Privacy Policy

Last updated: 10 October 2026.

This Privacy Policy explains how we collect and use personal information when you visit palazzettomanassei.com, download one of our free guides (on this site or through a form in one of our Facebook or Instagram adverts), join our opening list or contact us. It applies to the English and Italian versions of the site.

Who we are

Palazzetto Manassei is run by Phenom Digital Limited (“we”, “us”, “our”), a company registered in England and Wales (company number 12332317) with its registered office at 445 Limpsfield Road, Warlingham, CR6 9LE, United Kingdom.

We are the controller of the personal information described in this policy. We handle it in line with:

  • the UK General Data Protection Regulation (UK GDPR);
  • the Data Protection Act 2018;
  • the Privacy and Electronic Communications Regulations;
  • for visitors in the European Union, the EU General Data Protection Regulation.

If you have any questions about this policy or your personal information, email us at benvenuti@palazzettomanassei.com.

The information we collect

When you download a free guide

Our free guides (for example the water-release planner and the 3-day itinerary) are offered through short forms. When you fill one in we collect:

  • your email address (required);
  • your first and last name (optional);
  • your consent to receive the guide and our emails;
  • which guide you asked for.

When you join the opening list or send us an enquiry

Our “opening list” and enquiry forms ask for:

  • your email address (required);
  • your name (optional);
  • a message (optional).

There is also an optional box you can tick to join the opening list and receive our emails. If you don’t tick it, we only use your details to reply to your enquiry.

Your email address is needed so we can send you our emails or reply to you. Without it we cannot do either. All other fields are optional.

Technical details sent with a form

When you submit any of our forms, our form software also records:

  • your IP address;
  • your browser and device type;
  • the page you sent the form from.

We keep these details with your submission to help prevent spam and abuse, and to show when and how you signed up.

When you fill in a form in one of our adverts

Some of our adverts on Facebook and Instagram include a short form, so you can ask for a free guide without leaving the app. Meta may fill in some details from your profile, and you can change them before you submit. When you submit the form, we receive:

  • your email address;
  • your first name;
  • your answer to when you are thinking of visiting;
  • whether you ticked the optional box to receive our emails;
  • which form you used, and Meta’s reference number for your submission.

We keep these details in our mailing list database, but we only send you our emails if you ticked the box agreeing to receive them.

When you email us

If you email us directly, we receive your email address, your name if you include it, and whatever you choose to tell us.

Information collected automatically

  • Cookies and similar technologies.
    • A few cookies are needed to run the site, remember your cookie choices and remember your language.
    • Analytics and advertising cookies are only used if you agree to them in our cookie banner.
    • Full details, including each cookie and how long it lasts, are in our Cookie Policy.
  • Analytics (only with your consent).
    • If you accept “Statistics” cookies, we use Google Analytics to see how visitors use the site, for example which pages are popular, so we can improve it.
    • Google says it uses the IP addresses of visitors from the UK and EU only to work out an approximate location, and then deletes them.
  • Meta Pixel (only with your consent).
    • If you accept “Marketing” cookies, we use the Meta Pixel, a piece of code from Meta (the company behind Facebook and Instagram).
    • It tells Meta which pages of our site you visit, together with technical details such as your IP address, your browser and the _fbp cookie.
    • We use it to measure how well our adverts work, and we may use it to show our adverts to people who have visited the site.
    • If you are logged in to Facebook or Instagram, Meta may link this information to your account.
  • Server and security logs. Our hosting provider and our security software automatically record standard technical information to keep the site secure and running. This includes your IP address, your browser type and the pages requested.

Our fonts and images are stored on our own server, so simply viewing a page does not share your data with font or image providers.

How we use your information, and our legal basis

  • To give you the guide you asked for and send you our emails.
    • Legal basis: your consent.
    • The guide appears as a download link straight after you submit the form.
    • If you sign up on the English site, we send a short series of emails over the following three weeks or so, then occasional updates.
    • If you sign up on the Italian site, we send occasional updates.
    • Our emails cover visiting Marmore Falls and the Valnerina, and news about our own house in Collestatte when it is ready for guests.
  • To see whether our emails are useful.
    • Legal basis: your consent, which you give when you sign up.
    • Our emails contain a small tracking image and tracked links, so we can see whether an email was opened and which links were clicked.
    • Unsubscribing stops this at any time. Blocking images in your email app stops the open tracking.
  • To deal with a request made through a form in one of our adverts.
    • The guide is available from a link at the end of the form.
    • Legal basis for sending you our emails: your consent, given by ticking the box in the form.
    • If you did not tick the box, we keep a record of your request on the basis of our legitimate interest in knowing who has asked for our guides, and we do not email you.
  • To reply to your enquiry. Legal basis: our legitimate interest in responding to you, or taking steps you have asked for before any booking.
  • To understand and improve the website (analytics) and to measure our adverts (Meta Pixel). Legal basis: your consent, given through the cookie banner.
  • To keep the website secure, prevent spam and keep records of consents and unsubscribes. Legal basis: our legitimate interests and our legal obligations.

Where we rely on consent, you can withdraw it at any time:

  • for emails, use the unsubscribe link at the bottom of any email, or email us;
  • for cookies, use the “Manage consent” tab (shown on larger screens), or the consent settings on our Cookie Policy page.

Withdrawing consent does not affect anything we did before you withdrew it.

We do not sell your personal information, and we do not make decisions about you based solely on automated processing.

Who we share your information with

Our mailing list and form entries are stored in our own website database, not with a third-party email marketing company. We share personal information only with the following service providers, and only as far as they need it to provide their service:

  • Hostinger hosts the website, its database and backups. It also provides our email, which we use to send our emails and receive your messages.
  • Google provides Google Analytics, which only runs if you accept statistics cookies.
  • Meta provides the Meta Pixel, which only runs if you accept marketing cookies.
    • Under Meta’s Business Tools Terms, we and Meta are joint controllers for collecting this data on our site and sending it to Meta.
    • For visitors in the EU, Meta’s party is Meta Platforms Ireland Limited. For visitors in the UK, it is Meta Platforms, Inc. The terms are set out in Meta’s Controller Addendum.
    • After that, Meta uses the data as an independent controller under its own privacy policy.
    • If you fill in a form in one of our adverts on Facebook or Instagram, Meta passes us the details you submit in it.
  • Uncanny Owl provides Uncanny Automator, the software that copies the details from our advert forms into our website. The details pass through its servers on the way. Uncanny Owl says it does not store them.
  • Wordfence (Defiant, Inc.) is our security software. It checks traffic to protect the site from attacks and may process IP addresses for that purpose.

We may also disclose information where the law requires us to.

Sending data outside the UK and EU

Some of these providers are based outside the UK and the EU, or may process data there. Google, Meta and Defiant are based in the United States, and Uncanny Owl may also process data outside the UK and the EU. Where that happens, we rely on one of the following:

  • for providers certified under them, the UK–US “data bridge” and the EU–US Data Privacy Framework;
  • otherwise, standard contractual clauses or the UK International Data Transfer Agreement.

You can ask us for details of these safeguards.

How long we keep it

  • Mailing list: until you unsubscribe or ask us to delete your details. If you unsubscribe, we keep your email address on a suppression list so that we do not email you again.
  • Enquiries and form entries (including the technical details above): for as long as we need them for the purposes described here. We then delete them, or sooner if you ask us to.
  • Analytics: in line with the data retention setting in our Google Analytics account.
  • Server and security logs: for a short period, for security.

Your rights

You have the right to:

  • ask for a copy of the personal information we hold about you;
  • ask us to correct it;
  • ask us to delete it;
  • restrict how we use it;
  • ask for a copy in a portable format;
  • withdraw consent where we rely on it.

You can also object at any time to our use of your information for direct marketing, and to any use based on our legitimate interests.

To exercise any of these rights, email benvenuti@palazzettomanassei.com. We will reply within one month.

If you are unhappy with how we have handled your information, you can complain to the UK Information Commissioner’s Office (ico.org.uk). If you live or work in the EU, you can also complain to the data protection authority in that country. In Italy, that is the Garante per la protezione dei dati personali (garanteprivacy.it). We would, however, appreciate the chance to put things right first.

Security

We take reasonable technical and organisational measures to protect your information, including secure hosting, encrypted (HTTPS) connections and security software. No method of transmission over the internet is completely secure, but we work to keep your data safe.

Children

This website is intended for adults planning travel. It is not directed at children, and we do not knowingly collect personal information from children.

Changes to this policy

We will update this policy when the way we handle personal information changes. For example, when we start taking bookings we will explain how booking and payment details are handled. The “last updated” date at the top shows when it was last changed.

Contact

Phenom Digital Limited, 445 Limpsfield Road, Warlingham, CR6 9LE, United Kingdom.

Email: benvenuti@palazzettomanassei.com.

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