Full Information Related to the Use of Video Surveillance Systems (art. 13 of the GDPR)

Documentversion and date (Version 01 of 26th July 2023)

Data Controller and/or Co-controller

The companies in the ERQOLE group, indicated below, depending on the specific purposes pursued and indicated in this notice, deal with your personal data independently or jointly pursuant to the European Regulation 2016/679 (hereinafter GDPR).

The aforementioned companies may act as joint data controllers in relation to the processing of data having jointly determined the purposes and means of processing through the conclusion of a specific agreement pursuant to art. 26 of the GDPR which is available at your written request.

The autonomous Controller of the data processing for the purposes related to the use of the video surveillance systems specified below is the Company ERQOLE HOSPITALITY S.r.L., represented by its legal representative.

The company, in compliance with the provisions of art. 13 of the GDPR and the guidelines 3/2019 of the Data Protection Authority on video devices, has provided for the placement of an adequate permanent first-level signage in the areas before the camera’s range of action.  

In addition to the information provided on the above-mentioned company sign indicating the presence of video surveillance equipment, in accordance with the transparency principle of the GDPR; the following second-level information is provided:

– the video surveillance systems installed in the premises of the following facilities: Rivadel Marchese, l’Isolotto, located in Porto Ercole (GR), at Le Viste without street number and Warehouse, located in Orbetello (GR), Via Mussi No. 6, have the objective of safeguarding the company’s assets. – the data processing isnot intended for remote monitoring of work activities and is conducted in compliance with the guarantees provided for in labour laws (art. 4 Law No. 300/1970);

Type of data

Your personal data processed by our company through the use of video surveillance systems consist of images that may potentially depict you whenever you enter the camera’s range of action.

Legal basis

The legal basis for the processing of images is established pursuant to art. 6 of the GDPR from the legitimate interest (art.6, paragraph 1, letter f) and, namely: protection of the Company’s assets.

Method of treatment

The data processing is carried out through the recording/detection of images. Only authorized individuals, who have been trained in GDPR compliance and bound by confidentiality agreements, may access and view the recordings when necessary for the purposes pursued.

Categories of entities to which data may be communicated

The images may be disclosed to subjects who, if strictly required by law, can access the data in accordance with legal provisions, within the limits established by the laws themselves (e.g., Police and Competent Authorities in case of criminal offenses).

In any case, the images will not be subject to dissemination or, except as indicated above, communication to third parties.

For the purposes of the efficiency and maintenance of the systems, the facility collaborates with an external company specifically appointed as the Data Processor (RANGERS S.R.L., REGISTERED OFFICE AT VIA LUCA DELLA ROBBIA No. 25 36100 - VICENZA). This company performs routine maintenance tasks, providing instrumental and subordinate services under the control of the Data Controller, as a supplier of the video surveillance system and/or image recording management software.

Maintenance interventions are carried out in the presence of a company employee.

Extra EU data transfer

The treated images are not transferred outside the European Union.

Image retention

The images are stored for a maximum of forty-eight hours following their recording.

However, special requirements for additional retention may apply during holidays or office closures, as well as in cases where compliance with a specific investigative request from judicial or law enforcement authorities is necessary.

The company has conducted a privacy impact assessment in accordance with art. 35 of the GDPR.

The employed system is programmed for the automatic deletion of images.

Rights of the data subject

At any time, the data subject may exercise their rights regarding the data as provided by articles 15-22 of the GDPR, if applicable, including:

These rights may been forced against the company by sending a specific request addressed to: ERQOLE HOSPITALITY S.r.L. with registered office in Monte Argentario (GR), ViaPrivata Cirio without street number, 58018 (District: Porto Ercole), with the object: “privacy rights”, or by email at: privacy@erqole.it. 

Automated decision-making

Under no circumstances will your data be used to obtain information about your preferences or behaviour, nor will you be subject to any decision based solely on the automated processing of your personal data.


The data subject has the right to lodge a complaint with the Data Protection Authority (whose contact details can be found on the website www.garanteprivacy.it) in case of unlawful processing or delay in the Data Controller’s response to a request relating to your rights.