Effective date: May 21, 2018
Cipriani ("us", "we", or "our") operates the website (the "Website").
Website - The website address, www.cipriani.com, operated by Cipriani
Personal Data - Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data - Usage Data is data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).
Cookies - Cookies are small pieces of data stored on your device (computer or mobile device).
Data Processors (or Service Providers) - Data Processor (or Service Provider) meansany natural or legal person who processes the data on behalf of the DataController. We may use the services of various ServiceProviders in order to process your data more effectively.
Data Subject (or User) - Data Subject is any living individual who isusing our Website or has provided information to us and is the subject ofPersonal Data.
The Controller Of Your Personal Information
Under applicable data protection laws, we are required to advise you who is the controller of your personal information. The controller of, and the person responsible for, the personal information covered by this Policy C Management S.a r.l. and/or Cipriani USA, Inc. 110 East 42nd St, 5th Floor, NY 10017
Information Collection And Use
We collect several different types of information for various purposes as follows:
Types of Data Collected
While using our website, we may ask you to provide us with certain personally identifiable information ("Personal Data") that may be used to respond to questions you may have, provide our services to you, or allow you to subscribe to our newsletters and exciting promotional materials or offers. The personally identifiable information we collect may include, but is not limited to:
First name and last name
Images and video and audio data via security cameras located in public areas
Cookies and Usage Data
We may also collect information how the Website is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type,browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons,tags, and scripts to collect and track information and to improve and analyze our Website.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies,you may not be able to use some portions of our Website.
Examples of categories of Cookies we use:
Necessary Cookies -These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
Performance Cookies: We use Performance cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.
Targeting Cookies: These cookies are set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They work by uniquely identifying your browser and device.
Use of Data
Cipriani uses the collected data for various purposes:
To allow us to manage your reservation;
To process gift certificates;
To process the purchase of products or goods from us on the Website;
To deliver catering or food orders to you from our locations;
To process payments received at our locations for meals and/or services provided.
To communicate with you [including sending you information about events and services which we think may be of interest to you and to which you have consented. You will be able to opt-out of such communications at any time];
To allow you to participate in interactive features of our Website when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Website
To monitor the usage of our Website
To detect, prevent and address technical and/or security issues
Legal Basis for Processing Personal Data Under General Data Protection Regulation(GDPR)
Cipriani may process your Personal Data because:
It is necessary for the performance of a contract between us for the provision ofservices or in order to take steps at your request prior to entering into sucha contract (for example, making a reservation, booking an event, or thecommunications leading up to making a reservation or booking an event).
You have given us permission to do so. In the case of Marketing, all communications to you will be based on consent, which you are free to remove at any time.
The processing is in our legitimate interests and it's not overridden by your rights. Examples of where we may use legitimate interests is in the collection of debts owed to us or the cyber security analysis of website logs to identify malicious activity.
For payment processing purposes relative to the contract
In pursuit of our legitimate interests, to record CCTV footage to ensure the safety and security of our premises, staff and customers
To comply with the law
Retention of Data
Cipriani will also retain Website Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.
Transfer Of Data
Your information, including Personal Data, may be transferred to ? and maintained on ? computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, includingPersonal Data, to the United States and process it there.
Sharing Of Data
We will not disclose personal information we hold about you to any third party except where required by law or as follows:
(i) to companies in the Cipriani group;
(ii) to third parties who provide services to us, and act as data processors for us;
(iii) to professional advisers including lawyers, bankers, auditors and insurers;
Please note that we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Disclosure for Law Enforcement
Under certain circumstances, Cipriani may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Cipriani may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Cipriani
To prevent or investigate possible wrongdoing in connection with the Website
To protect the personal safety of users of the Website or the public
To protect against legal liability
We may use third-party Service Providers to monitor and analyze the use of our Website.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
We may provide paid products and/or services within the Website.In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legallyr equired to do so.
"Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do NotTrack is a preference you can set in your web browser to inform websites thatyou do not want to be tracked.
You can enable or disable Do Not Track by visiting thePreferences or Settings page of your web browser.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA),you have certain data protection rights. Cipriani aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
Access to your personal data: You may request access to a copy of your personal data.
Right to withdraw: Where you have given your consent for us to use your personal data, you may withdraw your consent at any time. Please contact us using the details located below or if you would like to withdraw your consent and we will delete your data in line with your right to erasure.
Rectification: You may ask us to rectify inaccurate information held about you. If you would like to update the data we hold about you, please contact us using the details below and provide the updated information.
Erasure: You may ask us to delete your personal data. If you would like us to delete the personal data we hold about you, please contact us using the details below, specifying why you would like us to delete your personal data.
Portability: You may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such personal data to another data controller.
Make a complaint: If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the General Data Protection laws you have the right to lodge a complaint at the Information Commissioner's Office (ICO) (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data ProtectionAuthority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in theEuropean Economic Area (EEA).
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Website does not address anyone under the age of 18("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.