Privacy disclaimer
To the user;
In accordance with European Regulation n. 679/2016 EU (GDPR), European Union Directive on the processing of personal data, 94/46 / EC of the European Parliament and Council 24/10/95 and the Italian law on Privacy, Legislative Decree n. 196/2003 entitled 'Code regarding the protection of personal data' and subsequent modifications, you are hereby informed  that ForGuest, as owner of the related ForGuest portal and data controller, uses the services present as international communication methods in specific sectors with consequent processing of personal data where necessary and as specified in the relevant pages.

GDPR
ForGuest s.r.l.s. (hereinafter ForGuest) has established the necessary procedures in order to comply with the regulations necessary for the protection of the personal data of those who interact with the services.

ForGuest s.r.l.s. - V. Paolo Dettori, 13 - 07039 Valledoria (SS) - in the person of its legal representative, hereby acts as the data controller for the following personal data:

Personal data
Name, surname, address, country and place of residence, telephone, e-mail address.

Telematic data processing
IP address, log
No persistent cookies of any kind are used directly by ForGuest, except for the purpose of correct navigation.
The use of so-called session cookies (which are not stored permanently on the User's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe and efficient site browsing. The session cookies used on this site avoid the use of other IT techniques that are potentially detrimental to the confidentiality of Users' browsing and do not allow the acquisition of personal identification data of each User.

The use of cookies is however adjustable through the functions available in each browser which allow the user to disable this procedure.
However, the ForGuest sites make use of Google Analytics to track navigation data for statistical and aggregate purposes. If not accepted/desired this procedure can be disabled in line with the related Google specifications:

In addition to those present, only customer data required by law for tax and financial purposes are processed.

There are no other types of data processed in relation to the company services offered.

Purpose of the treatment
The data are processed for the purposes of:
Contact request management,
Registration and subscription to the services offered,
Providing of support services and assistance activities,
Promotion and institutional communication.

The data are entered optionally into the system, directly by the owners of the same, who are responsible for verification, and who at any time can carry out any rectification or cancellation concerning them in complete autonomy. Any refusal to provide data does not affect any activity other than those for which they are indispensable in relation to the services offered.

The data provided by users are used for the exclusive purposes related to the dedicated services, as indicated in the respective service points, as well as for carrying out research and activities permitted under  National and European law. The acquisition of the relative information is possible by means of specific pages, in areas of which dedicated applications have been prepared for the provision of data (for example registration cards), which simultaneously contain specific information on the processing of the same. The data processing takes place with online and/or telephone and/or telematic and/or alternative physical procedures, which allow the protection of confidentiality and through an entire process including collection, registration, cataloguing, storage, processing and modification, searches, extractions, publication, blocks, deletions, communication and distribution including the combination of two or more of the aforementioned activities, and may be carried out directly by ForGuest or by companies in charge of processing, whose identity is contained in the list available at the company office.

With regard to promotional and institutional communication activities, in the event of processing being authorized, the interested party accepts the receipt of information regarding ForGuest products and services, aimed at individual information, or periodicals about the products which in any case are always strictly linked to the services provided by ForGuest.

Security
In drafting the risk analysis for the data, the optimal level of flow control was assessed.
The data are recorded on servers equipped with anti-intrusion firewalls, and stored in data centres managed with ISO9001 processes and periodically duplicated with automated backup systems.
All the main company applications operate online on the same type of platform, including accounting management. All ForGuest Server systems are within the European Union and with data centres subject to the GDPR.
All systems are protected by anti-intrusion/Malware/Virus systems even for the sole temporary management of information. The list of those authorized for processing is available upon request.
Customer access for data management is carried out in secure mode by SSL certificates.


In the event of a security breach of one or more data, a specific communication procedure is envisaged and applied which is variable and immediate and based on the type of breach and/or loss of and/or tampering with the data.

Likewise, data recovery procedures have been put in place.

Minors
There are no activities regarding minors: all ForGuest actions and services are geared towards owners or corporate services.

Fraud
For the drawing-up of commercial contracts, in addition to registration by computer means, users are contacted by telephone and company data verified . There may be attempts at primary contacts by non-real subjects or pseudonyms not connected to our company, but for contractual security purposes, at the time of registration all references are checked by us.
With regard to online payments, ForGuest does not carry out any type of payment, but uses third party payment systems such as the client’s individual bank/Paypal/Stripe, with highly structured systems in place for the prevention and control of fraud.

Disclosure of personal data to third parties
The communication to third parties of the data processed by ForGuest derives from its corporate organization and legal obligations.

Below is a list of subjects permitted to process the data for which ForGuest is the data controller:

Aruba Business S.p.A.
Purpose: Data Center services (infrastructure), and legal obligations (accountancy procedures)

Telecom S.p.A./Vodafone/Wind/TIM/Telephone providers
Purpose: Data transport services, from the Data Center to the ForGuest headquarters or mobile staff stations.

Third Party Service Providers
Purpose: Application development and support related to contracts, tax consultants and accountancy procedures

Financial and payment systems
Purpose: management of payments and receipts related to contracts.

Public administration
Any person who by law may request for just cause and with the right to access data for checking or other legal reasons in relation to the parties involved.

With regard to the services offered by ForGuest, such services can be provided only if the company receives proof of ownership of the processing from the interested party, for registration and enrolment regarding the services offered, for the provision of services and support and assistance activities, under penalty of not being able to provide the services themselves.

Data retention period
The data will be kept for the entire period linked to the purpose of collection.

Below is a list of the different types of storage

Session cookies
Solely for each individual navigation session

Google Analytics data
Based on the collection methods operated by Google https://www.google.com/intl/it/policies/privacy

Personal data relating to registrations and contracts with ForGuest
For the entire duration of the contract, and for the minimum legal period following the required custody of administrative documents as required by Law

Generic contact data not linked to a service contract
2 years

Rights of the interested party
The interested party may at any time apply the regulated rights and in specific detail may:

• Withdraw consent.
• Oppose the processing
• Access their data
• Check and modify the data
• Restrict processing
• Obtain cancellation
• Receive their data or transfer them to another owner
• Submit a complaint

For detailed information concerning the rights and duties of the interested party, please refer to the detailed document of the Guarantor for the Protection of Personal Data.

With regard to the specific treatment by ForGuest in terms of any action or request from the interested party, it is possible to send an email to info@forguest.eu

ForGuest is exclusively required to provide the tools/instruments through which the above rights can be exercised by users according to current legislation. The user has the right for legitimate reasons to object to the processing in whole or in part and can, in line with regulatory provisions, request confirmation of the existence of personal data concerning him/her, be aware of its origin, receive communication, have information on the methods and purposes of the processing, request updating, rectification, integration, cancellation, transformation into anonymous form, blocking in case of violation of the law, including those no longer necessary for the pursuit of the purposes for which they were collected and in general exercise all the rights that are recognized by the current provisions of the law.

Data processing: The owner for the data processing of this portal is the ForGuest Registered office in Via Paolo Dettori, 13 - 07039 Valledoria (SS) - Italy, in the person of its legal representative as the person responsible for privacy and the person responsible for the Protection of Personal Data.


Update 20/04/2022