VIDEO SURVEILLANCE: What you need to know
Document updated on: March 20, 2024 (Version 02)
Who we are and what we do
The companies within the Erqole perimeter, listed below, process your personal data independently or jointly in accordance with the European General Data Protection Regulation (GDPR).
- ERQOLE S.r.L., registered office in Monte Argentario (GR), Via Privata Cirio snc, 58018 (Porto Ercole), certified email: erqole@pec.it, represented by its legal representative pro tempore;
- ERQOLE PROPERTIES S.r.L., same address as above, certified email: erqoleproperties@pec.it, represented by its legal representative pro tempore;
- ERQOLE HOSPITALITY S.r.L., same address as above, certified email: erqolehospitality@pec.it, represented by its legal representative pro tempore;
- ERQOLE COMMUNITY S.r.L., registered office in Orbetello (GR), Via Aurelia Km 145, 58015, certified email: hoteltris@cgn.legalmail.it, represented by its legal representative pro tempore;
- ERQOLE CALA PICCOLA S.r.L., same address as the first, certified email: erqolecalapiccola@pec.it, represented by its legal representative pro tempore;
- Società Agricola LA CAPITANA S.r.L., same address as the first, certified email: lacapitanaagricola@pec.it, represented by its legal representative pro tempore.
Hereafter, these entities are referred to either as individual Data Controller(s) or jointly as Joint Controllers.
Who is the data controller for video surveillance?
- Erqole Hospitality is the independent controller for systems located at the facilities listed under points 1 through 5.
- Società Agricola LA CAPITANA S.r.L. is the independent controller for the system at the facility listed under point 6.
These companies have signed a joint controllership agreement (Art. 26 GDPR), available upon written request.
What we record
We collect your images when you enter the field of view of our cameras.
Why we do it
We use video surveillance to:
Protect company assets (our legitimate interest – Art. 6(1)(f) of the GDPR)
Important: Cameras are NOT installed to monitor employees and comply with Art. 4 of the Workers’ Statute (Law 300/1970).
Who can view the footage
• Authorized personnel: only employees specifically trained in privacy regulations
• Law enforcement: when legally required
• Maintenance company: RANGERS S.R.L., registered office at Via Luca Della Robbia 25, 36100 – Vicenza, performs technical maintenance as an external data processor (always in the presence of one of our employees)
Images are not disclosed or communicated to third parties.
How long we keep footage
48 hours from recording, with automatic deletion.
Exceptions:
• During holidays or office closures
• Upon request by judicial or police authorities
Where we store footage
Images are not transferred outside the European Union.
Impact assessment
We have carried out a Data Protection Impact Assessment as required by Art. 35 of the GDPR.
Your rights
Right and what it means:
- Information: receive clear information about data processing
- Access: obtain a copy of your images (if it doesn’t infringe others’ rights)
- Rectification: correct inaccurate data
- Restriction: temporarily block processing in specific cases
- Portability: receive your data in electronic format
- Erasure: request data removal when no longer needed
Automated decisions
Your data will never be used to:
- Analyze your behavior
- Make automated decisions that affect you
How to exercise your rights
Send your request to the contact details provided above or by email to: privacy@miramis.it
Complaints
You have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) if you believe your rights have been violated.