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Privacy Policy

Pursuant to Art. 13 of EU Regulation 679/2016 -General Data Protection Regulation

With this information notice Pamela Moliterno intends to inform users visiting the website “[]” of the policy adopted with regard to the protection of personal data, emphasising its
commitment and attention to the protection of the privacy of visitors to the Site.

Please read our Privacy Policy carefully, which applies both if you access the Site and simply browse
using our services, without purchasing a reservation, and if you decide to make a reservation.
Please also read our general terms and conditions.

Navigating within the Site is free and does not require any registration, with the exception of certain
areas where you may freely and expressly provide a set of personal data to access certain services (e.g.
to stay updated on our activities and products, etc.). When we ask you to provide your personal data
in order to access such further services, we will always inform you in accordance with the EU
Regulation 679/2016 General Data Protection Regulation (the “Regulation”) about the purposes and
methods of use of the data, as well as your right to request the deletion of the data or its update at any

Pursuant to the Regulation, we provide you with the following information:

1. The Data Controller and Data Processors

Pamela Moliterno collects and processes your personal data, as Data Controller, in accordance with EU
Regulation 679/2016 General Data Protection Regulation.
For purely organisational and functional requirements, we may appoint certain service providers
functional to the management of the Site as data processors of users’ personal data for purposes strictly
connected and related to the provision of the services provided by the Site, including the intermediation
of tourist services: detailed information may be requested by means of a communication to be sent to

2. Types of personal data processed

No registration is required to access the Site. However, there are sections within the Site that are
functional for booking services (e.g. your data may be requested in order to complete the booking
process, etc.).
The data relating to connection and navigation within the Site (such as the URI-Uniform Resource
Identifier addresses of the resources requested, the time of the request, the method used to submit the
request to the server, the size of the file obtained in response, the numerical code indicating the status
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of the response given by the server (successful, error, etc.) and other parameters relating to the user’s
operating system and computer environment) are collected for the sole purpose of obtaining
anonymous statistical information on the use of the Site and to check its correct operation, and are
deleted immediately after processing. The data could be used to ascertain responsibility in the event of
hypothetical computer crimes to the detriment of the Site: to the exclusion of this possibility, the data
will be deleted after the time required to provide the services illustrated on the Site has elapsed.
With reference to data relating to navigation within the Site, see also point 6 below concerning the
profiling tools used by the Site.


3. Purpose

Data are collected and processed for purposes strictly related to the use of the Site, its services and the
booking of online tourist services. The purposes for which the data is used are set out in detail in the
specific notices provided by the Site in all cases of data collection. We therefore ask you to read the
information notices that from time to time illustrate the characteristics of the processing that will be
carried out (e.g. for booking experiences, or to keep in touch with us and our activities and offers, etc.).

4. Modalities, duration of data processing and scope of communication

The data may be processed both electronically and on paper (e.g. for the management of purchases on
the Site). The Company guarantees the lawful and correct processing of the personal data provided
through the Site, in full compliance with the regulations in force, as well as the maximum confidentiality
of the data provided during registration.
Any data provided by users will be processed for the time periods stipulated in the specific information
provided at the time of data collection.
Regarding the retention time of data collected through the use of profiling tools (e.g. cookies), see our
Cookie Policy.
The data will not be communicated or disclosed to third parties except to the extent and under the
conditions expressly indicated in the information notice provided from time to time.

5. Links to other sites

This information is provided only for the Site [] and not for other websites that may be consulted by
the user through links. The Company cannot be held responsible for the processing of personal data
provided by users to external parties or to any websites linked to this Site.
6. Profiling and/or customisation tools
The Company does not carry out any promotional and/or advertising communication activities
without the prior express consent of the user.
The Site uses ‘cookies’, both technical (i.e. to facilitate navigation and use of the Site) and profiling (i.e. to
analyse users and their behaviour and preferences, and to provide them with personalised
For a detailed explanation of the cookies used by the Site and how to deactivate them, please read our
Cookie Policy .

7. Place of data processing

Processing related to the services provided by the Site is carried out (i) at the domicile of the Data
Controller, as well as (ii) through companies that provide functional services for the management of the
Site, if necessary appointed as data processors. More detailed information may be requested by means
of a communication to be sent to

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).

8. Rights of data subjects

By means of a communication to be sent to the e-mail, you may at any time exercise
your rights under Articles 15 to 22 of the Rules, including:

Right of access: the data subject may request which data concerning him or her are processed,
the purposes of the processing, the categories of data processed, the recipients to whom the data
have been or will be communicated, the possible transfer of data outside the European Union,
the storage period of the data, the existence of an automated decision-making process
(including profiling), as well as the origin of the data if they are not collected from the data
subject (Art. 15 of the Regulation).

Right of rectification: the data subject may request the correction or updating of inaccurate data
or, taking into account the purpose of the processing, the integration of incomplete personal
data (Art. 16 of the Regulation).

Right to erasure (oblivion): (where applicable) the data subject has the right to obtain the
erasure of personal data concerning him/her, e.g. when the personal data are no longer
necessary for the purpose for which they were collected. However, it will not be possible to
request the deletion of data if they are necessary to fulfil a legal obligation (e.g. keeping of
accounts, security, etc.) or for the establishment, exercise or defence of a legal claim (Art. 17 of
the Regulation).

Right of restriction: the data subject may request that the processing of data be restricted, e.g.
when the accuracy of personal data is contested, for the period necessary to verify the accuracy
of such data (Art. 18 of the Regulation).

Right of notification: the data subject has the right to be informed of any rectification or erasure
or restriction of processing carried out in relation to personal data concerning him or her, and of
the recipients to whom they have been communicated (Art. 19 of the Regulation).

Right of portability: (where applicable) thedata subject has the right to receive data concerning
him/her in a structured, commonly used and machine-readable format (e.g. in .excel, .csv
format). This right is, however, limited to data processed by automated means and on the basis
of a contract with the data subject, or his/her consent. If technically feasible, it will be possible to
request transmission of the data directly to another data controller (Art. 20 of the Regulation).

Right to object: (where applicable) the data subject has the right to object at any time, on
grounds relating to his or her particular situation, to the processing of personal data concerning
him or her carried out, for example, in pursuit of a legitimate interest of the controller or a third
party (including profiling). You may also always object to the processing of data carried out for
direct marketing purposes, including profiling related to such direct marketing (Art. 21 of the

Right not to be subjected to automated decisions, including profiling: (where applicable) the
data subject has the right not to be subjected to a decision based solely on automated processing,
including profiling, which produces legal effects concerning him or her or significantly affects
him or her, except where the automated decision is necessary (i) for the conclusion or
performance of a contract between the data subject and a data controller, (ii) is provided for by
law, subject to measures and safeguards, (iii) is based on the data subject’s explicit consent (Art.
22 of the Regulation).

9. Who you can turn to in order to file a complaint

If you consider that the processing that concerns you violates the provisions of the Regulation, you can
always lodge a complaint with the Data Protection Authority (, or, if different,
with the Data Protection Authority of the country where you reside, work, or where you believe the
violation occurred.

10. Revision Clause

The Data Controller reserves the right to revise, amend or simply update, in whole or in part, at its sole
discretion, in any way and/or at any time, without prior notice, this Privacy Policy, also in consideration
of changes in laws or regulations on the protection of personal data. Changes and updates to the Privacy
Policy will be notified to users by means of publication on the Home Page of the Site, and will be binding
as soon as they are published and communicated. We therefore ask you to regularly access this section
to check the publication of the most recent and updated Privacy Policy.