Privacy Policy
This Application collects some Personal Data of its Users.
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Data Controller.
Bontempo Srl, Via Felisati, 67 – 30172 Venezia Mestre (Italy)
Owner’s email address: info@mygoldenkeytravel.com
Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, are: Cookies; Usage Data; first name; last name; phone number; email.
Full details on each type of Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of such Data.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who may have doubts about which Data is mandatory are encouraged to contact the Data Controller.
The possible use of Cookies – or other tracking tools – by this Application or the owners of third party services used by this Application, where not otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and warrants that he/she has the right to communicate or disseminate it, releasing the Owner from any liability towards third parties.
Method and place of processing of collected Data
Methods of processing
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators personnel) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis of the processing
The Data Controller processes Personal Data related to the User in case one of the following conditions exists:
the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
the processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
the processing is necessary for the performance of a legal obligation to which the Controller is subject;
processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
the processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.
However, it is always possible to ask the Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.
Location
The Data are processed at the Holder’s operational offices and at any other location where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the country where the User is located. To obtain more information about the location of the processing, the User may refer to the section on Personal Data processing details.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.
The User can verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Data Controller by contacting it at the contact details given at the beginning.
Retention Period
Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.
Purposes of the Data collected
User Data is collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Statistics, Contacting the User, Viewing content from external platforms, Heat mapping and session logging, Content and functionality performance testing (A/B testing), Contact management and message sending, Tag management, and Hosting and backend infrastructure.
To obtain detailed information about the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section “Personal Data Processing Details.”
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Contacting the User
Contact Form (This Application)
The User, by filling out the contact form with his/her Data, consents to their use to respond to requests for information, quotes, or any other nature indicated by the header of the form.
Personal Data processed: last name; email; first name; phone number.
Managing contacts and sending messages
These types of services allow the management of a database of email contacts, telephone contacts or contacts of any other type used to communicate with the User. These services may also allow for the collection of data related to the date and time of the User’s viewing of messages, as well as the User’s interaction with them, such as information about clicks on links embedded in messages.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an address management and email message delivery service provided by The Rocket Science Group, LLC.
Personal data processed: email.
Place of processing: United States – Privacy Policy.
Tag Management.
This type of services is functional for the centralized management of tags or scripts used on this Application.
The use of such services involves the flow of User Data through them and, if applicable, their retention.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data Processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Hosting and backend infrastructure
These types of services have the function of hosting Data and files that allow this Application to function, enable its distribution, and provide a ready-to-use infrastructure to deliver specific functionality of this Application.
Some services among those listed below, if any, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.
Aruba (Aruba S.p.A.).
Aruba is a hosting and backend service provided by Aruba S.p.A.
Personal Data processed: Usage Data.
Place of processing: Italy – Privacy Policy.
Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads in its advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: USA – Privacy Policy – Opt Out.
Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads in its advertising network. This Google Analytics integration anonymizes your IP address. Anonymization works by abbreviating within the borders of the member states of the European Union or other countries that are party to the Agreement on the European Economic Area the IP address of Users. Only in exceptional cases, the IP address will be sent to Google’s servers and abbreviated within the United States.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: Ireland – Privacy Policy – Opt Out.
Performance testing of content and functionality (A/B testing).
The services contained in this section allow the Data Controller to track and analyze the response from the User, in terms of traffic or behavior, in relation to changes in the structure, text or any other component of this Application.
Google Optimize (Google LLC)
Google Optimize is an A/B testing service provided by Google LLC (“Google”). Google may use Personal Data to contextualize and personalize ads in its ad network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. In the event that such a service is installed, it is possible that, even if Users do not use the service, it may collect traffic data related to the pages where it is installed.
Google Fonts (Google Inc.)
Google Fonts is a font style display service operated by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data, which allows this Application to integrate such content within its pages.
Personal Data processed: Usage Data; various types of Data as specified by the privacy policy of the service.
Place of processing: USA – Privacy Policy.
Google Maps Widget (Google Inc.)
Google Maps is a map display service operated by Google Inc. that allows this Application to integrate such content within its pages.
Personal Data Processed: Cookies; Usage Data.
Place of processing: USA – Privacy Policy.
YouTube Video Widget (Google Ireland Limited).
YouTube is a video content display service operated by Google Ireland Limited that allows this Application to integrate such content within its pages.
Personal Data Processed: Usage Data; Tracking Tools.
Place of processing: Ireland – Privacy Policy.
Information on how to disable interest-based advertisements.
In addition to any opt-out features provided by any of the services listed in this document, Users can read more about how to turn off interest-based advertisements in the appropriate section of the Cookie Policy.
User Rights
Users may exercise certain rights with respect to the Data processed by the Data Controller.
In particular, Users have the right to:
Revoke consent at any time. The User may revoke the previously expressed consent to the processing of his/her Personal Data.
object to the processing of their Data. The User may object to the processing of its Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.
access to one’s own Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
obtain restriction of processing. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
Receive their Data or have their Data transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.
Propose Complaint. The User may propose a complaint to the competent data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes Data with direct marketing purposes, Users may refer to the respective sections of this document.
How to Exercise Rights
To exercise the User’s rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Holder as soon as possible, in any case within one month.