DESTINATION ITALIA S.p.A. – BOOKINGS

PERSONAL DATA PROCESSING POLICY

(pursuant to Article 13 of Regulation (EU) 2016/679)

Regulation (EU) 2016/679 (GDPR) establishes the right to protection of natural persons with regard to the processing of their data. In compliance with this legislation, with reference to the personal data you provide to us, Royal Travel Jet Sardegna S.r.l. informs you, pursuant to Articles 12 and 13 GDPR, that such processing will be based on principles of lawfulness, fairness, transparency and protection of their confidentiality and of your rights as laid down in Article 5 GDPR.

The “Data Controller” is Royal Travel Jet Sardegna S.r.l., with registered office in Cagliari, Via San Tommaso d’Aquino n. 18, TIN/VAT: 02834280923.

You can contact the Controller at any time using the following contact methods:

• Telephone: +39.070.51.34.89
• Fax: +39.070.554.964
• Letter/Registered letter: Via San Tommaso d’Acquino n. 18 a - Cagliari Postcode 09134
• Email: booking@charmingitaly.com

CONTACT DETAILS OF THE DATA PROTECTION OFFICER

In accordance with Article 37 GDPR, the “Controller” has appointed a Data Protection Officer (DPO).

DPO contact information: dpo@charmingitaly.com

PURPOSES OF THE PROCESSING FOR WHICH THE PERSONAL DATA ARE INTENDED AND THE LEGAL BASIS OF THE PROCESSING;

The data entered by filling out the relevant fields will be processed exclusively for specified, explicit and legitimate purposes and not further processed in a way that is incompatible with those purposes. In particular, Royal Travel Jet Sardegna S.r.l. will process the personal data you provide only to process your subscription to our newsletter and for the following purposes:

• Sending targeted advertisements/newsletters
• sending commercial information and offers, also from partner companies, matching your consumer preferences and habits, recorded by tracking your navigation on our website pages and accesses made by selecting offers sent by email;
• sending advertising and information materials and/or commercial communications, also interactive;

     In order to send you targeted advertisements/newsletters your data may be communicated to third companies, even outside the territory of the European Union.

For the processing of your personal data for the purposes stated in point 2, your consent is required. You may give it by checking the appropriate box (“I have read the privacy policy [link]. I wish to receive targeted information and offers from Charming”), on the webpage containing the online form.

You may withdraw your consent at any time by contacting the Controller at the above addresses, or by cancelling the newsletter service in the manner set out above. However, the withdrawal of consent shall not affect the lawfulness of the processing based on consent before its withdrawal.

HOW YOUR PERSONAL DATA WILL BE PROCESSED AND PERIOD FOR WHICH IT WILL BE STORED

Your data will be processed in paper format or using IT procedures by duly authorised in-house staff. Such staff members will be given access to your personal information to the extent and insofar as it is necessary for performance of the data processing activities concerning you. Your data, especially those belonging to special categories, are processed separately from others’ data also through pseudonymisation or aggregation methods to prevent your easy and immediate identification.

In addition, to ensure its confidentiality and integrity, the personal data you provide to us will be processed in a manner that ensures its appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.

Royal Travel Jet Sardegna S.r.l. periodically reviews the tools used to process the data and the security measures put in place, and regularly updates such tools and measures; we check, also through duly authorised parties, that no personal data whose processing is not required or is no longer necessary is collected, processed, stored or retained; we check that the stored data is complete and accurate and is used only for its intended processing.

Royal Travel Jet Sardegna S.r.l. warrants that any data which, also as a result of checks, is found to be excessive, irrelevant or unnecessary, will not be used for any purpose other than for possible filing, in accordance with the law, of the act or document containing such data.

The data requested from you will be kept in a format permitting your identification for the minimum period required for achievement of the intended purposes, after which your data will be permanently and irreversibly erased or anonymised.

In particular, for achievement of the above-mentioned aims, your personal data will be kept for no more than 12 months, or until you cancel the newsletter service;

CANCELLING YOUR NEWSLETTER SUBSCRIPTION

If you would like to stop receiving targeted advertisements/newsletters from Royal Travel Jet Sardegna S.r.l., you can do so by sending us an email request and following the procedure described in our reply.

If you also wish to be permanently deleted from our archives, please send us a request at booking@charmingitaly.com

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE PERSONAL DATA

All your data will be kept at the registered office of the Controller and may be disclosed to other recipients for compliance with legal obligations under the applicable laws, while ensuring protection of all your rights.

Your data may be processed by duly authorised and trained mandated Parties, entrusted with the activities necessary to achieve the purposes.

Where necessary, for the stated purposes, some processing of your personal data may be also performed by third parties to which Royal Travel Jet Sardegna S.r.l. may entrust certain activities (or part thereof) necessary for provision of services you require. In this case, said third parties will operate as Processors. They may include: credit recovery firms, third-party billing firms, accounting, tax and other advisory firms, factoring companies, suppliers of IT services for administrative and booking management, content providers and CRM firms.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANISATIONS

To achieve the above-mentioned purposes, the Controller may disclose your personal data to a third country (non-EU), namely to HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA, Attn: Privacy. Such company shall act as Processor, processing your data in order to send you targeted newsletters on the basis of your choices and browsing experience.

The personal data will be transferred in accordance with the “EU-US Privacy Shield” agreements, on the basis of the authorisation by the Personal Data Protection Authority (Decision No 436 of 27 October 2016) and of European Commission Implementing Decision (EU) 2016/1250 of 12 July 2016. To obtain a copy of such data, you can contact the Controller or HubSpot, Inc., attn: Ms. Paulina Zgorzelska (Director of Risk and Compliance), HubSpot, Inc. HubSpot Headquarters (Cambridge, MA) 25 First St., 2nd floor, Cambridge, Massachusetts 02141 – e-mail address: pzgorzelska@hubspot.com, Telephone (857) 829-5884.

OPTIONAL NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL TO PROVIDE DATA

Provision of your data for the above-mentioned purposes, subject to your express consent, is optional but necessary for subscribing for our newsletter and obtaining the requested services. Should you fail to provide any of the information marked as required, provide incorrect information or fail to give your consent, we will be unable to provide you with the services you requested and send you the newsletters. If, on the other hand, you do not provide any of the optional information, we will still be able to provide you with the requested service.

You should notify the Controller of any change to the data you provided, to ensure proper provision of the requested services, without prejudice to your right to rectification.

PROFILING ACTIVITIES

With regard to user profiling and the sending of targeted advertisements/newsletters, Royal Travel Jet Sardegna S.r.l. Wishes to inform you about the logics we use and the importance and expected consequences of this processing for you. In particular, when you register for our newsletter by filling in our online form or access our website by clicking an email message or a newsletter you received, website https://www.charmingsardinia.com, using cookies released by Hubspot Inc.’s marketing automation software, will track your interactions with the website and the information supplied by the browser, such as geographical area, IP address and repeated visits. In all other cases, when you don’t access by clicking on the newsletter or you don’t fill in the online form, the data will be processed in exclusively anonymous form.

RIGHTS OF THE DATA SUBJECT

In your capacity as data subject, you may exercise at any time your right of access (Article 15 GDPR), right to rectification (Article 16 GDPR), right to erasure, (Article 17 GDPR), right to restriction of processing (Article 18 GDPR), right to data portability (Article 20 GDPR) and your right to object (Article 21 GDPR) in the manner set out in the same articles, to which you are referred.

In particular, you, as data subject, have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including profiling.

To exercise said rights, you may contact the Controller at the following email address: booking@charmingitaly.com. For any further information and communication on your data, you may contact the Controller using the above contacts.

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes Regulation (EU) 2016/679.

RIGHTS OF THE DATA SUBJECT

Article 15 GDPR - Right of access by the data subject

1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
2. a) the purposes of the processing;
3. b) the categories of personal data concerned;
4. c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
5. d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
6. e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
7. f) the right to lodge a complaint with a supervisory authority;
8. g) where the personal data are not collected from the data subject, any available information as to their source;
9. h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
10. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
11. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
12. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.”

Article 16 GDPR - Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.”

Article 17 GDPR - Right to erasure (‘right to be forgotten’)

1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
2. a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
3. b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
4. c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
5. d) the personal data have been unlawfully processed;
6. e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
7. f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
8. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
9. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
10. a) for exercising the right of freedom of expression and information;
11. b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
12. c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
13. d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
14. e) for the establishment, exercise or defence of legal claims.

Article 18 GDPR - Right to restriction of processing

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
2. a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
3. b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
4. c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
5. d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
6. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
7. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 20 GDPR - Right to data portability

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
2. a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
3. b) the processing is carried out by automated means.
4. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
5. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
6. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21 GDPR - Right to object

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22 GDPR - Automated individual decision-making, including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
2. Paragraph 1 shall not apply if the decision:
3. a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;
4. b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
5. c) is based on the data subject’s explicit consent.
6. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
7. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.