Agenzia Petruz Viaggi srl (hereinafter also referred to as "ADV"), as data controller, pursuant to Article 13 of the European General Data Protection Regulation 679/2016 (hereinafter the "GDPR"), provides the following information regarding the processing of personal data that you, as the data subject, have communicated to us:
a. for the organisation of a tourist package;
b. to facilitate the purchase of related tourist services;
c. for intermediation in the purchase of a tourist package organised by third parties or individual tourist services provided by third-party suppliers (e.g. hoteliers, carriers);
d. for the intermediation in the purchase of financial/insurance services ancillary and related to the tourist packages/services facilitated or purchased individually (medical/baggage policies; cancellation; assistance to travellers in difficulty; consumer credit financing);
e. to fulfil the task of issuing visas;
f. for registration on our website and/or app or the completion of forms on the website or app;
Purpose and legal basis of processing.
Furthermore, among the data you provide, there may also be some personal data defined by the GDPR and Italian harmonisation legislation as "special" (e.g. health, judicial). Sensitive/particular data will be processed for the purposes indicated below and only with your express consent.
a) Purposes relating to contractual performance. Your personal data will be processed for the purpose of fulfilling the obligations arising from the negotiations and from the contract relating to the organisation of the tourist package, or to the mandate to facilitate the purchase of related tourist services or to the mandate of intermediation for the purchase of single tourist services or in any case for the execution of the obligations arising from all the contractual relationships, including the negotiation phase, indicated in the previous letters from a) to f), in order to allow ADV to provide the service in an optimal way, in particular for:
i. the conclusion, management and execution of the contractual relationship between you and ADV;
ii. respond to your requests;
iii. the communication of notices, related to the purchased tourist package or services or other additional and accessory services (e.g. information related to the purchased tourist services; modification of the contractual conditions; cancellations);
b) Legal purposes. Your personal data will also be processed for:
i. implement legal obligations, regulations, national, Community and international standards or arising from provisions issued by Authorities empowered to do so by law;
ii. ascertain, exercise and/or defend a right of ADV. in contentious or judicial proceedings
iii. comply with obligations in the field of taxation and accounting;
iv. comply with obligations related to regulations on the safety and health of travellers;
v. to fulfil obligations related to regulations on passenger and freight transport.
c) Business and statistical purposes. Your personal data will also be processed for purposes related or pertinent to the activity carried out by ADV and for the anonymous processing of statistics and market research.
d) Further purposes. In addition, if you expressly consent, your personal data will be processed for the following purposes:
Marketing Purposes, which include:
a. promotional activities of ADV, and/or of business partners, carried out both by automated means (e.g. email, sms, instant messaging applications, etc.) and by non-automated means (e.g. ordinary mail, telephone with operator, etc.). In particular, ADV may use your email address, provided at the time of the purchase of tourist packages or services, to send you informative and promotional communications related to the services and similar products offered by ADV and/or by commercial partners even without your consent, as long as you do not oppose such use.
The commercial partners belong to the following product categories:
a. accommodation activities;
b. airlines/ shipping companies; rail carriers; road carriers;
c. travel agencies and travel agency networks;
d. insurance companies.
b. profiling activities, i.e. the analysis of your travel preferences and market research in order to improve the services and commercial information offered by us, making them more consistent with your interests. This activity may also take place through the administration of satisfaction questionnaires and/or the use of profiling cookies used during navigation on our websites and apps.
Processing for Marketing Purposes (i.e. for both promotional and profiling activities) may only take place with your consent.
Nature of data provision and consequences of refusal.
The provision of your personal data is optional, however, in the absence of the data requested for the purposes indicated in points a) and b) (purposes relating to contractual and legal performance) the service requested or part of it cannot be performed and you will not be able to take advantage of the opportunities mentioned above.
The provision of optional data will allow ADV to improve the services offered in order to make them more and more responsive to the personal interests of its clients.
The provision of sensitive/particular personal data is voluntary; however, without such consent ADV may not be able to fulfil some contractual obligations related to the processing of such data.
Categories of recipients of personal data.
Your data will not be disseminated. Your data may be communicated, exclusively for the above mentioned purposes, to the following categories of subjects
- ADV's internal staff, in their capacity of person in charge and/or responsible for processing;
- to suppliers of tourist services included in the packages sold, or who provide related or individual ones purchased from ADV;
- to the insurance companies that provide the accessory and connected covers with the purchased tourist packages and services;
- persons, companies, associations or professional offices that provide services or activities of assistance and consultancy in favour of ADV in order to protect one's own rights (for example, accountants, lawyers, tax consultants, auditors, consultants within the scope of auditing or due diligence operations, etc.);
- persons, companies, or agencies that provide marketing and analysis services or consultancy activities in favour of ADV;
- subjects whose right to access your data is recognised by legal provisions and secondary regulations or by provisions issued by Authorities legitimated to do so by law, including airport, port, customs and border authorities.
Transfer of personal data outside the European Union.
Your personal data may be transferred abroad to third party companies belonging or not belonging to the European Union, always for the above mentioned purposes.
In case of transfer of the data to countries outside the European Union, these countries will guarantee an adequate level of protection on the basis of a specific decision of the European Commission or alternatively the recipient will
will be contractually obliged to protect the data with an adequate level of protection comparable to the protection provided by the GDPR.
Retention of personal data.
Personal data will be retained for a period not exceeding that which is necessary to achieve the purposes for which the data were collected and subsequently processed. Personal data will be retained for the duration of the contract concluded by you and also for a period thereafter:
i. within the terms established by the legislation in force;
ii. within the terms established by the legislation, including secondary legislation, which impose the retention of data (e.g. tax returns);
iii. within the period necessary to protect the rights of the data controller in the event of any disputes relating to the provision of the service.
Personal data collected and processed for profiling purposes shall be retained for a maximum period of ten (10) years, after which they shall be automatically deleted or permanently anonymised.
Data Controller and Data Processors.
The data controller is Agenzia Petruz Viaggi srl, with head office in Romans d'Isonzo, via E.Fermi 1
Legal representative Mr Marco Petruz
Rights of the interested party.
At any time, pursuant to Articles 15 to 22 of the GDPR you have the right, including in relation to profiling activities, to:
l request from the data controller access to your personal data and information relating thereto; rectification of inaccurate data or integration of incomplete data; deletion of personal data concerning you (upon the occurrence of one of the conditions indicated in Article 17(1) of the GDPR and in compliance with the exceptions provided for in paragraph 3 of the same Article); restriction of the processing of your personal data (upon the occurrence of one of the cases indicated in Article 18(1) of the GDPR);
l request and obtain from the data controller - where the legal basis for the processing is a contract or consent, and the processing is carried out by automated means - your personal data in a structured, machine-readable format, also for the purpose of communicating such data to another data controller (so-called right to data portability);
l object at any time to the processing of your personal data in the event of special situations concerning you;
l withdraw your consent at any time, limited to cases where the processing is based on your consent for one or more specific purposes and concerns common personal data (e.g. date and place of birth or place of residence), or special categories of data (e.g. data revealing your racial origin, political opinions, religious beliefs, state of health or sex life). Processing based on consent and carried out before the revocation of consent is still lawful;
l to lodge a complaint with a supervisory authority (Italian Data Protection Authority - www.garanteprivacy.it).