Bradipo Travel Privacy Statement

Bradipo Travel Designer Spa

Informative Briefing According to Legislative Decree No. 196/2003

Dear Customer,
According to Article 13 of the Personal Data Protection Act (Legislative Decree 196/03), we are obligated to inform the data subject on processing elements related to the aims and methods of the same, the obligatory and optional nature of giving your data, the consequences of refusing to answer, the subjects and categories which may be authorised to access your personal data or which may learn them in the capacity as managers and delegates, the scope of diffusion of said data and the rights of the data subject.
Therefore, Bradipo Travel SpA with which you have established relations is hereby providing you with the following information. Pertanto, la società Bradipo Travel Spa con la quale ha instaurato rapporti, vi adempie comunicandoLe le seguenti informazioni.

AIMS
Your data are collected for the following aims:
- Analysis of your spending habits and choices, sending advertising material, conducting promotions even in connection to organisation of events.
- Preparing travel offers and personalised leisure services
- Planning your trip and experiences comprised in it

PROCESSING METHODS
In connection with said aims, your personal data are processed by paper, information technology (and screen-based) instruments to guarantee their security and privacy, as well as to fully comply with the requirements of Legislative Decree 196/03. This informative briefing is provided for data: collected directly from the data subject (paragraph 1, Art. 13 of Legislative Decree 196/03); collected from others (paragraph 1, Art. 13 of said decree); obtained from public registers, lists, deeds or documents anyone may know (paragraph 1, letter C of Art. 24), limited to the manners established by regulations on their knowledge.

NATURE OF THE PROCESSED DATA
The data to be processed are generally ordinary, as they essentially consist of personal identifying elements. If you specify in the proper data fields that they are sensitive data according to letter D of Article 4 of said decree, they shall be processed by us within the limits prescribed by the Privacy Act. We remind you that letter D of Article 4 of said decree defines sensitive data as personal data “susceptible to reveal racial and ethnic origin, religious, philosophical or other sorts of convictions, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data susceptible to reveal state of health or sex life”.

NATURE OF GIVING AND CONSEQUENCES OF REFUSING TO ANSWER Providing your data is at times:
- Obligatory according to laws, regulations and community provisions; in these cases your refusal shall make it impossible to execute the contract stipulated;
- Conditional for the possibility of efficaciously fulfilling contract obligations undertaken; in these cases your refusal shall impact the quality of performance of the contract, in which case Bradipo Travel S.r.l. retains the right to revise the contract conditions;
- Optional for the aims of conducting analysis of your spending habits and choices, sending advertising material, and conducting promotions; in these cases your refusal shall prevent us from conducting analysis of our spending habits and choices, sending advertising material and conducting promotions.

COMMUNICATION
The above-mentioned data may be communicated if necessary to only the categories of subjects specified below:
- The Post Office or other mail delivery companies;
- Businesses affiliated with the group Bradipo Travel SpA belongs to;
- Trade partners of Bradipo Travel SpA;
- Public corporations for legal, regulatory or community provision aims;

The above-mentioned data may be disclosed to the following if necessary:
- Administrative, control and management bodies;
- Persons assigned to surveying and rendering services;
- Employees in charge of accounting and billing;
- Employees in charge of marketing services;
- Persons assigned to surveying customer satisfaction and public relations;
- Self-employed, project-related and occasional workers.

However your data shall not be diffused.

RIGHTS OF THE DATA SUBJECT
Besides the information contained in this informative briefing, you may at any time contact the processing manager to exercise the following rights foreseen by Article 7 of the Privacy Act, which has been reproduced in full below.

Legislative Decree No.196/2003, Art. 7 – Right to Access Personal Data and Other Rights

1. The data subject is entitled to obtain confirmation as to the existence of his or her personal data, even if not yet recorded, and receive them in an easy to understand manner.
2. The data subject is entitled to obtain information on:
a) The source of the personal data;
b) Processing aims and methods;
c) The applied logic in case processing is done with the use of electronic instruments;
d) Identifying details on the controller, processors and designated agent according to paragraph 2 of Article 5;
e) Individuals or groups of individuals whom personal data may be communicated to or who may access them in their capacity as designated agent in Italy, processors or delegates.
3. The data subject is entitled to obtain:
a) Update, correction or supplementation of data when interested in doing so;
b) Cancellation, transformation into anonymous form or blocking of data processed against the law, including data whose continued storage is unnecessary for the purposes for which they were collected or processed;
c) Certification that the operations as set forth in the foregoing points A and B have been disclosed, including as regards their contents, whom the data have been communicated or distributed to, except when doing this duty is impossible or entails use of disproportionate means to the right protected.
4. The data subject is also entitled to fully or partially oppose:
a) Processing of his or her personal data for justified reasons even if pertinent to the purpose of collection;
b) Processing of his or her personal data for the purpose of sending advertising or direct sales material or for conducting market research or sending business communication.

DATA PROCESSOR
The data processor is Bradipo Travel SpA with registered office at Via Boito 8, 20121 Milan, VAT Reg. No. 05927220961
The processing manager is Mr. Marcello Piccardo.
The data subject may ask for further information on data processing at the electronic mail address info@bradipotravel.com or by viewing the provision in force at the Internet address www.garanteprivacy.it.