VIAGGI DELL’ELEFANTE S.R.L., with registered office at via d’Ascanio 8, 00186 Rome, in its capacity as data controller (hereinafter the “Controller”), informs you, pursuant to EU Regulation 679/2016 (“GDPR”) and the applicable personal data protection legislation, including national provisions (the “Privacy Law”), that your data will be processed in the following manner and for the following purposes:
The Controller processes personal, identifying and non-sensitive data (by way of example but not limited to: first name, last name, address, telephone number, email, etc. – hereinafter “personal data” or “data”) provided by you when registering on the website viaggidellelefante.it - blu.travel - ecoluxury.com - ecoluxurytravel.it - (hereinafter the “Website”), when subscribing to the Controller’s newsletter, when placing orders and/or purchasing products or services online through the Website, when completing and submitting a contact form to the Controller, or in connection with any request made by you to the Controller.
2. Purposes and Legal Basis of the Processing
Your Data are processed, without your prior consent, for the following purposes:
A. Service purposes:
a) performance of a contract or pre-contractual obligations:
- to fulfill pre-contractual, contractual and tax obligations arising from existing relationships with you;
- to allow you to register on the Website;
- to process and manage orders received and/or purchases made online;
- to allow you to use any services you may have requested;
- to process a contact request;
- to allow you to apply online and process your application;
- to manage and maintain the Website;
- to comply with obligations established by law, regulation, EU legislation or by an order of an Authority;
- to prevent or detect fraudulent activities or abuses harmful to the Website;
- to exercise the Controller’s rights, for example the right of defense in court;
- to prevent or detect fraudulent activities or abuses harmful to the Website.
b) pursuit of the legitimate interest of the Controller, in particular:
- to analyze cookies – as indicated in the Cookie Policy – resulting from your use of the Website;
- to prevent or detect fraudulent activities or abuses harmful to the Website;
- to comply with obligations established by law, regulation, EU legislation or by an order of an Authority;
- to exercise the Controller’s rights, for example the right of defense in court;
- to send you commercial communications relating to services and products of the Controller similar to those you have already used, if you are already our customer. You may object at any time.
B. Only with your prior consent, for Marketing purposes:
to send you newsletters, commercial communications and/or advertising material by email regarding products or services of the Controller and its affiliated companies.
Methods of Processing
Your Data are processed – in paper form (archives) and electronically (website and management systems Molecole srl and Office 365) – through operations of collection, registration, updating, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, deletion and destruction of the Data.
Data Retention
The Controller processes the Data for the time necessary to respond to your request and fulfill the above-mentioned purposes, and in any case no longer than 5 years from collection for contact data and no longer than 6 months from collection for browsing data. Data processed for Marketing purposes will be retained for no longer than 2 years from their collection.
Access to Data
Your Data may be accessed for the above purposes by:
- employees and/or collaborators of the Controller, in their capacity as persons authorized to process data and/or internal data processors and/or system administrators;
- third-party companies or other entities (for example, website providers, e-payment service providers, suppliers, technicians responsible for hardware and software maintenance, credit institutions, professional firms, travel agencies, etc.) that carry out outsourced activities on behalf of the Controller, in their capacity as external data processors.
Communication of Data
Your Data may be communicated, even without your consent, for the above purposes to supervisory bodies, law enforcement authorities or judicial authorities who will process them, upon their express request, as independent data controllers for institutional purposes and/or pursuant to law during investigations and checks. Your Data may also be communicated to third parties (for example, partners, freelancers, agents, etc.), as independent data controllers, for the performance of activities instrumental to the above purposes.
Data Transfer
The Data are not disclosed nor will they be transferred to non-EU countries. The management and storage of personal data will take place on servers located within the European Union. It is understood that, should it become necessary, the Controller may move the servers to Italy and/or the European Union and/or non-EU countries. In such case, in order to ensure an adequate level of protection of Personal Data, the transfer of data to non-EU countries will take place pursuant to adequacy decisions approved by the European Commission or through the adoption by the Controller of Standard Contractual Clauses approved by the European Commission.
Provision of Data
The provision of Data is mandatory for Service purposes. If you decide not to provide the Data, we will not be able to process your request.
The provision of Data for Marketing purposes is optional. You may therefore decide not to provide the Data or subsequently deny the possibility of processing Data already provided: in this case, you will not receive personalized commercial communications about the Controller’s products, but you will still be entitled to use the Website services.
Rights of the Data Subject
As data subjects, you are informed that you have the right to:
obtain confirmation of the existence or otherwise of your Personal Data, even if not yet recorded, and to have such Data communicated to you in an intelligible form;
obtain indication and, where appropriate, a copy of: a) the origin and category of the Personal Data; b) the logic applied in case of processing carried out with the aid of electronic instruments; c) the purposes and methods of processing; d) the identification details of the Controller and processors; e) the subjects or categories of subjects to whom the Personal Data may be communicated or who may become aware of them, in particular if recipients are located in third countries or international organizations; f) where possible, the retention period of the Data or the criteria used to determine that period; g) the existence of an automated decision-making process and, in such case, the logic used, the significance and the expected consequences for the data subject; h) the existence of adequate safeguards in case of transfer of Data to a non-EU country or international organization;
obtain, without undue delay, the updating and rectification of inaccurate Data or, where interested, the completion of incomplete Data;
obtain the deletion, anonymization or blocking of Data: a) processed unlawfully; b) no longer necessary in relation to the purposes for which they were collected or subsequently processed; c) in case of withdrawal of consent on which the processing is based and if there is no other legal ground; d) if you have objected to the processing and there are no overriding legitimate grounds to continue the processing; e) in case of compliance with a legal obligation; f) in the case of Data relating to minors. The Controller may refuse deletion only in the event of: a) exercise of the right to freedom of expression and information; b) compliance with a legal obligation, performance of a task carried out in the public interest or exercise of official authority; c) public health reasons; d) archiving in the public interest, scientific or historical research or statistical purposes; e) establishment, exercise or defense of legal claims;
obtain restriction of processing in the event of: a) contesting the accuracy of the Personal Data; b) unlawful processing by the Controller to prevent deletion; c) exercise of your rights in court; d) verification of the possible prevalence of the Controller’s legitimate grounds over those of the data subject;
receive, where the processing is carried out by automated means, without hindrance and in a structured, commonly used and machine-readable format, the Personal Data concerning you in order to transmit them to another controller or – where technically feasible – obtain direct transmission by the Controller to another controller;
object, in whole or in part: a) on legitimate grounds, to the processing of Personal Data concerning you, even if relevant to the purpose of collection; b) to the processing of Personal Data concerning you for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator by email and/or through traditional marketing methods by telephone and/or paper mail;
lodge a complaint with the Data Protection Authority.
In the above cases, where necessary, the Controller will inform the third parties to whom your Personal Data are communicated of any exercise of your rights, except in specific cases (e.g., where such fulfillment proves impossible or involves a manifestly disproportionate effort compared to the protected right).
How to Exercise Your Rights
You may exercise your rights at any time by:
sending a registered letter with return receipt to the Controller’s address;
sending an email to info@viaggidellelefante.it;
calling +39 06 60513000.
Controller and Data Processors
The Data Controller is:
Viaggi Dell’Elefante SRL, via d’Ascanio 8, 00186 Rome.
The internal Data Processor is:
Enrico Ducrot
The appointed Data Protection Officer is: Angelo Adamo.
The updated list of internal and external data processors is kept at the Controller’s registered office.
Rome, [24/05/2018]
VIAGGI DELL’ELEFANTE S.R.L.
The Privacy Authority has implemented a European directive requiring website administrators to display a banner informing visitors about the site’s cookie policy and to make acceptance a condition for continuing navigation.
If you need further information or have any questions about this site’s privacy policy, please contact us by email at info@viaggidellelefante.it
This page describes how personal information is received, collected and used by www.viaggidellelefante.it. For this purpose, cookies are used, i.e., text files to facilitate user navigation.
COOKIE LAW
1) What are cookies?
Cookies are text files that visited websites send to the user’s browser, where they are stored and then retransmitted to the site on the next visit.
2) What are cookies used for?
Cookies may be used to monitor sessions, authenticate a user so that they can access a site without entering their username and password each time, and to store their preferences.
3) What are technical cookies?
Technical cookies are used for navigation and to facilitate access to and use of the site by the user. Technical cookies are essential, for example, to access Google or Facebook without logging in at every session. They are also essential in very sensitive operations such as home banking or payments by credit card or other systems.
4) Are Analytics cookies technical cookies?
In other words, are cookies placed in the browser and retransmitted through Google Analytics or through Blogger’s Statistics service and Facebook or similar services technical cookies? The Authority has stated that these cookies may be considered technical only if “used for site optimization purposes directly by the site owner, who may collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules regarding information and consent applicable to technical cookies apply to analytics cookies.”
5) What are profiling cookies?
These are cookies used to track user navigation to create profiles of their tastes, preferences, interests and even searches. You have certainly seen advertising banners related to a product you previously searched for online. The reason lies precisely in the profiling of your interests, and servers appropriately directed by cookies have shown you advertisements deemed most relevant.
6) Is user consent required for the installation of cookies on their device?
Consent is not required for the installation of technical cookies, whereas profiling cookies may be installed on the user’s device only after the user has given consent and has been informed in a simplified manner.
7) How can webmasters request consent?
The Privacy Authority has established that when a user accesses a website, a banner must appear containing a short notice, a request for consent and a link to a more detailed notice like the one visible on this page regarding profiling cookies and their use on the site.
8) How must the banner be structured?
The banner must be designed to partially obscure the page content and specify that the site uses profiling cookies, including those of third parties. The banner must be removable only through an active action by the user, such as a click.
9) What information must the banner contain?
The banner must contain the short notice, the link to the extended notice and the button to give consent to the use of profiling cookies.
10) How should consent to the use of cookies be documented?
A technical cookie may be used to record the user’s consent so that they do not have to express consent again on a subsequent visit to the site.
11) Can consent to the use of cookies only be obtained through the banner?
No. Other systems may be used provided they meet the same requirements. The use of the banner is not necessary for sites that use only technical cookies.
12) What should be included in the extended information page?
The characteristics of cookies installed, including those of third parties, must be illustrated. Users must also be informed how to navigate the site without their preferences being tracked, including by using incognito browsing and deleting individual cookies.
13) Who is required to notify the Authority about the use of profiling cookies?
The site owner has this obligation. If the site uses only third-party profiling cookies, the owner is not required to notify the Authority but must indicate which third-party cookies are used and provide links to their privacy policies.
14) When did this regulation enter into force?
The Authority granted one year to comply and the deadline was June 2, 2015.
COOKIES USED ON THIS SITE
Log files: Like many other websites, this site uses log files that record the history of operations as they are performed. The information contained in log files includes IP addresses, browser type, Internet Service Provider (ISP), date, time, entry and exit pages and number of clicks. All this is used to analyze trends, administer the site, monitor user movement within the site and collect demographic data. IP addresses and other information are not linked in any way to the user’s identity and are considered technical cookies.
THIRD-PARTY COOKIES PRESENT ON THE SITE
Cookies: www.viaggidellelefante.it uses cookies to store information about visitors’ preferences and the pages visited by the user and to personalize web page content based on the type of browser used and other information that the browser sends.
Third-party servers or advertising networks may access this site and use such technology to send advertisements to your browser through www.viaggidellelefante.it. By detecting your IP address, they display advertisements most relevant to your interests. Similar technologies (such as cookies, web beacons and JavaScript) may be used by third-party advertising networks to measure the effectiveness of their advertising messages and to personalize their content.
The site www.viaggidellelefante.it and its administrator have no control over the cookies used by third parties. Therefore, to learn more, please consult the privacy policies of such third parties as well as the options to disable the collection of this information. The site administrator cannot control advertisers’ activities. You can disable cookies directly from your browser. The site www.viaggidellelefante.it does not use its own profiling cookies; those present are exclusively controlled by third parties such as Google, Facebook or Twitter.
These provisions of the Privacy Authority are not only Italian but common to most European countries. You can learn about the rules of each jurisdiction by visiting the website Your Online Choices in your own language.
Categories of Cookies Used and How They Can Be Managed by the User
The types of cookies used can be classified into the following categories:
Essential website cookies (session and navigation)
These cookies are essential for proper navigation and use of the site’s features. These cookies do not collect personal information for marketing purposes, nor do they store visited sites. The use of these cookies (which are not stored persistently on the user’s device and are automatically deleted when the browser is closed) is strictly limited to the transmission of session identifiers (random numbers generated by the server) necessary to enable secure and efficient site browsing. This category of cookies cannot be disabled.
Source and how to block them (first-party cookies)
First-party functionality cookies
These cookies allow us to remember choices you make (such as username, language or geographic location) and provide enhanced, personalized features. The information collected by these cookies may be anonymized and does not track browsing activity on other websites. This category of cookies cannot be disabled.
Source and how to block them (first-party cookies)
Third-party analytics and advertising cookies
These cookies, including cache cookies, are set by Google Analytics and are used to collect information about how visitors use the site, including the number of visitors, referring sites and pages visited on our website. We use this information to compile reports and improve our website; for example, to identify any errors encountered by users and ensure immediate navigation to find what they are looking for. In general, these cookies remain on the visitor’s computer until deleted.
Similarly, AddThis, Facebook, Twitter, Google+, YouTube may use cookies useful for sharing content on social networks or for processing access statistics. Viaggi Dell’Elefante does not use these cookies for profiling purposes.
Facebook Connect allows users already registered with Facebook to authenticate on the site without entering login credentials used during registration. If voluntarily used by the user, Viaggi Dell’Elefante may adopt the Facebook Connect system and cookies to integrate the login with the user’s Facebook account. In addition to simplifying registration, Facebook Connect allows the website to extend certain social network features, making it easier to share content via Facebook.
Additionally, the Facebook Pixel cookie is installed, allowing Viaggi Dell’Elefante to monitor conversions occurring on its website as a result of advertisements run on Facebook. For example, if you wish to monitor subscriptions to a specific campaign advertised on Facebook, the cookie communicates to Facebook whenever a user has subscribed to a specific campaign on the Viaggi Dell’Elefante website. Facebook compares the conversion event with the group of people who were shown or clicked on the advertisement to provide Viaggi Dell’Elefante with information to understand the return on investment of its advertising expenditure. Viaggi Dell’Elefante does not use this cookie for profiling purposes but only for statistical purposes.
Hotjar allows visualization of which parts of the site are clicked most frequently; these statistical data – completely anonymous – are used to verify the effectiveness of the site design and possibly make changes to improve navigation experience.
The Google Adwords/Doubleclick conversion Pixel cookie is used by Viaggi Dell’Elefante to understand which keywords generate the highest number of clicks on Google and conversions into requested services (e.g., campaign subscriptions). This tool indicates what happened after users clicked on its Google ad, for example whether they subscribed to a campaign. Thanks to this information, Viaggi Dell’Elefante identifies the most effective keywords. Viaggi Dell’Elefante does not use this cookie for profiling purposes but only in aggregate form for statistical purposes.
Finally, third parties may use this information, combining it with other information already available to them for purposes other than strictly technical ones (functionality or session), subject to user consent. To learn more, access the privacy policy links of the individual third parties and manage your options through the links provided and/or by setting your browser as described below.
How to Control or Delete Cookies
By choosing to refuse cookies, the user may not be able to use all the site’s features.
You can block cookies by following the instructions provided by your browser (usually found in the “Help”, “Tools” or “Edit” menus). Disabling a cookie or category of cookies does not delete them from your browser. This operation must therefore be carried out directly in your browser.
If you wish to delete, disable or restore cookies on your computer, you may use the cookie configuration pages provided by third-party content providers or through your browser options.
Below is a list of instructions for managing cookies in the most common browsers:
If you use a mobile device, please refer to its instruction manual to learn how to manage cookies.
For further information on cookies, including how to view those set on your device, manage and delete them, visit www.allaboutcookies.org.
ANONYMOUS BROWSING
Browsing without the use of technical and profiling cookies is possible through what is known as incognito browsing, available in all major browsers.
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