Privacy Policy

Information on the processing of personal data in accordance with the GDPR (Articles 13 and 14 of EU Regulation 2016/679)

FRIGERIO VIAGGI S.r.l.(hereinafter also “FV” or the “Company”) processes personal data of all parties with whom it has business relations in compliance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (hereinafter the “Regulation” or “GDPR”).
The guidance provided below is also inspired by Recommendation No. 2/2001 of the Group of European Data Protection Supervisors adopted on May 17, 2001 ex art. 29 of Directive No. 95/46/EC, which specifically, but not exclusively, concerns the collection of personal data on the Internet, and aims to identify the minimum measures that will have to be implemented with respect to the persons concerned in order to ensure the fairness and lawfulness of such practices (in application of Articles 6, 7, 10 and 11 of Directive 95/46/EC).

Who is the interested party

This information is intended for all subjects who visit and interact with the website of the company FRIGERIO VIAGGI S.r.l. www.frigerioilgruppo.com.
It describes how we manage the processing of the personal data of users and visitors to our site, as well as the personal data we process relating to customers, suppliers, subscribers to our mailing lists and, in general, all subjects with whom we come into contact for business reasons.
The information does not apply to other websites that may be consulted through our links, for which FRIGERIO VIAGGI S.r.l. is in no way responsible.

Who is the Data Controller

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

• e-mail: [email protected];
• iordinary mailing address: Frigerio Viaggi S.r.l., via Ambrogio Viganò n. 5 – 20833 Giussano (MB)

 

What data are collected

Personal data are collected:

• identifying information, such as first name, last name, date and place of birth, residence, domicile, pictures depicting the person.
• special categories of personal data (Art. 9 of the GDPR), relating to habits and/or customs related to travel needs or enjoyment of the tourist service.
• data related to new technologies: data related to electronic telephone and Internet communications, data that allows a person to be geolocated, and genetic and biometric data.

Special categories of data will be processed only upon the express and specific request of the user and if deemed relevant and/or necessary for the provision of the requested service.

What treatments are performed and why

Pursuant to Article 13 of the Regulations, you may disclose your personal data or those of third parties that you are in legitimate possession of to FV for:

• The activities of proposing, organizing, and providing services in support of travel that involve the disclosure of personal data to airlines, car rental service operators, hotels, insurance companies, tour operators, and other third party operators that provide services or perform activities by reason of contractual relationships with FV;
• The organization of a tourist package or the provision of individual tourist services;
• The purchase of related tourist services;
• Making a payment;
• intermediation in the purchase of a tour package organized by a third party or individual tour services provided by third-party suppliers (e.g., hoteliers, air carriers, etc.);
• intermediation in the purchase of financial/insurance services ancillary and/or related to the facilitated and/or individually purchased tourist packages/services (medical-baggage policies; cancellation policies; assistance to travelers in distress; consumer credit financing);
• Fulfilling the task related to the issuance of visas;
• register on our website and/or mobile application;
• subscribe to our newsletter.

The user of the site is free to provide personal data to solicit the sending of informative material or request other types of services offered by the Company. Failure to provide them may result in the inability to provide the requested service. Also for other categories of interested parties (customers, suppliers, subjects registered in our mailing lists and, in general, all subjects with whom we have business relations), the provision of their personal data is optional, but failure to provide them may result in the impossibility of following up on agreements made or concluding the contract or providing the requested service.
The voluntary sending of electronic mail to the addresses on the site involves the subsequent acquisition by FV of the sender's address and any personal data transmitted together with that missive.
In all cases in which the user will have the faculty to freely enter his/her personal data concerning him/her (e-mails, freely filled in fields, etc.), such data will be processed by our Company - if deemed pertinent and necessary - in order to fulfill the user's requests. If the personal data communicated are not considered pertinent and necessary for the provision of the requested service or if the relevant consent has not been given, if necessary, FV reserves the right, at its sole discretion, to delete such data.
In terms of mobile devices we collect:

• the model;
• The present operating system and its version;
• information about the connection mode (for example: the operator, network type, etc.);
• the selected and/or enabled settings (for example: Wi-Fi, GPS, etc.);
• some usage data (for example: dates and times of access, functions used, data and files downloaded, etc.);
• any other technical information necessary for proper operation of the application (for example: version of the installed application).

Specific permission will always be required from the user to enable location-based services through GPS, Wi-Fi, Bluetooth or other signals.
Location authorization is optional and can be given either at the time of downloading the application or afterwards; without authorization, you will still be able to download and use the application, but you will not be able to use the location-based services in the application.
To disable the location-based functionality from the application after giving permission, it will be sufficient to change the settings from the mobile device.
In no case, however, will revocation of consent affect the lawfulness of processing based on the consent given before revocation.
For all other personal data that may be disclosed through the mobile application, everything stated with this policy applies.
We may also collect and use information about minors, but only if provided to us by their parent or guardian and with their express consent. In the event that we become aware that we have processed a minor's information without the valid consent of a parent or guardian, we reserve the right to delete such information.

What are the purposes of processing

a. Purpose related to contractual performance.
The data subject's personal data will be processed for the purpose of fulfilling obligations arising from the negotiation and conclusion of contracts necessary for the provision of services or, in any case, for the performance of obligations arising from all contractual relationships, including the negotiation phase, in order to enable FV to optimally deliver the service.
Specifically, data will be processed for:

• The conclusion, management and execution of contractual relationships, including brokerage activities;
• Respond to requests from the data subject;
• The communication of notices related to purchased services or other additional and ancillary services (ad information related to purchased services; modification of contract conditions; cancellations, refunds, etc.).

Online purchasing.
In order to proceed with the online purchase, it is necessary to create a personal account by registering through the appropriate procedure dedicated to this. When creating the 'personal account, the interested party will receive the specific information on the processing of his personal data. As provided for in Recommendation No. 2/2001, the data subject will always have the possibility to access his/her personal account to modify, update, correct and delete certain data concerning him/her. For certain personal data (such as first name, last name, date of birth, gender, etc.), the right to change may be exercised only by sending a specific and reasoned written request to the Data Controller using the contact details provided in this policy. The Data Controller, before proceeding with the requested change, reserves the right to verify the correctness of the new data provided and the validity of the reasons underlying the request.
The provision of personal data and, where applicable, of data falling under the definition of “special categories of personal data” (art. 9 of the Regulations), is optional: in default, however, FV will not be able to perform, in whole or in part, the requested service.
In this case, the processing will be based on the need to fulfill pre-contractual, contractual and legal obligations.
However, the processing of particular categories of personal data will be based on the express and free consent of the data subject. In this case, by sending such particular categories of data, the data subject expressly authorizes our Company to process the same data for the provision of the requested services. If, however, FV does not consider the data sent relevant and/or necessary for the provision of services, FV reserves the right to delete it.
FV detects the type of means of payment used to make an online purchase (credit card, debit card, etc.), but does not display or retain in any way the identification data of the means of payment (full number of cards, expiration date, security code, etc.). Only some particular data (last four digits of the card, date and time of the transaction, etc.) are retained in order to be able to process refunds in favor of the person concerned, if necessary.
 
b. Legal purposes.
Personal data will also be processed for:

• To execute legal obligations, regulations, national, community and international standards or arising from provisions issued by Authorities empowered to do so by law;
• ascertain, exercise and/or defend in litigation, including judicial proceedings, a right of FV;
• Fulfilling the obligations required in the area of taxation and accounting;
• Fulfilling obligations related to traveler health and safety regulations;
• Fulfilling obligations related to passenger and freight transport regulations.

In this case, processing will be based on the need to fulfill any obligation arising from laws, regulations and, in general, from the legislation - including EU legislation - from time to time applicable to the relationship established with our Company.
 
c. Marketing purposes and sending newsletters.
The personal data provided through the different services of the site, excluding data that fall under the definition of “special categories of personal data” (art. 9 of the Regulations), may be processed - exclusively upon prior, free and express consent - for the purpose of sending newsletters, commercial and/or promotional information and free products, i.e. for invitations to shows and/or events, for carrying out market research, for reporting all special initiatives dedicated to FV's customers, as well as for offering promotions, discounts, facilitations and other services.
This activity may take place by different means: e-mail, text message, instant messaging applications, social networks, regular mail, telephone operator, etc.
The user will have the opportunity to give his or her consent at the bottom of the specific disclosures issued from time to time for access to each service of the site or by making it signed in original or in electronic format.
The user may modify and/or revoke the consent and authorization given for the conduct of marketing and newsletter activities by writing to the contact details given in this notice. You will also be able to revoke the consent thus given by exercising the “opt-out” option at the bottom of each newsletter by clicking on the “unsubscribe” button.
Under no circumstances, however, may revocation of consent affect the lawfulness of the processing based on the consent given prior to revocation.
 
d. Profiling purposes.
Personal data profiling is the collection of information about an individual or group of individuals in order to analyze their characteristics and put them into categories or groups and be able to make evaluations or predictions. FV conducts profiling with systems that are not solely automated.
The personal data provided through the different services of the site, excluding those that fall under the definition of “special categories of personal data” (art. 9 of the Regulations), may be processed - exclusively upon prior, free and express consent - for activities of analysis of travel preferences and market research, in order to improve the offer of services and commercial information presented by FV, making them more and more in line with the interests of its users.
This activity may also be carried out through the administration of satisfaction questionnaires and/or the use of profiling cookies used while browsing our websites and mobile applications.
The user will have the opportunity to give his/her consent at the bottom of the specific disclosures issued from time to time for access to each service of the site or by making it signed in original or in electronic format and may modify and/or revoke it by writing to the contact details given in this disclosure.
Profiling of minors is excluded.
 
 e. Purposes related to statistics and market research.
Personal data will also be processed for anonymous and aggregate statistical and market research purposes.
 
f. Third-party marketing.
Personal data provided through the various services on the site are not disclosed and/or transferred by FV to its business partners for marketing purposes.

What is the legal basis for processing

The personal data thus collected are necessary for:

• fulfill pre-contractual obligations
• properly execute the contract
• Fulfilling specific legal obligations.

For marketing and commercial information and profiling activities, the legal basis for processing will be solely the prior, free and express consent of the data subject.

Method of treatment

The processing carried out will be collection, consultation, processing, storage, deletion, communication.
Personal data are processed on paper and/or with automated tools, exclusively for the time necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.

Categories of recipients of personal data

Data subjects' data will not be disseminated.
The data may be made accessible or communicated, exclusively for the purposes set forth in this notice, to the following categories of subjects:

• FV's internal staff, acting as appointees and/or processors;
• Providers of tourist services included in packages sold or providing related services or individual services purchased from FV;
• suppliers and third parties, including in countries outside the EU, for the purpose of carrying out the travel booking (hotels, airlines, sales operations area, back office, charter flight and distribution line contracting, assistance, administration);
• External data processors and authorized persons in charge of handling the travel file regularly appointed and trained on the processing of personal data;
• insurance and financial companies that provide the coverage and benefits incidental to and connected with the purchased tour packages and services;
• persons, companies, associations or professional firms that provide services or activities of assistance and advice for FV or in order to protect one's right (for example: accountants, lawyers, tax consultants, auditors, consultants within the framework of auditing or due diligence operations, );
• Third parties in charge of the maintenance/development service of our computer system for the time required to perform the service;
• Third parties who provide marketing and analytical services or consulting activities on behalf of FV;
• Third parties to whom the right to access your data is recognized by provisions of law and secondary legislation or by provisions issued by Authorities empowered to do so by law, including airport, port, customs and border authorities.

Transfer of personal data outside the European Union

Personal data may be transferred abroad to Third Party Companies belonging or not belonging to the European Economic Area, always for the above-mentioned purposes, subject to verification of compliance with the applicable rules and the presence of guarantees of an adequate level of protection of natural persons, based on the assessments given by the Commission of the European Union (art. 45 of the Regulations) or, alternatively, that the recipient has obligated itself to the protection of data by offering an adequate level comparable to the protection provided by the GDPR (art. 46 of the Regulations).

Retention of personal data

Personal data will be retained by the Company for a period not exceeding that necessary to achieve the purposes for which the data were collected and subsequently processed.
Personal data and data that fall under the definition “special categories of personal data” will be retained for the period provided for by the applicable legal regulations and/or for the time necessary to enforce a right of the Data Controller in court. Where consent has not been given by the data subject to collect and process his/her personal data also for marketing and/or profiling purposes, at the end of this period it will be automatically deleted or permanently anonymized.
Where the user has given consent to process his or her personal data also for profiling purposes, it will be processed for this purpose for a maximum period of five years at the end of which it will be automatically deleted or permanently anonymized.

Rights of the data subject

At any time, in accordance with Articles 15-22 of the GDPR, the data subject has the right, including in relation to profiling activities, to ask the owner:

• access to their personal data and information related to them;
• The rectification of inaccurate data or the supplementation of incomplete data;
• The deletion of personal data concerning him/her (upon the occurrence of one of the conditions set forth in Article 17(1) of the GDPR and subject to the exceptions set forth in paragraph 3 of the same article);
• the restriction of the processing of one's personal data (in the occurrence of one of the cases indicated in Article 18(1) of the GDPR);
• to obtain-in cases where the legal basis for processing is a contract or consent, and the processing is carried out by automated means-their personal data in a structured, machine-readable format, including for the purpose of communicating such data to another data controller (so-called right to personal data portability);
• To object at any time to the processing of personal data in the event of special situations concerning him/her (Art. 21 GDPR);
• revoke consent at any time, limited to cases where the processing is based on your consent for one or more specific purposes and involves common personal data (e.g., date and place of birth or place of residence) or special categories of data (e.g., data revealing racial origin, political opinions, religious beliefs, health status, or sex life); processing based on consent and carried out prior to your revocation retains, however, its lawfulness;
• Propose complaints to the Data Protection Authority.

Data breach

In the event of a breach of the personal data of data subjects, where 'breach' means destruction or loss, even accidental, of the data, unauthorized access, or processing that is not permitted or not in accordance with the purposes of collection, FV will promptly activate the Data breach notification procedure and inform the data subjects, as required by the GDPR.

Navigation data and cookies

The computer systems and software procedures used to operate the site acquire during their normal operation some personal data whose transmission is implicit in the use of Internet communication protocols.
This is information (for example: IP address, domain names of computers used, etc.) that is not collected in order to be associated with identified interests, but which by its very nature could, through processing and association with data held by third parties, allow a subject to be identified: this data is used to obtain anonymous statistical information on the use of the site and to check its correct operation and is deleted immediately after processing. The data in question could also be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the site: except for this possibility, at present the data on the site do not persist for more than 15 days.
For cookies, please refer to the cookies policy section on the site.

Changes to this policy

This document, which is linked to the company's privacy policy, may be subject to change over time - also related to the possible entry into force of new industry regulations, the updating or provision of new services or to intervening technological innovations - so the user/visitor is invited to consult this page periodically.