Privacy Policy
Last updated: 2025-02-21
This privacy notice is provided pursuant to Article 13 of Regulation (EU) 2016/679 («GDPR») and to Italian Legislative Decree no. 196/2003 («Privacy Code»), as amended, and describes how Napulè Apartment processes the personal data of users who access the website and use the booking services.
1. Data Controller
The data controller is Napulè Apartment, with registered address at Via Example 123, 80100 Napoli, Italia.
- Email: info@napuleapartment.it
- Phone: +39 342 334 7947
2. Data Protection Officer (DPO)
For small-scale accommodation providers, the appointment of a Data Protection Officer is not mandatory. You may contact the Controller directly at the details above to exercise your rights.
3. Data collected and purposes of processing
We collect and process the following categories of personal data:
3.1 Data provided directly by the data subject
- Identity and contact data: name, surname, email address, phone number (including WhatsApp if provided).
- Booking-related data: arrival and departure dates, number of guests, special requests, identity documents (when required by law, e.g. guest registration).
- Payment data: the site does not store credit card details; payments are processed securely via Stripe. Transaction-related data (amount, date, outcome) may be processed for contractual and tax purposes.
3.2 Data collected automatically
- Browsing and technical data: IP address, browser type, device, usage data (e.g. pages visited), including via cookies and similar technologies, as described in the Cookie Policy.
3.3 Purposes and legal basis
| Purpose | Legal basis (GDPR) |
|---|---|
| Managing bookings, confirmations and communications related to your stay | Performance of contract (Art. 6(1)(b)) |
| Payment processing (via Stripe) and issuing receipts | Performance of contract (Art. 6(1)(b)) |
| Tourist tax and guest registration (local and national law) | Legal obligation (Art. 6(1)(c)) |
| Tax and accounting obligations (retention of documents, invoices) | Legal obligation (Art. 6(1)(c)) |
| Fraud prevention and site security (e.g. anti-spam, CSRF protection) | Legitimate interest (Art. 6(1)(f)) |
| Responding to enquiries sent via contact form or email | Pre-contractual measures / legitimate interest (Art. 6(1)(b) or (f)) |
4. Mandatory or optional nature of provision
Provision of data necessary for booking (name, surname, email, phone, dates, number of guests) is mandatory for the performance of the contract. Failure to provide it will prevent us from processing your booking. Provision of additional data (e.g. special requests, preferences) is optional.
5. Recipients and transfers
Personal data may be disclosed to:
- Stripe (payment processing): entity with EU/EEA presence and adequate safeguards; see Stripe’s privacy policy for details.
- Hosting and infrastructure providers (e.g. Vercel, email services): as processors (Art. 28 GDPR), within the EU or with adequate safeguards.
- Public authorities (e.g. law enforcement, municipality for tourist tax) when required by law.
We do not sell or transfer data to third parties for commercial purposes. We do not carry out systematic transfers to countries outside the EU without adequate safeguards (standard contractual clauses or adequacy decision).
6. Retention period
- Booking and payment data: retained for the time necessary to perform the contract and to comply with legal obligations (in Italy, tax and accounting documents for at least 10 years from the end of the relevant year, unless stricter rules apply).
- Tourist tax / guest registration data: for the period required by local law.
- Contact data for general enquiries: until the enquiry is dealt with and, if no contract is concluded, for a limited period (e.g. 12–24 months) unless you have given different consent.
- Logs and technical data: for the time strictly necessary for security and debugging (e.g. 12–24 months).
After the periods indicated, data will be deleted or irreversibly anonymised.
7. Your rights
As a data subject you have the right to:
- Access (Art. 15 GDPR): obtain confirmation as to whether data concerning you are being processed and receive a copy.
- Rectification (Art. 16 GDPR): obtain the correction of inaccurate or incomplete data.
- Erasure / right to be forgotten (Art. 17 GDPR): obtain erasure of data, within the limits and exceptions provided by law (e.g. retention obligations).
- Restriction of processing (Art. 18 GDPR): obtain that data are only processed for certain purposes where the legal conditions are met.
- Data portability (Art. 20 GDPR): receive the data in a structured, commonly used format and, where technically feasible, have them transmitted to another controller.
- Object (Art. 21 GDPR): object to processing based on legitimate interest on grounds relating to your situation.
- Withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.
- Lodge a complaint (Art. 77 GDPR): with a supervisory authority. In Italy: Garante per la protezione dei dati personali — www.garanteprivacy.it.
To exercise your rights you may contact the Controller at info@napuleapartment.it or +39 342 334 7947. The Controller will respond without undue delay and in any event within one month of receipt of the request, extendable by two months where necessary, with reasons given.
8. Minors
The services are intended for adults. We do not voluntarily collect data of minors under 18; where data of minors are provided in connection with a booking (e.g. name in guest list), processing is limited to what is strictly necessary for the performance of the contract and legal obligations, and is assumed to be provided with the consent of the holder of parental responsibility.
9. Changes
This notice may be updated to reflect legal changes or changes in processing. The date of the last update is shown at the top. Please check this page periodically.
10. Contact
For any privacy-related request: info@napuleapartment.it, tel. +39 342 334 7947, address Via Example 123, 80100 Napoli, Italia.