The following statement sets out the privacy policy of Progetto Esmeralda S.r.l. and the other Group companies, as posted on their websites, with reference to the processing of the personal data of any site visitors and users.

The privacy statement is provided in accordance with the Personal Data Protection Code (see art. 13 of D. Lgs. n°196/2003), to the users of the online services accessed through the sites of Progetto Esmeralda S.r.l.

The statement is also inspired by Recommendation 2/2001 on certain minimum requirements for collecting personal data on-line in the European Union, and intended to identify the concrete measures to be put in place by the players concerned for ensuring that processing is fair and lawful, which was adopted on 17.05.2001 by the Working Party on the Protection of Individuals with regard to the Processing of Personal Data (set up in accordance with article 29 of Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data), comprising the representatives of the Data Protection Supervisory Authorities appointed by each Member State.

Data controller

The personal data of any identified or identifiable persons may be processed when visiting this website.

The data controller of personal data collected through this website is: Progetto Esmeralda S.r.l. – Strada Statale n. 195 Km. 39,600 – 09010 Santa Margherita di Pula (CA) (Italy).

Place of processing

The website of Progetto Esmeralda S.r.l. may be visited without having to provide any personal details. The personal information held by Progetto Esmeralda S.r.l. is held on and processed by computers situated in our hotel complex at Santa Margherita di Pula (Cagliari – Italy) SS195 Km 39.600, and our administrative headquarters at S.S. 195 Km. 39,600 – Forte Village Resort, Santa Margherita di Pula, Cagliari (Italy) – under the coordination of the parent company, Progetto Esmeralda S.r.l.. All personal information is processed exclusively by technical staff specifically employed for this purpose and, occasionally, by maintenance personnel.

The personal data of website visitors who fill in online booking forms or register with our email newsletter service, which provides, on a periodical basis, the latest news on Castel Monastero and the Forte Village Resort and their partners, and information on any promotional offers, will be used solely for providing the related services and will be disclosed to others only subject to authorization by the data subject and if strictly necessary.

Visitors who fill in online booking forms and register with the email newsletter will be required to provide their personal details (first name, surname, mail address, email address, telephone number, etc.) and consent to the processing thereof.

If no consent to the processing of the personal data is forthcoming, Progetto Esmeralda S.r.l. will not be able to accept the booking request and/or registration to the email newsletter. The personal data collected through this service will not be disclosed without the data subject’s consent.

The personal data collected through the online services provided by Progetto Esmeralda S.r.l. and the other Group companies will be held and stored at Santa Margherita di Pula (Cagliari – Italy) SS195 Km39.600, at the Forte Village Resort, S.S. 195 Km. 39,600, Santa Margherita di Pula, Cagliari (Italy), and at O&DS s.r.l, Via Pordenone 32/a, Milan (Italy). All personal information is processed exclusively by technical staff specifically employed for this purpose and, occasionally, by maintenance personnel.

Types of processed data

Browsing data

The IT systems and software procedures used to operate this website routinely collect certain personal data of the site visitors, the transmission of which is implicit and automatically connected to the use of the Internet communication protocols.

This data is not collected for the purpose of being associated with any identified viewers, however, due to its nature it can enable the identification of the website users, when processed and associated with any other information held by third parties.

This class of data includes IP addresses or the domain names of the computers used by the website viewers, the URI (Uniform Resource Identifier) addresses of the accessed resources, the time of the request and the method used for submitting a request to the server, the size of the file received in response, the number code specifying the status of the server’s response, and other parameters relating to the user’s operating system and general IT environment.

This data is used solely for the purpose of collecting anonymous statistical information relating to the use of the site, and to provide feedback as to its proper operation. It may also be used to determine responsibility for any hypothetical computer offences committed against the website: except in the latter case, the personal data will be stored for no more than thirty days.

Data voluntarily provided by the user

The voluntary and explicit submission of personal data, via email, to the contact addresses given in this site will entail the subsequent acquisition of the sender’s address, in order for us to reply, and of any other personal data entered in any application or request form, or otherwise supplied by the site visitor or user. Any specific summary information will be displayed in the site pages dedicated to the requested services.

Cookies

Progetto Esmeralda S.r.l., and all the Progetto Esmeralda S.r.l. Group companies, do not collect and/or automatically retrieve any personal data of the visitors to their websites. The websites make use of session cookies solely to enable the secure browsing of the site. The cookies do not allow the collection of the users’ personal data. By viewing the websites of the Progetto Esmeralda S.r.l. Group companies, visitors and users consent to the processing of their personal data by the cookies, in the manner and for the purposes set out above.

Optional supply of data

Without prejudice to the privacy statements set out in the paragraph above on browsing data, users are free to supply their personal data for requesting information materials or in connection with

other types of online services provided by Progetto Esmeralda S.r.l. and the other Progetto Esmeralda S.r.l. Group companies.

Failure to provide any personal data, however, may entail the impossibility to provide the requested service.

Data transmission

Personal data is electronically processed for the time strictly necessary to achieve the purpose for which it is collected. Specific security measures are observed to prevent the loss of any data, the illegal or improper use thereof and non-authorized access thereto.

Rights of the data subjects

Pursuant to article 7 of D.Lgs. 196/2003, a data subject is entitled to obtain, at any time, confirmation as to whether or not any personal data concerning him/her exists, to determine the accuracy thereof and/or to request the integration, updating, rectification or cancellation of the data.

Under the same article, a data subject is also entitled to request the erasure, anonymization or blocking of data that have been processed unlawfully, and to object to the processing thereof, on legitimate grounds.

Any requests made under the above mentioned article 7 of D.Lgs. 196/2003 must be addressed to Progetto Esmeralda S.r.l., PULA (CA) – Fraz. Santa Margherita Strada Statale n. 195 Km. 39,600, or emailed to privacyfvr@fortevillage.com.

The Data Controller

Progetto Esmeralda S.r.l.