Privacy Policy for the website visitors pursuant to Article 13 of the UE Regulation 679/2016
This Privacy Policy complies with Article 13 of the UE Regulation 2016/679 (“Regulation”) and explains our privacy policy and how your personal data are treated when you visit our website (, “Website”), so that you can express your consent to the treatment of your personal data explicitly and consciously, when it is required. The information and data you provide us with, or that we collect in any other way when you visit our Website (“Services”) will be treated pursuant to the Regulation and the principles of data protection, which inspire the activities of Homefidence.

Pursuant to the Regulation, Homefidence is committed to process your personal data lawfully, fairly and in a transparent manner, restricting the purposes of processing and archiving, minimizing data collection and ensuring accuracy, integrity and confidentiality, in accordance with the responsibility principle of Article 5 of the Regulation. 


Homefidence di Cristiano Berti, with headquarters in Viale Monte Nero 59, 20135 Milan (“Homefidence” or “Data Controller” or “We”), is committed to protect the privacy of the visitors of its website. Before sharing any personal data of yours with the Data Controller, please read this Privacy Policy carefully, because it contains important information about how your personal data are protected. 

Personal data subject to processing may include, depending from the services required: identification information (your name, identification number, localization data, online identification code), one or more features regarding your personal, physiological, psychical, economic, cultural or social identity, which may either identify or make you more easily identifiable.  
Personal data collected by our Website are the following: 

 a) Navigation data
Information systems and software procedures allowing the Website to work properly, automatically collect web browsing information, required by Internet communication protocols. Although the purpose of colleting this information is not to identify visitors, this may happen by associating and elaborating it with data owned by third parties. This category comprises: IP address, domain names of the computers used by visitors of the Website, URIs (Uniform Resource Identifier), time of the request, method of submitting the request to the web server, size of the file sent to the system, numeric code indicating the status of the request given by the web server (successful, error, etc.), other indicators of the visitors’ operating system and web infrastructure. Collecting this information allows us only to get anonymous statistics, which show how the Website is used and if it works properly, i.e. we can detect problems/frauds. Data are immediately destroyed after being processed. Data may be processed in the event of internet crimes suffered by the website or by third parties. 
For the relevant policies please visit the sections of our website dedicated to special services, some of which may be provided upon registration. Sharing your personal data will thus be required.  

 b) Special categories of Personal Data 
If you access the services offered by the Website page “Agents” (, we may collect some of your personal data belonging to the special categories mentioned by the Article 9 of the Regulation: “[…] personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”. Please do not disclose this information if not strictly necessary. If you disclose special categories of personal data without any explicit consent to the processing, which still allows you to send your curriculum vitae, Homefidence will neither bear liability nor be subject to any reprimand, because you have authorized the data to be processed by publicly and personally disclosing them pursuant to Article 9.1.e) of the Regulation. Notwithstanding that, we recommend you explicitly give your consent to the processing of special categories of personal data, if you decide to share them. 
During the CV screening process, Homefidence may visit the profiles of the candidates freely available on professional social networks on the Internet (such as LinkedIn). 

c) Data collected through Cookies
What are cookies? 
When you browse our Website, you may detect cookies, i.e. short pieces of data sent by websites to the visitor’s browser (the program you use to surf the net, such as Chrome, Explorer, Mozilla, etc.), where they are stored and later sent back to the same websites upon the following visits. When you navigate a website, you may be tracked by cookies of websites and web servers of other providers (i.e. “third parties” cookies). You find detailed information in the sections of our website dedicated to special services. Some of them may be provided upon registration, so that your personal data are required. We can make a distinction between technical cookies, which allow the website to work properly and can be used freely, and profiling cookies, which display advertising based on the interests of visitors whilst browsing the website. Profiling cookies must be accepted by visitors. 
Our website uses both technical and third parties profiling cookies. 

Technical cookies 
We use both technical Cookies, which store the browsing habits of the users and improve the navigation on our website, and analytical Cookies (such as Google Analytics provided by Google Inc., or “Google”), which collect statistics on users’ navigation in an anonymous and aggregate way (for instance, the number of pages visited, the number of accesses, the time spent on the website), useful to understand how the website can be improved. 
If you want more information about how data are treated by Google through Google Analytics, please visit the following page:, and read Google privacy policy at the following page:
These cookies do not need to be allowed, but you can always decide to disable them. Cookies by Google Analytics can be disabled as explained by Google itself (v.

d) Profiling Cookies by Third Parties
Some pages of this Website also send to your browser profiling cookies of third parties, so as to allow contents hosted on external platforms (such as YouTube) or linked to either Google AdWords or Facebook services (with the purpose of displaying advertisement based on the websites you visited previously) to be displayed and to interact with them. For this reason, when you visit these pages, a banner appears to inform you that these cookies are issued. You give your consent to these cookies by either closing the banner or clicking on any other element of the page outside it. Homefidence has no access to the data collected by third parties cookies, which are used autonomously by service providers. For more information about how data collected by these cookies are processed, you can read the privacy policies of the service providers. 
Third party cookies can be disabled by clicking on the links provided. If there are no links for this purpose, you can refer to the following website, which allows you to manage your preferences regarding cookies. 

e) How to manage Cookies in your browser
You can set up your browser, so that it informs you if cookies are issued. In this way, you can decide whether to accept a single cookie, disable it or reject all the cookies automatically. Below are the instructions about how to enable/disable cookies for the most common browsers: 

• Google Chrome:
• Mozilla Firefox: 
• Apple Safari:
• Opera:
• Microsoft Internet Explorer and Microsoft Edge:
Disabling cookies may result in some functions of the Website not to work completely or partly.  

f) Data collected for the purpose of the booking 
The website showcases the services and the activities of Homefidence. According to your own preference, you can book accommodation in the apartments we manage directly or whose reservations we are responsible for. 
After choosing the accommodation you prefer, you must provide Homefidence with the following data, in order to complete the reservation: name, surname, date of birth, fiscal code and/or VAT number, address of residence, ID number, phone number, fax and email address. 
We will use these data to complete the reservation and manage the deposit/down payment only. When the hospitality contract is signed, you will receive a new, detailed statement regarding this kind of data processing. 

Your data will be processed in order to: 
3.1 allow you to browse the Website and successfully provide our services, such as ensuring the Website security and managing the reservations; 
3.2 fulfill the obligations enforced by applicable laws, regulations or the EU legislation, or comply with the instructions of the authorities;
3.3 carry out statistical analysis, without tracing the identity of the person; 
3.4 screen CVs and give feedbacks to the candidates who sent their application through the website page “Agents”;
3.5 send newsletters and communications for direct marketing via email, text message, mms, push notifications, fax, mail, telephone with operator assistance, either directly or indirectly through third parties providing marketing and communication services;
3.6 carry out profiling activities by collecting and analyzing the choices and preferences of the Website’s visitors, with the aim of sending personalized offers about products and/or services. 
Security measures are applied to avoid data loss, illegal or wrong use, and non-authorized access. 

Article 6.1.b) of the Regulation serves as legal basis for personal data processing for the purposes of Section 3.1: personal information processing is required to provide services or to satisfy your requests. 
Article 6.1.c) of the Regulation serves as legal basis for personal data processing for the purposes of Section 3.2 (“processing is necessary for compliance with a legal obbligation to which the controller is subject”). Giving consent to personal data processing for these purposes is optional, but refusing to consent would prevent the required services from being provided.
Please note that the operation of data processing as provided for in Section 3.3 is not based on personal data, therefore no limitation is foreseen upon the Controller. With reference to point 3.4 and the analysis of the social profiles on professional platforms available on the Internet as mentioned in Section 2.b, the legal basis for personal data processing falls within the scope of Article 6.1.f) of the Regulation, i.e. the legitimate interest of Homefidence to ensure the candidate is suitable for the vacant position. 
The legal basis for personal data processing for the purposes of Sections 3.5, 3.6 and 3.7 falls within the scope of Article 6.1.a) of the Regulation, since consent is required to process personal data. Consent is optional and can be withdrawn anytime with no consequence, apart from the fact that you will stop receiving marketing communications, and/or no profiling activities will be carried out. Previous consent can be withdrawn following the instructions of Paragraph 8 of this Privacy Policy. 
If data processing serves the purpose of sending advertisement, promoting direct selling, carrying out market researches or sending commercial communications for products or services offered by the Controller and similar to those currently purchased by the User, Homefidence can use email addresses pursuant to and within the scope of the legislation in force (ex Article 130, Sub-article 4 of the Privacy Regulation) and as prescribed by the Data Protection Authority regulation of 19 June 2008, also when no explicit consent is given. Legal basis for this operation of data processing is Article 6, Sub-article 1, Letter f) of the Regulation. You have the right to refuse or withdraw consent for this operation of data processing any time, immediately or following later communications, easily and with no charge, by writing to the contacts listed in the “Contacts” section. Interruption of the data processing will be notified immediately (Article 15 of the Regulation). 

The personal data we collected may be shared for the purposes described in Section 3 of the Privacy Policy with the following:
5.1. people acting as Data Processor pursuant to Article 28 of the Regulation, i.e. people working with the Data Controller for the purposes described above, including those carrying out technical maintenance (jointly known as “Representatives”); the list of external Data Processors may be asked to the Data Controller in writing using the contacts listed in the “Contacts” section of this Privacy Policy; 
5.2. people, bodies or authorities we are obliged to disclose your personal information to, as prescribed by the law or following the provisions of competent authorities; 
5.3. people committed to maintain confidentiality or placed under a reasonable confidentiality obligation by law, who pursuant to Article 29 of the Regulation process personal data in order to perform activities strictly related to the provision of services, under the authority of the Data Controller.
The updated list of those who may process personal data as Data Processor will be provided by sending a written request to the Data Controller using the contacts listed in the “Contacts” section of the website. 

Although transferring personal Data to Countries not belonging to the European Economic Area is not foreseen by our standard procedure, we inform you that data processing complies with one of the provisions of the regulations in force, including consent of the subject, application of Standard Clauses approved by the European Union, choice of entities belonging to International programs for the free movement of data (such as the EU-USA Privacy Shield) or operating in Countries considered safe by the European Commission. More information will be provided upon request by the Data Controller at the contacts listed above. 

Personal data processed for the purposes listed in Section 3.1 are retained for the time strictly necessary to satisfy these purposes. In any case, since processing aims at providing services, the Data Controller will keep personal data for the time prescribed and allowed by the Italian regulations protecting legitimate interests (Article 2946 of the Civil Code and later amendments). 
Personal data processed for the purposes listed in Section 3.2 are retained for the time prescribed by the applicable legislation or pursuant to legal obligations.  
More information about how long data will be kept and applicable laws can be requested in writing to the Data Controller at the contacts mentioned in this Privacy Policy. The Data Controller has the right to keep personal data for the time prescribed and allowed by the Italian regulations protecting legitimate interests (Article 2947 of the Civil Code). 
Pursuant to Article 15 and later amendments of the Regulation, you have the right to ask Homefidence to: access, rectify or delete your Personal Data; object to the processing or restrict its scope in the circumstances set out in Article of 18 of the Regulation; obtain your data in an structured, commonly used and machine readable format, in the circumstances set out in Article 20 of the Regulation. 
Requests of this kind must be made in writing to the Data Controller using the contacts listed in this Privacy Policy. Pursuant to Article 77 of the Regulation, you always have the right to lodge a complaint with the Data Protection Authority, if you have concerns about your Personal Data not being handled in compliance with the law. 

We may change or update the content of this Privacy Policy from time to time, entirely or in part, to comply with changes in the applicable law. We encourage you to visit this page regularly to be informed of the latest changes of the Privacy Policy and be updated about how Homefidence uses your personal data. To enforce the rights mentioned above or for any other request, please contact us: you may write to our postal address or send an email to, preferably adding in the subject line the title “Request to enforce privacy rights”.

Updated on Oct 12, 2018