(GDPR 679/2016)

European Data Protection Regulation GDPR 679/2016

(General Data Protection Regulation)
Data controller

The Data Controller is the writer, in the person of the legal representative pro tempore.
Data Protection Officer (DPO)

The Data Protection Officer (DPO) has not been designated.
Purpose of the treatment

The personal data supplied by you are necessary for the fulfilments required by law.
Methods of treatment and conservation

The treatment will be carried out in an automated and / or manual form, in compliance with the provisions of art. 32 of GDPR 679/2016 concerning security measures, by persons specifically appointed and in compliance with the provisions of art. 29 GDPR 679/2016. Please note that, in compliance with the principles of lawfulness, purpose limitation and data minimization, pursuant to art. 5 GDPR 679/2016, subject to your free and explicit consent expressed at the bottom of this information, your personal data will be kept for the period of time necessary to achieve the purposes for which they are collected and processed.
Scope of communication and dissemination

We also inform you that the data collected will never be disclosed and will not be communicated without your explicit consent, except for the necessary communications that may involve the transfer of data to public bodies or other subjects for the fulfillment of legal obligations.
Transfer of personal data

Your data will not be transferred either to Member States of the European Union or to third countries outside the European Union. There is no provision for an automated decision-making process, including profiling.
Rights of the interested party

At any time, you may exercise, under Articles 15 to 22 of the GDPR 679/2016, the right to: request confirmation of the existence or otherwise of your personal data; obtain information about the purposes of the processing, the categories of personal data, recipients or categories of recipients to whom the personal data have been or will be communicated and, where possible, the retention period; obtain data correction and deletion; obtain treatment limitation; obtain data portability, ie receive them from a data controller, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without impediments; oppose the processing at any time and also in the case of treatment for direct marketing purposes; to oppose an automated decision-making process concerning people, including profiling. ask the data controller to access personal data and to rectify or cancel them or limit their processing or to oppose their processing, in addition to the right to data portability; revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation; propose a complaint to a supervisory authority.

You can exercise your rights with a written request sent to the postal address of the registered office or to the e-mail address (in hypertext link) that is highlighted in this communication.

This policy outlines the information we collect from you — and what we do with it. At HTE we consider your privacy to be extremely important to us. These are the fundamental principles that we follow in relation to your personal information:

  • We don’t ask you for personal information unless we truly need it.
  • We don’t share your personal information with anyone except to provide you with services, products, to comply with the law, or to protect our rights.
  • As a subscriber, your data is inherently yours, and it’s our job to keep it safe. We never market to your customers or share your data without your consent (not assumed by this policy).
  • As a customer (making a booking), your credit card is not stored on our systems. Your personal information is protected and is only made available to the operator accepting the booking.
  • We safeguard all data collected with industry leading security practices and encryption.

This policy was last updated May 24, 2018. This is the Privacy Policy of the HTE website located at  –  –  and our related products and services. It describes the information that we collect from you as part of the normal operation of our Site and Services, and how we use, disclose, and otherwise process this information. By accepting the Privacy Policy in registration or by visiting and using our Site or Services, you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. In this Privacy Policy, we use the following terms to describe different types of visitors and users of our Site and Services. Our customers are called “Subscribers” and our Subscribers’ customers are called “Customers”. We use the word “staff” to describe persons to whom Subscribers give “staff” access on the Site. Visitors to our Site are collectively described in this Privacy Policy as “Users” of our Site or “You”.

How We Use Your Information

We use personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Site and Services, to provide to you our Services; resolve service and billing disputes; troubleshoot problems; bill any amounts due from you; measure consumer interest in our products and Services, inform you about online and offline offers, products, services, events and updates; deliver information to you that, in some cases, is relevant to your interests, such as product news; customize your experience; detect and protect us against error, fraud and other criminal activity; provide you with system or administrative messages, and as otherwise described to you at the time of collection.On occasion we use email address or other contact information to contact our Subscribers to ask them for their input on our services, to forward to them media opportunities, and even to invite them to dinner. We may also use personal information about you to improve our marketing and promotional efforts, to analyze Site usage, to improve our content and product offerings, and to customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site. If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe in the email. If you wish to no longer receive our newsletters you may update the settings in your account, follow the unsubscribe instructions located in the email, or you may contact us at Please note that you may continue to receive transactional and account-related electronic messages from us.

What Information Do We Collect?

Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose. Once you become a User, we require you to provide various contact and identity information and other personal information as indicated on the relevant forms on the Site (which vary, depending on what kind of User you are), and you are no longer anonymous to us. Where possible, on these forms we indicate which fields are required and which fields are optional. In addition, as you use the Site, you can from time to time enter or send to us personal information. As you use the Site you can also from time to time enter personal information about third parties. For example, if you are a Subscriber, you can enter personal information about your Customers or your staff. You always have the option to not provide information by choosing not to become a User or by not using the particular feature of the Site for which the information is being collected. In general, you can browse the Site without telling us who you are or revealing any personal information about yourself. However, we automatically track certain information about you based upon your behaviour on our Site and store it through log files. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve you and our community, and to improve our Site. This information may include the URL that you just came from, which URL you next go, your computer browser information, and your IP address.


Please see our Cookies Policy for information about our use of cookies. Our Disclosure of Your Information We will share your personal information with third parties only in the ways that are described in this Privacy Policy, or as otherwise in accordance with instructions provided by our Subscribers. We do not sell your personal information to third parties. The following describes some of the ways that your information may be disclosed in the normal scope of business to provide our services:

Subscribers and Customers

In general, information you enter on the Site is available to staff members or others – to whom you give access to your account or to whom you give access to the information through the normal operation of the Site .

Anonymized Aggregated Data

We aggregate and anonymize sales information including (but not limited to) industry type, sales amounts and average sale per customer, and disclose such information in a non-personally identifiable manner to Subscribers as part of our Services to them. However, in these situations, we do not disclose any information that could be used to identify you personally. Subsidiaries and Affiliates; Service Providers We may from time to time use the services of affiliates, subsidiaries and unrelated service providers in the operation of the Site and Services, and may transfer personal information to them in the course of our use of their services. For example, we may use a third-party to operate our support services. This may involve the hosting of data, including personal information, on servers operated by those providers. We take care to use only service providers that we believe are reputable and able to live up to our and your expectations, including the handling of confidential information. These companies are authorized to use your personal information only as necessary to provide these services to us. Personal information may be maintained and processed by our affiliates, subsidiaries and unrelated service providers in the US or other jurisdictions. When personal information is in another jurisdiction for processing it may be accessed by the courts, law enforcement and national security authorities in accordance with the laws of that jurisdiction. For additional information about the manner in which our third-party service providers treat personal information, contact us as set out below.

Legal Requests and Business Transitions; Emergencies.

HTE and our US and other service providers may disclose your personal information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), (b) in response to a court order, subpoena, discovery request, search warrant or other lawful judicial or administrative proceeding, inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, court or law enforcement agencies), (c) as otherwise required or permitted under any applicable law, rule, or regulation, (d) to other organizations in the case of a breach of an agreement or contravention of law, for the purposes of detecting, preventing or suppressing fraud, and (e) in good faith, to protect or defend the rights or property of HTE and other users and (f) if HTE is involved in a prospective or completed merger, acquisition, or sale of all or a portion of its assets or as part of a corporate reorganization or other change in corporate control. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Your Use of Other Persons’ Information

In order to facilitate the Services provided by the Site, the Site allows you in certain circumstances to give other Users limited access to the personal information of other persons. For example, if you are a Subscriber, you may use the Site to give access to a staff member to the personal information of your Customers.


HTE strives to protect your personal information. We have implemented reasonable administrative, technical and physical safeguards designed to protect personal information in our custody and control from unauthorized access, use, modification and disclosure of personal information in our custody and control. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot warrant the security of any information you transmit to us.

Other Information Collectors

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect. To the extent that you disclose your information to other parties through the Site, whether they are Subscribers or Customers or otherwise, different rules may apply to their use, collection and disclosure of the personal information you disclose to them. Since we do not control the information use, collection or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose your personal information to others. Accessing, Correcting and Updating Your Personal Information To access, review, delete, correct and update your personal information in our custody and control to ensure it is accurate, you may login into your account to make the changes, or you may contact us at If we receive a request from an individual to access or update personal information we maintain on behalf of a Subscriber, we will direct that individual to the relevant Subscriber. We will assist our Subscribers wherever possible in responding to individual access requests.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Additional Policy Information With your consent we may post your testimonial along with your name. If you want your testimonial removed please contact us at Our Site includes Social Media Features, such as the Facebook and Twitter buttons and Widgets, such as the Share this button or interactive mini-programs that run on our Site. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. When you engage with our content on or through Social Media platforms, you may allow us to have access to certain information associated with your Social Media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your Social Media account, we may use this information to personalize your experience on the Site and on the Social Media platform, and to provide you with other products or services you may request. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. We will do our best to notify you when these terms change through our usual channels. We encourage you to periodically review this page for the latest information on our privacy practices.


It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information about how we or our third party service providers process your personal information, please email our privacy officer at: HTE di Conti Maurizio  Sede Legale e Operativa: Via Cà Magra 8/a 36010 Carrè (VI) Tel. +39 0445 540641