Privacy Policies
This Privacy Policy is provided pursuant to art. 13 of the European Regulation n. 679/2016 and applies exclusively to all Data collected through the Website. This Privacy Policy is subject to updates that will be published promptly on the Website. This Privacy Policy, together with theTerms and conditions, any other documents referred to in it and the Cookie Policy, establish the basis on which the Personal Data of the interested party will be processed.
Data Controller
The Data Controller of the data collected from this website is Easy relax Travel Srl
Via Muzio Attendolo 5, 20141 Milan - VAT/VAT: IT12973460962, REA: MI: 2696356
email: support@easyrelaxtravel.com
Personal data
Personal Data means any information relating to an identified or identifiable natural person (Data Subject). An identifiable natural person is one who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, one or more characteristic elements of his identity physics.
Category of Personal Data processed
Among the Personal Data processed by this Website, independently or through third parties or because communicated by the interested party, there are Common Data such as:
- Cookies, Usage Data, login and account information, including username, password and unique user ID.
- Contact details including name, email, phone number.
- Depending on the Travel Reservation, home address, telephone number, payment details, date of birth, residence, name of persons traveling with the Data Subject and your travel preferences .
In case of purchase of the online check-in service, information on the passport or another document such as identity card and/or driving licence.
Personal Data Processing Methods
The Personal Data provided or acquired will be processed based on principles of correctness, lawfulness, transparency and protection of confidentiality in accordance with current regulations. The Data Controller processes the Users' Personal Data by adopting the appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data. The Processing is carried out using IT and/or telematic tools, with organizational methods and with logics strictly related to the purposes indicated.
Purpose of the Processing of Personal Data and Legal Basis
Personal Data can be collected independently by the Data Controller or through third parties. In this case, the computer systems and software procedures used to operate this Website acquire some Personal Data of the Users, of a technical-IT nature (e.g. the IP address, the type of browser used, the operating system, the name domain name and the addresses of websites from which access or exit was made, etc.), the transmission of which is inherent in the normal functioning of the internet. Such Data may be processed for the sole purpose of obtaining anonymous statistical information on the use of the site and/or to check its correct functioning and will be canceled immediately after processing.
The data that the interested party chooses to provide spontaneously will be processed in compliance with the conditions of lawfulness pursuant to art. 6 GDPR and will be processed to allow the Website to provide its services, as well as for the
purposes indicated below and will be kept for the time necessary to fulfill the aforementioned purposes.
The purposes of the treatment are:
1) Respond to requests and provide information
The Data will be processed in order to be contacted or to follow up on the specific requests addressed to the Data Controller by the Data Subject for communications of a nature relating to the Services and/or Contents of the same Data Controller, via e-mail messages or other communication tools such as telephone or messaging WhatsApp Business Snapshot.The data are also processed to provide the aCustomer support to share booking or user account details
Legal basis: this treatment isoptionaland based on the consent of the interested party, however the provision of data is necessary for the pursuit of the indicated purpose.
Data retention period: until revocation of consent by the interested party.
2) Site registration form
The Data will be processed in order to be registered on the Owner's website for the purchase of the Products of the same Owner.
Legal basis: this treatment isoptionaland based on the consent of the interested party, however the provision of data is necessary for the pursuit of the indicated purpose.
Data retention period: until revocation of consent by the interested party.
3) Information and pre-contractual obligations
The Data will be processed in order to be contacted or to follow up on the specific requests addressed to the Data Controller by the Data Subject for communications of an informative nature and/or for information regarding the purchase of the Services of the same Data Controller, via e-mail messages or filling in the Form contacts and other communication tools.
Legal basis: this treatment isoptionaland based on the consent of the interested party, however the provision of data is necessary for the pursuit of the indicated purpose.
Data retention period: until revocation of consent by the interested party.
4) Processing necessary under a contract
The Data will be processed in order to fulfill the obligations deriving from the contract stipulated between the interested party and the Data Controller for the sale of the Services on the Website, to contact the interested party in relation to the Contract and for the management of the same, for the management of requests for legal guarantees, assistance, requests for withdrawal, management and termination of the Contract itself
Legal basis: this treatment is necessary for the execution of the contract of which the interested party is a part, for the execution of pre-contractual measures or to fulfill a legal obligation to which the Data Controller is subject.
Data retention period: 10 (ten) years or different legal obligation.
5) Fulfillment of any obligations established by current laws
The Data will be processed to fulfill any type of obligation contemplated and provided for by current laws, regulations, related regulations, commercial uses and tax/fiscal matters, including also for the purposes established by the legislation on anti-money laundering Legislative Decree 231/ 2007 and subsequent amendments.
Legal basis: this treatment is necessary to fulfill a legal obligation to which the Data Controller is subject.
Data retention period: 10 (ten) years or different legal obligation.
6) Soft spam
The Data will be processed to allow the Data Controller to send the interested party commercial and promotional communications via e-mail concerning Products and/or Services similar to the Products/Services being sold without the need for the express and prior consent of the interested party, such as provided for by art. 130, 4 paragraph, Privacy Code as amended by Legislative Decree n.101 of 2018, and on condition that the interested party does not exercise the right to object.
Legal basis: this processing is based on the legitimate interest of the Data Controller pursuant to art. 6, letter. F and Recital n. 47 of the GDPR.
Data retention period: until objection by the interested party.
7) Newsletters
The Data will be processed for sending communications and promotional, commercial and advertising material or concerning initiatives and events of the Data Controller, via newsletter.
Legal basis: this treatment is based on the consent freely expressed by the interested party pursuant to art. 6, par. 1, lit. A of the GDPR.
Data retention period: until revocation of consent by the interested party through the appropriate tool at the bottom of the newsletter or by request to the Data Controller.
8) Direct marketing
The Data will be processed for the direct sale of Products/Services, market research, sending communications and promotional, commercial and advertising material or concerning initiatives and events, via e-mail, SMS, Whatsapp, Chat, Direct Messaging from social media, social network or by telephone calls, paper mail and other information material.
Legal basis: this treatment is based on the consent freely expressed by the interested party pursuant to art. 6, par. 1, lit. A of the GDPR.
Data retention period : until revocation of consent by the interested party.
9) Statistics
The Data will be processed to carry out statistical analyzes on aggregated and anonymous data to analyze the behavior of the interested party to improve the products and services provided by the Data Controller as well as meet the expectations of the interested party.
Legal basis: this treatment is based on the consent freely expressed by the interested party.
Data retention period: until revocation of consent by the interested party.
10) Profiling
The Data will be processed for the analysis and evaluation of interests, habits, consumption choices, including the creation of profiles in order to be able to send personalized information and promotional material on the Services/Products offered by the Data Controller.
Legal basis: this treatment is based on the consent freely expressed by the interested party pursuant to art. 6, par. 1, lit. A of the GDPR.
Data retention period: until revocation of consent by the interested party.
Data Communication
In addition to the Data Controller, in some cases, they may have access to the Data:
a) categories of specially trained Persons involved in the organization of the Website (administrative, commercial, marketing, legal, system administrators);
b) external subjects (such as third party technical service providers, hosting providers, IT companies, communication agencies) also appointed as Data Processors by the Data Controller pursuant to art. 28 GDPR. The updated list of Managers, if appointed, can always be requested from the Data Controller;
c) public or private entities that can access the Data in compliance with legal obligations;
d) subjects who carry out ancillary and instrumental tasks with respect to the activity of the Data Controller.
Sharing of data with third parties
The Data Controller shares the Personal Data of the Data Subject with third parties. These third parties include:
1) The Travel Provider with whom you have booked. In fact, in order to complete the booking, the relative data must be transferred to the Supplier. The data that is shared may include the name, contact details, payment details, the name of the people traveling with the interested party and the preferences or other information that may be indicated at the time of booking the trip.
The Trip Providers will subject personal data to further processing, beyond the control of the Data Controller.
2) Third parties to process payments, handle reversals or provide invoice collection services.
Security and conservation measures
The Data Controller uses special procedures to prevent unauthorized access to data and their improper use. It uses systems and procedures to protect and safeguard personal data, including with security procedures and technical and physical restrictions in order to prevent access and use of personal data contained in the servers.
Methods of treatment of minors
The services offered by the Owner are not intended for minors. The Data Controller may collect the personal data of minors in cases in which such data form part of a reservation or purchase of other travel-related services. In this case, these data will only be collected and used for contractual purposes.
Times of Treatment
As expressly provided for by art. 5, co. 1, lit. e) of the GDPR, the Data are kept for the time necessary for the Processing of the same in relation to the performance of the service requested by the interested party, or required by the Purposes described above in this document.
At the end of the retention period, the Personal Data will be deleted and therefore,they can no longer be exercisedthe rights of access, cancellation, rectification and data portability
Cookies
This Website uses cookies. Cookies are small text files that can be used by websites to make the user experience more efficient and to personalize content and ads, provide social network functions and analyze traffic.Cookie Policy.
Place of processing and transfer of data abroad
The Data is processed at the Data Controller's operational headquarters. For further information, you can contact the Data Controller. The Data may be processed by natural persons and/or legal entities operating on behalf of the Data Controller and by virtue of specific contractual obligations and based in EU or non-EU member countries. In the event that the Data is transferred outside the EEA, the Data Controller will adopt all suitable contractual measures to guarantee adequate data protection.
Exercise of the rights of the interested party
The interested party has the right to exercise the faculties provided for in articles 7, 15-22 of the European Reg. 679/2016. In particular, you have the right to withdraw your consent at any time and, upon simple request to the Data Controller, you can request access to Personal Data, receive the Personal Data provided to the Data Controller and, where possible, transmit them to another Data Controller without impediments (so-called portability), obtain updating, limitation of processing, rectification of data and cancellation of data processed in breach of current legislation. He has the right, for legitimate reasons, to object to the processing of personal data concerning him and to the processing for the purpose of sending advertising material, direct sales and for carrying out market research. You also have the right to lodge a complaint with the Privacy Guarantor as the supervisory authority for the protection of personal data or to appeal to the appropriate judicial offices. The interested party can exercise his rights by contacting the Data Controller by e-mail at the address: support@easyrelaxtravel.com
Tools used for the processing of personal data
The interested party, by filling in the contact form with his own data, consents to their use to respond to requests for information, or for any other purpose indicated by the header of the form. Personal Data collected through the contact form: Email, Name, Surname, telephone number.
WhatsApp Business
WhatsApp Business is an instant messaging service provided by WhatsApp Ireland Limited. For the purposes of the treatment methods, the Terms for the treatment of WhatsApp Business data can also be found at the following link: https://www.whatsapp.com/legal/business-data-processing-terms/.The Data Subject's data will transit through the WhatsApp Business services according to the terms that WhatsApp reports in the "WhatsApp Business Terms of Service" document at the following link: https://www.whatsapp.com/legal/business-terms/. Personal Data collected: telephone number, email, Usage Data, Cookies. Place of Processing: Ireland-Privacy Policy ( link to activate https://www.whatsapp.com/legal?eea=0#privacy-policy)
EMAIL ADDRESS MANAGEMENT
These services allow you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the interested party. These services could also allow the collection of data relating to the date and time of viewing of messages by the interested party, as well as the interaction of the interested party with them, such as information on clicks on the links inserted in the messages.
SECURITY MEASURES ADOPTED
This Website, to secure the moment Personal Data is entered, has an SSL certificate and uses the HTTPS protocol. With the use of this protocol, the transactions and data that are transmitted on the websites take place with maximum security and the content of the communication is not read or manipulated in any way by third parties.
reCAPTCHA
This Website uses reCAPTCHA which is a service subject to the privacy policyprivacy (link to activate https://policies.google.com/privacy?hl=it)
and aiterms and conditions (link to activate https://policies.google.com/terms?hl=it)
of use of Google.
WEBSITE REGISTRATION
With the registration service, the interested party allows the site to identify him and give him access to dedicated services. The interested party registers directly on the site by filling in the form and providing their data. The registration and authentication services can also take place with the help of third parties. In this case, the application will be able to access some data stored by the third-party service used for registration and identification.
STATISTICS
The statistical services allow the Data Controller exclusively to monitor and analyze traffic data and are used to keep track of the behavior of the interested party. This Website uses the following services:
Google Analytics (Google Ireland Limited)
Google Analytics is an analysis service provided by Google Ireland Limited. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google's behalf. The IP address anonymization function is active on this site. The IP address transmitted by the browser for purposes related to Google Analytics will not be incorporated into other data already held by Google.
At the following link https://tools.google.com/dlpage/gaoptout?hl=it The browser add-on for deactivating Google Analytics is made available by Google. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – USAPrivacy Policy (link to activate https://policies.google.com/privacy?hl=it)
REMARKETING AND RETARGETING
These services allow this Website to communicate, optimize and serve advertisements based on the past use of this Website by the interested party. Through these services it is possible to understand the actions that people perform on the Website. The data that is collected can be used for:
- ensure that adverts are shown to the right people;
- create audience groups to target advertisements;
- take advantage of the additional advertising tools of the platform on which you advertise.
The information collected is anonymous to the operators of this site and cannot be used to identify the identity of a single interested party. However, the information is saved and analyzed by the Third Party Service Providers, who may link the action to an individual profile and use this information for internal advertising purposes. This activity is carried out through the tracking of Usage Data and the use of Cookies with the consent of the interested party.
PAYMENT MANAGEMENT
Payment management services allow this Website to process payments by credit card, bank transfer or other means. The Data used for payment are acquired directly by the manager of the requested payment service without being processed in any way by this Site. Some of these services could also allow the programmed sending of messages to the interested party, such as emails containing invoices or notifications regarding the payment. This Website uses the following services:
PayPal (Paypal Europe S.à.rl et Cie, SCA Inc.)
PayPal is a payment service provided by PayPal Europe S.à.rl et Cie, SCA Inc., which allows the interested party to make online payments using their PayPal credentials. Personal data collected: Cookies and various types of data as specified in the privacy policy of the service. Place of processing: Luxembourg -Privacy Policy (link to activate https://www.paypal.com/it/webapps/mpp/ua/privacy-full)
Changes to this Privacy Policy
The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to Users on this page. Therefore, please consult this page often, referring to the date of the last modification indicated at the bottom. In the event of non-acceptance of the changes made to this Privacy Policy, the interested party is required to cease using this website and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous Privacy Policy will continue to apply to the Personal Data collected up to that moment. The Owner is not responsible for updating all the links that can be viewed in this Privacy Policy, therefore whenever a link is not functional and/or updated.
