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Privacy Policy

Information on the processing of personal data

This information is intended for all those who visit and interact with the site internet of FRIGERIO VIAGGI S.R.L. (also referred to as “FV" or the "Company“) and is made only for this site and not for other sites , eventually consulted by the user via link content on this site. The Company will not be liable in any way for the unlawful processing of your data by third parties. Therefore, for the exercise of the rights referred to in paragraph “Rights of the data subject” refers to the specific information that will have to be provided to you, from time to time, by these third parties as independent Data Controllers.

This information is inspired by Recommendation No. 2/2001 adopted by the European Data Protection Authorities on 17 May 2001 to identify certain minimum requirements for the collection of personal data on-line and, in particular, the modalities, timing and nature of the information that the Data Controllers must provide to users when they link to the pages ,regardless of the purpose of the connection.

Specific information on the processing of your personal data will be progressively reported or displayed in the pages of the site prepared for particular services on request.

The Company will process your personal data in compliance with the provisions of Regulation (EU) 2016/679 of 27 April 2016. (hereinafter referred to as “Regulation” or “GDPR”).

Pursuant to Art. 13 of the Regulation, you may communicate your personal data or those of third parties of which you are lawfully in possession to FV in order to:

the activities of proposing, organising and providing services to support travel which involve the communication of personal data to airlines, operators of car rental services, hotels, insurance companies, tour operators and other third party operators providing services or activities by virtue of contractual relationships with FV;
make a payment;
the organisation of a package tour or the provision of individual tourist services;
the purchase of related tourism services;
intermediation in the purchase of a package tour organised by a third party or of individual tourist services provided by third party suppliers (e.g. hoteliers, air carriers, etc.);
intermediation in the purchase of financial/insurance services ancillary to and/or linked to discounted and/or individually purchased tourist packages/services (medical – baggage policies; cancellation policies; assistance to distressed travellers; consumer credit financing);
fulfil the mandate relating to the issuance of visas;
register on our website , and/or on the application for mobile devices;
subscribe to our newsletter.

Purpose and legal basis of the processing

The data provided by you and requested by FV for access to the various services on the site will be processed for the purposes and according to the methods indicated in the information provided or displayed on the pages of the site prepared for access to these services and for the collection of related data.

The voluntary sending of e-mails to the addresses on the website involve the subsequent acquisition by us of the sender’s address and any personal data transmitted together with the e-mail.

In all cases where you have the right to freely enter your personal data concerning you (e-mail, free-form fields, etc.), these data will be processed by our Company - if deemed relevant and necessary- to process your requests.

If the personal data communicated are not considered relevant and necessary for the provision of the requested service or if the relevant consent has not been given, FV reserves the right, at its absolute discretion, to delete such data.

The personal data thus collected are necessary to fulfill pre-contractual obligations, to properly execute the contract, and to fulfill specific legal obligations.

We may also collect and use, in order to fulfil pre-contractual obligations, to properly perform the contract and to comply with specific legal obligations, information relating to children only if you provide us with their parent or guardian and with their consent. In the event that we become aware that we have processed the information of a child without the valid consent of a parent or guardian, we reserve the right to delete such information.

We may also collect, in order to fulfil pre-contractual obligations, to perform the contract correctly and to fulfil specific legal obligations, data that can be attributed to the definition of “special categories of personal data” (Article 9 of the Regulation), i.e. data that collects “racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to a person's health or sex life or sexual orientation” or data relating to your habits and/or usages and customs related to the needs of travel or the use of the tourist service. In this case, these special categories of data will only be processed in response to your express and specific request and if deemed relevant and/or necessary for the provision of the service requested by you.

a. Purpose related to the contractual performance

Your personal data will be processed for the purpose of fulfilling obligations arising from the negotiation and conclusion of contracts necessary for the provision of services or, in any case, for the performance of obligations arising from all contractual relationships, including the negotiation phase, in order to enable FV to optimally deliver the service.

In particular, the processing of your data will take place for:

the conclusion, managing and executing contractual relationships, including brokering;
respond to your requests;
the communication of notices relating to purchased services or other additional and ancillary services (information relating to purchased services; modification of contractual conditions; cancellations, refunds, etc.).

To proceed with the purchase online, you need to create a personal account by registering through the dedicated procedure. When you create your personal account, you will receive the specific information on the processing of your personal data. As provided in Recommendation No. 2/2001, you will always have the opportunity to access your personal account to change, update, correct and delete certain data about you. We inform you that for some personal data (such as first name, last name, date of birth, gender, etc.) the right to change can only be exercised by sending a specific and reasoned written request to the Data Controller using the contact details given in this notice. The Holder, before proceeding with the requested change, reserves the right to verify the correctness of the new data provided and the validity of the reasons behind your request.

The provision of personal data and, where applicable, data relating to the definition of “special categories of personal data” (Article 9 of the Regulation) is optional; however, FV will not be able to perform, in whole or in part, the service requested by you.

In this case, the processing will be based on the need to fulfil pre-contractual, contractual and legal obligations.

The processing of particular categories of personal data will, however, be based on your express and free consent. In this case, by submitting these particular categories of data, you expressly authorize our Company to process the same data for the provision of the services you have requested. However, if our Company does not consider the data you provide relevant and/or necessary for the provision of the services, FV reserves the right to delete them.

FV detects the type of payment method used to make an online purchase (credit card, debit card, etc.), but does not display or store in any way the identification data of the payment method (full number of cards, expiry date, security code, etc.). Only certain details (last four digits of the card, date and time of the transaction, etc.) are stored in order to be able to process refunds on your behalf, if necessary.

b. Legal purposes. Your personal data will also be processed for:

to execute obligations of law, regulations, national, Community and international regulations or deriving from provisions issued by the Authority to this end legitimized by law;
establish, exercise and/or defend in litigation, including judicial proceedings, a right of FV;
fulfil with tax and accounting obligations;
fulfil obligations related to legislation on the safety and health of travellers;
fulfil obligations related to passenger and freight transport regulations;

In this case, the processing will be based on the need to comply with any obligation arising from laws, regulations and, in general, from the legislation -including Community legislation- applicable from time to time to the relationship established with our Company.

c. Business-related purposes and statistics

Your personal data will also be processed for the anonymous processing of statistics and market research.

d. Commercial marketing purposes and newsletters.

The personal data that you provide through the various services of the website, with the exception of data that can be attributed to the definition of “special categories of personal data” (Article 9 of the Regulation), may be processed –only with Your prior, free and express consent– for sending newsletter, commercial and/or promotional information and free products, or to invite you to events and/or events, or to carry out market research, or to report on all special initiatives dedicated to FV customers, as well as to offer you promotions, discounts, facilities and other services.

The activity in question can be done with different methods: e-mail, sms, instant messaging applications, ordinary mail, telephone operator, etc..

In this case, the legal basis for the processing will be your prior, free and express consent.

The user will have the opportunity to give his consent at the bottom of the information specifications issued from time to time for access to each service of the site or by making it subscribed in the original or in electronic format.

You may modify and/or revoke the consent and authorization given to carry out the activity of commercial marketing and of newsletter by writing to the contact details given in this information. You may also withdraw your consent by exercising the option “opt-out” at the bottom of every newsletter by clicking on the “deleted” sign.

However, under no circumstances may the revocation of consent affect the lawfulness of the processing based on the consent given prior to the revocation.

e. Purposes of profiling.

The personal data that you provide through the various services of the website, with the exception of data that can be attributed to the definition of “special categories of personal data” (Article 9 of the Regulation), may be processed –only with Your prior, free and express consent– for analysis of your travel preferences and market research, in order to improve the services offered and the commercial information presented to you by FV, making it more in line with your interests.

This activity may also be carried out through the administration of satisfaction questionnaires and/or the use of cookies used when browsing our websites and applications for mobile devices.

In this case, the legal basis for the processing will be your prior, free and express consent.

You may modify and / or withdraw your consent and authorization for the profiling activity by writing to the contact details provided in this policy.

f. Marketing of third parties

The personal data you provide through the various services of the site are not communicated and / or transferred by FV to its commercial partner for purposes of marketing.

Application for mobile devices

More specifically, relative to and from your mobile device we collect:

the model;
the current operating system and its version;
information on connection modalities (e.g. operator, type of network, etc.);
the settings selected and/or enabled (e.g. Wi-Fi, GPS, etc.);
certain usage data (e.g. access dates and times, functions used, downloaded data and files, etc.);
any other technical information necessary for the proper functioning of the application (e.g. version of the application installed).

You will always be asked for your specific permission to enable location-based services via GPS, Wi-Fi, Bluetooth or other signals.

Authorization to localization is optional and can be provided either at the time of downloading the application or at a later time; in the absence of authorization, you will still be able to download and use the application, but you will not be able to use the location-based services in the application.

To disable the location feature by the application after you have given your permission, simply change the settings from your mobile device.

However, under no circumstances may the revocation of consent affect the lawfulness of the processing based on the consent given prior to the revocation.

For all other personal data that may be communicated via the mobile application, the provisions of this policy apply.

Navigation data and cookies

The computer systems and software procedures responsible for the operation of the site acquire some personal data during their normal operation, the transmission of which is implicit in the use of internet communication protocols.

This is information (e.g. IP address, domain names of the computers used, etc.) which is not collected in order to be associated with identified interests, but which by its very nature could, through processing and association with data held by third parties, allow the identification of an individual: these data are used to obtain anonymous statistical information on the use of the website and to check its proper functioning and are deleted immediately after processing. The data in question could also be used to ascertain liability in the event of hypothetical computer crimes against the site: except for this eventuality, the data on the site does not persist for more than 15 days.

For cookies please refer to the appropriate section cookies policy on the site.

Methods of treatment

The processing of data will be carried out with the help of paper, telematic and informatical tools.

The processing will always be based on the principles of fairness, lawfulness and transparency and the protection of your rights and your privacy.

The data will be processed in such a way as to minimise the risks of destruction, loss, unauthorised access or unauthorised processing or processing not in accordance with the purposes for which it was collected.

Categories of recipients of personal data

Your data will not be disseminated.

Your data may be made accessible or communicated, exclusively for the purposes referred to in this information, to the following categories of subjects:

FV’s internal staff, as data processors and/or controllers;
suppliers of tourism services included in packages sold or providing related services or individual services purchased from FV;
suppliers and third parties, also in non-EU countries, for the execution of the travel reservation (hotels, airlines, sales operations area, back office, charter flights and distribution lines, assistance, administration);
external controllers and authorised data processors in charge of the management of the travel practice who are regularly instructed and trained on the processing of personal data;
insurance and financial companies providing cover and benefits ancillary to and connected with purchased tourist packages and services;
people, companies, associations or professional studios providing assistance and consultancy services or activities for the benefit of FV or for the protection of their rights (e.g. accountants, lawyers, tax consultants, auditors, auditing or due diligence consultants;
third parties in charge of the service of maintenance/development of our IT system for the time required for the execution of the service;
third parties providing marketing and analytical services or consulting to FV;
third parties whose right to access your data is recognized by provisions of law and secondary legislation or by provisions issued by Authorities authorized 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 to the European Union, always for the purposes indicated above.

In the event of data transfer to countries outside the European Union, FV will verify in advance that the rules applicable to the processing of data are complied with and that guarantees are in place to maintain an adequate level of protection of natural persons, based on the assessments made by the Commission of the European Union (Article 45 of the Regulation) or, alternatively, that the recipient has undertaken to protect data by offering an adequate level of protection comparable to that provided by the GDPR (Article 46 of the Regulation).

Preservation of personal data

Your personal data will be kept by the Company for a period not exceeding that necessary to achieve the purposes for which they were collected and subsequently processed.

Your personal data and your data attributable to the definition of “special categories of personal data” will be kept for the period provided for by the legislation in force and / or for the time necessary to assert a right of the Data Controller in court. Where you have not given your consent to collect and process your personal data also for marketing purposes and/or profiling, at the end of this period will be automatically deleted or made permanently anonymous.

We remind you that the consent given to the processing of personal data for marketing commercial purpose may be revoked at any time according to the methods indicated in this policy.

Where, on the other hand, you have given your consent to process your personal data also for profiling purposes, they will be processed for this purpose for a maximum period of five years at the end of which they will be automatically deleted or made permanently anonymous.

Data Controller and Data Protection Officer

Owner of the processing of personal data is FRIGERIO VIAGGI S.r.l., C.F. 07215280152 e P.IVA. 00851420968, with registered office in (20833) Giussano (MB) Via Ambrogio Viganò n. 5.

For the purposes of data processing, FV has appointed a Data Protection Officer whose contact details, for the purpose of exercising the rights arising from the legal provisions regarding the processing of personal data, are as follows:

e-mail: dpo@frigerioviaggi.com;
ordinary postal address: Frigerio Viaggi S.r.l., via Ambrogio Viganò n. 5, 20833 Giussano (MB)

Rights of the data subject

At any time, pursuant to art. 15-22 of the GDPR You have the right, also in relation to profiling activity, to:

ask the holder:
access to your personal data and information relating to them;
rectification of inaccurate data or completion of incomplete data;
the deletion of personal data concerning you (if one of the conditions set out in Article 17, paragraph 1 of the GDPR occurs and subject to the exceptions set out in paragraph 3 of the same Article);
the restriction of the processing of your personal data (in one of the cases referred to in Article 18, paragraph 1, of the GDPR);
request and obtain from the data controller – in cases where the legal basis for the processing is the contract or consent, and the same is carried out by automated means – your personal data in a structured and machine-readable format, also for the purpose of communicating these data to another data controller (so-called right to personal data portability);
object at any time to the processing of your personal data to the recourse of special situations concerning you (Art. 21 GDPR);
withdraw your consent at any time, unless 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); however, the processing based on consent and carried out prior to its withdrawal remains lawful;
submit a complaint to the Data Protection Authority