Cookie Policy

This Cookie Policy is issued by Villa Traiano Holding Ltd, 20 Wenlock Road, London, England, N1 7GU (Companies House: 16607218), acting as Data Controller jointly with the Italian company VT Hospitality S.r.l. (registered office at Viale dei Rettori 9, 82100 Benevento, Italy — VAT: 01892000629 — REA BN-313670), and describes the types of cookies and tracking technologies used on the website www.villatraiano.com.

1. What Are Cookies

Cookies are small text files that websites send to the user's browser, where they are stored and then retransmitted to the same websites on subsequent visits. Cookies are used for various purposes, including enabling efficient page navigation, remembering user preferences and, in general, improving the browsing experience. They may be set by the visited website (first-party cookies) or by other websites (third-party cookies).

2. Types of Cookies Used

a) Technical Cookies (necessary)

These cookies are essential for the proper functioning of the website and cannot be disabled in our systems. They are set in response to actions taken by the user, such as setting privacy preferences, logging in or completing forms. They do not require user consent.

The site also uses Cloudflare Web Analytics to collect aggregate performance and traffic metrics (Core Web Vitals, pages viewed). This measurement is cookieless and does not identify the visitor; it is therefore classified as a technical / statistical processing under the Italian Data Protection Authority guidelines of 8 May 2014 and does not require consent.

b) Preference Cookies

Preference cookies allow the website to remember choices made by the user (such as language or other personalised settings) to provide a more tailored browsing experience.

c) Analytics Cookies

Analytics cookies collect information in aggregate and anonymised form about website usage, enabling us to understand how visitors interact with pages, which sections are most visited and how to improve the browsing experience. We use Google Analytics with IP address anonymisation.

d) Marketing Cookies

Marketing cookies are used to track visitors across websites in order to display relevant and engaging advertisements tailored to the individual user. They are installed only with the user's explicit consent.

3. Consent and Cookie Banner

Upon first accessing the website, an information banner allows users to accept or reject non-essential cookies (analytics and marketing). Technical cookies, being indispensable for the operation of the website, do not require consent. Users can express their consent in a granular manner, choosing which categories of cookies to enable.

4. Preference Management

You can change your cookie preferences at any time through the cookie management panel accessible from the link in the website footer. You can also manage cookies directly from your browser settings:

• Google Chrome
• Mozilla Firefox
• Apple Safari
• Microsoft Edge

Disabling certain cookies may affect the full usability of the website.

5. Cookie Details

5.a Data processors

In addition to the providers listed above (Google, Meta, Cloudflare), the site relies on the following data processors under Art. 28 GDPR:

• Selfbook Inc. (USA) — booking engine (sdk.selfbook.com SDK). Necessary to complete a booking; US transfer covered by SCCs.
• Sabre / SynXis (USA) — hotel channel manager connected to the Selfbook booking engine.
• Stripe Payments Europe Ltd. (Ireland, checkout.stripe.com) — payment processor for experiences and event tickets.
• Spreedly Inc. (USA, core.spreedly.com) — card tokenisation for the booking engine.
• Twilio Segment Inc. (USA, cdn.segment.com) — aggregates analytics/marketing events to authorised destinations.
• Triptease Ltd. (UK, onboard.triptease.io) — on-site messaging and offer personalisation.
• Statsig Inc. (USA) — feature flag and A/B testing management.
• Cloudflare Inc. (USA) — CDN, WAF, cookieless analytics (Cloudflare Web Analytics), DNS.
• Villa Traiano Hub (hub.villatraiano.com, pos.villatraiano.com) — the group's proprietary CRM for customer management and POS.

A complete and up-to-date list of processors is available on request at privacy@villatraiano.com. For transfers outside the EEA, Villa Traiano relies on the Standard Contractual Clauses (SCCs) approved by the European Commission or on adequacy decisions where available.

6. Cookie Wall

This website does not use a cookie wall. Access to the website content is not conditional upon acceptance of non-essential cookies. Users are free to reject analytics and marketing cookies and continue browsing the website without any restrictions.

7. User Rights

In relation to personal data collected through cookies, users may exercise the rights provided by the GDPR and the UK GDPR (access, rectification, erasure, restriction, portability, objection) by contacting the Data Controller. For further details, please refer to our Privacy Policy.

8. Legal References

This Cookie Policy has been drafted in compliance with:

• EU Regulation 2016/679 (GDPR)
• Directive 2002/58/EC (ePrivacy Directive) and subsequent amendments
• Italian Legislative Decree No. 196 of 30 June 2003 (Personal Data Protection Code), as amended by D.Lgs. 101/2018
• Guidelines of the Garante per la protezione dei dati personali on cookies and other tracking tools (10 June 2021)
• UK GDPR and Data Protection Act 2018

9. Contact

For any questions regarding cookies and the processing of personal data, please contact:

DPO: dpo@villatraiano.com
Privacy: privacy@villatraiano.com