PRIVACY POLICY | INFORMATION NOTICE PURSUANT TO ART. 13 OF LEGISLATIVE DECREE NO. 196/03

In accordance with Article 13 of Legislative Decree No. 196/2003 regarding the protection of personal data, we would like to inform you that Tirler GmbH, as the data controller, stores your personal data in its archives. The use of your data follows the principles of fairness, lawfulness, and transparency, while respecting your privacy and rights.

This data may be used by Tirler GmbH for the collection of (exclusively anonymous) statistics and to send you advertising material, catalogs, and price lists, as well as to keep you informed about our initiatives and offers. You may exercise your rights under Article 7 of Legislative Decree No. 196/2003 at any time, including the right to access, rectify, update, supplement, anonymize, or delete your data, and to object to its use, by contacting the data officer appointed by us in accordance with Article 13, letter f) of Legislative Decree No. 196/2003.
Our data officer, Hannes Rabanser, can be reached at the following email address: info@tirler.com

Processing of Personal Data through the KOSMO Virtual Assistant

A virtual assistant provided by KOSMO (hereinafter referred to as the “Chatbot”) is active on our website to assist you during navigation, provide information about our services, and answer your questions. This service has been developed by AI KOSMO S.r.l., which acts as a data processor pursuant to Article 28 of the GDPR, based on a specific agreement governing its duties and responsibilities. The data controller of the personal data you provide through the Chatbot remains Tirler Dolomites Living Hotel.

The Chatbot uses artificial intelligence systems (LLMs – Large Language Models) to understand your requests and provide relevant responses.

Types of Data Processed

The processing concerns the following personal data:

  • Data actively provided by the user: any information you voluntarily enter into the chat window, such as questions, requests for information, first name, last name, contact details, or accommodation preferences;
  • Technical session data: IP address, browser type, operating system, and other technical data necessary to ensure the proper functioning of the chat service;
  • Conversation content: the complete text of your interactions with the Chatbot.

Purposes and Legal Basis of Processing

Your personal data is processed for the following purposes:

1. Provision of Chat Assistance and Support Services

To respond to your requests, assist you in navigating the website, and provide the necessary information about our services.

The legal basis for this processing is the legitimate interest of the Data Controller in providing an efficient and immediate customer support service. In the case of pre-contractual requests (e.g., quotations or booking availability requests), the legal basis is the implementation of pre-contractual measures.

2. Service Improvement and Training of Artificial Intelligence Algorithms

To analyze conversations (in aggregated and anonymized form where possible) in order to improve the accuracy of the Chatbot’s responses and the effectiveness of the service.

The legal basis for this processing is the legitimate interest of the Data Controller and the Data Processor in improving the technology and quality of the service offered, provided that your interests or fundamental rights and freedoms do not override such interests.

Providing data for Purpose 1 is voluntary but necessary in order to use the Chatbot service. Regarding Purpose 2, you may object at any time without affecting your ability to use the chat service.

Processing Methods and Security Measures

Data processing is carried out using electronic and telematic tools.

In accordance with the principles of Data Protection by Design and by Default (Article 25 GDPR), appropriate technical and organizational measures are implemented to ensure a level of security appropriate to the risk, including pseudonymization or anonymization of data whenever possible, especially for the purpose of training algorithms.

Data Retention Period

Your personal data will be retained in accordance with the principle of storage limitation:

  • For assistance purposes, conversation logs will be retained only for the time strictly necessary to manage your request and, in any case, for no longer than 24 months from the end of the chat session, unless legal disputes arise that justify further retention.
  • For algorithm training purposes, personal data will be retained in a form that allows your identification only for the time strictly necessary for analysis and extraction of information useful for improving the model. Thereafter, the data will be irreversibly anonymized or deleted. In any case, this period will not exceed 365 days.

Data Disclosure and Transfers

The data collected through the Chatbot is processed by our service provider AI KOSMO, appointed as Data Processor.

AI KOSMO may use sub-processors (e.g., cloud service providers) to deliver the service, in compliance with the requirements of Article 28 GDPR.

The use of such services may involve the transfer of your personal data outside the European Economic Area (EEA). Such transfers will only take place where appropriate safeguards are in place, such as adequacy decisions adopted by the European Commission or the execution of Standard Contractual Clauses.

Use of Artificial Intelligence Systems

The Chatbot service uses artificial intelligence technologies, particularly LLM systems.

In accordance with the transparency principles established by the European AI Act, the GDPR, and Italian Law No. 132/2025, we would like to provide you with the following information:

Transparency Obligation

We inform you that you are interacting with a system that uses AI components. This system has been designed to assist hotel staff in interpreting and routing your requests.

Operation and Logic of the System

The AI system analyzes the text of your requests to understand their content and purpose and to direct them to the appropriate department.

Human Oversight and Absence of Automated Decision-Making

We guarantee that the AI system operates solely as a support tool for our staff.

No decision that produces legal effects or similarly significant effects concerning you (within the meaning of Article 22 GDPR) is made solely by automated means. Any complex request, charge, or relevant decision is subject to review and validation by a human operator.

Fairness and Non-Discrimination

The AI systems have been developed and are regularly monitored to minimize the risk of errors and discriminatory effects, in line with best practices and applicable legal requirements.

Rights of Data Subjects in Relation to the Use of AI

In addition to the general rights provided under the GDPR (access, rectification, erasure, restriction, data portability, and objection), you are entitled to the following rights in relation to the use of artificial intelligence systems:

  • Right to Rectification: If you believe that information generated by the Chatbot concerning you is inaccurate, you have the right to request its correction.
  • Right to Erasure: If correction of inaccurate data is not technically possible, you have the right to request its deletion.
  • Right to Object: You may object at any time to the processing of your personal data for the purpose of training algorithms where such processing is based on legitimate interest.

To exercise your rights, you may contact Tirler Dolomites Living Hotel using the contact details provided in this Privacy Notice.

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