Privacy

In accordance with Article 13 of EU Regulation 2016/679 and Legislative Decree No. 101 of 10 August 2018, we provide
the information regarding the processing of personal data that may be provided by users interacting with the web services of Villa Guinigi Borgo di Matraia, starting from the address
www.villaguinigi.it
This notice exclusively relates to the processing of your personal data communicated by you or otherwise obtained by the site www.villaguinigi.it as a result of your use of the
Site.
The processing of your personal data will be based on the principles of fairness, lawfulness, transparency,
limitation of purposes and retention, data minimization and accuracy, integrity, and
confidentiality, as well as the accountability principle set forth in Article 5 of the Regulation.
Therefore, your personal data will be processed in accordance with the provisions of the Regulation and the confidentiality obligations set forth therein.

Data Controller
The Data Controller is Villa Guinigi Borgo di Matraia (Bianchi Luxury Group Srl - Culliness), with
registered and operational office at Via di San Donato, n.1319/H – 55100 Lucca (LU), VAT No. 02552710465, email: info@culliness.com
The Data Processor is Mr. Walter Bianchi.

Subject of Data Processing
Following browsing on the Site, we inform the user that Villa Guinigi Borgo di Matraia (Bianchi
Luxury Group Srl – Culliness) will process personal data, which may include an
online identifier such as the user’s IP address, relevant data related to bookings
made (via third-party providers such as the TeamSystem Hospitality portal, please review
their privacy policy (https://www.teamsystem.com/privacy-policy/)), and contact data (name,
surname, email address, phone contact) if voluntarily entered in the "contact" form.

The website contains Cookies, small text files that the websites visited by the user
send and record on their computer or mobile device, to be then retransmitted to the same websites
on the next visit. The Cookies used on this website are described in detail
within the Cookie Policy.

Purposes and Methods of Data Processing
The data is collected and used to allow browsing on the Site, keep
the user updated on the offered services, and allow the user to make bookings.
Where necessary, the user's consent will be requested for the processing of the provided data.
The personal data provided will be processed with the aid of electronic/telematic tools equipped with
appropriate measures to ensure the security of such data as required by EU Regulation
2016/679.

Data Retention
The Personal Data processed (IP address, contact data such as name, surname, email address, phone
contact, and booking data) for the purposes described will be retained for
the time strictly necessary to achieve those same purposes and until the end of the service.

Types of Data Processed
Personal data processing refers to any operation or set of operations,
carried out with or without the use of automated processes and applied to personal data or sets of
personal data, such as collection, recording, organization, structuring, storing, adapting or modifying, extracting, consulting, using, communicating
by transmission, dissemination, or any other form of making available, comparison or
interconnection, restriction, deletion, or destruction.
The personal data of the User processed includes online identifiers such as
the IP address, email contact, and others as described in the previous paragraph regarding
the subject of processing.
The site also processes personal data such as:
Browsing data: the IT systems and software procedures responsible for the operation of
this website acquire, during their normal operation, some personal data whose
transmission is implicit in the use of internet communication protocols.
This information is not collected to be associated with identified subjects, but
that, by their very nature, could, through processing and association with data held by
third parties, allow users to be identified. This category includes IP addresses or
domain names of the computers used by users connecting to the site, the URIs (Uniform Resource Identifier) of the requested resources, the time of the request, the
method used to submit the request to the server, the size of the file obtained in response, the
numeric code indicating the status of the server's response (e.g., successful, error, etc.) and
other parameters related to the user's operating system and computing environment. This data
is used solely to obtain anonymous statistical information on the site usage and to
check its correct functioning, and is deleted immediately after processing.
The data could be used for the identification of responsibility in case of hypothetical computer crimes
damaging the site.
Data voluntarily provided by the user: the optional, explicit, and voluntary submission of data through web forms
or emails to the addresses indicated on this site will result in the subsequent acquisition
of the sender's address, necessary to respond to requests, as well as any other personal data
inserted in the communication.
Third-party data provided by the user: when using some services on the Site, there may be a
processing of Third-Party Personal Data sent by you to Villa Guinigi Borgo di Matraia (Bianchi
Luxury Group Srl – Culliness). In such cases, you act as an independent data controller, assuming all legal obligations and responsibilities. In this regard, you take responsibility for any dispute, claim, or compensation request arising from the processing, etc., that may be directed to Villa Guinigi Borgo di Matraia (Bianchi Luxury
Group Srl – Culliness) by third parties whose Personal Data have been processed through your
use of the Site’s functions in violation of applicable Data Protection laws. In any case, if you provide or otherwise process Third-Party Personal Data while using the Site,
you guarantee – taking full responsibility – that this processing is based on an appropriate legal basis under Article 6 of the Regulation, legitimizing the processing of the data in question.

Cookies: the Cookies used on the site are described in detail in the
Cookie Policy.

Legal Basis and Obligation to Provide Data
Personal data of the visitor user, such as browsing data (e.g., IP address and similar), contact data, or personal data useful for completing the booking, are collected on the site.
Except as specified for browsing data, the user is free to provide personal data to
request the services offered by Villa Guinigi Borgo di Matraia (Bianchi Luxury Group Srl – Culliness).

Communication of Data to Third Parties and Data Transfer
The processed data may be communicated to subjects for the management/maintenance of the Site and/or for
providing web services, to external subjects for booking management and other entities or
subjects for compliance with legal, administrative, and fiscal obligations. The processed data may
also be communicated to entities, organizations, or authorities following legal provisions or orders
from them for control purposes.
Your personal data will be processed within the European Union.
If, for technical and/or operational reasons, it is necessary to use subjects
located outside the European Union, we inform you that these subjects will be appointed
Data Processors pursuant to Article 28 of the GDPR, and the
transfer of your personal data to such subjects, limited to performing specific
processing activities, will be regulated in accordance with the GDPR. All necessary precautions will be taken to ensure the complete protection of your personal data, based
on the evaluation of appropriate guarantees, including, by way of example,
adequacy decisions from the European Commission regarding the third countries concerned; adequate guarantees from the third-party recipient pursuant to Article 46 of the GDPR.
In any case, you may request further details from the Data Controller if your personal data is processed outside the European Union, requesting evidence of the specific
guarantees adopted.

Nature of Data Provision
The provision of data is mandatory as it is necessary for the fulfillment of contractual,
accounting, fiscal, and administrative obligations in general. The failure to provide, or
incorrect communication of any mandatory information, will result in the inability
of the controller to ensure the compliance of the processing with the contractual agreements for which it is
carried out, or the potential failure to meet the requirements of the processing results as per the fiscal, administrative, or labor laws to which it is addressed.

Rights of Data Subjects
Under Articles 15 and following of the Regulation, the user has the right to request access to their
personal data, their rectification, or deletion, or to object to their processing; pursuant
to Article 21 of the Regulation, they have the right to request the restriction of processing in cases provided
under Article 18 of the Regulation, and to obtain in a structured, commonly used, and machine-readable format the data concerning them, in cases provided under Article 20 of the
Regulation. Requests should be addressed in writing to the following address: info@culliness.com
In any case, they always have the right to file a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if they believe that the
processing of their Personal Data is contrary to the applicable regulations.

Updates and Changes to the Privacy Policy
Villa Guinigi Borgo di Matraia (Bianchi Luxury Group Srl – Culliness) may make changes
to this Privacy Policy, ensuring the timely update of this
web page. We encourage users to visit this section frequently to stay
informed about any variations.

Last updated: September 2025