Privacy policy

Privacy Policy – Alpina Sanico


1. Data Controllers

Depending on the specific accommodation unit booked, the independent Data Controllers responsible for data processing under the EU General Data Protection Regulation (GDPR) and the Italian Privacy Code (Codice della Privacy – D.Lgs. 196/2003, as amended by D.Lgs. 101/2018) are:

  • For the apartments: Björn Balkenhol (Codice Fiscale: BLKBRN80S26Z112K), Harkortweg 4, 58332 Schwelm, Germany (regarding the rental of the apartments).
  • For the double rooms (matrimonial rooms): Jasmin Balkenhol (Codice Fiscale: BLKJMN80S59Z112L), Via Sanico 47, 25088 Toscolano Maderno (BS), Italy (regarding the rental of the rooms).

For any inquiries regarding data protection or to exercise your statutory rights, you can reach us centrally at: alpina-sanico@libero.it


2. Data Collection During Booking and Website Usage

  • Booking Processing & Smoobu: To process bookings and manage our availability calendars, we utilize the management software provided by Smoobu GmbH, Wriezener Str. 12, 13359 Berlin, Germany. Any data you enter during the booking process will be forwarded to Smoobu for this purpose. We have executed a Data Processing Agreement (DPA) with Smoobu in accordance with Art. 28 GDPR. The processing of your data is necessary for the performance of a contract or to take steps prior to entering into a contract (Legal basis: Art. 6 para. 1 lit. b GDPR).
  • Server Log Files: When you visit our website, the web hosting provider automatically collects and temporarily stores technically necessary server log files (e.g., IP address, date, time, browser type). This processing is required to ensure the secure and stable operation of the website (Legal basis: Art. 6 para. 1 lit. f GDPR, based on our legitimate interest).


3. Statutory Reporting Obligations in Italy Under Italian law, we are legally required to transmit the personal data of our guests (identity details, passport/ID numbers, and duration of stay) to the local public security authorities (Questura / Alloggiati Web) within 24 hours of arrival, as well as to the regional statistical office (ISTAT / Ross 1000) for statistical purposes. The legal basis for this data transfer is Art. 6 para. 1 lit. c GDPR in conjunction with mandatory Italian public safety regulations.

Data Minimization Regarding Identity Documents: If copies or photographs of identity documents are provided to us (e.g., via WhatsApp or email) to facilitate this registration, they will be permanently and immediately deleted once the mandatory reporting to the authorities is successfully completed, unless other statutory retention periods apply.


4. Payment Service Providers

If you choose to use online payment methods (e.g., PayPal, credit card) during the booking process, payment processing is handled by the respective payment service provider. Your data is transmitted securely and encrypted solely for the purpose of transaction processing (Legal basis: Art. 6 para. 1 lit. b GDPR). The privacy policies of the respective payment providers apply.


5. Data Retention Period

We store personal data only for as long as necessary to fulfill our contractual obligations or as required by statutory retention periods. Due to tax and commercial record-keeping obligations under both Italian and German law (e.g., for invoices and accounting records), we are legally required to retain certain financial and booking-related data for a period of generally 10 years.


6. Your Rights as a Data Subject

In accordance with the GDPR, you hold the following rights regarding your personal data:

  • Right of Access (Art. 15 GDPR) to obtain information about your data stored by us.
  • Right to Rectification (Art. 16 GDPR) to correct inaccurate data.
  • Right to Erasure / Right to be Forgotten (Art. 17 GDPR), provided that no statutory retention obligations conflict with the request.
  • Right to Restriction of Processing (Art. 18 GDPR).
  • Right to Data Portability (Art. 20 GDPR).
  • Right to Object (Art. 21 GDPR) to processing based on our legitimate interests.

To exercise any of these rights regarding the apartments or the double rooms (matrimonial rooms), simply send an informal request via email to: alpina-sanico@libero.it

Furthermore, pursuant to Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your data violates data protection regulations. You may contact the competent supervisory authority in your country of residence or the Garante per la protezione dei dati personali in Italy (Piazza di Monte Citorio n. 121, Rome).


7. Governing Language Version


 This privacy policy is provided in multiple languages. In the event of any discrepancies, inconsistencies, or interpretation doubts between the German, English, or Italian versions, the Italian version shall prevail and be legally binding for guests residing in Italy; for all other guests, the German version shall govern.