Privacy policy
This page is a translation. If the English and German texts differ, the German version prevails.
This page explains which personal data are processed when you visit this website or send an enquiry, who processes them and what rights you have. We set no cookies. When you open the website, your browser connects only to our host, Vercel; it loads no content from other providers.
Controllers
The controller for this website is:
Sabatino Capital UG (haftungsbeschränkt)
Grünstraße 57a
40667 Meerbusch
Germany
- Represented by
- Massimo Sabatino, managing director
- Phone
- +49 211 56387598
For enquiries made through this website and for bookings, the controller is the landlord of the villa:
Geoffrey Richard Burton
Moerser Straße 60
40667 Meerbusch
Germany
Hosting with Vercel
The website is hosted by Vercel Inc. (USA). Server functions, such as sending the enquiry form, run in Vercel’s Frankfurt am Main region. Static content such as pages, images and fonts is delivered through Vercel’s global network.
Each time a page is requested, Vercel processes technical data about the connection, such as your IP address, the date and time of the request, the address requested and the browser type and operating system your browser reports. Some of these data are kept in server logs.
- Recipient
- Vercel Inc., USA
- Purpose
- Delivering the website and protecting it against misuse and errors
- Legal basis
- Art. 6(1)(f) GDPR; our legitimate interest is delivering the website, keeping it secure and finding errors.
- Transfer to the USA
- Based on the EU standard contractual clauses in Vercel’s data processing agreement.
- Retention
- Vercel keeps log data (IP address, time, page requested, browser details) only briefly, for delivering the website, finding errors and preventing misuse.
Enquiry form and email
With the enquiry form you send your name, email address, travel dates, the number of guests and, if you wish, a phone number and a message. Name and email address are required; without them no reply is possible.
The form passes your details on to the landlord by email; no automatic confirmation is sent to your address. The email is sent by the service Resend. Your details are used to answer your enquiry and to prepare an offer for the villa.
- Recipient of enquiries
- The landlord, Geoffrey Richard Burton, see Controllers
- Sending
- Plus Five Five, Inc. (Resend), USA; emails are sent through servers in the EU
- Legal basis
- Art. 6(1)(b) GDPR, steps taken at your request before entering into a contract
- Transfers outside the EEA
- Transfers outside the EEA are based on the EU standard contractual clauses in Resend’s data processing agreement.
- Retention
- Enquiries that do not lead to a booking are deleted after 12 months. For bookings, the statutory retention periods apply.
- Protection against misuse
- To prevent mass submissions, the server derives a hash value from your IP address (for IPv6, from its network prefix) using a random key. The hash value is kept only in memory and deleted ten minutes after your last enquiry; if the server is paused, it does so as soon as it runs again, and when the server stops, the value is gone anyway. Neither your IP address nor the content of your enquiry is stored or logged for this. In addition, each server accepts only a limited number of enquiries per hour. A hidden field and the time between loading the page and sending the form, which your browser sends along, help to recognise automated submissions.
- Vercel BotID
- When you send the form, Vercel BotID, a service of our host Vercel Inc., also checks whether a person or a program is sending the enquiry. For this, a script gathers technical characteristics of your browser and of how you use the page, solves a challenge in the background and sends the solution with your enquiry; Vercel checks it and reports the result to us. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is protecting the form against automated submissions. Transfers to the USA are covered in the same way as for hosting. Without JavaScript this check cannot run; in that case please write to us by email.
If you write directly to hello@villagiulietta.com or phone, the same applies, but Resend is not involved.
Links to other providers
Links to other providers, such as Booking.com, Airbnb, Google Maps and Instagram, only open their pages when you click them. From then on, their privacy policies apply.
Exterior cameras at the villa
Exterior cameras secure the grounds of the villa; there are no cameras inside the house.
- Operated by
- The landlord, see Controllers
- Purpose
- Protecting the house and grounds
- Legal basis
- Art. 6(1)(f) GDPR; the legitimate interest is protecting the house and grounds.
Bookings and your stay
If your enquiry turns into a booking, the landlord processes your data for the contract, payment and your stay (Art. 6(1)(b) GDPR). The statutory retention periods apply.
In Italy, the landlord is required by law to record the identity details of all guests on arrival and report them to the police (Art. 109 TULPS, through the “Alloggiati Web” portal). The landlord also collects the municipal tourist tax. The legal basis for this is Art. 6(1)(c) GDPR.
Your rights
You have the right to
- access the data we process about you (Art. 15 GDPR),
- have inaccurate data corrected and incomplete data completed (Art. 16 GDPR),
- have your data erased (Art. 17 GDPR),
- have processing restricted (Art. 18 GDPR) and
- receive your data in a structured, commonly used and machine-readable format and have them transmitted to another controller (Art. 20 GDPR).
If we correct or erase data or restrict their processing, we tell every recipient to whom we disclosed the data, unless this proves impossible or involves disproportionate effort. On request, we tell you who these recipients are (Art. 19 GDPR).
Right to object: Where your data are processed on the basis of legitimate interests (Art. 6(1)(f) GDPR), you may object to this processing at any time on grounds relating to your particular situation (Art. 21 GDPR).
To exercise these rights, write to info@sabatinocapital.de; for enquiries and bookings, you can also contact the landlord.
Complaints to a supervisory authority
You may lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), for example in the EU country where you live or work, or with the authority responsible for us, the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (the data protection commissioner of North Rhine-Westphalia).