Privacy note & whistleblowing

Protection of personal data & whistleblowing information

Declaration on the use of the personal data

in accordance with legislative decree 196 of 30.06.2003 “ Code on the subject of protection of personal data” and art. 13 of regulation (EU) 2016/679.

In accordance with art. 13, decree of 30.06.2003 196/2003, the P&H Management ltd, declares to have possession of and to treat personal data of clients and suppliers as well as personal data of those who voluntarily (personally, by telephone per fax, via email or registering on the site) communicates to all branches of industry of the P&H Management ltd.

Furthermore, P&H Management srl “data controller”, pursuant to the 2016 European Regulation, informs potential reporters, reported persons, facilitators and any other natural person potentially involved in the management of reports of the methods of processing their data.

P&H Management srl guarantees, within the framework of legal requirements, that the processing of personal data takes place in full respect of fundamental rights and freedoms, as well as the dignity of the interested party, with particular regard to confidentiality, personal identity and the right to the protection of personal data.

The contact details of P&H Management srl are as follows:
– e-mail:
– tel: +39 0473 448 335

Purpose of processing, scope of the treatment of data and legal basis

The processing of personal data concerns the management of reports and may concern heterogeneous categories of information relating to natural persons, including, at least potentially, particular categories of personal data (art. 9, GDPR) and personal data relating to criminal convictions and crimes ( art. 10, GDPR). Legal bases legitimizing the processing are the fulfillment of a legal obligation (art. 6, paragraph 1, letter c), GDPR) and, with regards to particular and criminal data, respectively the provisions of the art. 9, paragraph 2, letter. g) and art. 10, in conjunction with art. 2-octies, Legislative Decree 196/2003.:

It consists in the carrying out of legal obligations, derived from regulations, EC norms as well as civil and penal, in the carrying out of contractual obligations for the interested party, in carrying out activity related with commercial activity of  all branches of industry of the P&H Management ltd, for example the compiling of internal statistical data for invoicing as well as the activity of accounting client/supplier with a commercial scope such as transmission of commercial and publicity material (via post, fax or email) marketing, market research, in the protection of credit and management of debits. It also consists for the facilitation and realisation of guest booking, the successful execution of the guest’s stay, to coordinate the hotel stay according to the wishes and interests of the guest, to ensure the provision of future hotel services which correspond with the interests of the guest, for marketing purposes as pertaining to hotel performance and the improvement of this performance.


Data transmission

With references to the uses indicated, the personal data in case of necessity are transmitted to the public administration and authorities and when required by law credit institutions with whom P&H Management ltd has an agreement for the managing of credits ad debits and for financial intermediation to all persons real or judiciary, public or private (legal offices, administrative. fiscal tribunal, chamber of commerce, etc.), if the transmission is deemed necessary or used in the undertaking of commercial activity of all branches of industry of the P&H Management ltd with regard to suppliers/producers, or if it is deemed necessary for the registration of products. They will be also transmitted to contracted service providers who supply cloud-based software and data handling solutions to the hotel. These providers operate with the sole purpose of processing and analysing guest data for the aforementioned purposes.


Scope of communication and dissemination

The personal data treated by P&H Management ltd is not subject to distribution. The reporting person’s identification data will be visible exclusively by the specialized external company, acting as data controller pursuant to art. 28, GDPR and technological or telecommunications sub-suppliers, unless express consent is given by the reporting party. No further cases of communication of personal data are envisaged.

The Data Controller may be required to communicate the Data upon request from public authorities, including judicial ones.


Treatment mode

The treatment of data may take place with or without the auxiliary of electronic means or in any case automatic means and encompass all procedures outlined in art. 4, par. 1, letter a) of the legislative decree 196 of 30 June 2003 and necessary to the treatment of said data. In any case the treatment of data is executed in respect of all security norms that guarantee security and privacy.


Registration of data in the sphere of internet informatics services

The procedure and the informatics systems put at the disposal for the operation of the website of the P&H Management ltd – – collects, during its normal functioning certain personal data used for protocol of data exchange. This is information not used to identify persons, but that, via the treatment and connection with data possessed by third parties, in virtue of its character reveals the identification of the user.
Belonging to this category are: data with IP address or name or dominion of the computer that create a connection with a website, the URI addresses (Uniform Resource Identifier) the resources requested, the time of the request and other parameters that refer to the transmission and to the location of the computer of the user. This data is utilised solely for the purpose of collecting anonymous information on web use and for checking the correct functionality. The data treated may be used to determine a responsibility in case of illicit acts with the help of information technology that might damage this website.


Duration of retention of personal data

Personal data that is clearly not useful for processing a specific report are not collected or, if collected accidentally, are deleted immediately. In any case, the data will be retained for a period not exceeding five years from the date of communication of the final outcome of the reporting procedure.


Rights of interested parties

The law on personal data protection offers the interested party the possibility to exercise certain rights pursuant to Art. 7. By contacting the owner you can exercise the following rights at any time:

  • access to data: be made aware of whether or not personal data concerning you is being processed and receive a copy of the personal data being processed
  • have precise indications in clear form on these data, on their origin and on the reason and purpose of their processing as well as information on the owner and manager of the processing and on the people and categories of people to whom these data are presumably communicated
  • rectification: if the owner carries out processing operations on your data and these are incorrect, you can request their rapid correction
  • the interested party has the right to check, confirm, update, correct and integrate his data, as well as to request that such data be deleted, blocked and transformed into anonymous form, if their processing violates the provisions of the law
  • cancellation: obtain the rapid elimination of all data concerning you with the exception of those that the owner is required to process by law for the assessment, exercise or defense in court
  • limitation: obtain the temporary obscuring of part or all of the data in the possession of the owner so that no further processing operations are carried out while awaiting further determinations (the mere storage of the data is excluded from the limitation, as is their use for the exercise or the defense of a right in court)
  • portability: receive all data concerning you in a structured format of common use, or obtain their direct transmission to another owner (applicable only in cases of processing based on consent or on the execution of a contract)

The individual has the right to check, confirm, update, correct and add to his data as well as demand that his data be cancelled, blocked or transformed in anonymous form, when their custody violates the law. He has the right to deny in the treatment of his data full or part, for legitimate motives, and without legitimate motives when it is used for a commercial purpose or to send promotional material for direct sales for market research and demographic studies.

The rights according to art. 7 may be exercised by the interested party or for a proxy via written request to the manager of treatment of personal data: P&H Management ltd, Via XXX Aprile 2, 39012 Merano, South Tirol, Italy – sending a letter or email to


Right to lodge a complaint with the Supervisory Authority

If you believe that your data has been processed illegitimately, you have the right to contact the Supervisory Authority to lodge a complaint.


The proprietor of the treatment of data

P&H Management ltd
Legal representative: Dr. Pippi Stefano
Director: Dr. Hölzl Barbara

Editorial, web content and personal Data Controller: Dr. Hölzl Barbara
Responsibility for contents according to § 6 MDStV: P&H Management ltd


Whistleblowing Reports

In implementation of Legislative Decree 10 March 2023, n. 24, P&H Managementltd has equipped itself with the prescribed channels for receiving and managing reports called “whistleblowing”.

Who can report?

  • Shareholders and people with administrative, management, control, supervisory or representation functions, even if these functions are exercised on a purely de facto basis, at the Company;
  • Employees, interns, self-employed workers, freelancers and consultants who work for the Company;
  • Subjects who have held the roles indicated above in the past, if the information on the violations was acquired during the relationship and subjects with whom the relationship has not yet arisen – for example candidates for personnel selection or employees during the trial.

More detailled Information (in Italian) …


Areas of potential reporting

The list is very detailed and complex. For completeness, please refer to Legislative Decree 24/2023.

Generally speaking, violations of European Union regulatory provisions which harm the public interest or the integrity of the Company, of which the reporting person has become aware in the work context, consisting of: illicit conduct relevant pursuant to of Decree 231/2001 or violations of Model 231 if adopted; offenses that fall within the scope of application of European Union or national acts or of national acts that constitute the implementation of European Union acts on public procurement; financial services, products and markets and prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental Protection; radiation protection and nuclear safety; food and feed safety and animal health and welfare; public health; consumer protection; protection of privacy and protection of personal data and security of networks and information systems; acts or omissions that harm the financial interests of the European Union referred to in art. 325 of the Treaty on the Functioning of the European Union; acts or omissions concerning the internal market, referred to in art. 26, par. 2, T.F.U.E. (including competition and state aid infringements and corporate tax infringements); acts or conduct which, while not amounting to an offence, frustrates the object or purpose of the provisions of the Union acts in the sectors indicated above.


The reporting Channels

    toll-free number: 800 – 231 – 670 (in Italian) / 800 – 294 – 670 (in German)
    The call is recorded
  • EMAIL :
    email address:
    To protect the confidentiality of the Reporter, if he or she wishes not to give consent to the disclosure of his or her identity, written reports must be sent from personal, not company, email accounts (therefore, it is necessary to avoid sending reports from boxes on the company domain) .
    The whistleblower also has the right to request a direct meeting with a professional external to the company, who manages the channel to provide the report in a confidential conversation; it will be sufficient to request it via one of the two channels indicated above, leaving a contact number to be contacted.


Information about cookies

In accordance with the art. 13 of the Legislative Decree nr. 196/2003 of 30.06.2003 (Privacy Code, hereinafter PC) and the Italian Authority guarantor for the protection of personal data (Privacy Guarantor) of 8th May 2014, “Identification of simplified procedures for the information and the acquisition of the consent to the use of cookies”, we would like to inform you about the methods of data processing carried out by P & H Management srl , Via XXX Aprile 2, 39012 Merano, South Tyrol, Italy, through cookies.


What are cookies?

Cookies consist of small portions of code that the website (hereinafter “Site”) and browsers store on a client computer’s hard drive to save small quantities of information about the website for a certain period.

There are different types of cookies that assists the P&H Management ltd in providing the service provided through their website. This website uses technical cookies and profiling cookies.

Technical cookies are needed for the unobstructed function of the website. The navigation and session cookies make the website navigation more user-friendly. The analytics cookies collects information about the visitor (for example the number of visitors and how those navigate to the website). Technical cookies also includes function cookies which allow the website to remember visitor’s choices (automatic language settings or filter settings).

Profiling cookies create user profiles by recording settings, preferences and actions of the visitors. This makes target group-specific advertising possible and allows advertising messages to be combined with the user’s interests. Some of the purposes of installation of cookies may also require the consent.


Cookies used and purposes

The Site uses different types of cookies. Session cookies to save the sessions your visits and to carry out other activities that are strictly necessary for the functioning of the same, for example in relation to the distribution of traffic. In addition, the Site uses cookies to save your preferences and optimize the experience of the navigation. Among these cookies are, for example, the ones to set the language (_icl_visitor_lang_js and _icl_current_language).
If among the instruments mentioned below were present services operated by third parties, they may – in addition to what is specified and also the knowledge of the P&H Management ltd – complete activity tracking and treatment. For detailed information we recommend you to read the privacy policy and cookie policy of the services listed.

Google Analytics – etracker

This website uses Google Analytics, a web analysis service by Google Inc. (“Google”) and/or etracker, a web analysis service by etracker S.r.l. (“etracker”). These programmes use “cookies”: text files saved on your pc which allow the analysis of the use of the website. The stored information (including your IP address) is transmitted and saved on a server by Google and/or etracker, who use these data to evaluate your use of the website, create reports about the website activities for their owners and to offer you further services connected with internet and the website. Google and/or etracker are allowed to transmit this information to third parties, if it is legally mandatory or necessary for thirds to elaborate this information on behalf of Google and/or etracker. Under no circumstances will Google and/or etracker connect your IP address with other data from Google and/or etracker. You can avoid the installation of cookies by configurating your browser software correspondingly: in any case, we would like to inform you that with this you will not be able to use the full service range of the website. By using this website you agree with the treatment of your personal data stored by Google and/or etracker according to the modalities, with the goal and to the extent stated before.


Facebook Social Plug-ins

This website uses social plug-ins of the so-called “social network” (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA). You will recognize the plug-in by the facebook logo or the explanatory remark “facebook social plug-in” exposed on a website. The following actions are carried out by this plug-in:

  • Your browser will connect directly to the servers of facebook.
  • The plug-in content is transferred by facebook directly to your browser and implemented automatically.
  • If you are logged into facebook while visiting a website that uses this plug-in, facebook will be informed of it and thus relate your browsing this site to your facebook account.
  • All interaction on your part with the plug-in will be redirected from your browser to facebook and stored there.

Please find more information on the purpose, amount and processing of your data as well as your rights concerning them on facebook’s data protection terms. If you want to prevent facebook from collecting information about you through this website, you must log out from facebook before visiting our website.


Last modification 2024