Mountain village with snow-covered houses and rooftop pool in winter

Privacy

Privacy Statement and Cookie Policy

Excelsior Dolomites Life Resort ****s, having registered office in Via Valiares 44, IT-39030 San Vigilio di Marebbe (hereafter Excelsior Dolomites Life Resort) is committed to protecting the online privacy of users. Pursuant to art. 13 of EU Regulation 2016/679 (hereafter: "Regulation"), this statement was written to inform you on our privacy policy and how your personal data is handled when you visit our website (hereafter “Website”), as well as to enable you to give your specific and informed consent to the processing of your Personal Data, where applicable. Please be informed that parental consent is required for children under 16 years of age. The information and data provided by you, or otherwise acquired through use of our online services (hereafter "Services") on your part, will be processed in compliance with the Regulation and the Data Controller’s obligation to confidentiality.

Pursuant to the Regulation, Excelsior Dolomites Life Resort shall process Personal Data based on the principles of lawfulness, fairness, transparency, limitation of purpose and retention, data minimisation, accuracy, integrity and confidentiality.

TABLE OF CONTENTS

  1. Data Controller
  2. Personal Data subject to processing
    1. Browsing data
    2. Special categories of Personal Data
    3. Data volunteered by Data Subjects
    4. Cookies
  3. Purposes of data processing
  4. Lawful basis and mandatory or optional nature of data processing
  5. Disclosure of Personal Data
  6. Transfer of Personal Data
  7. Retention of Personal Data
  8. Your rights
  9. Additional services and external service providers
  10. Changes
1. Data Controller

In relation to the data processing carried out through our website, the Data Controller as defined above is Excelsior Dolomites Life Resort ****s. For any information regarding the processing of Personal Data by the Data Controller, including the list of Data Processors, please write to the following address: info@myexcelsior.com

2. Personal Data subject to processing

Please be informed that as a result of website browsing, the Data Controller will collect and process Personal Data that may consist of information like name and surname, identification number, online identifier, mail address, e-mail address, landline and/or mobile telephone number or information on one or more physical, physiological, psychological, financial, cultural or social features relating to an identified or identifiable person (hereafter “Personal Data”).

The following Personal Data is processed through our Website:

a. Browsing data

During normal operation, the computer systems and software used to operate our Website acquire some Personal Data the transmission of which is implicit in the Internet communication protocols. The collection of this information is intended to be associated with identified parties; however, the data collected might by its nature allow users to be identified through processing and association with data held by third parties. This category of data includes IP addresses or domain names of computers used by users who connect to the Website, URI (Uniform Resource Identifier) of requested resources, the time of request and method used to submit it to the server, the size of the file obtained in reply, the numerical code indicating the server response status (successful, error, etc.) and other parameters relating to the user's operating system and IT environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to ensure its correct functioning by identifying any anomalies and/or abuses, and are therefore deleted immediately after processing. The data could be used to ascertain responsibility in the event of possible computer crimes against the Website or third parties; except for this possibility, the data collected from the Website is removed within a short period of time.

b. Special categories of Personal Data

If you send us your application via e-mail or through our website, you might provide us with Personal Data that falls within special categories as set forth in art. 9 of the Regulation, namely: “[…] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and [...] genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation”. Please do not disclose this type of data unless it is strictly necessary. Please be informed that if you do choose to provide this type of data without giving your specific consent to the processing (e.g. by sending a CV), the processing on our part will relate to data made manifestly public by the Data Subject, as provided for by art. 9(1)(e) of the Regulation. Therefore, the Data Controller will be released from any liability or dispute whatsoever in connection with the processing of such data. As previously mentioned, explicit consent to the processing of special categories of Personal Data is fundamental if you do choose to disclose such information.

Please be also informed that the Data Controller may view any social media profiles made openly available on professional networking sites or platforms (e.g. LinkedIn).

c. Data volunteered by Data Subjects

We may process Personal Data of third parties that you send to the Data Controller when using certain services on our Website (e.g. the request/contact/booking forms). In these cases, you act as independent Data Controller, thereby assuming all the obligations and liabilities set by law. In this sense, you release the Data Controller from any and all responsibilities and obligations with respect to any dispute, claim, compensation for damages etc. that may be received from third parties whose Personal Data has been processed through the Website functions in violation of applicable data protection laws. In any case, if you provide or process Personal Data of third parties while using our Website, you warrant – assuming full liability – that processing has a lawful basis in compliance with art. 6 of the Regulation.

d. Cookies General information about cookies

Cookies are small text files which can be stored by a website, and with the help of the browser, on the hard drive of a client computer, to save smaller amounts of website information for a specific period of time. Generally, there are different types of cookies; some are essential for the functioning of the website, such as navigation or shopping cart cookies. Furthermore, there are so-called Analytics cookies, which collect information, for instance about the number of website visitors and the way they found the website. Function cookies allow the website to remember your selection (e.g. selected filter settings or automatic language setting of a website).

In addition, so-called profiling cookies record the user's preferences and actions. A user profile is created on the basis of this information. This serves to combine advertising messages with the interests of the user and thus enables more target-group-specific advertising. In many cases, cookies from third parties are used by the website operator to broadcast personalised advertising.

Compulsory consent for cookies

Website visitors must actively consent to the use of cookies, which are not essential for the functionality of the website, and also have the right to revoke their consent at any time.

This website uses a technology called CMP (Consent Management Platform) to administer this right. When you visit the website, a banner appears informing you about the use of cookies, giving you various options for accepting them (all cookies, individual categories of cookies, or each individual cookie separately), and providing detailed information about the various cookies. The CMP remembers the settings made by visitor and applies them the next time the user visits the website. Here the website visitor can exercise the right of withdrawal or adjust the settings.

How to block cookies in your browser settings
Firefox:
  1. Go to Menu and then to Options.
  2. Select the Privacy panel.
  3. Set Firefox will to: Use custom settings for history.
  4. Remove the check mark from Accept cookies from sites.
  5. Click OK to close the Options window.

Click here for more details and information: https://support.mozilla.org/en-US/kb/block-websites-storing-site-preferences

Google Chrome
  1. Click the Chrome menu on the browser toolbar and go to Settings.
  2. Select „Show advanced settings“.
  3. In the "Privacy" section, click the Content settings button.
  4. In the "Cookies" section, select "Block sites from setting any data".
  5. Click OK to conclude the action.

Click here for more details and information: https://support.google.com/chrome/answer/95647?hl=en-GB

Internet Explorer
  1. Click Extras on the menu and select internet settings.
  2. Select the Privacy panel.
  3. To set what types of cookies are blocked or allowed, move the slider. Generally, if the slider is all the way up, all cookies are blocked; if the slider is down, all cookies are allowed.
  4. Click OK to conclude the action.

Click here for more details and information: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Safari
  1. Choose Safari Preferences, and then click Privacy.
  2. In the “Block cookies” section, specify if and when Safari should accept cookies from websites. To see an explanation of the options, click the Help button (question mark).

Click here for more details and information: https://support.apple.com/kb/PH5042?locale=en_US


3. processing

If necessary and with your specific consent, we will process your Personal Data for the following purposes:

  1. Provide the services you require;
  2. Respond to requests for assistance, information or bookings;
  3. View CVs and contact applicants;
  4. Comply with legal and tax obligations;
  5. Marketing purposes: the data provided may be used, subject to explicit and specific consent, for the sending of promotional and marketing communications, including newsletters and market surveys, using automated tools (SMS, MMS, e-mails, push notifications) and non-automated tools (paper mail, telephone calls by operators). The lawful basis for the processing of your data for these purposes is art. 6, paragraph 1, letter a) of the Regulation. The processing of data for direct marketing is optional and based exclusively on your free choice, and denying your consent for this purpose will not affect the use of services on your part.

4. Lawful basis and mandatory or optional nature of data processing

The lawful basis for the processing of Personal Data for the purposes referred to in section 3 (a-b-c) is art. 6(1)(b) of the Regulation (performance of a contract) as the data is necessary to provide the services required and/or to respond to requests from the interested party. Giving your Personal Data for these purposes is optional, but indispensable to activate the services provided by the Website, to answer requests or evaluate CVs. With specific reference to the purpose 3.c and the viewing of profiles on professional networking platforms made freely available on the Internet, as mentioned in section 2.b, the lawful basis is art. 6(1)(f) of the Regulation, i.e. the legitimate interest of the holder in verifying the candidate’s suitability for the open position and any potential risks.

For the purposes illustrated in section 3.d, the lawful basis is art. 6(1)(c) of the Regulation (compliance with legal obligations). Once provided, Personal Data must be processed for the Data Controller to comply with legal obligations.

Art. 6(1)(a) of the Regulation (your consent) is the lawful basis for the processing of data for the purposes referred to in section 3.e. In this respect, activities that involve the direct sending of advertising material, direct sales or market surveys and commercial communications in relation to products or services similar to those you purchased, the Data Controller may use your e-mail and mail addresses without your consent, in accordance with and within the limits allowed by art. 130, paragraph 4 of the Italian Data Protection Code and the by the Decision of the Italian Data Protection Authority of 19 June 2008. The lawful basis for the processing of your data for this purpose is Art. 6(1)(f) of the Regulation (legitimate interest).


5. Disclosure of Personal Data

For the purposes listed in section 3, your Personal Data may be shared with:

  1. Parties who typically act as Data Processors, namely: i) persons and/or organisations providing us assistance and counselling services on marketing and communication; ii) persons and/or organisations who assist us in providing certain services (e.g. hosting providers) iii) persons and/or organisations who perform technical maintenance activities (including maintenance of network equipment and electronic communication networks); (collectively, “Recipients”);
  2. Persons, entities or authorities to whom Personal Data must be disclosed by virtue of legal provisions or orders given by a competent authority;
  3. Parties authorised by the Data Controller to perform activities that are strictly related to the provision of services or for the purposes listed in section 3, who have committed themselves to confidentiality or have legal obligation to confidentiality (e.g. employees).

6. Transfer of Personal Data

Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area. The Data Controller ensures that these Recipients process your Personal Data in compliance with the Regulation. Transfer of Personal Data may be based on an adequacy decision, on Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis. For further information please contact the Data Controller by sending an e-mail to: info@myexcelsior.com


7. Retention of Personal Data

Personal Data processed for the purposes referred to in section 3(a-b) will be kept only for as long as strictly necessary to achieve those purposes. In any case, since data is used in order to provide services, the Data Controller will process the Personal Data up to the time allowed by Italian law (art. 2946 of the Italian Civil Code and subsequent amendments). With regard to any CVs submitted through the Website or by e-mail (see section 3.c), the Personal Data will be kept for as long as necessary for the purpose. The Data Controller may contact the candidate again shortly before the indicated deadline to ask for an extension of the retention period.

Personal Data processed for the purposes referred to in section 3(d) will be stored for as long as provided for by applicable laws and regulations.

Personal Data processed for the purposes referred to in section 3(e) will be kept until we have consent; if you do not withdraw your consent, your data will be stored for a time deemed appropriate.

For more information on our data retention policy and criteria, please contact: info@myexcelsior.com


8. Your rights

Pursuant to Art. 15 and following of the Regulation, you have the right to obtain access to your Personal Data at any time. You have the right to request from the Data Controller rectification or erasure of your data, as well as to object to and restrict processing of your data in the cases provided for by Art. 18 of the Regulation. You have the right to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format in compliance with Art. 20 of the Regulation.

Requests must be submitted in written form and sent to:info@myexcelsior.com

In any case, you also have the right to lodge a complaint with the competent Supervisory Authority (Italian Data Protection Authority) if you consider that the processing of your Personal Data infringes the applicable law, pursuant to Art. 77 of the Regulation.


9. Additional services and external service providers

ADDITIVE+ LANDINGPAGE - Online Marketing and Landing Pages

Beside our website we do also operate optimized landing pages for means of hotel online marketing. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”), our partner in the field of hotel digital marketing. The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
You can prevent the data collection connected to your use of our online services through cookies and the processing of this data by Google, by installing the browser-plugin available at the following link: https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence.
Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. If you continue using the website or click on the respective button you consent to the use of cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.

ADDITIVE+ MARKETING AUTOMATION - Direct Marketing

In order to increase customer loyalty and to sell our services and additional services we use hotel online marketing software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”) within the field of hotel marketing automation.
Therefore your data, which we gather and process in connection with your request, reservation, order, activation, registration or the transmission of other contact forms on our website, will be analysed and used to provide you with automatically generated offers for our services and additional services. Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.
You can deny the use of your data for this purpose anytime by clicking on the “unsubscribe” link in the respective message.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the prevention of competitive disadvantages, the increase in brand awareness and the maximisation of our economic success through an optimal use of the acquired contacts.

ADDITIVE+ NEWSLETTER

On our website you have the possibility to subscribe to our newsletter. For the subscription we need your email address and your consent to receive our newsletter through ADDITIVE, our provider for hotel e mail marketing. To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin in our hotel newsletter tool.
After signing up for our newsletter you will receive an email containing a link to confirm the subscription.
Your subscription can be cancelled any time by clicking on the cancellation link in the respective newsletter.
To process your subscriptions and to send our newsletters we use software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”). Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.


10. Changes

This Privacy Policy takes effect on 16.10.2025. The Data Controller reserves the right to amend or update the content of this policy, in part or in full, especially in the case of changes in the applicable law. Since the content of our Website and Privacy Policy may be subject to change, we recommend you visit this section regularly for updates on how we collect and use Personal Data.

How to block cookies in your browser settings
Firefox:
  1. Go to Menu and then to Options.
  2. Select the Privacy panel.
  3. Set Firefox will to: Use custom settings for history.
  4. Remove the check mark from Accept cookies from sites.
  5. Click OK to close the Options window.

Click here for more details and information: https://support.mozilla.org/en-US/kb/block-websites-storing-site-preferences

Google Chrome
  1. Click the Chrome menu on the browser toolbar and go to Settings.
  2. Select „Show advanced settings“.
  3. In the "Privacy" section, click the Content settings button.
  4. In the "Cookies" section, select "Block sites from setting any data".
  5. Click OK to conclude the action.

Click here for more details and information: https://support.google.com/chrome/answer/95647?hl=en-GB

Internet Explorer
  1. Click Extras on the menu and select internet settings.
  2. Select the Privacy panel.
  3. To set what types of cookies are blocked or allowed, move the slider. Generally, if the slider is all the way up, all cookies are blocked; if the slider is down, all cookies are allowed.
  4. Click OK to conclude the action.

Click here for more details and information: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Safari
  1. Choose Safari Preferences, and then click Privacy.
  2. In the “Block cookies” section, specify if and when Safari should accept cookies from websites. To see an explanation of the options, click the Help button (question mark).

Click here for more details and information: https://support.apple.com/kb/PH5042?locale=en_US


3. processing

If necessary and with your specific consent, we will process your Personal Data for the following purposes:

  1. Provide the services you require;
  2. Respond to requests for assistance, information or bookings;
  3. View CVs and contact applicants;
  4. Comply with legal and tax obligations;
  5. Marketing purposes: the data provided may be used, subject to explicit and specific consent, for the sending of promotional and marketing communications, including newsletters and market surveys, using automated tools (SMS, MMS, e-mails, push notifications) and non-automated tools (paper mail, telephone calls by operators). The lawful basis for the processing of your data for these purposes is art. 6, paragraph 1, letter a) of the Regulation. The processing of data for direct marketing is optional and based exclusively on your free choice, and denying your consent for this purpose will not affect the use of services on your part.

4. Lawful basis and mandatory or optional nature of data processing

The lawful basis for the processing of Personal Data for the purposes referred to in section 3 (a-b-c) is art. 6(1)(b) of the Regulation (performance of a contract) as the data is necessary to provide the services required and/or to respond to requests from the interested party. Giving your Personal Data for these purposes is optional, but indispensable to activate the services provided by the Website, to answer requests or evaluate CVs. With specific reference to the purpose 3.c and the viewing of profiles on professional networking platforms made freely available on the Internet, as mentioned in section 2.b, the lawful basis is art. 6(1)(f) of the Regulation, i.e. the legitimate interest of the holder in verifying the candidate’s suitability for the open position and any potential risks.

For the purposes illustrated in section 3.d, the lawful basis is art. 6(1)(c) of the Regulation (compliance with legal obligations). Once provided, Personal Data must be processed for the Data Controller to comply with legal obligations.

Art. 6(1)(a) of the Regulation (your consent) is the lawful basis for the processing of data for the purposes referred to in section 3.e. In this respect, activities that involve the direct sending of advertising material, direct sales or market surveys and commercial communications in relation to products or services similar to those you purchased, the Data Controller may use your e-mail and mail addresses without your consent, in accordance with and within the limits allowed by art. 130, paragraph 4 of the Italian Data Protection Code and the by the Decision of the Italian Data Protection Authority of 19 June 2008. The lawful basis for the processing of your data for this purpose is Art. 6(1)(f) of the Regulation (legitimate interest).


5. Disclosure of Personal Data

For the purposes listed in section 3, your Personal Data may be shared with:

  1. Parties who typically act as Data Processors, namely: i) persons and/or organisations providing us assistance and counselling services on marketing and communication; ii) persons and/or organisations who assist us in providing certain services (e.g. hosting providers) iii) persons and/or organisations who perform technical maintenance activities (including maintenance of network equipment and electronic communication networks); (collectively, “Recipients”);
  2. Persons, entities or authorities to whom Personal Data must be disclosed by virtue of legal provisions or orders given by a competent authority;
  3. Parties authorised by the Data Controller to perform activities that are strictly related to the provision of services or for the purposes listed in section 3, who have committed themselves to confidentiality or have legal obligation to confidentiality (e.g. employees).

6. Transfer of Personal Data

Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area. The Data Controller ensures that these Recipients process your Personal Data in compliance with the Regulation. Transfer of Personal Data may be based on an adequacy decision, on Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis. For further information please contact the Data Controller by sending an e-mail to: info@myexcelsior.com


7. Retention of Personal Data

Personal Data processed for the purposes referred to in section 3(a-b) will be kept only for as long as strictly necessary to achieve those purposes. In any case, since data is used in order to provide services, the Data Controller will process the Personal Data up to the time allowed by Italian law (art. 2946 of the Italian Civil Code and subsequent amendments). With regard to any CVs submitted through the Website or by e-mail (see section 3.c), the Personal Data will be kept for as long as necessary for the purpose. The Data Controller may contact the candidate again shortly before the indicated deadline to ask for an extension of the retention period.

Personal Data processed for the purposes referred to in section 3(d) will be stored for as long as provided for by applicable laws and regulations.

Personal Data processed for the purposes referred to in section 3(e) will be kept until we have consent; if you do not withdraw your consent, your data will be stored for a time deemed appropriate.

For more information on our data retention policy and criteria, please contact: info@myexcelsior.com


8. Your rights

Pursuant to Art. 15 and following of the Regulation, you have the right to obtain access to your Personal Data at any time. You have the right to request from the Data Controller rectification or erasure of your data, as well as to object to and restrict processing of your data in the cases provided for by Art. 18 of the Regulation. You have the right to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format in compliance with Art. 20 of the Regulation.

Requests must be submitted in written form and sent to:info@myexcelsior.com

In any case, you also have the right to lodge a complaint with the competent Supervisory Authority (Italian Data Protection Authority) if you consider that the processing of your Personal Data infringes the applicable law, pursuant to Art. 77 of the Regulation.


9. Additional services and external service providers

ADDITIVE+ LANDINGPAGE - Online Marketing and Landing Pages

Beside our website we do also operate optimized landing pages for means of hotel online marketing. To process your request, reservation, order, activation, registration or the transmission of other contact forms on our website as well as to save and store your data we use cloud services, CRM systems and software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”), our partner in the field of hotel digital marketing. The adequate level of data protection is based on data processing agreements with the respective company.
Our landing pages use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics enables website operators to analyse the user behavior of the visitors. The information about the user behavior is transmitted to and stored by Google on its servers.
Your IP address is collected but immediately anonymised (for example by deleting the last 8 bits). As a result the geolocation data is less accurate.
You can prevent the data collection connected to your use of our online services through cookies and the processing of this data by Google, by installing the browser-plugin available at the following link: https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh
ADDITIVE has an insight into data gathered through Google Analytics. This data will be used only to analyse the use of our websites and to evaluate our marketing and distribution strategies.
Our website and landing pages also use functions provided by ADDITIVE for the multi-channel monitoring of the use of our websites as well as marketing and distribution strategies like landing pages, newsletter and social media presence.
Information about your visits and submitted forms on our websites are also transmitted to ADDITIVE in order to evaluate and optimize our marketing and sales measures.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the improvement of our products and services and our web presence through the analysis of the use of our website as well as marketing and distribution strategies.
Our website and our landing pages also use remarketing functions provided by Google Inc. (“Google”) and by Meta Platforms Inc. (“Meta”). Therefore, Meta and Google will know that you have visited our website. This way visitors of our website and of our landing pages will find ads adapted to their interests on Google’s advertising platforms and on the social media platforms Facebook and Instagram.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit a (consent) of the GDPR.
When you visit our landing pages a banner will inform you about the use of cookies for remarketing functions. If you continue using the website or click on the respective button you consent to the use of cookies. You can deny your consent anytime, by visiting the page containing the cookie information and denying the use in the banner that will be displayed.

ADDITIVE+ MARKETING AUTOMATION - Direct Marketing

In order to increase customer loyalty and to sell our services and additional services we use hotel online marketing software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”) within the field of hotel marketing automation.
Therefore your data, which we gather and process in connection with your request, reservation, order, activation, registration or the transmission of other contact forms on our website, will be analysed and used to provide you with automatically generated offers for our services and additional services. Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.
You can deny the use of your data for this purpose anytime by clicking on the “unsubscribe” link in the respective message.
The data processing takes place in accordance with the requirements of art. 6 para. 1 lit f (legitimate interests) of the GDPR.
Our objective in accordance with the GDPR (legitimate interests) is the prevention of competitive disadvantages, the increase in brand awareness and the maximisation of our economic success through an optimal use of the acquired contacts.

ADDITIVE+ NEWSLETTER

On our website you have the possibility to subscribe to our newsletter. For the subscription we need your email address and your consent to receive our newsletter through ADDITIVE, our provider for hotel e mail marketing. To provide you with relevant information we also gather and process voluntary information concerning interests, name, date of birth and country/region of origin in our hotel newsletter tool.
After signing up for our newsletter you will receive an email containing a link to confirm the subscription.
Your subscription can be cancelled any time by clicking on the cancellation link in the respective newsletter.
To process your subscriptions and to send our newsletters we use software provided by ADDITIVE s.n.c., 39011 Lana (BZ), Italy (“ADDITIVE”). Through the use of these services and systems your data will be processed and stored, at least in part, also outside of the EU or the EEC. The adequate level of data protection is based on data processing agreements.


10. Changes

This Privacy Policy takes effect on 16.10.2025. The Data Controller reserves the right to amend or update the content of this policy, in part or in full, especially in the case of changes in the applicable law. Since the content of our Website and Privacy Policy may be subject to change, we recommend you visit this section regularly for updates on how we collect and use Personal Data.

(Pursuant to Article 13 of Regulation (EU) 2016/679 concerning the protection of natural persons with regard to the processing of personal data)

We invite you to read this privacy notice, which provides information on the processing of personal data in connection with the operation of our Website www.myexcelsior.com/en (“Website”) and our official WhatsApp channel (together, the “Chat Channels”), as well as the use of our Chatbot Excelly (“Chatbot”), in accordance with Regulation (EU) 2016/679 (“GDPR”).

This privacy notice supplements our general privacy notice for visitors to our Website, which contains all information pursuant to Articles 13 and 14 GDPR and is also available on the Website. 

For comprehensive information about the processing of your personal data, we also recommend that you consult the general privacy notice. 

The Chatbot is made available with the aim of providing users (“Users” or “you”) with quick, accessible and interactive access to information concerning accommodation as well as cultural and leisure offerings in San Vigilio di Marebbe / Excelsior Dolomites Life Resort. Any further use for purposes not compatible with this informational purpose is excluded. 

  1. Controller - Who we are
    Excelsior Dolomites Life Resort
    VAT No. and Tax No.: IT01699840219
    Valiares street 44
    IT-39030 San Vigilio di Marebbe
    Tel. +39 0474 501036 
    E-Mail: info@myexcelsior.com
    processes Users’ data as Controller within the meaning of Article 4, No. 7 GDPR.
     
  2. What personal data do we process and how

    a) Technical data, system and security logs: 
    In the course of providing the Chatbot, we collect certain personal data that are technically necessary and the transmission of which is inherent in the use of internet and communications protocols, such as IP addresses, date and time of requests, time zone, browser, language and version of the browser software and the operating system of the end device, and the referrer URL, i.e. the Website from which access occurs. If the Chatbot is provided via our WhatsApp channel, we may also collect the User’s phone number and displayed profile name, which we retain for the duration of use and for maintenance purposes. 

    These are not collected with the intention of being associated with individual Users; however, by their nature they could, through processing and matching with data held by third parties, allow Users to be identified.
     

    b) Dialogue content and other information
    Use of the Chatbot, regardless of the Chat channel, also entails the processing of the messages you send and receive. This may include, in particular, information or files you provide or upload about yourself as well as information about your interactions with the Chatbot.
     

    c) Contact details
    To respond to enquiries or to handle complaints regarding the Chatbot, we also process contact details provided by Users for that purpose, such as first name, surname, email address and telephone number. 

     

    No information relating to your health, religious or political beliefs, or other special categories of personal data is required for the provision and use of the Chatbot. Please do not transmit such data. If you nevertheless share such information via the message window, you expressly consent to processing thereof pursuant to Article 9, paragraph 2, letter a) of the GDPR. 

     

    Personal data are processed using IT-based tools, including cookies. Further information on the cookies used for this purpose can be found on our website: Privacy Statement and Cookie Policy.

     

  3. Legal bases and purposes of the processing of personal data
    In relation to the provision and use of the Chatbot, we collect and use your personal data solely for the following purposes and on the following legal bases:
     

  4. Legal basisPurposes of processing

    Fulfilment of contractual obligations or pre-contractual measures (Article 6, para. 1, letter b) GDPR): 
    when Users use the Chatbot through one of the Chat Channels provided.

    1. Provision of the Chatbot via one of our Chat Channels
      We process Users’ personal data, such as technical data, system and usage logs, dialogue content, profile names and phone numbers, to provide the Chatbot via our Chat Channels and to enable its use and the delivery of information. 

      We regularly assess the necessity of retaining such requests and messages and delete the relevant data when they are no longer needed.

      Users are free to provide their personal data for the above purposes. However, the provision of this data is necessary in order to process requests via the Chatbot and/or to maintain the business relationship with Excelsior Dolomites Life Resort. If these data are not provided, we may be unable to process the request or provide our services.

    2. Management of complaints
      The Chatbot is able to detect indications of negative feedback or complaints. Relevant dialogue excerpts may—after a preliminary technical relevance check—be forwarded to us in order to be recorded as part of an internal process that includes an individual review, feedback to the complaining User and, where appropriate, further measures. 

      For this purpose, in addition to the dialogue content we also process the contact details provided for contacting the User, as well as, where applicable, booking- or order-related information relevant to handling the complaint.

      Users are free to provide their personal data for the above purposes. However, the provision of this data is necessary in order to process requests via the Chatbot and/or to maintain the business relationship with Excelsior Dolomites Life Resort. If these data are not provided, we may be unable to process the request or provide our services.

    Legitimate interests (Article 6, para. 1, letter f) GDPR): 
    to ensure the availability, proper operation and security of the Chatbot, to detect and prosecute potential criminal offences, and to pursue other legitimate interests—provided that the protection of our interests or those of third parties does not override the user’s fundamental rights and freedoms.

    1. Security and maintenance
      We process technical and network data that could indirectly reveal the User’s identity in order to ensure a reliable User experience. These data are automatically collected during normal operation of the Chatbot and are processed for technical purposes (including troubleshooting, testing, system maintenance, technical support and reporting) or for statistical and analytical purposes to improve the User experience.

      The latter are generally processed in aggregated and non-identifiable form for statistical purposes. For example, it may be assessed how often certain functions are used or how much time is typically required for certain requests. These evaluations help us to identify technical weaknesses and to further develop the Chatbot in a targeted manner. 

    2. Quality assurance, content maintenance and reporting
      We use excerpts from the Chatbot’s dialogue content to continuously verify the quality of the information provided, maintain content and compile reports to assess and improve our digital offering.

      For these purposes, the dialogue excerpts are cleansed of personal characteristics—such as phone numbers, profile names or other identifiers traceable to a natural person—or pseudonymised before analysis, in order to prevent the prepared content from being attributed to individual Users.

    3. Disclosure of dialogue content to affiliated companies
      To improve the Chatbot’s content offering, response speed and subject-matter quality, we may share dialogue excerpts via secure technical interfaces with software solutions of affiliated companies in the same tourism region. For these purposes, dialogue excerpts are cleansed of personal characteristics—such as phone numbers, profile names, or other identifiers traceable to a natural person—or pseudonymised before analysis, to prevent attribution of the prepared content to individual Users.

      The receiving companies use these dialogue excerpts solely to answer the User’s enquiry automatically and, where applicable, to evaluate them statistically.

    Legal obligations (Article 6, para. 1, letter c) GDPR): 
    to comply with applicable laws and regulations and to respond to requests from competent authorities.

    1. Personal data we process to comply with legal obligations
      We process Users’ personal data in order to comply with any legal obligations, such as fiscal, administrative and accounting obligations



    g) Use of dialogue content and technical data by SaaS service providers 

    To operate the Chatbot, we rely on the specialist and technical support of a service provider that processes technical data, aggregated User statistics and dialogue content for the provision of the Chatbot under a contractual arrangement with us (Article 6, para. 1, letter b) GDPR).

    In addition, these data are also used by the service provider on its own responsibility to train the algorithms and models underlying the Chatbot, to improve response quality and to enhance system stability (Article 6 para. 1, letter f) GDPR). For this purpose, the service provider uses pseudonymised, or where possible fully anonymised, dialogue excerpts and usage statistics. The service provider cannot readily infer your identity from these data.

    You may object at any time to the transmission of your data to the service provider, unless compelling legitimate grounds prevail. 

     

  5. Recipients of data – How and to whom we disclose personal data
    Without prejudice to the provision set out in our general privacy notice, we may forward certain dialogue excerpts and contact information for the above purposes to affiliated companies in the tourism region. Each receiving affiliated company processes these data under its own responsibility pursuant to Article 4, no. 7 GDPR and solely for the purpose of responding to your enquiry for quality assurance reasons.

    If the Chatbot is used via our WhatsApp channel, your phone number may also be stored and processed for internal service purposes by WhatsApp Ireland Ltd. under its own responsibility. We have no influence over such processing activities. Details can be found in the privacy notice made available by WhatsApp: https://www.whatsapp.com/legal/privacy-policy-eea.

     

  6. Transfers of personal data – Where personal data are processed
    Management and storage of the personal data processed in connection with the operation of the Chatbot take place within the EU and/or the EEA, on servers managed by Excelsior Dolomites Life Resort and/or third-party companies engaged by it. However, as part of individual functional components (e.g. cloud hosting, monitoring or support tools), a transfer of personal data outside the EU or EEA may be required. In such cases, before any transfer we ensure that all appropriate measures and safeguards required by the GDPR and applicable law are duly adopted.
     
  7. Storage period for personal data
    We process and store Users’ personal data in accordance with our general privacy notice and in any event only for as long as is strictly necessary to achieve the purposes for which they were collected.
     
    In particular:
    Plain-text dialogues: retained for a period necessary to process User enquiries and to deliver information, and generally deleted or anonymised after 72 hours. Where the Chatbot is used via our WhatsApp channel, message texts and the phone number stored with WhatsApp may be retained for up to one year from the creation of the relevant chat. They may be processed for a longer period where circumstances exist that justify an extension of the data storage period. In such cases, the personal data will be deleted or anonymised no later than 30 days after the reason for retention ceases to apply. 
    System and security logs: are kept for the period required for stable operation and network security, but generally no longer than 90 days.

    After expiry of the above storage periods, the data are deleted from our live and backup systems or anonymised for statistical purposes.
     
  8. Data security – How we protect personal data
    We take the protection of our Users’ personal data very seriously. For this reason, we continuously adapt organisational, technical and administrative measures to protect Users’ personal data against unauthorised access, alteration, disclosure or destruction.
     
  9. Rights of data subjects
    As a data subject, the User may exercise his or her rights under the GDPR (Articles 15 to 21), in particular:
    Right to withdraw consent (Article 7 GDPR): to withdraw at any time the consent given for the various processing operations that require it. The lawfulness of the processing of the User’s personal data carried out before withdrawal remains unaffected. Withdrawal means that from that moment the personal data will no longer be processed for the purposes to which the withdrawn consent related.
    Right of access (Article 15 GDPR): to obtain confirmation of whether personal data are being processed and, if so, to be informed about the purposes of processing, the categories of personal data processed, the recipients and categories of recipients, the data storage period, etc.
    Right to rectification (Article 16 GDPR): to request the rectification of inaccurate personal data and/or the completion of incomplete personal data.
    Right to erasure (Article 17 GDPR): to obtain the erasure of personal data in the cases and under the conditions laid down by law.
    Right to restriction of processing (Article 18 GDPR): to obtain restriction of processing in the cases and under the conditions laid down by law.
    Right to data portability (Article 20 GDPR): to obtain the portability of personal data, i.e. the transmission of personal data, insofar as technically feasible, from one Controller to another, in the cases and under the conditions laid down by law.
    Right to object (Article 21 GDPR): to object to the processing of personal data on grounds relating to his or her particular situation, or where personal data are processed for the purposes of direct marketing.
    You may exercise your rights by sending a request to the Controller at the contact details given above.  
    If the User considers that the processing concerning him or her infringes the GDPR, he or she has the right to lodge a complaint with the supervisory authority: Garante per la protezione dei dati personali (Italian Data Protection Authority), Piazza Venezia 11, 00187 Rome, https://www.garanteprivacy.it/.
     
  10. Use by minors
    The Chatbot is intended solely for individuals who are 18 years of age or older. If we become aware that a individual under the age of 18 years is using our Chatbot, we will prevent further use and delete all associated personal data.

    If you have reason to believe that a minor has provided personal data to the Chatbot, please contact us immediately at the contact addresses indicated in section 1 (Who we are). We will endeavor to remove the relevant information from our systems without delay.

     

  11. Changes to this privacy notice

    We reserve the right to amend this privacy notice in order to adapt it to applicable provisions. The updated privacy notice will be published on our Website.

     

  12. Licences
    "Privacy icons" created by the Maastricht European Centre on Privacy and Cybersecurity; licence ECPC CC BY 4.0.