Rome and Italy PRIVACY AND COOKIES POLICY (last modified on 25/05/2018)
This Privacy and Cookies Policy (the “Policy“) refers to the websites, www.romeanditalygroup.com and www.romeanditaly.com. The Website are operated by Rome and Italy Group (“we“, “our” or “Rome and Italy“), whose principal place of business is at Gist Travel di Rome and Italy s.r.l.
Address: Via Giuseppe Veronese 50, 00146, Rome – Call us: +39 06 44258441 Email: firstname.lastname@example.org Partita IVA: 09466991008
This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and applies to all of your personal data irrespective of the medium or method by which we obtained/received your personal data.
In this Policy, the term “personal data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).
Please read the following carefully. Entering into this Website and providing your consent to our use of your personal data in accordance with the terms of this Policy indicates that the user has reviewed this Policy and has agreed to be bound by it as well as our Ts&Cs and Data Processing Terms. You will be required to expressly accept and consent to this Policy before we process your personal data. If you do not agree to these terms you must leave the Website immediately. We will keep a record of your consent in this regard. If you no longer consent to our processing of your personal data, you may request that we cease such processing by emailing email@example.com
WHAT INFORMATION DO WE COLLECT?
We fully respect your right to privacy in relation to your interactions with the Website and endeavor to guarantee to be transparent in our dealings with you as to what information we will collect and how we will use your information. [Also, we only collect and use individual user details where we have legitimate business reasons. Information in relation to personal data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commissioner (“DPC”).
We will handle your personal data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Data Protection Acts 1988 and 2003 and Directive 95/46/EC, any other applicable law or regulation relating to the processing of personal data and to privacy (including the E-Privacy Directive), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and laws implementing or supplementing the GDPR).
We only collect and use individual user details where we have your consent to do so, or it is necessary for the performance of a contract between us and you, or it is necessary for our legitimate interests and where we are legally entitled to do so under Data Protection Legislation. Where you have provided your consent to our collection and use of your personal data, you are entitled to withdraw such consent by notice to us.
HOW DO WE COLLECT INFORMATION FROM YOU?
We collect IP addresses from visitors to our Website (an IP address is a number that can uniquely identify a specific computer or other network device on the internet). This allows us to identify the location of users, to block disruptive use and to establish the number of visits from different countries. We analyze this data for trend and statistics reasons, such as which parts of our Website users are visiting and how long they spend there. [We may personalize the contents based upon the location of users].
A cookie is a small text file that is place d on your hard disk by a web server which enables a website and/or mobile app to recognize repeat users, facilitate the user’s ongoing access to and use of a website and/or the mobile app and allows the website and/or mobile app to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising.
Certain cookies are necessary in order for you to use our Websites. These cookies are either ‘in-session’, which expire when you leave the Website, or kept for a short duration of up to 1 week. These cookies do not contain any personal data.
You should also be aware that there are cookies which are found in other companies’ internet tools which we are using to enhance the Website. You may see ‘social buttons’ during your use of the Website, including but not limited to Twitter, YouTube, and Facebook which enable you to share or bookmark certain web pages. These websites have their own cookies, which are controlled by them.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
HOW DO WE USE THE INFORMATION WE COLLECT?
We collect different types of information about our users for the following reasons:
• to personalize the way our content is presented to you and to ensure that content from our Website is presented in the most effective manner for you and for your computer/device;
• to help us to monitor and improve the services we offer, including the Website. As part of this, we may use and disclose information in aggregate (so that no individuals are identified);
• to carry out any legal obligations arising from your interaction with the Website; and
• to allow you to participate in interactive features of our service, when you choose to do so.
With your consent, we may also use your data to provide you with information about goods and services from third parties which may be of interest to you. By providing your consent, you agree to be contacted by such third parties.
The personal data that we collect from you may be transferred to, and stored by Rome and Italy group. It may also be processed by staff of Rome and Italy group. By submitting your personal data, you agree to this transfer, storing or processing of your personal data by Rome and Italy group for the purposes set out in this Policy.
ARE THERE CASES WHERE WE MAY USE YOUR INFORMATION TO CONTACT YOU?
We may contact you:
- to provide you with information about our services, activities or online content. You should only receive e-newsletters or similar correspondence and updates from romeanditaly.com if you have agreed to in response to any contact you have made with us, e.g. on e-newsletter subscription forms, by email or via the ‘How to contact us’ facility. It will be made clear to you where you have these choices, for example, by providing tick boxes on the checkout page for you to decide whether you wish to receive e-newsletters, or clearly stating on the e-newsletter your subscription preference; and
• to invite you to participate in surveys about our services (participation is always voluntary).
Where we wish to use your personal information in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed in this Policy.
WHAT RIGHTS DO YOU HAVE?
As a data subject, you have the following rights under the Data Protection Legislation:
• the right of access to personal data relating to you;
• the right to correct any mistakes in your personal data;
• the right to ask us to stop contacting you with direct marketing;
• rights in relation to automated decision taking;
• the right to restrict or prevent your personal data being processed;
• the right to have your personal data ported to another data controller;
• the right to erasure; and
• the right to complain to the DPC if you believe we have not handled your personal data in accordance with the Data Protection Legislation.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see ‘How to contact us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Right to access to personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
• a summary of such personal data and the categories of personal data held;
• details of the purpose for which it is being or is to be processed;
• details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
• details of the period for which it is held (or the criteria we use to determine how long it is held);
• details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
• any information available about the source of that data;
• whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
• where your personal data are transferred out of the EEA, what safeguards are in place.
Requests for your personal data must be made to us (see ‘How to contact us’ below) specifying what personal data you need access to, and a copy will be retained on your personnel file. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal date requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your personal data or correct any mistakes in your personal data
You can require us to correct any mistakes in your personal data which we hold free of charge. If you would like to do this, please:
• email, call or write to us (see ‘How can you contact us’ below);
• let us have enough information to identify you (e.g. name, registration details); and
• let us know the information that is incorrect and what it should be replaced with.
If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please email, call or write to us (see ‘How can you contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 5 days for this to take place.
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’
Right to restrict or prevent processing of personal data
In accordance with Data Processing Legislation, you may request that we stop processing your personal data temporarily if:
• you do not think that your data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
• the processing is unlawful but you do not want us to erase your data;
• we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
• you have objected to processing because you believe that your interests should override our legitimate interests.
If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:
• you consent to such processing;
• the processing is necessary for the exercise or defence of legal claims;
• the processing is necessary for the protection of the rights of other individuals or legal persons; or
• the processing is necessary for public interest reasons.
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.
The right to data portability also only applies where:
• the processing is based on your consent or for the performance of a contract; and
• the processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us to erase your personal data where:
• you do not believe that we need your personal data in order to process it for the purposes set out in this Policy;
• if you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
• you object to our processing and we do not have any legitimate interests that mean we can continue to process your personal data;
• your data has been processed unlawfully or have not been erased when it should have been; or
• the personal data have to be erased to comply with law.
We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.
Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC
If you do not think that we have processed your personal data in accordance with this Policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the DPC website at https://www.dataprotection.ie
If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the Website or otherwise engage in any disruptive behavior on any Rome and Italy group, we may remove such content.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
DO WE PROTECT YOUR PERSONAL INFORMATION?
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to personal data to employees, contractors and agents who need to know such personal data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, the Website contains hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks that are presented by the processing of your personal data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Website and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. We are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the Website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.
We will notify serious data breaches to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A personal data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your personal data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
• we have implemented appropriate technical and organizational measures that render the personal data unintelligible to anyone not authorized to access it, such as encryption; or
• we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialize; or
• it would involve disproportionate effort, in which case we may make a public communication instead.
WHO WE SHARE DATA WITH
We may disclose your personal information to any company or other corporate entity under the control and direction of Italy Rome Tour. As stated above, with your consent, we may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these. We reserve the right to access and disclose personal data in compliance with Data Protection Legislation.
We may also use service providers to help us run the Website or services available on the Website. Any third parties who access your data in the course of providing services on our behalf are subject to strict contractual restrictions to ensure that your data is protected, in compliance with Data Protection Legislation.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. The safeguards in place with regard to the transfer of your personal data outside of the EEA are the entry by us into appropriate contracts with all transferees of such personal data.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
RETENTION OF PERSONAL DATA
Any information that you provide to us will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance, and our obligations under Data Protection Legislation.
In general, your personal data will be retained by us for only as long as is necessary for the processing set out in this Policy.
We may collect financial information such as credit card information when a payment is made via the Website. We do not share this information with anyone outside of Rome and Italy Group, other than other companies and individuals we employ to perform functions on our behalf such as sending mail and processing payments and this information will not be kept for longer than necessary for providing the services. Any such third party service providers will be subject to contractual provisions which safeguard the security of your personal data. Any such company or individual will have access to personal data needed to perform these functions but may not use such personal data for any other purpose.
If you choose not to progress with the order or your payment method fails, we may still hold the details placed with that order.
CHANGES TO THE POLICY
This Policy may be updated from time to time, so you may wish to check it each time you submit personal information to the Website. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use this Website to submit personal information. If material changes are made to the Policy, we will notify you by placing a prominent notice on the Website. We will not process your personal data in a manner not contemplated by this Policy without your consent.
LEGAL INFORMATION AND HOW TO CONTACT US
The data controller (as defined in Data Protection Legislation) for the Website and services provided through the Website is Rome and Italy, located at Via Giuseppe Veronese 50, 00146, Rome Italy. If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing to Rome and Italy, located at Via Giuseppe Veronese 50, 00146, or by email to firstname.lastname@example.org
This Application collects some Personal Data from its Users.
Data Controller and Owner
Via Giuseppe Veronese 50, 00146, Roma Phone: +39 06 44258441 Email: email@example.com
Owner contact email: firstname.lastname@example.org
Types of Data collected
Mode and place of processing the Data
Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.
The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics. The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics with anonymized IP (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US. Personal Data collected: Cookies and Usage Data.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Definitions and legal references
Personal Data (or Data)
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.
The legal or natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The hardware or software tool by which the Personal Data of the User is collected.
Small piece of data stored in the User’s device.
Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.