Privacy Policy

1. Data Controller

The Data Controller for personal data collected through this website is Orazio Spina, based in Acireale (CT), Sicily, Italy.

For any request regarding this notice or the processing of personal data: info@oraziospina.com. For requests related to Best Way Hotel Solution Group: info@bestwayhotelsolution.com.

2. Data Collected and Purpose of Processing

This website collects personal data only when a user voluntarily fills in the contact form in the "Contact" section: full name, company or property name (if provided), email address, type of inquiry, and message content.

This data is processed solely to respond to the request received and, where relevant, to follow up on a professional or consulting collaboration.

The website does not use profiling cookies, does not install analytics tools, and does not carry out any form of user behaviour tracking.

3. Legal Basis for Processing

Processing is based on the consent freely given by the user at the moment they complete and submit the contact form (Art. 6(1)(a) GDPR) and, where applicable, on the performance of pre-contractual steps requested by the data subject (Art. 6(1)(b) GDPR).

4. How Data Submission Works

The contact form on this website does not transmit data to an external server: when the "Send inquiry" button is pressed, the user's browser simply opens their own default email client with a pre-filled message, which the user is free to edit, send, or discard. The data entered therefore remains under the user's full control until the email is actually sent.

5. Data Retention

Messages received by email are retained for as long as needed to handle the request and, if a professional relationship follows, for the duration of that relationship, in accordance with applicable legal requirements for tax and business documentation.

6. Third-Party Services

This website is hosted on infrastructure provided by Netlify, Inc. Simply by visiting the site, the hosting server automatically logs standard technical information (such as the IP address) in its system logs, for security and service-operation purposes.

The website also loads typefaces (fonts) directly from Google Fonts servers. As a result, when the page loads, the user's browser establishes a direct connection to Google's servers, which may involve transmitting the user's IP address to Google LLC.

7. International Data Transfers

Some of the providers listed above (Netlify, Google) are based, or operate infrastructure, outside the European Economic Area. Where such transfers occur, they are governed by the Standard Contractual Clauses approved by the European Commission, adopted by these providers to ensure an adequate level of protection.

8. Data Subject Rights

Users may exercise the rights set out in Articles 15-22 of Regulation (EU) 2016/679 at any time, including:

• access to their personal data;
• rectification or erasure of data;
• restriction of processing;
• data portability;
• objection to processing.

To exercise these rights, simply write to info@oraziospina.com.

Users also have the right to lodge a complaint with the Italian Data Protection Authority — Garante per la Protezione dei Dati Personali (www.garanteprivacy.it) if they believe the processing of their data violates applicable law.

9. Changes to This Notice

This notice may be updated over time, for example following changes to the website's functionality or to applicable regulations. The date of the last update is shown at the top of this page.