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details held by the Owner. Therefore, please consult this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)
Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data
This is the information collected automatically through Valueguest (also from third-party applications integrated into Valueguest), including: the IP addresses or domain names of the computers used by the User connecting with Valueguest, the addresses in URI (Uniform Resource Identifier ), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin , the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application,with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

User
The individual using Valueguest who, unless otherwise specified, coincides with the Data Subject.

Interested
The natural person to whom the Personal Data refers.

Data Processor (or Manager) The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Data Controller)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the measures security related to the operation and use of Valueguest. The Data Controller, unless otherwise specified, is the owner of Valueguest.

Valueguest (or this Application)
The hardware or software tool through which the Personal Data of Users are collected and processed.

Service
The Service provided by Valueguest as defined in the relative terms (if available) and on this site / application.

European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookie
Small piece of data stored in the User’s device.
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Legal references
This privacy statement has been drawn up on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to Valueguest.
Last modified: November 23, 2018
iubenda hosts this page and collects the Personal Data strictly necessary for the contents of this page to be available

VALUEGUEST PRIVACY POLICYValueguest collects some Personal Data from its Users.

VALUEGUEST PRIVACY POLICY
Valueguest collects some Personal Data from its Users.