Privacy GDPR

Privacy GDPR

information pursuant to GDPR EU 2016/679 regulation

Privacy GDPR

Holder:

Sportoutdoor Viaggi S.r.l. – Viale Coni Zugna 5/A – 20144 MILANO

Holder contact email: info@sportoutdoorviaggi.com

Types of data collected and processing purposes

The data that can be requested such as Name, Surname, Place and Date of birth, Tax code, Gender (gender), Name of person to contact in case of emergency, Passport (number, issue date, expiry date), Residence Address, E-mail address, Mobile phone number, Telephone number of person to contact in case of emergency, Credit card/IBAN data are collected to allow the purchase of our excursions and our agency services. The communication of their data by the interested party is a fundamental requirement for the conclusion of the purchase contract for our excursions and our services in general.

Sportoutdoor Viaggi Travel Agency (hereinafter also “ADV”), as holder, pursuant to art. 13 of the General European Regulation on the Protection of Personal Data 679/2016 (hereinafter the “GDPR”), provides the following information about the processing of personal data that you, as an interested party, has communicated to us:

a) for the organization of a tourist package or an excursion;

b) to facilitate the purchase of related tourist services;

c) for intermediation in the purchase of a tourist package organized by third parties or individual tourist services provided by third party suppliers (e.g. hoteliers, carriers);

d) for intermediation in the purchase of accessory financial/insurance services and connected to packages or tourist services facilitated or purchased individually (medical policies - baggage; cancellation; assistance to the traveler in difficulty; consumer credit financing);

e) to fulfill the visa assignment;

f) to register on our website and/or app or fill in the forms on the website or in the app;

Purpose and legal basis of the processing.

Among the data you have provided, there may also be some personal data defined by the GDPR and by the Italian harmonization legislation as “special” (i.e. health, judicial). Sensitive/particular data will be processed according to the purposes indicated below and only with your express consent.

A. Purpose relating to the contractual service.

Your personal data will be processed for the purpose of fulfilling the obligations arising from the negotiation and the contract relating to the organization of the excursion or the tourist package, or to the mandate to facilitate the purchase of the related tourist services or to the brokerage mandate for the purchase of individual tourist services or in any case for the execution of the obligations deriving from all contractual relationships, including the negotiation phase, indicated in the previous letters. from a) to f), in order to allow the ADV to optimally provide the service, in particular for:

a) the conclusion, management and execution of the contractual relations between you and the lawyer;

b) respond to your requests;

c) the communication of notices relating to the package or tourist services purchased or other additional and accessory services (e.g. information relating to the tourist services purchased; modification of the contractual conditions; cancellations);

In legal terms it is said that these treatments find their legal basis in the need to respond to a specific request by the interested party (e.g. execution of pre-contractual measures) and to execute a contract.

The Contact Data, if (and only if) the Users provide their consent by clicking in the appropriate box, they will also be used to provide commercial information which will be transmitted by way of example via e-mail, WhatsApp or through telephone calls with the operator. This treatment finds its legal basis in the consent of the interested party.

B. Legal purposes.

Your personal data will also be processed for:

a) to implement legal obligations, regulations, national, community and international regulations or deriving from provisions issued by Authorities legitimated by the law;

b) ascertain, exercise and/or defend a right of ADV in litigation, including judicial proceedings;

c) fulfill tax and accounting obligations;

d) fulfill obligations related to travelers' health and safety regulations;

e) fulfill obligations related to passenger and freight transport regulations.

C. Business and statistical purposes.

Your personal data will also be processed for purposes related or pertinent to the activity carried out by the ADV and for the anonymous processing of statistics and market research.

D. Marketing purposes.

Furthermore, if you expressly consent, your personal data will be processed for the following marketing purposes, which include:

promotional activities of the ADV, and/or commercial partners, carried out both with automated methods (e.g. email, SMS, instant messaging applications, etc.) and with non-automated methods (e.g. ordinary mail, telephone with operator, etc. .). In particular, the ADV may use your email address, provided at the time of purchase of tourist packages or services, to transmit information and promotional communications related to similar services and products and offered by the ADV and/or commercial partners even without your consent, provided you do not object to such use.

The commercial partners belong to the following product categories:

a) accommodation activities;

b) airlines/shipping companies; railway carriers; vectors on rubber;

c) travel agencies and network of travel agencies;

d) insurance.

profiling activities, i.e. analysis of your travel preferences and market research in order to improve the offer of services and commercial information presented by us, making them more compliant with your interests. This activity may also take place through the administration of satisfaction questionnaires and/or the use of profiling cookies used when browsing our sites and apps.

The processing for Marketing Purposes (therefore both for promotional and profiling activities) can only take place with your consent.

E. Access and navigation data collected automatically by the site.

Whenever Users access the Site, the computer systems and software procedures used to operate the Site acquire, during their normal operation, access and navigation data (for example: information on the browser used by the User, pages visited, date, time and duration of each visit, as well as other parameters relating to the User's operating system and IT environment - the “Navigation Data”).

F. Why is Data collected and what is it used for?

The Navigation Data will be used: (i) to monitor the correct functioning of the Site, (ii) anonymously and in aggregate form, for statistical purposes related to the understanding of how the Site is used by Users, to improve ease of access and increase their attractiveness, as well as (iii) to detect any technical problems as soon as possible

These treatments are necessary to improve navigation on the Site to facilitate the use of the digital services offered by the Holder and that is in the legitimate interest of the Holder to improve its products and is compatible with the position of the Users in that: (a) monitoring the functioning of the Site and statistical data related to its use does not involve direct identification; and (b) the interest of the Holder appears reasonably to be proper also to the Users, who will thus be able to benefit from an increasingly performing and optimized Website.

Data required to activate the “Newsletter” function: email address

Users have the opportunity to provide their e-mail to Sportoutdoor Viaggi Srl as contact data also to subscribe to a newsletter service (“Newsletter Data”), aimed at allowing the user to benefit from this service and, therefore, to receive updates via e-mail on excursions and destinations of tourist packages, on activities and possible trips thanks to Sportoutdoor Viaggi Srl.

Images

With the purchase of the Excursion or Tourist Package - therefore, by accepting the General Conditions - the User gives free of charge to the Holder the right to use, disseminate, reproduce, elaborate, modify, publish, communicate to the public, transmit - on each and any analog, electronic, IT and/or digital support (including but not limited to, transmission systems over the air, cable, satellite, web, also on social network pages such as, for example: Pinterest® Facebook®, Instagram® , Twitter®, YouTube®) - your own portrait and image contained in the videos and images that can be created on the occasion of the excursion or trip purchased (hereinafter, the “Images”). The User also: (i) assigns any rights of any kind and nature existing on the Images necessary for the exploitation of the Images for commercial, promotional and advertising purposes; (ii) expressly declares to be fully satisfied and to have nothing to claim for any reason or title (for example, of an economic nature) from the Holder, his assigns and/or assignees and/or in general by anyone who uses and exploits the Images; (iii) guarantees the Holder the permission to all rights assigned pursuant to this article and indemnifies the Holder and/or its assignees as of now from any eventual action and/or claim by third parties regarding the Images and their exploitation, assuming all responsibility for it. In any case, the Holder will not use the Images in contexts or in ways that affect the honor, reputation and dignity of the user portrayed and/or taken up. However,  if the User does not want his image to be disseminated, he must communicate it at the time of purchase and in any case before the start of the Excursion or Tourist Package by writing to info@sportoutdoorviaggi.it

Cookies

The site uses computer techniques for the direct acquisition of user identification data consisting of “code strings”: “cookies”. For all information on the cookies active on the Site and on the related processing of personal data.

To whom the Data are communicated (Navigation Data, Personal Data, Contact Data, Newsletter Data and Images).

The Data will be communicated and may be known (i) by employees and collaborators of the Holder, who have been specifically designated for the processing; and (ii) by third parties who provide ancillary or instrumental services to the activities of the Holder, in relation to the development, delivery and operational management of the Site; these subjects have either received a specific appointment as Data Processors or, as in the case of payment service providers, they will treat the Data as independent holders and will also request additional personal data. Furthermore, the images may be disseminated in advertising contexts and known by an indefinite audience of people.

The complete list of data processors is kept at the headquarters of the holder and can be consulted on request to be sent to the holder using the contact details indicated in this statement.

Where is the data processed?

The processing of data will be carried out at the headquarters of the holder and the data will be stored in servers and/or archives located within the European Union or in countries that provide adequate guarantees of protection of personal data.

For example: some IT service providers for the management of contact and e-mail databases used by the Holder (or even the social networks on which the Images may be published) process data in the USA, but fall within the so-called Privacy Shield: a system that protects European citizens when their data pass through the United States of America.

How is the Data processed, protected and stored? And for how long?

The data finalized to the realization of a contract is stored as required by law. Once the retention terms have been completed, or after the request for revocation, the data is deleted.

The Data will be processed both in paper form and with electronic, IT or automated tools, through systems that ensure its protection, security and confidentiality.

Furthermore, the Holder has adopted specific and appropriate logical, legal, organizational and technical security measures to prevent the loss of the Data, illicit or unauthorized use of the same and unauthorized access.

The data will not be kept for longer than necessary. In particular:

The Navigation Data - which does not allow the identification of Users - does not persist for more than 1 week and is deleted immediately after their aggregation (except for any need for the detection of crimes by the competent Judicial Authority);

The Personal Data and Contact Data, which are used to respond to Users' requests, are kept for up to 1 year after receiving the request;

The Personal Data and Contact Data, which are used to make the reservation and subsequently to access the personal area of ​​reservations/purchases (and therefore to allow them to access without having to register every time!) are also kept until the execution of the contract of purchase of the trip and, in any case, for 10 years (the ordinary limitation period);

The Contact Data of those who have given their consent to receive commercial information relating to Sportoutdoor Viaggi and other travel proposals, will be kept and processed for 24 months.

Newsletter data will be stored and processed up to 24 months after registration. With a month's notice, we will ask the User if he wishes to continue receiving the newsletter: in case of refusal, the Newsletter Data will be deleted; in the event of consent, it will be kept and processed for the further 24 month period.

The images that will be collected during the trip will be kept for the time necessary to (i) collect, organize and “edit” them, and (ii) publish them for promotional purposes.

The Data will be kept for longer if this is necessary to comply with obligations established by law or to ensure the judicial protection of the Holder's rights, in compliance in any case with the maximum terms allowed by law.

What are your rights?

Users, as interested parties (i.e., subjects to whom the Data refer), are holders of rights conferred by the GDPR. In particular, pursuant to art. 12-23 of the GDPR, data subjects have the right of this information lists their rights to the interested party:

a) access, i.e. access to your data at any time upon request to obtain information regarding the purposes and methods of treatment;

b) of correction, that is, of being able to obtain, at any time, modifications to one's data “without justified delay”;

c) to be forgotten, that is, to be able to request and obtain, at any time, the cancellation of your data;

d) to the limitation of the treatment i.e. to limit the Holder in the use of their data (for some purposes, for others not, or for none and therefore there is only conservation);

e) to the portability of the data, that is, to be able to receive all personal data concerning him; or the direct transmission of such data to another Holder;

f) of opposition to the treatment i.e. to be able to oppose, at any time, to the treatment if there is no legal basis (where consent is not required), or to the treatment for direct marketing purposes without providing any explanation, to the treatment for purposes scientific, historical, statistical, finally to the automated decision-making process.

The above rights can be exercised at any time, by simple request to the Holder, to be transmitted:

to the email address info@sportoutdoorviaggi.it

at the address Viale Coni Zugna 5/A - 20144 Milan.

For other information or clarifications on the rights mentioned, it is possible to contact the Holder at the same addresses.

The Holder may modify this information to adapt it to future extensions or future modifications of the Site.

The rights listed above may be limited for security and defense reasons.

The Holder, in relation to the exercise of his rights, must reply to the interested party within one month of receiving the request or within 3 months, in more complex cases, with the obligation to justify this extension within one month of receiving the question.

For the exercise of his profession, the Holder gives third parties the data he has collected, appointing these as Data Processors, the data processors process the data in the manner indicated by the Holder (you can ask for details on the Holder).

The data collected by the Holder are aimed at stipulating contracts, the interested party cannot refuse to provide their data if he intends to make use of the work of the Holder himself.

None of the collected data will be transferred to non-EU countries.

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