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Privacy and Cookie Policy

TOURMAKE S.r.l., with registered office in C.da Monopoli, 3 – 70013 Castellana Grotte (BA), Fiscal Code and VAT number 08043360729 (hereinafter, “Owner”), as data controller, informs you pursuant to art. . 13 Legislative Decree 6/30/2003 n. 196 (hereinafter, “Privacy Code”) and art. 13 EU Regulation no. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the manner and for the following purposes:

1. Object of the Treatment

The Data Controller processes personal identification data (for example, name, surname, company name, address, telephone, e-mail, bank and payment details), hereinafter “personal data” or even “data”, communicated by you on the occasion of the conclusion of contracts for the services of the Owner.

2. Purpose of the Processing

Your personal data are processed:

  1. without your express consent (art. 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:
    • conclude the contracts for the services of the Owner;
    • fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with you;
    • fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as in the matter of anti-money laundering);
    • exercise the rights of the Owner, for example the right of defense in court.

The Owner makes a service platform available to its Partners whose purpose is the interaction of visitors with the manager and/or owner of a place and/or commercial activity.

A non-exhaustive list by way of example is the following:

  1. Booking and purchasing services;
  2. Filling in contact forms;
  3. Posting comments and reviews.

The Data Controller plays the role of intermediary between the visitor and a third party, designated by the Partner for receiving data sent by visitors through the completed forms.

The Data Controller may keep the data sent by visitors for the exclusive purpose of guaranteeing the service requested by the visitor; such data will not be used for commercial, marketing or profiling purposes by the Data Controller.

However, the Owner cannot guarantee the correct use of the data, by third parties, sent for the provision of a service to the visitor. The visitor who wants to use one of the services listed above will eventually be informed of further methods and purposes of data processing by the third party just before sending the data. These methods will be defined by the Partners during the creation of the service, through the means provided by the platform. The visitor fully accepts all the purposes listed to use the services.

The visitor who uses these services is aware that the data will be sent to third parties. In the absence of methods relating to the use of data by third parties for the provision of the service, the visitor has the right to ask the Data Controller for the destination and methods for sending the data. The Owner is exempt from any responsibility regarding the incorrect use of the data by third parties.

  1. Only with your specific and distinct consent (Articles 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes:
    • send you by e-mail, mail and/or sms and/or telephone contacts, newsletters, commercial communications and/or advertising material on products or services offered by the Owner and detection of the degree of satisfaction with the quality of the services;
    • send you via e-mail, mail and/or sms and/or telephone contacts commercial and/or promotional communications from third parties (for example, business partners, insurance companies, other companies of the Tourmake group).

We point out that if you are already a Tourmake customer, it will be possible to send you commercial communications relating to the Owner’s services and products similar to those you have already used, unless you disagree (art. 130 c. 4 of the Privacy Code).

3. Methods of treatment

The processing of your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 no. 2) GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper and electronic and/or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes and for no more than 2 years from the collection of data for marketing purposes.

 

4. Data access

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):

  • to employees and collaborators of the Data Controller or of the companies of the Tourmake Group in Italy and abroad, in their capacity as persons in charge and/or internal data processors and/or system administrators;
  • to third-party companies or other subjects (as an indication, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourced activities on behalf of the Data Controller, in their capacity as external managers of the treatment.

 

5. Data communication

Without the need for express consent (ex art. 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to supervisory bodies (such as IVASS), judicial authorities, to insurance companies for the provision of insurance services, as well as to those subjects for whom the communication is mandatory by law in the performance of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers.

Your information will not be disseminated.

6. Data transfer

Personal data is stored on servers located in Roubaix (France) and in Strasbourg (France), within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses envisaged by the European Commission.

7.Nature of data provision and consequences of refusal to respond

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we will not be able to guarantee you the Services.

The provision of data for the purposes referred to in art. 2.B) is instead optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller. However, you will continue to be entitled to the Services pursuant to art. 2.A).

8. Rights of the interested party

In your capacity as an interested party, you have the rights referred to in art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:

  1. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
  2. obtain the indication: a) of the origin of the personal data; b) the purposes and methods of processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, of the managers and of the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as designated representatives in the territory of the State, managers or agents;
  3. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means manifestly disproportionate to the protected right;
  4. object, in whole or in part: a) for legitimate reasons, to the processing of your personal data, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator , by e-mail and/or traditional marketing methods such as telephone and/or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.

Where applicable, you also have the rights pursuant to articles 16-21 GDPR (Right to rectification, right to be forgotten, right to limitation of treatment, right to data portability, right to object), as well as the right to complain to the Guarantor Authority.

9. Methods of exercising rights

You can exercise your rights at any time by sending:

  • a registered letter with return receipt to Tourmake s.r.l. – C.da Monopoli, 3 – 70013 Castellana Grotte (BA) Italy
  • an e-mail to tourmake@pec.it

10. Owner, manager and appointees

The Data Controller is Tourmake s.r.l. with registered office in C.da Monopoli, 3 – 70013 Castellana Grotte (BA) Italy.

The updated list of data processors and persons in charge of processing is kept at the registered office of the Data Controller.

11. Integrations to external services

Tourmake allows the integration of Social Media Platforms such as YouTube, Facebook, Twitter and Instagram within your virtual tours in the form of Widgets. The integration of your YouTube channel takes place using YouTube API Services, specifically YouTube Data API. By entering their YouTube channel, users agree to be bound by the following YouTube Terms of Service. Reference to Google Privacy Policy. Tourmake requires you to enter your Channel ID to get the YouTube channel name and the latest videos list. The information obtained is NOT used for statistical and marketing purposes and is NOT shared with third parties.