Information on the processing of personal data e Acquisition of consent  

According to the art. 13 of the General European Regulation n. 679/2016 (hereinafter GDPR), containing provisions for the protection of persons and other subjects regarding the processing of personal data, you communicate your personal data or those of third parties of which you are in legitimate possession to HONEY TRAVEL sas di Galeano Francesca. (hereinafter “HT”) which provides you with the following information about the processing of personal data:

• for the organization of a tourist package;
• to facilitate the purchase of connected tourist services;
• for the intermediation in the purchase of a tourist package organized by third parties or individual tourist services provided by third-party suppliers (and hoteliers, carriers and so on);
• for the intermediation in the purchase of ancillary insurance services and connected to the facilitated or individually purchased tourist packages / services (medical policies – baggage; cancellation; assistance to the traveler in difficulty; consumer credit loans);
• to fulfill the visa release assignment;
• to register on our website and / or the app or complete the forms on the website or in the app Purpose and legal basis of the processing.

Pursuant to articles 9 and 10 of the GDPR, you acknowledge that, due to the negotiation and / or establishment and / or execution of the contract, data attributable to the definition of “special categories of personal data” or data can be communicated to HT, already known as sensitive data, which reveal “ethnic racial origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, from biometrics intended to uniquely identify an individual, data relating to health or sexual life or sexual orientation of a person “or data relating to your habits and / or customs and habits related to travel needs or use of the tourist service. 

a) Purpose relating to the contractual service. Your personal data will be processed for the purpose of fulfilling the obligations arising from the negotiation and stipulation of the contract relating to the organization of the tourist package or in relation to the mandate to facilitate the purchase of the connected tourist services or the brokerage mandate for the purchase of individual tourist services or, in any case, for the execution of the obligations deriving from all the contractual relationships, including the negotiation phase, previously indicated, in order to allow HT to deliver the services in an optimal manner. In particular, the data will be processed for the following activities:

• the conclusion, management and execution of contractual relations between you and HT, including the aforementioned intermediation;
• respond to your requests;
• the communication of notices, relative to the package or services purchased tourists or other additional services and accessories (ad and information on the purchased tourist services; modification of the contractual conditions; cancellations, refunds and so on). 

b) Purpose of the law. Your personal data will also be processed for:

• execute legal obligations, regulations, national, EU and international regulations or deriving from provisions issued by Authorities legitimated to do so by law;
• ascertaining, exercising and / or defending an HT right in litigation, including judicial proceedings;
• fulfill the obligations set forth in the tax and accounting areas;
• fulfill obligations related to the legislation on safety and health of travelers;
• fulfill obligations related to passenger and freight transport regulations. 

c) Purposes related to the business and statistics. Your personal data will also be processed for purposes related to or relevant to the activity carried out by HT and for the anonymous processing of statistics and market research.

d) Further purpose. Furthermore, if you expressly consent, your personal data will be processed for the following purposes:

• Marketing purposes, which include:

1. promotional activities of HT and / or commercial partners, carried out both with automated methods (eg e-mail, text messages, instant messaging applications, etc.) and with non-automated methods (eg ordinary mail, telephone with operator, etc.). In particular, HT may use your e-mail or other contact address, provided at the time of providing the data or when purchasing tourist packages or services, to send you informational and promotional communications related to the services and similar products offered by HT and / or its business partners even without its consent, provided you do not object to such use.
HT’s business partners belong to the following product categories:

• accommodation activities;
• airlines / shipping companies; railway carriers; vectors on rubber;
• travel agencies and travel agency networks;
• insurance;

2. profiling activities, ie analysis of your travel preferences and market research, in order to improve the offer of services and commercial information presented by HT or by making them more in line with your interests. This activity can also be carried out through the provision of satisfaction questionnaires and / or the use of profiling cookies used when browsing our sites and apps.
The processing for Marketing purposes (therefore both for promotional and profiling activities) may take place under the condition that you have expressed your consent.

Nature of the provision of data and consequences of a possible refusal.

The provision of your personal data is optional, however, in the absence of the data required for the purposes indicated in points a) and b) (purposes relating to contractual and legal performance) the requested service or part of it cannot be performed and you do not you can take advantage of the opportunities mentioned above.

The provision of optional data will allow HT to improve the services offered in order to make them more and more responsive to the personal interests of its customers.

The provision of sensitive / particular personal data is voluntary; however, in the absence of such consent HT treatment may not be able to comply with certain obligations related to the performance of contractual services.

Categories of recipients of personal data.
Your information will not be disseminated. Your data may be communicated, exclusively for the purposes mentioned above, to the following categories of subjects:

• HT internal staff, in their capacity as appointee and / or data processor
• To the providers of tourist services included in the packages sold or that provide related services or individual services purchased from HT.
• Foreign countries for which there is a decision of Adequacy by the European Commission pursuant to art. 45 and / or adequate guarantees pursuant to art. 46 EU 2016/679, specifically as: Andorra, Argentina, Australia, PNR, Canada, FaerOer, Guernsey, Isle of Man, Israel, Jersey; New Zealand, Switzerland and Uruguay.
• Suppliers and third parties, even in non-EU countries, for the purpose of booking travel (hotels, airlines, sales operations, back office, chartering of charter flights and distribution lines, assistance, administration).
• External managers and subjects authorized to the treatment in charge of the management of the travel practice regularly entrusted and trained on data processing
• To insurance companies that provide coverings and ancillary services and connected with the packages and tourist services purchased;
• Persons, companies, associations or professional firms that provide services or activities of assistance and advice in favor of HT, in order to protect their own rights (for example, accountants, lawyers, tax consultants, auditors, consultants in operations auditing or due diligence, etc.).
• People, companies or agencies that provide marketing and analysis services or consultancy activities in favor of HT;
• Subjects whose right to access your data is recognized by provisions of law and secondary legislation or by instructions given by Authorities legitimated to do so by law, including airport, port, customs and border authorities. 

Transfer of personal data outside the European Union.

Your personal data may be transferred abroad to third party companies belonging or not to the European Union, always for the purposes indicated above.

In case of transfer of data to countries outside the European Union, HT will verify in advance that the rules applicable to the processing of data are respected and that there are guarantees that allow an adequate level of protection of natural persons, based on assessments given by the Commission of the European Union or, alternatively, that the recipient is contractually obliged to protect data with an adequate level comparable to the protection provided by the GDPR.    

Storage of personal data.

Personal data will be stored for a period not exceeding that necessary for achieving the purposes for which they were collected and subsequently processed. Personal data will be kept for the duration of the contract concluded by you and also for a subsequent period:

• within the terms established by current legislation;
• within the terms established by the regulations, including secondary regulations, which require the retention of data (for example, tax returns);
• within the period necessary to protect the rights of the data owner in the event of any disputes related to the provision of the service.

Personal data collected and processed for profiling purposes will be kept for a maximum period of ten (10) years after which they will be automatically deleted or permanently made anonymous.

Data Controller and Data Protection Officer

The owner of the processing of personal data is HONEY TRAVEL sas of Galeano Francesca based in Milan via V Maggio, 1.

For the purposes of processing the traveler’s data, HT has appointed a Data Protection Officer whose contact data, for the purpose of exercising the traveler’s rights arising from the provisions of the law concerning the processing of personal data, are the following:

mail: info@romegolftrip.com

odinary postal address: Via V Maggio, 1 20157 (MI)

Rights of the interested party

At any time, pursuant to articles 15 to 22 of the GDPR You have the right, also in relation to the profiling activity, to:

• ask the owner to access your personal data and information relating to them; the correction of inaccurate data or the integration of incomplete ones; the deletion of your personal data (if one of the conditions indicated in article 17, paragraph 1 of the GDPR occurs and in compliance with the exceptions provided in paragraph 3 of the same article); the limitation of the processing of your personal data (in the event of one of the hypotheses indicated in article 18, paragraph 1, of the GDPR);
• request and obtain from the owner – in cases where the legal basis of the processing is the contract or consent, and the same is carried out by automated means – your personal data in a structured and machine-readable format, also for the purpose of communicate such data to another data controller (so-called right to the portability of personal data);
• oppose the processing of your personal data at any time in the event of special situations affecting you;
• withdraw consent at any time, limited to cases in which the processing is based on your consent for one or more specific purposes and concerns common personal data (for example, date and place of birth or place of residence) or particular categories of data ( such as data revealing your racial origin, your political opinions, your religious beliefs, your health or sexual life). The treatment based on the consent and carried out prior to the revocation of the same preserves, however, its lawfulness
• lodge a complaint with a supervisory authority (Authority for the protection of personal data – www.garanteprivacy.it).

To exercise any of the aforementioned rights, it will be sufficient to write an email, containing the right that it intends to exercise, your name, surname and the email address used for registration to this portal, by sending this communication to: info@romegolftrip.com