Privacy notice.

Who handles the data

The data controller is Horto S.r.l., Via San Protaso 5, 20121 Milan, Italy, VAT 11335020969.

For anything concerning your data, write to ciao@hortorestaurant.com.

What we collect, and when

We collect data at five moments, and at no other. The first four happen on this site, the fifth at the restaurant.

• Booking a tableThe booking form is an external service, Prenota-Web, shown inside a window on the site. Your name, telephone number, email and any requests reach the restaurant's booking system when you type them there. On certain dates a card is required as a guarantee, handled by Stripe: card details never pass through our systems.
• Buying a gift cardPayment happens on Stripe, which collects the buyer's email. If the gift card is a present, you also give us the recipient's name, email and a message: they serve to deliver it, and stay attached to the voucher.
• Subscribing to the newsletterWe ask for your email address and a consent box, which is never ticked in advance. Alongside the address we keep the proof of that consent: the exact wording you accepted, the moment you did, and the IP address the subscription came from. It exists so we can show, if it is ever needed, that you asked for it.
• Writing to usIf you email the addresses shown on the site, we handle what you write in order to reply.
• Coming to dinnerWhen you book and come, we keep a record of the visit: when you were here, how many you were, the occasion if you told us, what you chose and what the bill was. If you tell us you prefer a table, a wine or a way of eating, we note it down so we remember next time. If you tell us about an allergy or an intolerance, we note it so we can serve you safely: it is health data, and we treat it with the care it deserves (see below).

The site has no registration area, asks for no password and creates no accounts.

Why, and on what basis

• Handling the booking or the purchaseLegal basis: performance of a contract, or steps taken at your request before entering one (art. 6.1.b GDPR). Without this data we cannot hold your table or issue the gift card.
• Delivering the gift card to its recipientLegal basis: performance of the contract with the person who bought it. For the recipient we handle the minimum needed to deliver it: name, email and the message written for them.
• Sending you the newsletterLegal basis: your consent (art. 6.1.a GDPR). You can withdraw it whenever you like and we stop from that moment: the link is at the foot of every email, or write to ciao@hortorestaurant.com. Withdrawing consent does not affect what was done before.
• Serving you safely if you have an allergyAllergies and intolerances are health data (art. 9 GDPR) and we process them only with your explicit consent, which you give us the moment you tell us about them (art. 9.2.a GDPR). They serve one purpose only: not harming you. We do not use them to profile you or to decide what to offer you, and they never enter any commercial mailing. The detail is seen by whoever prepares and serves the dish; in the system we use to manage the relationship only the indication that you have a dietary requirement remains, not which one.
• Recognising you when you come backWe keep your visits, your preferences and your spending together so we can recognise you, remember what you enjoyed and look after the service. Legal basis: our legitimate interest in nurturing the relationship with the people who come to us (art. 6.1.f GDPR). You can object at any time by writing to ciao@hortorestaurant.com, and we stop from that moment.
• Tax and accounting obligationsLegal basis: a legal obligation (art. 6.1.c GDPR).
• Replying to people who write to usLegal basis: our legitimate interest in answering those who contact us (art. 6.1.f GDPR).

Who we share data with

We do not sell data and we pass it to no one for their own purposes. It is handled on our behalf, as processors, by those who provide a service we need:

• Prenota-Webthe restaurant's booking system. It receives the booking details.
• Stripegift card payments and guarantee cards. Card details are handled by them, not by us.
• Amazon Web Services (SES, Ireland)sending transactional email, for instance delivering a gift card.
• Scaleway (Paris)the infrastructure hosting the site, the database and the images.
• OpenStreetMapthe map showing where we are, on the Contact page. It loads with that page, and at that moment it receives your IP address.

The data of the people who come to see us flows into our guest relationship management system. It is not a third-party service: it is software running on our own infrastructure, and nobody outside our team has access to it.

The site, the database and the email stay on servers within the European Union. Stripe may also handle data outside the EU: in that case the transfer relies on the standard contractual clauses approved by the European Commission. The map is served by the OpenStreetMap Foundation, based in the United Kingdom, a country the European Commission has recognised as providing an adequate level of protection.

How long we keep it

• Bookingsfor as long as the service and our relationship with you require.
• Gift cardsuntil the voucher expires or is redeemed.
• Allergies and intolerancesfor as long as you come to see us, because they are needed at every visit. We delete them along with the rest, and sooner if you ask.
• Visits, preferences and spendingfor as long as our relationship with you is alive. If you do not come back for five years, or if you ask us to stop, we delete them.
• Newsletter subscriptionfor as long as you stay subscribed. When you unsubscribe the subscription ends at once, but the proof of consent remains: it is what lets us show that it existed, and when it ended.
• Tax recordsten years, as the law requires.
• Emails you send usfor as long as it takes to reply and keep a record of the exchange.

Cookies

This site measures how it is used, with Google Analytics loaded through Google Tag Manager. Nothing starts before your consent: until you choose, nothing is downloaded. The only cookie we set ourselves is called NEXT_LOCALE and remembers the language you picked: it is technical, and the law does not require your consent for it.

Two parts of the site, however, come from elsewhere: the map on the Contact page (OpenStreetMap) and the table booking form (Prenota-Web). Loading them hands them your IP address. That is why they do not start on their own: on your first visit a strip at the bottom of the page asks, with two answers, and until you choose they stay off. In their place you see a panel saying what is missing and who it comes from.

Your choice, either way, is kept in a cookie called horto-consenso for six months: we do not ask again on every page, and a refusal counts exactly as much as a yes. You can change your mind at any time via «Cookie preferences» at the foot of every page. For individual tracking technologies there is a second panel, provided by Iubenda, that lets you choose item by item.

When you pay for a gift card the payment happens on Stripe's own pages, which set their own cookies, needed to make it work and to prevent fraud. That processing is described in Stripe's notice.

Your rights

At any time you can ask us to:

• tell you what data we hold about you, and give you a copy;
• correct it, if it is wrong or incomplete;
• delete it, where no legal obligation requires us to keep it;
• restrict how it is handled, or object to handling based on legitimate interest;
• give it to you in a machine-readable format, so you can take it elsewhere.

Write to ciao@hortorestaurant.com. We reply within one month. If you believe something is wrong, you may contact the Italian data protection authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it).

Minors

The site is not aimed at children under fourteen and does not knowingly collect their data.

If this notice changes

If the way we handle data changes, we update this page and the date at the top. Earlier versions remain available on request.