EU Regulation 679/2016 -General Data Protection Regulation

The site https://puglia-experiences.com/ – uses cookies and/or other tracking technologies for the following
purposes:

• enable the proper functioning of the Site and the provision of related services;
• carry out aggregate statistical analysis to understand and improve the user’s browsing
experience (e.g. count the number of visitors to the site; see how successful a specific
advertising campaign has been; understand how popular a product or service is; etc.), and
• analyse the preferences and navigation of users visiting the Site in order to send
advertisements in line with their preferences and personalise the content.

The information below refers to both the use of “cookies” and other tracking tools that may be used
(except where otherwise indicated). For convenience we will use the term “cookies” to refer to all
different tracking technologies, except where expressly stated otherwise.

Information on who we are, how we process personal data, how you can contact us, what your privacy
rights are and how to exercise them can be found in our Privacy Policy of which this
Cooke Policy is an integral part.

Pursuant to Article 13 of EU Regulation 2016/679 General Data Protection Regulation (the “Regulation”)
and Directive 58/2002 as amended, Pamela Moliterno provides the following information.

1. What are cookies

Cookies are text files that are sent from a web server (i.e. the computer where the website visited is
“hosted”) to the user’s browser (Microsoft Edge, Mozzilla Firefox, Google Chrome, Opera, Safari, etc.)
and stored in the device, fixed or mobile (computer, smartphone, tablet), used for the user’s navigation.
The cookie (but possibly also another tracking tool) allows the Site to identify the user’s device, through
the information stored in it, every time the user reconnects to the Site through that device.

Through the use of cookies (or other tracking tools) we can make it easier for users to navigate the Site,
as well as analyse their preferences and tastes by verifying their navigation (profiling activities), and
consequently offer products and services that are more consistent with the user’s interests and
expectations (e.g. by displaying advertisements in line with the user’s interests).

Cookies can be either ‘session’ (when they are stored only for the duration of the browsing session on the
Site and are deleted when the browser is closed), or ‘persistent’ (they are stored for a longer time, until
they expire or are deleted by the user). Furthermore, cookies or other tracking tools can be either “first
party” (when they are created and used only by the owner of the website that issued them and are not
transferred to third parties) or “third party” (when they are issued and managed by parties other than
the Company).

An example of other tracking tools are the ‘tracking pixels’, small code fragments integrated into the
website that, once downloaded on the user’s browser, allow the social media provider (e.g. Facebook
or Instagram) to monitor the user’s session, collecting data for user analysis and profiling purposes.

2. What types of cookies (or tracking tools) the Site uses

Cookies and technical or necessary tools

The Site uses technical cookies to allow normal and efficient navigation and enjoyment of the content.
Their use enables us to facilitate user navigation, for example by remembering the data provided by the
user when filling in forms on the Site (so-calleduser input cookies), to customise the site interface based
on the preferences indicated by the user, etc.
These cookies can be either first-party or third-party cookies and do not require the acquisition of the
user’s prior and express consent as they are strictly necessary to provide the service requested by the
user of the Site.

Analytical cookies

Analytical cookies, including third party cookies, allow us to understand how the Site is used by users
(e.g. number of visitors, pages visited, time spent on the site, etc.); no information about your identity
or any personal data is collected with these cookies. The information is processed in aggregate form and
requires the user’s prior and express consent. Consent will only be required when you first access the
Site: thereafter, through the use of a technical cookie, we will store the consent given/refused in order
to allow you to access the Site directly the next time you log in (see point 4).
It is understood that consent may be revoked at any time in the manner specified in point 4 of the Cookie
Policy.

Profiling (or marketing) cookies

These are cookies or other tools designed to create user profiles, for example in order to send advertising
messages that are consistent with the user’s preferences and navigation (e.g. by using these cookies, the
user will be able to see advertising content for products in which he/she has expressed an interest on
other sites, or will be able to receive content relating to products visited and saved in the shopping cart,
etc.). These cookies and tracking tools can be either first-party or third-party, session or permanent.
Other tracking tools (e.g. Facebook pixels) also work in a similar way (e.g. by allowing the user to see
advertisements on the social network).
The use of these cookies and tools requires the express and informed consent of the user. Consent will
only be requested the first time you access the Site: thereafter, through the use of a technical cookie, we
will store the consent given/refused in order to allow you to log in directly the next time you access the
Site (see point 4).
It is understood that consent may be revoked at any time in the manner specified in point 4 of the Cookie
Policy.

Third-party cookies

The Site uses ‘third-party’ cookies and tracking tools (e.g. Google Analytics; social network cookies; etc.),
i.e. tools that are issued and managed by parties other than the Company.
In some cases, social buttons/widgets (social plug-ins), i.e. those particular ‘buttons’ depicting the icons
of social networks such as Facebook, Instagram, Twitter, etc., can also be found on the Site. These
buttons allow users who are browsing the Site to reach and interact with a ‘click’ directly with the social
networks. (see point 6 for more information).

3. Details of the cookies and tracking tools used by the Site

The details of the cookies and tracking tools used by the Site can be checked by means of:
– selecting the ‘Show preferences’ button in the information ‘banner’; or
– by selecting the ‘cookies’ command on all screens of the Site.
Within the ‘Cookie preferences’ area, by selecting ‘details’ you can check the list of cookies/tracking tools
used with indication of (i) name, (ii) provider, (iii) purpose and type, (iv) duration/expiry.

4. Your consent

When accessing the Site, the user will see a ‘banner’ warning about cookies and other tracking tools that
may be used.

The banner provides concise information to enable the user to understand which cookies/tools are
used and for what purposes; furthermore, using the ‘Show preferences’ button the user can also check in
detail which types of cookies and tools are used.

The user can then freely choose whether and which cookies and other tracking tools to authorise.
The banner will only be displayed the first time the user accesses the Site: subsequently, thanks to the
use of a technical cookie, we will store whether the user has given or withheld consent to allow direct
access to the pages of the Site without having to display the “banner” again, except in particular cases
(e.g. if the user deletes cookies, if it is necessary to update users on the cookies used, etc.).

NB: consent may be revoked at any time by simply selecting the ‘cookies’ command at the bottom of
each page of the Site.

5. Deactivating/deleting cookies via web browser

You can in any case deactivate/activate or delete cookies at any time by using the settings of your web
browser. In particular, if you do not wish to receive cookies, you can set your browser in such a way
that you are warned of the presence of a cookie and can decide whether or not to accept it; you can also
automatically reject all cookies by activating the appropriate option in your browser. You can also delete
specific cookies that have already been stored in your browser, or block specific websites from storing
cookies on your computer, or block third-party cookies.
Each browser (Firefox, Chrome, Edge, Safari, Opera, etc.) has its own cookie management
methodology: in the settings or preferences panel, it is possible to change/manage cookie parameters
and/or delete cookies.

In order to do so, please consult the information in your browser’s User Manual (so-called Help Page)
or click on the following links:

• Edge
• Chrome
• Firefox
• Safari
• Opera.

You can also manage your cookie preferences at http://www.youronlinechoices.com.

6. Who will have access to the data

Data collected via cookies and other tracking tools will not be disclosed to the public and will be
processed by authorised persons of the Company.

In order to manage the Site and, if you provide your consent, to analyse your preferences, browsing
and to allow you to view content and promotional announcements that may be of interest to you, your
data will be processed by companies entrusted with the management of the Site, where appropriate as
Data Processors.

6.1 Social networks

Data relating to navigation within the Site may be transmitted to social networks (such as Facebook,
Instagram, etc.) for example:

1. to enable the sharing of content on social networks (e.g. if you use the sharing function – a socalled social plug-in – you will be able to publish, and thus share, content of interest within your
social profile);
2. to display promotional and advertising content when visiting social networks (e.g., the social
network may display advertisements relating to the Company and products that have been
viewed within the Site). The data relating to the user’s navigation within the Site and collected
by means of cookies or other tracking tools (e.g. pixels) will then be shared with the social
network which, by identifying the user, will make it display advertising content, then providing
the Company with statistics on the advertising campaigns carried out.

For such processing, the social networks will process the data – as co-processors (Art. 26 of the GDPR) –
to the extent necessary to enable – for example – content to be shared on their social pages or
news/advertising to be displayed.

Below is some information on the processing of Social Network data on the Site:

Facebook /Instagram

The data controller is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour,
Dublin 2 Ireland.
A co-ownership agreement (Art. 26 of the Regulation) governs the processing of personal data carried
out by means of the tracking tools provided by Facebook and present on the Site: the agreement defines
the respective responsibilities with regard to compliance with the obligations laid down in the
Regulation in relation to joint processing. A copy of the agreement is available at the following link:
https://it-it.facebook.com/legal/controller_addendum
Facebook, on the other hand, is the autonomous controller of the subsequent processing of user data.
As data controller, Facebook is responsible for providing the data subject with information on the
processing carried out or for enabling the exercise of privacy rights (Art. 15 – 20 of the Regulation).

The Site uses Facebook cookies and tracking tools (e.g. pixels) to (i) display customised promotional
and advertising content to users, (ii) provide statistical reports on advertising campaigns and users’
browsing of the Site, (iii) improve the publication of content on the Site.
For these purposes, data relating to the user’s navigation within the Site and collected by means of
cookies or other tracking tools are shared with Facebook.
Details on how Facebook processes data, the relevant legal basis for processing and how you can
exercise your privacy rights under the Regulation against Facebook are available at
https://www.facebook.com/about/privacy.

The Facebook Data Protection Officer can be contacted at:
https://www.facebook.com/help/contact/540977946302970

For more information on the processing carried out by social networks, please also check the privacy
policy provided by your social network.

Klaviyo

Klaviyo is the autonomous owner of the user data processing carried out. As data controller, Klaviyo is
responsible for providing data subjects with information on the processing carried out or for enabling
the exercise of privacy rights (Art. 15 – 20 of the Regulation).

The Site uses Klaviyo’s cookies and tracking tools (e.g., pixels) to (i) display customised promotional
and advertising content to users, (ii) provide statistical reports on advertising campaigns and users’
browsing of the Site, and (iii) improve the publication of content on the Site.
For these purposes, data relating to the user’s navigation within the Site and collected through cookies
or other tracking tools are shared with Klaviyo.
Details on how Klaviyo processes data, the relevant legal bases for processing and how to exercise your
privacy rights under the Regulation vis-à-vis Klaviyo are available at
https://www.klaviyo.com/marketing-resources/data-privacy

Klaviyo’s Data Protection Officer can be contacted at: klaviyo.com/support

7. Transfer of data outside the European Union

Data are not transferred outside the European Union/European Economic Area as our suppliers use
technologies located within the EU/EEA. In some cases, however, data may be transferred to third
countries with the application of transfer protection measures approved by the European Commission
(in particular standard contractual clauses and binding corporate rules).

Data collected using cookies and other social network tracking tools will instead be transferred outside
the European Union (e.g. to the United States): in particular, data collected through the Site by Meta
Platforms Ireland Limited (e.g. Facebook/Instagram) may be transferred. The applicable privacy
legislation provides that a specific consent to the transfer is not required when it is made to a country
that guarantees an adequate level of protection (art. 45 of the Regulation) or on the basis of the adoption
of adequate safeguards (articles 46 and 47 of the Regulation), and in particular on the basis of the
adoption of binding rules for groups of companies or the adoption of contractual clauses approved by
the European Commission: the transfer made by Meta Platforms Ireland Limited is governed by these
contractual clauses (see https://www.facebook.com/help/566994660333381?ref=dp).

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For more information about the data processing carried out through the Site (in particular about who
we are, how we process data, how to contact us, what your privacy rights are and how to exercise
them), please refer to our Privacy Policy.