INFORMATION MADE ACCORDING TO ART. 13 OF REGULATION (EU) 2016/679 FOR THE PROCESSING OF PERSONAL DATA OF NATURAL PERSONS
This statement informs you of the concrete ways of managing the website in relation to the processing of personal data of connected users. Data processing is always carried out according to the principles of lawfulness, transparency and correctness and appropriate security measures are adopted to guarantee data protection. Further and specific information on the processing of personal data may be obtained by sending a request to the Data Controller using the contact form.
The data controller of the personal data of the users browsing the website https://freelytours.com is Marco Romeo (VAT number 06147210824), whose registered office is in Via Re Federico n. 13 – 90139 Palermo. The Data Controller can be contacted at the registered office, at the phone number +39 3385074679, or by e-mail at email@example.com
Contractual Base:The processing of data for “Contractual Purposes” is mandatory as it is necessary for the purposes of providing the services you have purchased or booked. For these purposes it will not be necessary to expressly collect the consent for the processing of the personal data provided.
Legal base:The provision of data for the “Purposes of Law” is also mandatory as required by applicable regulations such as compliance in tax matters or for the protection of the rights of the Owner or of third parties in court and does not require prior approval from users.
Consensual Base:Data processing for specific purposes such as, for example, subscription to the newsletter for marketing purposes or profiling activities is optional and is only allowed with your consent (which can be revoked at any time), without which Marco Romeo won’t be able to process the services or requests made by users.
Legal interest of the Data Controller:The Data Controller may process the data collected for legal interest and within the limits set by Regulations. The user may object at any time to the processing for purposes of legal interest of the Data Controller and subject to the limits dictated by law.
TYPES OF PERSONAL DATA PROCESSED
Collecting additional data The computer system on which the operation of this website is based acquires some personal data during its operation. These data are not collected to be associated with identified users, but by their nature through the processing / association with data held by third parties may allow the identification of the user. This category of data includes, for example, IP address, domain name, access time, parameters relating to the operating system used by the user, etc…). These data are collected for the sole purpose of obtaining statistical information on the use of the website and on its correct functioning or to ascertain any cybercrimes against the website. Marco Romeo does not collect or process special categories of personal data, namely sensitive data, health data (including genetic or biometric data) and criminal data.
METHOD AND PURPOSE OF DATA PROCESSING
The processing of personal data is necessary to manage relations with the users of the website, including the purchase of services. The data collected is processed using computer, telematic and paper methods and is protected by appropriate security measures designed to guarantee confidentiality, integrity and recovery. In particular, organizational and procedural measures are adopted (e.g. distribution of roles among staff, internal / external controllers / processors) as well as technical measures (e.g. backup, antivirus, firewall).
The purposes for which we collect and process personal data are many. In any case, we treat the data provided solely for the purposes strictly pertinent to each service requested or used, in particular:
Customer Care: The Data Controller provides the website users with an assistance service (mainly provided through chat, telephone, e-mail) aimed at supporting its customers before, during and after the purchase of a service or to provide information on our activities. In some cases, to use the Customer Care service we may need to ask you for your personal data when this is necessary to respond to requests for clarification, information on the purchase of services, payments, cancellations, handling complaints or personal requests.
Newsletter subscription: our newsletter is a promotional / commercial communication sent to all interested parties who request it by registering for the service. The data provided for registration to the newsletter will be retained until we receive a request for cancellation from you also using the appropriate “Cancel registration” button, in which case we will delete your data from our databases within 48 hours since your request for cancellation from the service. The newsletter will be sent only under your consent, which will constitute the legal base with which we will process your data.
Contact Form: the data you enter in the form are exclusively used to give a precise response to what you requested and, for this purpose, it is not necessary to give your express consent. The data you have provided will be kept for a period of 24 months and then deleted from our systems.
Services Purchase: the data you provide will be used for the performance of the service purchased and the related activities (billing, payment management, customized requests, etc.). The settlement of the on-line sales contract will therefore constitute the legal base with which we will process your personal data that will be stored for the time necessary to fulfill the obligations dictated by law in relation to the performance of the sales activity.
work with us: when you write to the e-mail address firstname.lastname@example.org for a job application we will use the data you provided to carry out the necessary selection activities. Once the analysis of the application has been completed, the data collected will be kept for 24 months, after which they will be deleted from our databases.
We communicate your personal data to third parties only when this is necessary and functional to the achievement of the processing purpose pursued according to the requested service. In any case, we proceed to the communication only after having informed you and having received your consent to do so, when required. In general, the data collected through the single services and for the purposes pursued in this statement can be communicated to the following categories of subjects:
- Any Public Authority to which the right to access them is attributed by law;
- data processing and IT services companies (e.g. web hosting, data entry, management and maintenance of IT infrastructures and services, web agencies, etc.);
- companies and firms providing consulting services to comply with legal provisions or to protect the legal interests of the Data Controller;
- In particular, some specific services provided through our website also include communication to other categories of subjects, such as banks or other payment service providers;
- Some browsing data are collected by third parties, such as social networks, when the user decides to use the pertinent interaction key and, in some cases, even without using the interaction service. The processing of these data is subject to the privacy policies of each third party. In any case, the third-party websites accessible from this site are under the responsibility of third parties. The Data Controller declines any responsibility regarding requests and / or provision of personal data to third-party websites.
DATA TRANSFER IN OTHER COUNTRIES
The personal data collected through the website are saved and stored within the national territory or in other EU countries. Data can be transferred to non-EU countries. If wanting more information on the place of data storage, users can get it by requesting it expressly to the Data Controller. In particular, some cookies and the data entered for the purchase of services through Rezdy.com booking platform are transferred to and processed in the United States of America which, in any case, is considered a suitable place for the purposes of treatment established in Regulation EU 2016/679
DURATION OF DATA STORAGE
We retain, by adopting the appropriate security measures, the data provided for the period necessary to achieve the purposes for which they were collected, in particular:
- the data collected and processed to fulfill the purposes of law are kept for the period provided for by the single regulation;
- the data collected to enforce the contract of sale of the services are kept for the period necessary to cover the period of enforcement of the pertinent obligations and to fulfill all the obligations provided for by further regulations.
- the data collected when the user subscribes to the newsletter are kept until the user decides to unsubscribe from the service.
- The data collected in case of use of the contact form are kept for 24 months.
- the data voluntarily provided for by users (e.g. sending e-mails to the addresses indicated on the website) will be kept for a period of 24 months, after which they will be deleted.
PROFILING AND AUTOMATED DECISION-MAKING PROCESSES
Marco Romeo does not process the data collected during navigation for profiling purposes or activities of the website users and does not adopt decision-making systems based solely on the automated processing of data.
NATURE OF DATA PROVISION
Mandatory Provision:Providing the requested data is always mandatory when it is necessary for the settlement of a contract or to fulfill legal purposes. In such cases, failure to provide data will not allow the Data Controller to perform the requests received. For this purpose, the mandatory data entry fields in the forms on the website are marked with an asterisk.
Optional provisionFailure to provide the optional data in the collection forms does not affect the achievement of the requested service. The fields where it is optional to enter the data are recognizable as they are not marked by the asterisk that marks the mandatory fields.
Voluntary provision:When you spontaneously send an e-mail to one of the e-mail addresses indicated on our site, we acquire the sender’s address and any other personal data that you have entered in the message and in its attachments. The e-mail boxes corresponding to the addresses indicated on our sites and any other e-mail address of Marco Romeo are not of a personal nature even when they mention the name and / or surname of an individual. They belong to the Data Controller and have the primary purpose of allowing the effective performance of working activities within the company. By sending an e-mail to the e-mail addresses indicated on the website, you declare that you have read and accepted the processing conditions contained in this statement.
RIGHTS OF PERSONS INVOLVED
At any time, you can exert the rights recognized in Regulation EU 2016/679. In particular, by contacting the Data Controller or the Data Processor (it is possible to have a list of external supervisors by making a specific request to the Data Controller), you can exert:
the Right of Access (art. 15). You will be able to obtain from the data controller the confirmation that your personal data are being processed or not and, in this case, to get a copy of the data being processed; Right of Amendment (art. 16). You will get the amendment (i.e. the modification, integration or update) of inaccurate personal data, in case of inaccuracy, incompleteness or obsolescence; Right of Cancellation (art. 17) (so-called Right to be forgotten). You can get the cancellation of your personal data. The data controller will cancel them without unjustified delay in case of existance of one of the reasons listed in art. 17; Right to Limitation of Treatment (art. 18). As an interested party, you have the right to get the limitation of processing in case of occurrence of one of the hypotheses listed in art. 18; Right of Opposition (art. 21). At any time, you have the right to object to the processing of your personal data for reasons connected to your particular situation and if the conditions set in art. 21 occur; Right to Data Portability (art. 20). You have the right to receive the personal data you provided to a Data Controller in a format which is structured, commonly used and readable on automatic devices. You also have the right to transmit such data to another Data Controller without impediments by the Data Controller you provided them to if the conditions listed in art. 20 occur; Right to Cancellation of Consent. You have the right to cancel your consent in relation to all treatments based on it. To exert this right, without this circumstance affecting the lawfulness of the processing until then based on the consent given, you can at any time write to email@example.com; Right to Lodge a Complaint to the Data Protection Authority. When necessary, you can lodge a complaint to the competent Control Authority for the protection of the rights guaranteed by Legislative Decree 2003/196 and further modifications and the European Regulation 2016/679 (www.garanteprivacy.it).
Latest modification made on 23/03/2019