Privacy notice

In short

This notice is given under Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018. It explains which personal data are processed when you visit this website, make an enquiry, book and stay at Cherì Navona; why; for how long; to whom they are disclosed; and what rights you have.

1. Data controller

Viviana Averni, who lets Cherì Navona, Vicolo dei Soldati 44, 00186 Roma. For any question about your data and to exercise your rights: cheri.navona@voyagerrome.com.

No data protection officer has been appointed, as none of the cases set out in Article 37 GDPR applies.

2. Enquiries and bookings

Data: first name and surname, email, phone, country, dates of stay, number and ages of guests, arrival time, any pet, and the requests you write. If you book through a platform (for example Airbnb or Booking.com), we receive the dates and booking details from that platform.

Purpose and legal basis: to answer your enquiry and to enter into and perform the rental contract (Article 6(1)(b) GDPR). Without these data the booking cannot be accepted.

Retention: for the duration of the relationship and, after departure, for ten years, the ordinary limitation period for contractual claims under Italian law (Article 2946 of the Civil Code), which also covers tax obligations.

3. Payment

Online payment takes place on the page of Stripe Payments Europe, Ltd. (Ireland), which processes card data as an independent controller under its own privacy policy (stripe.com/privacy). The website never sees or stores the card number: it receives only the outcome of the payment, the amount and its reference.

Legal basis: performance of the contract (Article 6(1)(b)) and legal obligations in tax matters (Article 6(1)(c)).

4. Rental contract signed online

If you sign the contract on the website, we keep the name you sign with, the date and time of signature and the IP address it came from, as evidence of signature. Legal basis: performance of the contract and legitimate interest in being able to prove it (Article 6(1)(b) and (f)). Retention: ten years from the end of the stay.

Stays longer than 30 days (temporary rental contract): we also process the reason you state and the document proving it, which the Ministerial Decree of 16 January 2017 requires to be attached to the contract; the contract and the parties' data are sent to the Italian Revenue Agency for registration. The document is stored encrypted, only the controller can see it, it is kept together with the contract for the same time and it is deleted if the booking is cancelled. Please black out any data not needed to prove the reason: if the document nonetheless contains health data, the processing relies on the need to establish, exercise or defend legal claims (Article 9(2)(f) GDPR). Legal basis otherwise: legal obligation and performance of the contract (Article 6(1)(b) and (c)).

5. Identity documents and mandatory reporting

Italian law (Article 109 of the Consolidated Public Security Act, Royal Decree 773/1931) requires anyone providing accommodation to report the particulars of every guest to the police, through the State Police “Alloggiati Web” portal. For this reason we ask, for each guest, for personal details and identity-document details. Legal basis: legal obligation (Article 6(1)(c)). Providing them is mandatory: without these data it is not possible to stay. Before receiving the entry code, every guest is identified by the controller against the original document, in person or by real-time video call: the video call is not recorded and only the date and method of identification are noted.

As indicated by the Italian Data Protection Authority (decisions of 29 April 2026), copies of documents are not kept longer than necessary. The photograph of the document, if you upload it, serves only to check the details entered: only the controller sees it, it is passed on to no one, it is stored encrypted and deleted as soon as the data are reported to the police (if they are not reported, at the latest 2 days after departure). The document details (type, number, place of issue) and the tax code are stored encrypted and deleted as soon as the controller files the receipt issued by Alloggiati Web, and in any case within 30 days. The receipt is kept for five years in a restricted archive, as the Alloggiati Web rules require. The other personal details, also used for regional statistics, are deleted 90 days after departure.

City of Rome tourist tax: the number of nights, any exemptions and the amounts are recorded and declared to the City; the records are kept for five years, as the municipal regulation requires. Tourism statistics (Lazio Region and ISTAT): data on arrivals and nights are reported, without your name. Tax obligations: the data needed for receipts and returns.

6. Guest area, messages and Arianna

In your guest area we process what you write and choose: messages, requests, reports during your stay, answers to the arrival check, preferences. Legal basis: performance of the contract (Article 6(1)(b)). Retention: as for booking data.

Arianna, the digital concierge, is an automated assistant, not a person: it answers by fixed rules and with the information published by the house, processed by the website itself, and takes no decisions concerning you. If the controller turns on automatic message sorting, the text of your question, as you write it and without your name or booking details, is sent to Claude by Anthropic PBC (United States) to tell whether it is urgent, where to route it and to rephrase it more clearly, so the website finds the right answer among its own information; the answer remains the one written by the house. The most recent questions (up to 200) remain in an in-memory technical log, without names or bookings, visible only to the controller, used to correct wrong answers and emptied whenever the website restarts.

If you use the microphone, speech recognition is carried out by your browser, which may send the audio to its own provider (for example Google or Apple) under that provider's rules. The website receives only the text and does not record your voice.

7. Review, photograph of your stay, friends' code

Review: every guest whose email address we have is invited to write one, whatever their experience, within 30 days of departure, with no discounts or rewards. If you write one, it is published on the website under the name you give, with your country and the month of your stay, after the controller has read it, whether positive or negative (only offensive or off-topic content is removed); after two years it is no longer shown. Legal basis: your consent (Article 6(1)(a)), which you can withdraw by asking for its removal.

Photograph for the postcard of your stay: it remains in your personal area, is not published and is deleted automatically 90 days after departure; you can remove it earlier at any time.

Friends' code: we record the code assigned to you and how many times it has been used, in order to apply the reduction provided for. Legal basis: performance of the contract.

8. Song and Tale: creations made with artificial intelligence and, if you choose, published on YouTube

They are optional. For a special date, one of the two is a gift from the house; not asking for them has no effect on your booking or your stay. If you ask for them, we process what you choose to give us: for the song, the story, the name and the musical choices; for the Tale, the story, the name, the answers to the questions, the names of the characters, the photographs and their captions. The playlist of your journey is only a link to Spotify, which stays in your area.

Artificial intelligence. The song and the Tale are composed with third-party artificial-intelligence tools, starting from your story, under the care of the controller, who reads the stories. For the Tale, Claude by Anthropic PBC (United States) is used, and receives the story, the names and the captions. For the song, an AI-based music composition tool is used, which is given the lyrics written from your story. The website and the description of each video state that these are AI-generated contents (Article 50 of Regulation (EU) 2024/1689). The controller does not use your content to train artificial-intelligence models. Before you hand over your story, you are asked to consent to its processing with these tools, through a box that is never pre-ticked. Legal basis: your consent (Article 6(1)(a) and Article 7 GDPR).

Publication. Publication on the “Cherì Navona” YouTube channel is a separate, optional choice: the song or the Tale is published only if you tick the dedicated box, which is never pre-ticked. If you do not tick it, the creation stays private in your area and you receive it all the same. Legal basis: your consent (Article 6(1)(a) and Article 7 GDPR).

Photographs. To publish a Tale with photographs we also ask for a release, through a separate box: you state that the recognisable people have consented to the publication of their image (Article 10 of the Italian Civil Code and Articles 96 and 97 of Law 633/1941) and, for minors, that the holder of parental responsibility consents; and you tell us whether minors appear in the photographs. If minors appear, the photographs are published only as comic-style drawings; otherwise the comic style is the default and you may ask to publish them as they are. The comic-style rendering reduces the chance of people being recognised, but does not rule it out entirely. Without the release, photographs are not published. Location data are stripped from the photographs.

YouTube. The video — with the name you gave, the story and the photographs — is published on YouTube, a service of Google Ireland Limited, and can be seen by anyone, including outside the European Union. What happens on YouTube is also governed by Google's privacy policy (policies.google.com/privacy).

Withdrawal. You can withdraw your consent to publication at any time, without giving reasons, with the “Withdraw publication” button in your area (the memory stays private), or delete the memory altogether: the controller removes the video from the channel without delay. Withdrawal does not make what happened before unlawful; copies that third parties may already have made of a public video are beyond the controller's control.

Retention. Stories, photographs, song and Tale stay in your area until you delete them, and in any case no longer than 24 months after your departure, after which they are deleted automatically. Any published video stays on the channel until you withdraw your consent.

9. Website security

To protect the website and its users we record technical data: IP address, date and time of requests, operations carried out in the private area, sign-in attempts. They serve to prevent abuse and to reconstruct any malfunction. Legal basis: the controller's legitimate interest (Article 6(1)(f)). Retention: the operations log 24 months; the log of notices sent (email and Telegram) 12 months; they are then deleted automatically. Database backups are kept for a limited period (only the last ten) and then overwritten: deleted data also disappear from the backups within that period.

10. Who receives the data

Providers processing data on the controller's behalf, as processors (Article 28 GDPR): the provider of the server hosting the website (where the backups also are) and the email provider. Notices also travel through the Telegram messaging service: the controller receives only the booking code and dates, the cleaning staff the dates, times, number of guests and any cot; never names, contact details, documents or messages, which stay in the email and in the admin panel.

Parties processing data as independent controllers: Stripe Payments Europe, Ltd. (payments); the Rome police headquarters, the City of Rome, the Lazio Region and the Italian Revenue Agency, for legal obligations; the controller's tax adviser; Google Ireland Limited (YouTube), only if you choose publication; Anthropic PBC and the provider of the music composition tool, only for the song, the Tale and, if turned on, the message sorting described in point 6.

Whoever takes care of the cleaning receives only the dates, times, number of guests and any cot, without their names. Third-party operators — for example a chauffeured car or the supplier of a special request — receive the necessary data only if you ask for that service yourself.

Your data are never sold and are not used to send you advertising.

11. Transfers outside the European Economic Area

Some of the providers named above (Stripe, Google, Anthropic, Telegram) may process data in the United States or in other countries outside the European Economic Area. Transfers take place on the basis of a European Commission adequacy decision — for the United States, the Data Privacy Framework (Implementing Decision (EU) 2023/1795), for providers that adhere to it — or of the standard contractual clauses approved by the Commission (Articles 45 and 46 GDPR). You can ask the controller for information on these safeguards.

12. Your rights

You have the right to request access to your data and a copy of them, rectification, erasure, restriction of processing and portability; to object to processing based on legitimate interest; and to withdraw at any time a consent already given (Articles 15–22 and Article 7 GDPR). To exercise them, write to cheri.navona@voyagerrome.com: you will receive a reply within one month.

You may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome — www.garanteprivacy.it) or with the authority of the country where you live or work, and you may bring proceedings before the courts.

13. Automated decisions

No decision concerning you is taken by solely automated means, and no profiling is carried out (Article 22 GDPR). Prices depend on the dates and length of stay, not on the person.

14. Minors

Bookings are reserved for people aged eighteen or over. The data of minors who stay are provided by the adult accompanying them, for the legal obligations described in section 5.

15. Changes

This notice is updated whenever a processing operation changes. The date of the last update is shown at the top of the page.