Privacy Policy
# Privacy Policy
**Effective Date:** January 17, 2026
**Last Updated:** January 17, 2026
---
## 1. Introduction and Contact Information
Energy Clara Srl ("we," "us," "our," or "Company") operates the website **www.piciasuite.com** ("Website"). We are committed to protecting your privacy and ensuring you have a positive experience on our Website and when using our booking services.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Website and use our apartment rental and booking services. Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our Website.
**Data Controller Contact Information:**
- **Business Name:** Energy Clara Srl
- **Address:** Ties 36, 39030 (BZ), Italy
- **Email:** info@piciasuite.com
- **Jurisdiction:** Italy and European Union (GDPR applies)
---
## 2. Information We Collect
We collect information in several ways to provide and improve our booking services:
### 2.1 Information You Provide Directly
**Booking Information:**
- Full name, email address, and telephone number
- Residential address and billing address
- Payment information (processed securely through PayPal)
- Booking dates, number of guests, and special requests
- Communication preferences
**Account Information (if applicable):**
- Username and password
- Account preferences and saved properties
**Communication Data:**
- Inquiries submitted through contact forms
- Email correspondence
- Support requests and customer service interactions
### 2.2 Information Collected Automatically
**Cookies and Tracking Technologies:**
Our Website uses cookies and similar tracking technologies to enhance your experience. We use:
**Essential Cookies** (no consent required):
- Session management cookies (e.g., `svSession`, `XSRF-TOKEN`)
- Security cookies to protect against fraud and unauthorized access
- Shopping cart persistence cookies
- User authentication cookies
**Analytics Cookies** (consent required):
- Performance and analytics cookies that collect data about how you interact with our Website, including page views, clicks, time spent on pages, and user engagement
- These cookies help us understand Website performance and user behavior
- Wix Analytics and Google Analytics cookies may be used to measure Website effectiveness
**Non-Essential Cookies** (consent required):
- Functional cookies that remember your preferences (language, region, layout preferences)
- Targeting and marketing cookies used for retargeting and ad personalization (if implemented)
**IP Address and Device Information:**
- Your IP address
- Browser type and version
- Device type and operating system
- Approximate location based on IP address
- Referral source
### 2.3 Third-Party Data Collection
Our Website integrates with the following third-party services that may collect your data:
**Payment Processing:**
- **PayPal** processes payment information securely. PayPal acts as an independent data controller for payment processing purposes. Your payment data is encrypted during transmission and processed according to PayPal's Privacy Policy available at https://www.paypal.com/privacy
**Analytics:**
- **Wix Analytics** and **Google Analytics** collect usage data to help us understand how visitors use our Website and to optimize our services
- Google Analytics may place cookies and collect IP addresses and usage patterns
**Website Hosting and Platform:**
- **Wix** hosts our Website and provides platform functionality, including form processing, user authentication, and data storage
All third-party service providers are contractually obligated to protect your data and use it only as necessary to provide their services.
---
## 3. Legal Basis for Data Processing
Under GDPR Article 6, we process your personal data based on the following legal bases:
1. **Contract (Article 6(1)(b)):** Processing is necessary to perform our services—completing and managing your apartment rental bookings, processing payments, and sending booking confirmations.
2. **Legitimate Interests (Article 6(1)(f)):** We process data to:
- Improve and optimize our Website and services
- Conduct analytics and understand user behavior
- Prevent fraud and enhance security
- Comply with legal obligations
- Market our services (with your consent where required)
3. **Consent (Article 6(1)(a)):** For non-essential cookies, marketing communications, and certain analytics activities, we obtain your explicit consent via our Website's cookie consent banner.
4. **Legal Obligation (Article 6(1)(c)):** We may process data when required by applicable laws, including tax and financial regulations in Italy.
---
## 4. How We Use Your Information
We use the collected information for the following purposes:
- **Booking Management:** To process, confirm, and manage your apartment rental bookings
- **Payment Processing:** To securely process payments through PayPal
- **Customer Service:** To respond to your inquiries and provide support
- **Communication:** To send booking confirmations, reminders, updates, and relevant notifications
- **Website Optimization:** To analyze Website performance, user behavior, and engagement through analytics
- **Security and Fraud Prevention:** To detect, prevent, and address fraud, security issues, and technical problems
- **Compliance:** To comply with legal obligations under Italian and EU law
- **Marketing** (with consent): To send promotional materials and updates about our services
- **Improvement:** To develop new features, services, and improve existing offerings
---
## 5. Data Retention
We retain your personal data for different periods depending on the purpose and legal requirements:
**Booking and Customer Data:**
- Booking information is retained **indefinitely** for:
- Future booking purposes and customer relationship management
- Historical records and reference
- Tax and financial compliance (minimum 10 years under Italian tax law)
- Legal and contractual obligations
**Payment Information:**
- Payment data is processed and retained by PayPal according to their retention policies (typically the relationship period plus 10 years for legal and compliance purposes)
- We do not store full payment card details; PayPal handles secure payment storage
**Analytics Data:**
- Analytics and cookie data is typically retained for **24 months** or as specified by Google Analytics default settings
- Aggregate, anonymized data may be retained longer for trend analysis
**Communications:**
- Email correspondence is retained for **as long as necessary** to manage your account and resolve issues, typically 2-3 years
**Contact Form Inquiries:**
- Inquiries are retained for **1-2 years** or until resolved, unless longer retention is required for legal reasons
**Cookie Data:**
- Performance and analytics cookies expire after **12-24 months** depending on the cookie type
- Essential cookies remain active during your website session
You have the right to request deletion of your personal data, subject to legal retention obligations. See Section 9 for details on exercising your data rights.
---
## 6. Sharing and Disclosure of Information
We do not sell, trade, or rent your personal information to third parties. Your data is shared only:
### 6.1 Third-Party Service Providers
We share data with trusted service providers who assist in operating our Website and conducting our business:
- **Wix** (hosting and website platform) – processes data per their Data Processing Agreement
- **PayPal** (payment processing) – acts as an independent data controller for payment information
- **Google Analytics** (analytics) – processes anonymized and aggregated usage data
- **Email and communication providers** – if applicable, to send confirmations and customer communications
### 6.2 Legal Requirements
We may disclose your information when required by law or if we have a good faith belief that disclosure is necessary to:
- Comply with legal obligations or government requests
- Enforce our Terms of Service and other agreements
- Protect the security or integrity of our Website
- Protect the rights, privacy, safety, and property of our Company, you, or the public
- Detect, prevent, or address fraud or security issues
### 6.3 Business Transfers
If our Company is involved in a merger, acquisition, bankruptcy, or sale of assets, your personal data may be transferred as part of that transaction. We will provide notice if such a transfer occurs.
---
## 7. International Data Transfers
As your data may be processed by Wix (U.S.-based) and Google Analytics (U.S.-based services), your information may be transferred to and processed in the United States and other countries outside the European Union.
**Legal Safeguards:**
- PayPal has Binding Corporate Rules and EU Standard Contractual Clauses in place for international transfers
- Wix and Google comply with GDPR requirements for international data transfers
- These transfers are protected by appropriate legal mechanisms under GDPR Articles 44-49
By using our Website, you consent to the transfer of your information to countries outside the EU as described in this Privacy Policy.
---
## 8. Cookies and Tracking Technologies
### 8.1 What Are Cookies?
Cookies are small text files stored on your device that contain information about your Website visits. They help us enhance your experience, analyze usage patterns, and provide security.
### 8.2 Cookie Consent
When you first visit our Website, you will see a **cookie consent banner**. You can:
- **Accept All:** Consent to all cookies, including analytics and targeting cookies
- **Reject Non-Essential:** Decline non-essential cookies and continue with only essential cookies
- **Customize:** Choose specific cookie categories to accept or reject
**Essential cookies** are placed automatically to enable core Website functionality. **Non-essential cookies** (analytics, performance, targeting) will only be placed after you provide explicit consent.
### 8.3 Managing Cookies
You can control cookies through your browser settings:
- Most browsers allow you to refuse cookies or alert you when cookies are being sent
- You can delete cookies from your device at any time
- Disabling cookies may affect Website functionality
For more information on managing cookies, visit:
- **Chrome:** https://support.google.com/chrome/answer/95647
- **Firefox:** https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- **Safari:** https://support.apple.com/en-us/HT201265
- **Edge:** https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge
### 8.4 Third-Party Cookies
Third parties (Wix, Google Analytics, PayPal) may place their own cookies on your device. We encourage you to review their privacy policies to understand their cookie practices.
---
## 9. Your GDPR Rights and Data Subject Requests
Under the GDPR, you have the following rights regarding your personal data:
### 9.1 Right of Access (Article 15)
You have the right to request a copy of the personal data we hold about you in a structured, commonly used, and machine-readable format.
### 9.2 Right of Rectification (Article 16)
You have the right to request correction of inaccurate or incomplete personal data we hold.
### 9.3 Right to Erasure (Article 17)
You have the right to request deletion of your personal data, subject to certain legal exceptions (e.g., tax retention requirements, legal obligations).
### 9.4 Right to Restrict Processing (Article 18)
You have the right to request that we limit the processing of your personal data for specific purposes.
### 9.5 Right to Data Portability (Article 20)
You have the right to receive your personal data in a structured format and transmit it to another controller.
### 9.6 Right to Object (Article 21)
You have the right to object to certain types of processing, including marketing communications and processing for legitimate interests.
### 9.7 Right to Lodge a Complaint (Article 77)
You have the right to lodge a complaint with the Italian Data Protection Authority (**Garante per la protezione dei dati personali**) if you believe your rights have been violated.
**Data Protection Authority Contact:**
- **Website:** https://www.garanteprivacy.it
- **Phone:** +39 06 696771
- **Address:** Piazza di Monte Citorio 121, 00186 Rome, Italy
### 9.8 Exercising Your Rights
To exercise any of these rights, please contact us at:
- **Email:** info@piciasuite.com
- **Mail:** Energy Clara Srl, Ties 36, 39030 (BZ), Italy
We will respond to your request within **30 days** (extendable to 60 days for complex requests). We may request proof of identity to verify your request.
---
## 10. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, and destruction:
**Security Measures:**
- **Encryption:** Payment information and sensitive data are encrypted using industry-standard HTTPS/SSL protocols
- **PayPal Security:** Payment processing is handled by PayPal's secure, PCI-DSS compliant systems
- **Access Control:** Only authorized personnel with a legitimate need have access to your personal data
- **Regular Updates:** Our systems are regularly updated and monitored for vulnerabilities
- **Data Minimization:** We collect only the minimum data necessary for our services
**Important Note:** While we employ strong security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you use our Website at your own risk. Please use a strong password and protect your login credentials.
---
## 11. Children's Privacy
Our Website and services are not intended for children under the age of 18. We do not knowingly collect personal information from minors without parental consent. If we become aware that we have collected personal data from a minor without appropriate consent, we will promptly delete such information.
If you believe we have collected data from a minor, please contact us immediately at info@piciasuite.com.
---
## 12. Third-Party Links and Services
Our Website may contain links to third-party websites, including property listings, payment platforms, and partner services. This Privacy Policy does not apply to external websites. We encourage you to review the privacy policies of any third-party sites before providing your personal information.
We are not responsible for the privacy practices of third-party websites, and your use of them is at your own risk.
---
## 13. Marketing and Communications
### 13.1 Email Marketing
If you have opted in to receive marketing communications, we may send you:
- Promotional offers and special deals
- Website updates and new features
- Relevant property listings and recommendations
- Newsletter content
### 13.2 Unsubscribe
You can opt out of marketing communications at any time by:
- Clicking the "Unsubscribe" link in any marketing email
- Contacting us at info@piciasuite.com
- Updating your preferences in your account settings
### 13.3 Italian Telemarketing Consent
In compliance with Italian law and the Garante's recent guidance, if we collect your contact information for marketing purposes through online forms or lead generation, we will implement **double opt-in mechanisms** where you must confirm your consent via email verification to ensure the validity and demonstrability of your consent.
---
## 14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:
- Posting the updated Privacy Policy on our Website with a new "Last Updated" date
- Sending you an email notification (if we have your contact information)
- Requiring your explicit consent if required by law
Your continued use of our Website following the posting of changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed of how we protect your information.
---
## 15. Additional Information for Italian and EU Users
### 15.1 GDPR Compliance
As an Italian company processing data from EU residents, we comply fully with the EU General Data Protection Regulation (GDPR) (EU 2016/679). Our practices reflect:
- Lawful bases for processing (contract, consent, legitimate interests, legal obligations)
- Data subject rights and request procedures
- Data protection by design and default
- International transfer safeguards
- Transparency and accountability
### 15.2 Italian Data Protection Code
In addition to GDPR, we comply with the Italian Code for the Protection of Personal Data (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).
### 15.3 Contact with the Italian Data Protection Authority
If you have concerns about our privacy practices or believe your rights have been violated, you may lodge a complaint with:
**Garante per la protezione dei dati personali**
- **Website:** https://www.garanteprivacy.it
- **Phone:** +39 06 696771
- **Online Form:** Available on the Garante website
- **Address:** Piazza di Monte Citorio 121, 00186 Rome, Italy
---
## 16. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
**Energy Clara Srl**
- **Email:** info@piciasuite.com
- **Mail:** Ties 36, 39030 (BZ), Italy
- **Response Time:** We aim to respond to all inquiries within 10 business days
For data subject requests (access, rectification, erasure, portability), please see Section 9 for specific instructions. We commit to responding to all formal data requests within 30 days.
---
## 17. Data Processing Agreement
As required by GDPR Article 28, Energy Clara Srl maintains Data Processing Agreements with all third-party processors, including:
- Wix (website hosting and platform)
- PayPal (payment processing)
- Google (analytics services)
These agreements specify:
- The scope, nature, purpose, and duration of processing
- The types of personal data and categories of data subjects
- The rights and obligations of the data controller and processor
- Security and confidentiality obligations
Copies of our Data Processing Agreements with third parties are available upon request. Please contact info@piciasuite.com.
---
**End of Privacy Policy**
---
## Appendix: Cookie Consent Categories
### Essential Cookies (Always Active)
- Session and security cookies
- User authentication cookies
- Shopping cart and booking persistence
- Fraud detection and prevention
### Functional Cookies (Requires Consent)
- Language and regional preferences
- User interface preferences
- Accessibility settings
### Analytics & Performance Cookies (Requires Consent)
- Wix Analytics
- Google Analytics
- Website usage and performance metrics
- Error tracking and resilience logging
### Marketing & Targeting Cookies (Requires Consent)
- Retargeting cookies (if implemented)
- Affiliate tracking (if applicable)
- Ad personalization and remarketing
---
*This Privacy Policy is compliant with GDPR (EU 2016/679), the Italian Data Protection Code, and applicable Italian regulations as of January 2026.*