Privacy Policy

ACCEPTANCE

By visiting the website www.sugos.it (hereinafter the site or our site or our website), using its services, or interacting with ‘L Four s.a.s., you confirm that you have read and understood this Privacy Policy and consent to the collection, use, storage, transmission, and disclosure of personal data collected in accordance with this Privacy Policy.


1. PROCESSING OF PERSONAL DATA

In this Privacy Policy, the term “Personal Data” refers to any information that allows ‘L Four s.a.s. to directly or indirectly identify you (or a third party whose data you provide), including any information related to the purchase of goods or services, or that you choose to communicate to or share with us, or with third parties, while using our website or directly at our facilities. Personal data will be processed in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and, where applicable, the legislation of the country in which the data is collected. ‘L Four s.a.s. reserves the right to carry out further data processing where required by law or in the context of criminal or other investigations or proceedings.


2. PERSONAL DATA COLLECTED

Source of the data

‘L Four s.a.s. collects personal data from users only when they voluntarily provide information, for example:

  1. in the case of websites that distribute and/or provide ‘L Four s.a.s. services: by making a reservation through the website(s) as a “guest”; by opening or modifying an account; by conducting searches on the website; by contacting us by sending a comment or question or through our telephone, email, or social media contacts; or by requesting confirmation of a reservation;
  2. in the case of online reservations at our restaurant or residence: by completing any customer form available on our website, by engaging in informal conversations during reservation calls, by interacting through the same channels, or by purchasing services;
  3. in the case of ‘L Four s.a.s. customer service: by requesting assistance, special services, or post-stay support;
  4. in the case of emails, SMS, and other electronic messages: by exchanging communications between you and ‘L Four s.a.s.

If you provide personal data to third parties (for example, family members, other customers, or potential customers), you should ensure that such third parties are informed and have authorized the use of their data as described in this Privacy Policy.

Types of Data

‘L Four s.a.s. may collect and use different types of personal data depending on the specific purposes pursued and described below:

  1. Personal information, such as name, surname, gender, age/date of birth, country of origin, and other personal data permitted by applicable law;
  2. Contact information, such as home address, email address, telephone number, mobile phone number, fax number (if applicable), and other contact information permitted by applicable law;
  3. Payment information, such as payment method (credit or debit card), if required, and passport number, where required for tax purposes or in relation to applicable anti-money laundering regulations;
  4. Sales-related information, such as data, products or services provided, amount, sale total, VAT number, complaints, refunds, or other sales-related information permitted by applicable law.

3. PURPOSE OF PERSONAL DATA PROCESSING

Depending on the specific circumstances surrounding the interaction between the user and ‘L Four s.a.s., personal data may be used for the following purposes: online sales directly from our website.
The personal data provided by the user or collected at the time of booking, namely basic personal data, contact information, data relating to the individual booking, tax information, payment details, sales-related information, and any other data strictly necessary for the provision of the catering service or the sale of the stay, will be used to:

  1. manage, administer, and process accommodation purchases, sales, and after-sales services, such as administrative activities, accounting, warranties, refunds, where applicable, fraud prevention, and communications with the user, including via email, for any issues relating to the management of the accommodation or subsequent requests relating to the stay;
  2. comply with obligations imposed by laws, regulations or EU legislation (including anti-money laundering regulations) and establish or defend legal claims.

It is necessary to provide personal data for the aforementioned purposes, and refusal to do so would make it impossible to complete the purchase. Except where otherwise required to comply with applicable local regulations, data processing for these purposes, as it is necessary to fulfill contractual and legal obligations, may be carried out without requesting the user’s consent.


4. PRIVACY PROTECTION OF MINORS

Our website is intended for a general audience, but its services are intended for individuals aged 18 and over. ‘L Four s.a.s. does not knowingly solicit, collect, use, or disclose personal data provided by individuals under the age of 18, either online or at its facilities. If ‘L Four s.a.s. learns or is informed that it has personally collected data from a minor, it will delete that data.
If you are under the required age, please ask an adult (i.e., your parent or guardian) to complete the necessary procedures to make the reservation.


5. STORAGE, ACCESSIBILITY, AND TRANSFER OF PERSONAL DATA

The processing of personal data collected through our website is primarily carried out using electronic or Internet-based means, including web analytics services hosted on servers operated by providers selected by ‘L Four s.a.s.
Access to personal data will be granted only to authorized personnel at our facilities, based on a need-to-know basis and using multi-level access control tools.
If ‘L Four s.a.s. needs to transfer personal data abroad in order to pursue the purposes set out in this Privacy Policy, even where the legislation governing personal data differs from that applicable in the country in which the user is located, it will take measures to ensure that such communications comply with European data protection standards or other local standards used in the country in which the data is collected, so that your data remains secure and confidential.


6. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

‘L Four s.a.s. has implemented and will implement appropriate measures to protect your personal data from accidental loss and unauthorized access, use, modification, and disclosure. For example, when you provide order information, we use SSL (Secure Socket Layer) technology, an encryption tool that ensures the security of information transmitted over the Internet. This website also uses password controls, firewall technology, and other technological and procedural security measures. While we have implemented the aforementioned security measures for our website, you should be aware that 100% security cannot be guaranteed. Therefore, you provide your personal data at your own risk and to the fullest extent permitted by applicable law. ‘L Four s.a.s. will not be liable in any way for disclosure of such data due to errors, omissions, or unauthorized actions of third parties during or after its transmission to us.
‘L Four s.a.s. recommends that you:

  1. Periodically update your software to protect data transmission over networks (e.g., antivirus software) and ensure that your electronic communications service provider has implemented appropriate measures to secure data transmission over networks (e.g., firewalls and anti-spam filters);
  2. Keep your request data confidential and not disclose it to anyone;
  3. Periodically review your data.

In the unlikely event that ‘L Four s.a.s. believes that the security of your personal data in its possession or under its control has been or may have been compromised, it will inform you of the incident in accordance with applicable law, using the methods prescribed therein (by providing ‘L Four s.a.s. with your email address, you consent to receive such communications electronically via that email address).


7. RIGHTS OF ACCESS TO PERSONAL DATA – MANAGING CHOICES

At any time and free of charge, the user may access their data or receive their electronic personal data in a structured, commonly used, machine-readable format and transmit it to another data controller (data portability), as well as have it corrected, updated, amended, or deleted (subject to any applicable exceptions). The user may update the data provided by contacting the same at the address provided below. Requests for data deletion are subject to ‘L Four s.a.s.’s applicable legal and document retention obligations.
If you believe there is a problem with the way we are handling your personal data, you have the right to lodge a complaint with your national data protection authority or with the authority of any other EU or European Economic Area country.
To exercise these rights, you may submit a request by contacting us directly by email at titty@sugos.it or by post to the registered office of ‘L Four s.a.s.. When contacting ‘L Four s.a.s., please be sure to include your name, email address, postal address, and/or telephone number(s) to ensure we can properly handle your request.


8. DATA RETENTION

Personal data will be retained for the duration of the business relationship and for as long as necessary to achieve the purposes described in this Privacy Policy. After this period, your personal data will be retained only to comply with legal and regulatory obligations (for example, for 10 years for accounting purposes; for the duration of mandatory retention obligations for tax purposes; etc.) or to allow us to maintain proof of our respective rights and obligations.


9. DATA CONTROLLER – DATA PROTECTION OFFICER – COMPANY CONTACT DETAILS

For the purposes of this Privacy Policy and the data processing described herein, the Data Controller is ‘L Four s.a.s., with registered office at Via Assietta, 34 – 10050 – Sauze d’Oulx (TO).
For any comments or questions regarding this Privacy Policy and to speak with the local contact person responsible for handling requests relating to data processing, you can also contact ‘L Four s.a.s. at the following email address: titty@sugos.it.


10. UPDATES TO THIS POLICY – COMMUNICATIONS

‘L Four s.a.s. reserves the right, at its sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time by posting the revised version on this page of its website and updating the “Last Modified” date indicated below.


LAST UPDATED

This policy takes effect on December 9, 2025.

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