INFORMATION FOR THE PROCESSING OF PERSONAL DATA

(EUROPEAN REGULATION 2016/679)

Personal data collected pursuant to art. 13 and 14 GDPR

 

Itineraris s.r.l., in the person of the legal representative pro tempore Mrs. Gobbi Sara, resident in Santarcangelo (RN) in via Garibaldi 26, VAT no. 04470910409, hereinafter DATA CONTROLLER, as data controller, informs you, pursuant to art. 13 and art. 14 EU Regulation no. 2016/679, hereinafter GDPR, that your data will be processed in the following ways and for the following purposes:

1) identity and contact details of the data controller and data protection officer:  Itineraris s.r.l., in the person of the legal representative pro tempore Mrs. Gobbi Sara, current in Santarcangelo (RN) in via Garibaldi 26, VAT no. 04470910409, hereinafter DATA CONTROLLER, who can be contacted by e-mail info@itineraris.it and/or itineraris@pec.it and/or telephone 339 2220086. In fact, a data protection officer has not been appointed, nor a representative of the owner, as they are not required under European Regulation 2016/679. You may contact the data controller to exercise the rights granted to the data subject by GDPR and to obtain an updated list of all data processors, both internal and external, sub-processors and data processors

2) subject of the processing: the Data Controller processes your Personal Data (e.g. name, surname, company name, address, telephone, e-mail, facebook account, whatsapp account, bank and payment references as well as the location of where to deliver the goods ordered by you) subsequently Personal Data, communicated by you when concluding contracts for the services and supplies of the Data Controller, i.e. for the management of agencies and tour operators in the context of the organisation of travel for end users.

      3) Purpose of the processing and legal basis.

       Your data are processed:

  1. A) without the need for your express consent, pursuant to art. 6 letter b) GDPR for the following sales or service purposes:

– the provision of services and supplies of the Owner, i.e. for the management of agencies and tour operators within the organization of travel for end users and for associations and/or tour operators and/or travel agencies.

– Fulfillment of pre-contractual, contractual and fiscal obligations arising from existing relations with you.

-comply with obligations under the Law, a regulation, Community legislation or an order of the Authority (such as in the area of anti-money laundering)

-exercise the rights of the holder, for example the right of defence in a possible trial.

  1. B) Only after your specific and separate consent (art. 6 letter a) GDPR), informing you that you may at any time revoke the consent previously given, it being understood that for the processing operations carried out with explicit consent, the lawfulness of the processing until the revocation of consent, for the following marketing purposes:

-sending you emails, mail and/or sms, and/or telephone contacts, newsletters, commercial communications and/or advertising material on products or services offered by the Owner, and survey the degree of satisfaction with the quality of services.

– sending you emails, mail and/or sms, and/or telephone contacts, newsletters, commercial and/or promotional communications of third parties (e.g. business partners)

We inform you that you may revoke your previous consent at any time, without prejudice to the lawfulness of the processing carried out until the revocation of your previous consent.

C i) For a legitimate interest of the data controller, for statistical purposes or for better navigation on the site www.itineraris.it  This is specifically, with regard to statistical purposes, the use by the aforementioned website of the Google Analytics program, which, however, is used by the data controller only with IP anonymisation enabled The IP address transmitted by your browser will not be merged with other Google data. Users can prevent the storage of cookies by adjusting their browser settings accordingly. The legal basis for this processing of data is Article 6 paragraph 1 letter F) of the GDPR. Users can prevent the collection of data generated by cookies by downloading and installing the browser plug-in available at the following link: : http://tools.google.com/dlpage/gaoptout?hl=us.

C ii) For a legitimate interest of the owner, for a better navigation on the site www.itineraris.it, through the use of cookies, as better highlighted in the cookie policy on our site. In this case, the legal basis for the processing is given by art. 6 paragraph 1 letter f GDPR. It is in our legitimate interest to make our site easier to navigate, more effective, practical and secure. The cookies that install our site are known as “session cookies”. They are deleted after the end of your visit. You have the option of not accepting the use of cookies by selecting the appropriate settings in your browser.

 

C iii) Using facebook page. On our website we use Facebook Ireland LTD visitor action pixels, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland (FACEBOOK). This tool allows you to track users’ actions after they have been redirected to a provider’s website by clicking on an advertisement on facebook. This allows us to record the effectiveness of facebook advertising for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the data of individual users. However, it is stored and processed by Facebook, which is why we inform the user based on our knowledge of the situation. Facebook is able to link the data with your Facebook account and use it for its own advertising purposes in accordance with the policy on the use of data by Facebook available at the following address: https://www.facebook.com/about/privacy/update?ref=old_policy. The User may allow Facebook and its partners to display advertisements on Facebook and outside Facebook. For these purposes a cookie may also be stored on the User’s computer. The legal basis for the use of this service is art. 6 paragraph 1 letter F) GDPR The User may object to the collection of data by Facebook pixels or the use of data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.

  1. D) only with his specific consent, pursuant to art. 9 paragraph 2 letter A) GDPR, for the processing of Personal Data relating to health, in the context of the conclusion of contracts for the services and supplies of the Owner, i.e. for the management of agencies and tour operators within the organisation of travel for end users.

4) methods of processing: the processing of your Personal Data is carried out through the operations indicated in art. 4 n. 2 GDPR, namely: collection, recording, organisation, structuring, storage, adaptation and modification, extraction, consultation, use, communication by transmission, diffusion, or any other form of making available, comparison, interconnection, limitation, cancellation, destruction, portability at your request. Your Personal Data are subject to both paper and electronic and/or automated processing. Personal Data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected. As per your right, automated processing, including profiling, which produces legal effects concerning you or which affects your person in a similar way, will not be based solely on the aforesaid automated processing, unless it is necessary for the conclusion or performance of a contract between the data subject and a data controller, or unless there is explicit consent from the data subject. We inform you that specific security measures are observed to prevent the loss of data, unlawful or incorrect use and unauthorized access.

      5) any recipients or categories of recipients of Personal Data

The data may be communicated only to the interested party and to persons or companies explicitly indicated by the interested party. The data will not be further communicated except to persons or companies duly authorized by the Data Controller (internal and/or external data processors, sub data processors, data processors) and may not be disclosed. Without the need for your express consent, the Data Controller may communicate your data for the purposes set forth in art. 3 A) of this notice to Supervisory Bodies, Judicial Authorities as well as to all those subjects to whom the communication is mandatory by law and for the fulfillment of the said purposes. These subjects will process the data in their capacity as independent data controllers. The data will not be transferred to a third country or to an international organisation.

      6) storage times of Personal Data of the data subject.

The data controller will process Personal Data for the times defined by the reference legislation, which are specified below, pursuant to art. 13 GDPR: ten years for documents and related data of civil, accounting, tax, as required by current laws. With reference to the data subject to processing for marketing purposes or processing for profiling purposes, the same will be kept in compliance with the principle of proportionality and in any case until the purposes of processing have been pursued or until – if previously – the withdrawal of specific consent by the person concerned.

      7) Rights of the data subject

The data subject has the right to ask the data controller for access to, rectification or deletion of, or limitation of, the Personal Data held by him/her, or to object to the processing of his/her Personal Data, as well as the right to request the portability of his/her Personal Data held by the data controller.

      8) Consent given and its revocation

Where the processing is based on the explicit consent of the data subject for one or more specific purposes of the data subject, pursuant to art. 6 paragraph 1 letter A) or on the explicit consent of the data subject pursuant to art. 9 paragraph 2 letter A) for one or more specific purposes of the data subject, the data subject is informed that it is the right to withdraw the consent at any time without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.

      9) Right to lodge a complaint with a supervisory authority

The Data Controller informs the data subject that if he/she finds that the processing of his/her data is unlawful, non-transparent, incorrect, or any other irregularity within the meaning of GDPR, he/she has the right to lodge a complaint with the Supervisory Authority (Personal Data Protection Guarantor) or to take legal action.

10) Nature of the provision of Personal Data and consequences of any refusal to provide them.

The provision of Personal Data is optional. Any refusal to provide them makes it impossible to conclude contracts for the services and supplies and the purchase and sale of goods of the Owner referred to in point 3 A) of this notice.

      11) Profiling

The owner informs you that your Personal Data will not be processed through an automated decision making process (including profiling). 

      12) Further processing of data for further purposes

The owner informs you that your data will be processed only for the purposes for which they were provided. Further processing for purposes other than those for which the data were provided must be subject to further authorisation by the data subject.

      13) Advertising, marketing and User preferences in communications:

In case of specific consent we may use direct marketing strategies by e-mail, telephone, SMS or mail. For example, you may receive our newsletter via your email inbox. We make every effort to ensure that our site always clearly communicates our activities and the type of messages we deliver to you, both when you decide to receive our newsletter and when filling out the contact form. The User can change his or her mind at any time and decide to unsubscribe, all as in point B of art. 3.

14) Cookies
By using www.itineraris.it you consent to the use of cookies in accordance with this policy. If you do not consent to the use of cookies in this way, you must set your browser accordingly or you may not use the site.

Cookies are made up of portions of code installed in the browser that assist the Owner in providing the Service according to the purposes described. Some of the purposes of installing Cookies may also require your consent.

When Cookies are installed on the basis of consent, such consent may be revoked freely at any time by following the instructions contained in this document.

Aggregate statistics and technical cookies

Activities strictly necessary for operation

This Application uses Cookies to save your session and to perform other activities strictly necessary for the operation of this Application, for example in relation to traffic distribution.

Preference Saving, Optimization and Statistics Activities

This Application uses Cookies to save your browsing preferences and optimize your browsing experience. These cookies include, for example, those for setting the language and currency or for managing statistics by the Site Owner.

Other types of Cookies or third-party tools that may install them

Some of the services listed below collect statistics in aggregate and anonymous form and may not require the User’s consent or may be managed directly by the Owner – depending on what is described – without the help of third parties.

If among the tools indicated below there are services managed by third parties, they may – in addition to what has been specified and also without the knowledge of the Owner – perform activities of tracking the User. For detailed information on the subject, please consult the privacy policy of the listed services.

Advertising

This type of service allows the User Data to be used for commercial communication purposes in various forms of advertising, such as banners, also in relation to the User’s interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.
Some of the services listed below may use Cookies to identify you or use the technique of behavioural retargeting, ie display advertising tailored to your interests and behaviour, also detected outside of this Application. For more information about this, we suggest that you check the privacy policies of the respective services.

Google AdSense (Google)

Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” cookie, which tracks the use of this Application and the behaviour of the User in relation to advertisements, products and services offered.
The User can decide at any time not to use the Doubleclick cookie by deactivating it:google.com/settings/ads/onweb/optout.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

Interaction with social networks and external platforms

This type of services allow interactions with social networks, or with other external platforms, directly from the pages of this Application.
The interactions and information acquired by this Application are in any case subject to the User’s privacy settings relating to each social network.
If a social network interaction service is installed, it is possible that, even if Users do not use the service, it may collect traffic data relating to the pages where it is installed.

Facebook Like button and social widgets (Facebook, Inc.)

The “Like” button and social widgets of Facebook are services of interaction with the social network Facebook, provided by Facebook, Inc.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

+1 button and Google+ social widgets (Google Inc.)

The +1 button and Google+ social widgets are Google+ social network interaction services provided by Google Inc.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy. Subject adhering to the Privacy Shield.

Tweet button and social Twitter widgets (Twitter, Inc.)

Twitter’s Tweet button and social widgets are social networking services provided by Twitter, Inc.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy. Subject adhering to the Privacy Shield.

Infrastructure monitoring

This type of services allows this Application to monitor the use and behaviour of components of the Application, to allow the improvement of performance and functionality, maintenance or troubleshooting.
The Personal Data processed depends on the characteristics and the way these services are implemented, which by their nature filter the activity of this Application.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a Remarketing and Behavioural Targeting service provided by Facebook, Inc. that links the activity of this Application with the Facebook advertising network.

Personal data collected: Cookies and emails.

Place of processing: USA – Privacy Policy – Opt Out.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a Remarketing and Behavioural Targeting service provided by Facebook, Inc. that links the business of this Application with the Facebook advertising network.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

AdWords Remarketing (Google Inc.)

AdWords Remarketing is a remarketing and behavioural targeting service provided by Google Inc. that links the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

Remarketing with Google Analytics for display advertising (Google Inc.)

Google Analytics for display advertising is a remarketing and behavioural targeting service provided by Google Inc. that links the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Twitter Remarketing (Twitter, Inc.)

Twitter Remarketing is a remarketing and behavioural targeting service provided by Twitter, Inc. that links the activity of this Application with the Twitter advertising network.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Statistics

The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to keep track of the User’s behaviour.

Monitoring conversions of Facebook Ads (Facebook, Inc.)

Facebook Ads conversion monitoring is a statistics service provided by Facebook, Inc. that links data from the Facebook ad network with the actions performed within this Application.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy.

Display Advertisers Extension for Google Analytics (Google Inc.)

Google Analytics on this Application may use Google interest based advertising, third party audience data and information from the DoubleClick Cookie to extend statistics with demographic data, interests and ad interaction data.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Google AdWords Conversion Monitoring (Google Inc.)

Google AdWords conversion monitoring is a statistics service provided by Google Inc. that links data from the Google AdWords ad network with the actions performed within this Application.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy. Subject adhering to the Privacy Shield.

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and evaluating your use of this Application, compiling reports and sharing it with other services developed by Google.
Google may use Personal Data to contextualize and personalize ads in its advertising network.
This integration of Google Analytics makes your IP address anonymous. Anonymisation works by shortening your IP address within the borders of European Union Member States or other countries that are parties to the Agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google’s servers and shortened within the United States.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Monitoring Twitter Ads conversions (Twitter, Inc.)

Twitter Ads Conversion Monitoring is a statistics service provided by Twitter, Inc. that links data from the Twitter ad network with the actions performed within this Application.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy. Subject adhering to the Privacy Shield.

User ID extension for Google Analytics (Google Inc.)

Google Analytics uses a function called User ID on this application. This allows more accurate tracking of Users by assigning each one a unique ID for various sessions and devices, but in a way that does not allow Google to personally identify an individual or permanently identify a specific device.
The User ID extension also allows you to connect Data from Google Analytics with other User Data collected by this Application.
The Opt Out link provided below allows you to deactivate tracking for the device you are using, but does not exclude further tracking activities performed by the Owner. To deactivate these too, please contact the Owner via the contact email address.

Personal data collected: Cookie.

Place of processing: USA – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and to interact with them.
If a service of this type is installed, it is possible that, even if Users do not use the service, it may collect traffic data relating to the pages where it is installed.

YouTube Video Widgets (Google Inc.)

YouTube is a video content viewing service operated by Google Inc. that allows this Application to integrate such content within its pages.

Personal data collected: Cookies and Usage Data.

Place of processing: USA – Privacy Policy. Subject adhering to the Privacy Shield.

How do I consent to the installation of Cookie?

In addition to what is stated in this document, you can manage your Cookie preferences directly within your browser and prevent – for example – third parties from installing cookies. You can also use your browser preferences to delete cookies that have been installed in the past, including the Cookie in which you may save your consent to the installation of Cookies by this website. You may find information on how to manage Cookies with some of the most popular browsers at the following addresses, for example: Google ChromeMozilla FirefoxApple Safari e Microsoft Internet Explorer.

With respect to Cookies installed by third parties, you may also manage your settings and revoke your consent by visiting the relevant opt-out link (if available), using the tools described in the third party’s privacy policy or by contacting the third party directly.

Notwithstanding the foregoing, you may use information provided by EDAA (UE), Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services you can manage the tracking preferences of most advertising tools. The Owner, therefore, advises Users to use these resources in addition to the information provided herein.