Privacy and Cookie policy

Valid from April 2018

This Privacy and Cookie policy is valid for the website (“Site”), owned and managed by 4 Elementi S.r.l. based in Via Vito Nunziante s / n – 98050 Stromboli (ME) (Owner). It describes how, through cookies and other techniques that also include pixels (“Cookies”), the website collect and use informations, including your personal data. The policy also describes the  choices you can make regarding the use of your personal data, how you can access it and how to modify it.

4 Elementi S.r.l., based on the EU Regulation 2016/679 (hereinafter ‘GDPR’), intends to ensure the privacy and security of the personal data of each visitor in accordance with the provisions of this Notice. This Information is to be understood as information pursuant and under the art.13 and 14 of the GDPR.

Data collection

When you visit the Site or view our targeted advertisements (if present), we automatically collect information through Cookies.

More information on Cookies:   Cookies are a small fragment of data that a site deposits in your browser, saving them in the physical memory of the device. We deposit cookies on your computer when you visit our site. If you have any doubts about the presence of cookies on your device, you can set your browser to refuse all cookies or you can choose to accept or not cookies when they need to be deposited. You can also delete cookies from your device. However, if you choose to block or delete cookies, some functions of the site you visit may not work properly.

More information about pixels: Pixels (also known as web beacons or gifs) are a small graphic object consisting of a single pixel that arrives on your computer as part of a web page or via an informative email, for example a newsletter. We may use the pixels to deposit or recognize a Cookie on your device, in case of use of our services.

Third Party Cookies:We allow a specific number of third parties to deposit Cookies. If you have any questions about the cookies used and which third parties deposit these cookies, contact us using the contact details at the bottom of the page.

4 Elementi S.r.l. can   acquire information about the visitor, in the following ways:

Navigation data. The computer systems and software procedures used to operate this website acquire, during their normal operation, information, some of which may be personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes: language settings, IP addresses, device ID, location, navigation data, pages viewed, browser and operating system you use, your internet provider, system operational, the domain name and the addresses of websites from which the access was made, information on the pages visited by users within the site, the date and time of access, the permanence on the single page, analysis of the internal path and other parameters relating the operating system and the user’s IT environment. We may also collect data automatically via cookies.

Comments. When visitors leave comments on the site, we collect the data shown in the comments form as well as the visitor’s IP address and the browser user agent string to facilitate spam detection. An anonymized string created from your email address (otherwise called a hash) can be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: After your comment is approved, your profile picture is visible to the public in the context of your comment.

Media.  If you upload images to the website, you should avoid uploading images that include embedded location data (EXIF GPS). Visitors to the website can download and extract any location data from images on the website.

Embedded content from other websites. Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves exactly in the same way as if the visitor had visited the other website. These websites may collect data about you, use cookies, integrate additional third-party tracking and monitor your interaction with them, including tracking your interaction with embedded content if you have an account and are logged in to those websites.

Additional categories of data. (for example, data provided voluntarily by the user). The optional, explicit and voluntary sending of e-mails to the addresses indicated on this site and / or the filling out of data collection forms and / or the access to a reserved area and / or a service and / or participating in one of the initiatives launched by 4 Elementi Srl alone or in partnership with third parties, involves the subsequent acquisition of the sender’s address, necessary to reply to the requests, as well as any other personal data entered.

Purposes of the data collection

We use information that includes your personal data, collected through cookies, for the following purposes:

  • A. Ensure the correct use of our Site: we use the information collected through Cookies to allow you to browse our Site. The use of cookies for this purpose is within our legitimate business interests.
  • B. Statistics, improvements and research: Detect your experience of use of our platforms, products and services we offer and ensure the proper functioning of the web pages and their contents and to obtain usage reports. We use personal data to conduct research and analysis and we may involve a third party to do so. Potremmo condividere i risultati di tali ricerche, anche con terze parti, in forma anonima e aggregata. We use your personal data for statistical purposes, to improve our services, to improve the user experience and to increase the functionality and the quality of our online services. The treatments put in place for these purposes are based on a legitimate interest of the Owner. Carry out profiling activities, i.e. analysis and processing of information relating to the user, its preferences, habits, consumption choices and / or browsing experiences. The treatments put in place for these purposes are carried out with the specific consent provided by the user, except for an activity of analyzing elementary information relating to their consumption preferences based on our legitimate commercial interests.
  • C. Market research: we use the information collected through cookies in the context of our legitimate interests for market research (for example, the analysis of market segments or trends, preferences and behaviors, research on products or services or on the effectiveness of marketing campaigns) or product development (for example the analysis of the characteristics of a market segment or group of consumers or the performance of our site, in order to improve the site itself).
  • D. Complete and manage your online booking. Provide the good and / or service requested by the user, manage the contracts concluded by the user, carry out the related administrative, accounting, tax and legal obligations, as well as fulfill the requests made by the user. The treatments put in place for these purposes  are necessary for the fulfillment of contractual obligations and do not require specific consent from the interested party.
  • E. Customer Support: We use your personal information to provide you with customer support.
  • F. Reviews: We may use your contact details to invite you by email to leave a review after your stay. This can help other travelers to choose their ideal accommodation. If you submit a review, it may be posted on our site.
  • G. Marketing activities: we also use your data for marketing activities, in the manner permitted by law. We use your personal information for direct marketing purposes, for example commercial newsletters and marketing communications about new products and services, or about offers that we think may interest you and for which you may be entitled to benefit. The treatments put in place for these purposes are carried out with the specific consent provided by the user, with the exception of commercial communications relating to products and / or services similar to those already purchased and / or signed by the user for which the treatment is based on a legitimate interest of the Data Controller and on article 130 of the Privacy Code.
  • H. Security, Fraud Detection and Prevention: We use information, including personal data, to prevent fraud and other illegal activities. We also use this information to investigate and detect fraud. We may use personal data for risk assessment and security purposes, for example through user authentication. For these purposes, personal information may be shared with third parties, such as the police forces or external consultants, in accordance with the provisions of current legislation.
  • I. Legal and compliance purposes: in certain cases, we may use the information provided (including personal data) to manage and resolve legal disputes or disputes, for government investigations and compliance checks, or to honor contracts or to comply with requests made by law enforcement agencies, in accordance with the provisions of the law.

If you do not want to consent to the use of cookies in the manner described in this section, but there is no automatic consent cancellation system (for example through the settings of your browser), contact

Legal principles

We rely on the execution of a contract: the use of your data may be necessary to be able to implement the contract you have with us. For example, if you use our services to make an online booking, we will use your information to perform our obligation to complete and manage the booking under the contract between us.

We rely on legitimate interests: we use your information for our legitimate interests, for example to provide you with the most suitable content from our site, emails and newsletters, in order to improve and promote our products, services and content on the site. We may also use your information for administrative, legal, or fraud detection purposes. When we use personal data for our legitimate interests, we will always balance your rights and interests regarding the protection of your personal data with our rights and interests.

We also rely on our obligation to comply with the current legislation.

Where necessary and based on current legislation, we will obtain your consent before processing your personal information for direct marketing purposes.

If necessary and in accordance with current legislation, we will ask for your consent, which you can remove at any time, by contacting us at the addresses mentioned at the end of this statement.

f you do not want to consent to the processing of data in the manner described in the aforementioned purposes but there is no consent cancellation system (for example through the settings of your browser), as far as possible, contact

Data Sharing

  • Data Sharing with third parties: We share your personal data with third parties as permitted by law, in the manner described below, for example in the case of service providers acting on our behalf. We do not sell or rent your personal data. For administrative   purposes , we inform you that your data may be disclosed by the Owner to operating partners for the fulfillment of the contract signed by you. Furthermore, with your consent, your data may be disclosed to third-party companies operating in the tourism sector and to companies operating in other sectors with which 4 Elementi S.r.l. could conclude partnership agreements: social networking platforms and interactive platforms, mass consumption, distribution, financial, insurance, automotive, services and humanitarian and charitable organizations, as well as telecommunications, for commercial and / or promotional purposes.
  • Wubook: We collaborate with WuBook Srl, based in via dell’abbazia n. 7/1, zip code: 61032, Fano (PU) – – to offer you an online booking service. We provide the contents of the site and bookings are made with us, while the management of the bookings themselves is the responsibility of Wubook. The information you enter on this site will then be shared with Wubook and its affiliates and may include your name, contact details, payment details, the names of guests traveling with you and any preferences expressed during the booking. Wubook may send you a booking confirmation, an e-mail prior to your arrival, a online check-in request and information about the location of our facility. Wubook may use your information for technical, analytical and marketing purposes as described in Wubook’s Privacy Policy  . For this, your information may also be shared for analysis purposes and to provide you with a personalized service.
  • YouTube: Our website uses the YouTube plug-in, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit one of our pages with a YouTube plug-in, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you are logged in to your YouTube account, YouTube allows you to associate your surfing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to make our website attractive. This constitutes a legitimate interest pursuant to art. 6 (1) (f) DSGVO. Further information on the processing of user data can be found in the YouTube data protection declaration.
  • Akismet anti-spam: We collect information about visitors who comment on the site and who use our Akismet anti-spam service. The information collected depends on how the user has set up Akismet, but normally the information includes the commenter’s IP address, user agent, referrer, and site URL (along with other information provided directly by the user who comment, such as name, username, email address, and the text of the comment itself).
  • Visitor comments: may be checked through an automated spam detection service.
  • Other service providers: We use service companies to manage your data on our behalf. This management serves the purposes described in this statement, for example the management of booking payments and the sending of marketing material for analytical support purposes. These service providers are bound by confidentiality agreements and are not authorized to use your personal data for other purposes.
  • Competent Authorities: We share personal data with law enforcement and other government authorities when required by law or as absolutely necessary for the detection, prevention or conduct of legal proceedings against fraud or crime.

International data transfer

The transmission of personal data as described in this statement may involve the international transfer of information to countries whose data protection laws are not as detailed as those within the European Union. Where required by European law, we will only transfer personal data to entities that offer an adequate level of data protection. In these situations, we will make contractual arrangements to ensure that your personal data is protected according to European standards.

Data retention

There is a difference between session cookies and persistent cookies. Those of the session have a limited duration and are deleted when the browser is closed, while the permanent ones have a longer duration and are not automatically deleted when the browser is closed. We will retain your personal data for the period of time necessary to provide the service, in accordance  with the laws in force, in order to manage any disputes with any third party and in any case for the time necessary to carry out our activities, including the detection and protection of fraud or other activities  illegal provided that it is not necessary to keep them further to defend or assert a right or to fulfill any further legal obligations or orders of the Authorities. All personal information stored will be subject to the provisions of this Notice. If you have any questions about specific data retention periods, please contact us using our contact details.

If you leave a comment, the comment and its metadata are kept indefinitely so that we can automatically recognize and approve any subsequent comments instead of keeping them in a moderation queue.

Redirect to external sites

Social Plug-in. The website can use the so-called social plug-in. Social plug-ins are special tools that allow you to incorporate the social network features directly into the website (eg the ‘like’ function of Facebook). All social plug-ins on the site are marked with the respective logo owned by the social network platform (eg Facebook, Instagram, Google, Twitter). When you visit a page of our site and interact with the plug-in (e.g. by clicking the ‘Like’ button) or decide to leave a comment, the corresponding information is transmitted from the browser directly to the social network platform and stored therefrom. For information on the purposes, type and methods of collection, processing, use and storage of personal data by the social network platform, as well as for the methods by which to exercise their rights, please consult the privacy policy adopted by the individual social network.

Connection to / fromthird party sites.  From this website it is possible to connect, through specific links, to other company websites  with which 4 Elementi S.r.l. maintains collaborative relationships, i.e. it is possible from third party websites to connect to our website. 4 Elementi S.r.l. disclaims any responsibility for any request and / or release of personal data to third party sites and for the management of authentication credentials provided by third parties.

Your options  and your rights

We want you to be in control of how we use your personal data. You can do this in the following ways:

  1. You can ask us for a copy of your personal data in our possession;
  2. You can notify us of any changes to your personal data or you can ask us to correct any of your information in our possession;
  3. In specific situations, you can ask us to delete, block or restrict the processing of your personal data in our possession, or object to particular ways in which we are using your personal information. This does not include any data that we are required to keep for administrative, legal or security purposes;
  4. In specific situations, you can also ask us to send your personal information in our possession to a third party.
  5. You can ask us to limit the processing of your personal data, when one of the conditions referred to in art. 18 of the GDPR; in this case, your data will not be processed without your consent, except for storage and except as specified in the same article in paragraph 2.
  6. Wherever we use your personal information with your consent, you can ask us to withdraw this consent at any time and in the manner prescribed by the current legislation. Furthermore, wherever we process your personal data on the basis of legitimate interests or public interest, you have the right to object at any time to the use of your personal information, in the manner prescribed by law. You can object to the processing of your data at any time on the basis of our legitimate interest, unless there are legitimate reasons for us to proceed with the processing that prevail over yours, for example for the exercise or our defense in court; your objection will always and in any case prevail over our legitimate interest in processing your data for marketing purposes.
  7. We rely on you to make sure your personal information is complete, accurate and up to date. Promptly inform us of any changes or inaccuracies in your personal information by contacting We will handle your request according to current legislation.

Questions or complaints

If you have any questions or concerns regarding the management of your personal data or if you want to exercise your rights under this Notice, you can contact us via mail at  or by writing to 4 Elementi S.r.l. based in via Vito nunziante s / n, 98050 Stromboli (ME). You can also contact your local data protection authority with any questions or complaints.

Changes to the information

Since our businesses may be subject to change or in the event of new industry regulations coming into force, this Policy may also be changed. If you want to be updated on any changes to this Policy, we invite you to periodically visit this page to see any updates.