1. Introduction
Breakwater SRL (“We”) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (GDPR).

2. Definitions
Data controller: A controller determines the purposes and means of processing personal data.

Data processor: A processor is responsible for processing personal data on behalf of a controller.

Data subject: Natural person Website: www.breakwatercomo.com

Categories of data: Personal data

Personal data: the GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier (please refer to Article 6 of GDPR), e.g., name, surname, private email address, private phone number. Online identifiers include IP addresses and cookies.

Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party: A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

3. About us
Breakwater SRL is the data controller. This means we decide how your personal data is processed and for what purposes. For all data matters, please contact us writing to Breakwater srl, Via A. Stoppani 6, 22017 Menaggio (CO).

4. The purpose(s) of processing your personal data
We use your personal data for the following purposes:

4.1 We may use your name, surname, phone numbers and email to complete any future booking with us and organize your stay.

4.2. We may from time to time contact you with information about brochures, presentations or news about us. At any time, you may request to discontinue receiving marketing correspondence by mail from BREAKWATER SRL.

4.3. We have taken all reasonable steps to have appropriate security measures in place to protect your information. The transmission of information via Internet is never completely secure. We exclude our liability for personal data lost in transmission to our website.

4.4. At any time, depending on the specific processing, you may: revoke your consent to the processing, know which of your personal data we have in our possession, its origin and how it is used, request the update, correction, or integration and in the cases provided for by the current provisions, the cancellation, the limitation of processing or oppose their processing.

5. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of data:

5.1. Personal data for contact purposes
We usually collect some of your personal data such as: name, surname, phone number and email to be able to contact you back once you reach us using the contact form. We may also collect some information necessary to facilitate potential booking requested by you or members of your party. You are responsible for ensuring that other members of your party are aware of the content of this policy and consent to your acting on their behalf in all your dealings with us. We might collect information about your browsing on www.breakwatercomo.com, such as the pages you visit and how you interact with the single page and we save information on our servers.

5.2. Online surveys
We value opinions and comments from customers Breakwater SRL and you may have the opportunity to give us your feedback through site surveys and reviews (eventually done by third parties). In conducting these surveys and reviews, we may ask for your Personal Information so that we (or third parties) can appropriately identify you. Survey, Review and Personal Information collected might be aggregated and used to make improvements to the Website. Participation in these surveys and reviews is completely voluntary and you therefore have a choice whether or not to disclose the required information.

5.3. Non-Personally identifiable information
Some non-personally identifiable information and statistical data is collected and stored automatically when a Data Subject visits the Website. If a Data Subject does nothing during its visit but browse though the Website, read pages or download information, we may gather and store certain statistical information about your visit automatically. This information does not identify a Data Subject personally. Our system collects data in the server log that may include: IP address, domain name, type of browser, operating system, online activity (including, without limitation, pages viewed, search requests, and purchases made). We may collate and aggregate this data and use it for statistical purpose. For example, the aggregated data helps us to determine the volume of its Website users’ interest in areas of the Website. It also helps us understand how it can improve the navigation and content of the Website. We may disclose this information to third parties.

5.4. How do we use the personal data we collect?
Your personal data might have been acquired with us via:
- Requests through our contact form on our Website;
- Telephone and/or email;
- Social Media requests/messages through LinkedIn, Instagram, Facebook and Tiktok;

BREAKWATER SRL collects and processes your personal data for the following purposes:
- Management of requests to our Team, which uses your personal data to contact you back and assist you about any questions you might have;
- Statistical analysis and surveys. We use some information about your use of the site to perform statistical analysis and surveys in order to improve our offer and our Website;
- Subject to your express consent, we may use the contact details you have provided for commercial communications on our services, in order to update you on news about us;
- Should you wish to not receive further communications from Breakwater SRL or would like to limit the way in which to be contacted, you may interrupt these communications at any time by simply clicking on the appropriate unsubscribe link at the bottom of each communication;
- In relation to all the activities above mentioned, we will process your personal data mainly through IT and electronic means; the means we use guarantee high safety standards, in full compliance with current legislations;

6. What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR) 7. Sharing your personal data Your personal data will be treated as strictly confidential, and will be shared only in the following circumstances:

7.1. We may need to disclose your information where required by law, where such a request is made by a legal authority.

7.2. We may also disclose information to organizations who act as “data processors” on our behalf, or to organizations that perform business functions on our behalf. These functions may include research and analysis, marketing, monitoring and measuring your data.

8. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary, in any case no longer then 5 years from your last interaction with us and we only retain your data for marketing purposes such as sending regular news about us. You have the right to remove yourself from our database at any time.

9. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data.

10. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that we provide you with your personal data and where possible, to transmit data directly to another data controller (known as the right to data portability);

11. Transfer of Data Abroad
We have taken all reasonable steps to have appropriate security measures in place to protect your information. However, the transmission of information via the internet is never completely secure. We exclude our liability for personal data lost in transmission to the website.

12. Automated Decision Making
We don’t use any form of automated decision making in our business.

13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

14. External Links
Please note that our website contains certain hyperlinks to websites owned by third parties. This privacy statement covers websites owned and controlled by us only. Links to other websites and any information collected by these sites are not covered by this privacy statement.

15. Security
We will make reasonable efforts to ensure that information provided by the User will be maintained in a secure environment. Unfortunately, no data transmission via the Internet can be guaranteed as being 100% secure. Consequently, while we strive to protect your personal information, we can’t guarantee the security of any information transmitted to Breakwater SRL or from the website, and the User provides such information at its own risk.

The Website is hosted by a third-party service provider which is neither controlled by nor affiliated with Breakwater SRL. We can make no representation or warranty as to the security measures of any third party, including, but not limited to, the host of the Website. We expressly exclude any and all liability arising out of or in connection with acts or omissions by any third party including, but not limited to, the host of the Website. Breakwater SRL recommends that you review the privacy policy of any third party prior to using any third party’s website.

16. Cookies
Non-personal information may also be collected with the use of cookies. “Cookies” are small text files a website can use to recognize repeat users. When someone visits the Website, a cookie is placed on the visitor’s machine (provided that the visitor’s web browser has been set to accept cookies) or is read if the visitor has visited the Website previously. We may collect aggregated Website-visitation statistics using cookies. If the User does not wish to accept cookies it should set its web browser to reject cookies or to warn the User prior to accepting cookies.

17. Links to Third Party Website
Links to third party websites (not maintained by Breakwater SRL) may appear to our Website. If you use these links, you will leave this Website. Breakwater SRL does not have control over and is not responsible for any of these websites or their content. Breakwater SRL does not endorse or make any representations or warranties about such websites, or any information, opinions, software or other products or materials which may be found therein, nor does Breakwater SRL make any representations or warranties about any results that may be obtained from using them. If you decide to access any of the third party websites linked to this Website, you agree that you do this entirely at your own risk. It is your responsibility to ensure that any links you select or program/software/data/material you download (whether from this Website or other websites) is free of viruses. Trojan horses, worms, defects and similar potentially are harmful items. You should be aware that linked third party websites may contain rules and regulations, privacy provisions, confidentially provisions, transmission of personal data provisions, and other provisions that differ from the provisions provided on this Website.

18. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

19. How to contact us
To exercise all relevant rights, queries or complaints please contact Breakwater SRL, c/o Via A. Stoppani 6, 22017 Menaggio (CO), Italy.