Privacy Policy

This notice describes how personal data collected through the websites www.villaferri.it and www.cb48.it, and in connection with enquiries, bookings and stays at Villa Ferri Apartments Padova and CB48 Arzignano, are processed.

1. Data controller

The data controller is:

HOLDIMM S.R.L.
Registered office: Via Calavena Bassa 56/B, 36071 Arzignano (VI), Italy
Italian tax code and VAT number: 03507010241
Certified email (PEC): holdimm@globalcert.it

The properties managed by HOLDIMM S.R.L. include Villa Ferri Apartments Padova and CB48 Arzignano.

2. Personal data processed

HOLDIMM S.R.L. may process the following personal data:

personal and identification details, such as first name, surname, date and place of birth, and nationality;
contact details, such as telephone number, email address and residential address;
stay details, such as arrival and departure dates, number of guests, booked property and operational preferences communicated by the guest;
tax and administrative information needed for invoices, receipts, payments and accounting obligations;
information contained in identity documents, limited to what is needed to meet legal obligations to report guests to the competent authorities;
technical website browsing data, as described in the Cookie Policy.

3. Purposes of processing

Personal data are processed exclusively for purposes connected with handling the enquiry, booking and stay.

In particular, data are used to:

respond to enquiries made by telephone, email, WhatsApp or the website;
manage bookings, arrivals, departures and operational communications relating to the stay;
issue invoices, receipts or other tax and administrative documents;
comply with legal obligations, including reporting guests’ identification details to the public security authorities through the Alloggiati Web portal;
handle any communications after the stay, only when necessary for administrative, accounting, organisational or guest assistance purposes;
protect the controller’s rights in the event of disputes, non-payment, damage or a need to establish facts.

HOLDIMM S.R.L. does not use guests’ data to send unsolicited newsletters or promotional communications unless the data subject has provided specific, separate consent.

4. Legal basis for processing

Personal data are processed on the following legal bases:

taking pre-contractual steps and performing the contract, to respond to enquiries and manage the stay;
compliance with legal, tax, accounting and public security obligations;
the controller’s legitimate interest in organising the property, protecting its rights and preventing misuse or disputes;
the data subject’s consent, only where required by law.

5. Disclosure of data to the authorities

To comply with the law, guests’ identification details are reported to the territorially competent Questura (police headquarters) through Alloggiati Web, within the time limits and using the procedures required by applicable law.

Identification data must be collected to meet public security obligations. Any copies of identity documents obtained for operational reasons strictly connected with registration are retained no longer than needed to enter the data in the system and verify successful transmission, unless another legal obligation applies.

6. Data retention

Personal data are retained for as long as necessary to achieve the purposes for which they were collected.

In particular:

data relating to enquiries that do not result in a booking are retained for as long as needed to handle the enquiry;
booking and stay data are retained for as long as needed to manage the relationship and any subsequent obligations;
tax, accounting and administrative data are retained for the periods required by applicable law, normally up to 10 years;
data needed for public security obligations are processed according to the procedures and time limits required by law and the official systems used;
any copies of identity documents temporarily obtained for operational purposes are deleted or destroyed once the necessary obligations have been completed.

7. Processing methods

Data are processed in paper, electronic and online form, using reasonable security measures to protect them against unauthorised access, loss, misuse or unauthorised disclosure.

Access is limited to people authorised by HOLDIMM S.R.L. and external parties working with the company for purposes strictly connected with managing the properties and meeting tax, accounting, technical or legal requirements.

8. Disclosure to third parties

Where necessary, personal data may be disclosed to:

tax, accounting, administrative and legal advisers;
providers of IT, hosting, email, management software and communication services;
banks and payment service providers;
public authorities, the Questura, competent bodies and parties to whom disclosure is required by law;
staff and other authorised persons involved in managing the stay.

Data are not sold, transferred or disseminated for commercial purposes unrelated to managing the stay.

9. Data subject’s rights

Within the limits set by law, the data subject may exercise the rights of access, rectification, erasure, restriction, objection and personal data portability.

Requests may be sent to HOLDIMM S.R.L. by certified email (PEC) at holdimm@globalcert.it or using the contact details shown on the properties’ websites.

The data subject also has the right to lodge a complaint with the Italian Data Protection Authority, using the procedures provided for by applicable law.

10. Updates to this notice

This Privacy Policy may be updated over time to reflect legal, organisational or technical changes. The version published on the websites is the one currently applicable.

Last updated: July 2026