wonderful visits

PRIVACY POLICY

Data Controller

Incoming Partners srl

Via Lazzaro Palazzi, 21

20124 Milan

Address and e-mail of the Controller: michele.mondolfo@wisits.com

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Types of data collected

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The Personal Data collected by this Application, either autonomously or through third parties, include: email, name, surname, telephone number, address, nationality, province, postcode, various types of data, Cookies, Usage Data.

Complete details on each type of data collected are provided in the sections dedicated to this privacy policy or through specific informational texts displayed prior to collecting the data.

The Personal Data may be freely given by the User or, with regard to the Usage Data, automatically collected during the use of this Application.

Unless otherwise specified, all of the Data requested by this Application are mandatory. If the user refuses to provide the data, it may be impossible for this Application to provide the Service. If this Application indicates that the Data are optional, Users are free to refuse to provide such Data, without any consequence on the availability of the Service or its operation.

Users who have any doubts on which Data are mandatory should contact the Data Controller.

Cookies - or other tracking tools - used by this Application or by the controllers of third-party services used by this Application, unless otherwise specified, are necessary in order to provide the Service requested by the User as well as for other purposes set out in this document and in the Cookie Policy, where available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he/she has the right to share or disseminate them, thus releasing the Controller from any liability in relation to third parties.

 

Data processing methods and location

 

Processing methods

The Controller shall adopt the necessary security measures in order to prevent the unauthorised access, disclosure, modification or destruction of the Personal Data. 

The data will be processed using computerized and/or telematic tools following organizational procedures and using methods strictly related to the indicated purposes. In some cases, in addition to the Controller, the Data may be accessed by other people involved in the organization of this Application (administrative, commercial, marketing, and legal personnel, system administrators) or by external persons (such as third-party suppliers of technical services, couriers, hosting providers, IT companies, communications companies) who may be designated, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors may be requested at any time from the Data Controller.

 

Legal basis for the data processing

The Controller may process the Personal Data related to the User where any of the following circumstances apply:

•  The User has given their consent to one or more of the purposes specified. N.B. in certain jurisdictions, the Controller may be authorized to process the Personal Data in the absence of the User's consent or of another of the legal bases specified below, unless the User opts out of said processing. This, however, does not apply if the processing of the Personal Data is regulated by European legislation on the protection of Personal Data.

•  The processing is necessary in order to execute the contract with the User and/or to implement the pre-contract measures.

•  The processing is required in order to fulfil the legal obligations to which the Data Controller is subject.

•  The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.

•  The processing is required in order to pursue the legitimate interests of the Controller or of third parties.

It is possible at any time to request the Controller to clarify the specific legal basis for each processing operation and, in particular, to specify whether the processing is based on the law, provided for by contract, or necessary in order to conclude a contract.

 

Place

The Data will be processed at the operational sites of Controller and in other places in which the parties involved in the processing are located. For further information, contact the Controller.

The User's Personal Data may be transferred to a country other than that in which the User is located.

In order to obtain further information on where the processing takes place, the User may consult the section on the details of the Personal Data processing.

The User is entitled to obtain information regarding the legal basis for the transfer of their Data outside of the European Union or to an international organization subject to public international law or established by two or more countries such as, for example, the UN, as well as information regarding the security measures adopted by the Controller to protect the Data.

The User can check whether any of the transfers just described has taken place by examining the section of this document concerning the details of the Personal Data processing or by asking the Controller, whose contact details are given above.

 

Data retention period

The Data shall be processed and retained for the time necessary to achieve the purposes for which they were collected.

Therefore:

• The Personal Data collected for purposes related to the execution of a contract between the Controller and the User shall be retained until the contract execution is complete.

• The Personal Data collected for purposes related to the legitimate interest of the Controller shall be retained until such interests have been satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relative section of this document or by contacting the Controller.

When the processing is based on the consent of the User, the Controller may retain the Personal Data for longer, up until such time as the consent is withdrawn. Furthermore, the Controller may be required to retain the Personal Data for a longer period in order to comply with legal obligations or by order of a legal authority.

Upon expiry of the retention period, the Personal Data shall be erased. Therefore, upon expiry of said period, the right of access, erasure, rectification and of data portability may no longer be exercised.

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Purposes of the Data Processing

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The User's Data are collected to enable the Controller to provide its services and for the following purposes: to contact the User, social purposes, interaction with social networks and external platforms, statistical purposes, to view the content of external platforms, and to manage payments.

For more information on the purposes of the processing and on the Personal Data that are specifically relevant for each purpose, the User can refer to the relative section of this document.

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Details on the Personal Data Processing

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The Personal Data are collected for the following purposes and using the following services:

• To contact the User​​

       Mailing list or newsletter (this Application)

       If a User subscribes to a mailing list or newsletter, his/her email address is automatically added to a list of contacts to whom email messages may be sent containing information, which may also be of a commercial or promotional nature, related to this Application. The address of the User may also be added to this list as a result of registering with the Application or after having made a purchase.

       Personal Data collected: email.

       Contact form (this Application)

       In filling in the contact form with his/her Data, the User consents to the use of the same in order to respond to requests for information, a quote or requests of any other kind indicated in the subject line of the form.

       Personal Data collected: Postcode, surname, email, address, nationality, name, telephone number, province.

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• Social purposes

​       Invite or suggest friends (this Application)

       This Application may use the Personal Data provided to enable Users to invite their friends - for example through their address book if access has been authorised - and to suggest friends or connections therein.

       Personal Data collected: various types of Data.

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• Managing payments

       The payment management services allow this Application to process payments by means of credit cards, bank transfers or other instruments. The Data used are obtained directly by the manager of the payment service requested without being processed in any way by this Application.

       Some of these services could allow the sending of automatic messages to the User, such as emails containing invoices or notifications related to payment.

       PayPal (Paypal)

       PayPal is payment service provided by PayPal Inc., which allows the User to make online payments.

       Personal Data collected: various types of Data in accordance with that specified in the Privacy Policy for the service.

       Processing location: Consult PayPal's privacy policy – Privacy Policy.

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• Statistics

       The services indicated in this section allow the Data Controller to monitor and analyse the data traffic and to track the behaviour of the User.​

       Google Analytics (Google Ireland Limited)

       Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purposes of tracking and analysing the use of this Application, compiling reports and sharing them with other services developed by Google.

       Google could use the Personal Data to contextualize and personalise the adverts on its own advertising network.

       With the integration of Google Analytics, your IP address will remain anonymous. Data anonymization functions by abbreviating the IP address of Users within the borders of the EU Member States or in other countries that are part of the European Economic Area. In exceptional cases, the IP will be sent to the Google servers and abbreviated within the United States

       Personal Data collected: Cookies; Usage Data.

       Processing location: Ireland – Privacy Policy – Opt Out. Signatories to the Privacy Shield.

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    Further information on Personal Data

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• Online sale of goods and services​

      The Personal Data collected are used to provide the services to the User or to sell products, including payment and delivery. The Personal Data collected in order to process payment may be those related to the credit card or PayPal account. The payment Data collected by this Application depends on the payment system used.

   

    Rights of the User

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     Users may exercise certain rights with regard to the Data processed by the Controller.

     In particular, Users have the right to:

• withdraw their consent at any time. Users may withdraw their previously given consent to the processing of their Personal Data.

• object to the processing of their Personal Data. Users may object to the processing of their Personal Data when this is carried out on a legal basis other than consent. Further information on the right to object is provided below.

• access their Data. Users have the right to obtain information on the Data processed by the Controller and on certain aspects of the processing, and to receive a copy of the Data processed.

• check the Data and request rectification. Users may check the accuracy of their Data and request that they are updated or corrected.

• obtain a restriction on the processing of their Data. When certain conditions are met, Users may request that the processing of their Data be restricted. In such case, the Controller shall not process the Data for any purpose other than their retention.

• obtain the erasure or removal of their Personal Data. When certain conditions are met, Users may request that their Data be erased by the Controller.

• receive their Data or transfer them to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to transfer the Data without hindrance to another controller. This provision is applicable when the Data are processed using automated tools and the processing is based on the consent of the User, on a contract to which the User is a party, or on contractual measures related thereto.

• file a complaint. Users may file a complaint with the competent data protection authority or engage in legal proceedings.

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      Information on the right to object

      When the Personal Data are processed in the public interest, the exercise of public power in which the Controller is vested or in order to pursue the legitimate interest of the Controller, Users have the right to object to the processing for reasons related to their specific situation.

      Users should be aware that, where their Data are processed for direct marketing purposes, they can object to the processing without providing any reason. To find out whether the Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

      How Users can exercise their rights

      In order to exercise their rights, Users can send a request to the Controller using the contact details indicated in this document. There is no charge to submit a request which will be dealt with by the Controller as soon as possible and, in any case, within a month.

 

Cookie Policy

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This Application uses Cookies solely for statistical purposes and to monitor the individual access of Users. With the exception of "svSession", which unequivocally identifies, albeit anonymously, the visitors and tracks the sessions of each visitor to the site, the other cookies expire upon termination of the session.

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Further information on processing

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Legal defence

The Personal Data of the User may be used by the Controller in legal proceedings or in order to prepare for legal proceedings concerning any abuse in the use of this Application or of the related services by the User.

The User declares to be aware that the Controller may be required to reveal the Data by order of the public authorities.

 

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Application can provide the User with additional, relevant information regarding specific services or the collection and processing of Personal Data.

 

Maintenance and system logs

For operational and maintenance purposes, this Application and any third-party services used by the same may collect system logs, in other words the files that record interactions and that may also contain Personal Data, such as the User's IP address.

 

Information not contained in this policy

Further information relating to the processing of Personal Data can be requested at any time from the Data Controller using the contact details indicated in this document.

 

Response to “Do Not Track” requests.

This Application does not support "Do Not Track" requests.

To find out whether any third-party services used support these requests, the User can consult the respective privacy policies.

 

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time, providing Users with the relative information on this page and, if possible, in this Application as well as, where technically and legally feasible, sending a notification to the Users using the contact details possessed by the Controller. You are therefore advised to regularly check this page, taking into account the date it was last modified indicated at the foot of the page.

If the changes affect the data processing based on consent, the Controller shall seek to obtain the consent of the User again, if necessary.​

 

Definitions and legal references

Personal Data (or Data)

Personal Data refers to any information that, directly or indirectly, including in relation to any other information such as a personal identification number, identifies or renders identifiable a natural person.

 

Usage Data

Usage Data refers to information that is collected automatically through this Application (and through third-party applications integrated into this Application) including: IP addresses or the domain names of computers used by the User to connect to this Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to send the request to the server, the size of the file obtained in response, the numeric code indicating the status of the server response (success, error, etc.), the country of origin, the browser characteristics and the operating system used by the visitor, the various time connotations of the visit (e.g. the time spent on each page) and the details related to the itinerary followed inside the Application, with regard in particular to sequence of the pages consulted, the parameters related to the operating system and the IT environment of the User.

 

User

The individual that uses this Application who, unless otherwise specified, is also the data subject.

 

Data Subject

The natural person to whom the Personal Data refer.

 

Data Processor (or Processor)

The natural or legal person, public administration or any other organization that processes personal data on behalf of the Controller, in accordance with that set out in this privacy policy.

 

Data Controller (or Controller)

The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and methods of processing the personal data and the tools to be used, including the security measures to be adopted in relation to the functioning and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

 

This Application

The hardware or software tool through which the Personal Data of the Users are collected and processed.

 

Service

The Service provided by this Application as defined in the relative terms (if present) of this site/application.

 

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be understood as extending to all the current Member States of the European Union and the European Economic Area.

 

Cookie

A small piece of data placed in the device of the User.

 

Legal references

This privacy policy has been drawn up based on several regulatory provisions, including articles 13 And 14 Of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies only to this Application.