Information on the processing of personal data and acquisition of consent

Marina Giuliante, Travel consultant & Event Planner and owner of the website , (hereinafter referred to as “IW”), as data controller, pursuant to art. 13 of the General European Regulation on the Protection of Personal Data 679/2016 (hereinafter referred to as “GDPR”), provides the following information about the processing of personal data that you, as data subject, communicated to IW:


  1. a) for the organization of a tourist package *;
    b) to facilitate the purchase of related tourist services *;
    c) for the purchase of a package organized by third parties or of individual tourist services provided by third party suppliers (e.g. hoteliers, carriers,) *;
    d) for the purchase of financial services/insurance accessories and linked to tourist packages/tourist services facilitated or purchased individually (medical insurance, baggage insurance; trip cancellation insurance; assistance to the traveller in difficulty; financing of consumer credit) *;
    e) to fulfil visa application *;
  2. f) by filling in: the form on IW’s website, or the sales proposal booking form and/or sale contract booking confirmation form sent by email*, or any other form (e.g. requests by a tourist service provider), or any communication of data through one of the social networks indicated on IW’s website.This privacy policy relates only to the above-mentioned website and not to other sites that may be accessed by the user via links on the website.* in collaboration with and under the technical direction of Viaggimmagine Srl Tour Operator– Via G. Govone, 30 Milan – License 371049/2016


Purpose and legal basis of processing.
Among the personal data you provide there may also be some personal data defined by the GDPR and the Italian harmonisation legislation as “sensitive” (relating to racial or ethnic origin, religious, philosophical convictions, political opinions, trade union membership, health or sex life) and “judicial”  (which may reveal the existence of certain judicial measures or the status of accused or suspected).
The above mentioned data will be processed for the following purposes and only with your express consent.


  1. Purposes relating to the contract.
    Your personal data will be processed for the purpose of fulfilling the obligations arising from the negotiation and the contract relating to:
    – organization of the tourist package;
    – the mandate to purchase tourist services (also linked to the organised tourist package);
    – the mandate for purchasing individual tourist services;
    and, in any case, for the performance of the obligations arising from all contractual relationships, including the negotiation, as set out in the aforementioned points from a) to f), in order to enable IW to provide the best service, in particular for:


1.a. the conclusion, management and execution of the contractual relations between you and the responsible travel agency through IW;
1.b. responding to your requests;
1.c. the communication of notices relating to the tourist package or the tourist services purchased or to other additional services and accessories (e.g. additional information about the purchased tourist services; modification of the contract terms; cancellations);


  1. Purposes of the law.
    Your personal data will also be processed for:
    2.a. fulfilling and enforcing legal obligations arising from national, international and European Union regulations and laws or from provisions issued by an authorized Public Authority;
    2.b. ascertaining, exercising and/or defending a right of IW in litigation (including judicial

2.c. complying with tax and accounting obligations;
2.d. complying with obligations related to safety and health of travellers regulations;
2.e. fulfilling obligations related to passenger and freight transport regulations.


3.Business and statistical purposes.
Your personal data will also be processed for purposes relevant to IW’s activities and for the anonymous processing of statistics and market research.

4. Further purposes to be achieved.
In addition, if you expressly consent, your personal data will be processed for the following purposes:


4.1. Marketing purposes, which include:

4.1.a. promotional activities of IW, and/or IW’s business partners, carried out either through automated (e.g. email, sms, instant messaging applications, etc.) or through non-automated means (e.g. ordinary mail, telephone with operator, etc.). In particular, IW may use your email address, provided at the time of purchase of tourist packages or services, to send you informative and promotional communications related to services and similar products and offered by IW and/or IW’s commercial partners even without your consent, provided you do not oppose such use.

IW’s business partners belong to the following commercial categories:
– hotel, resort, b&b and similar activities;
– airlines and shipping companies;

– rail and road carriers;

– travel agencies and travel agency networks;
– insurance companies.


4.2.b. profiling activities, such as analysis of your travel preferences and market research, in order to improve IW’s offer of services and commercial information and making them more in line with your interests. This activity may also take place through satisfaction questionnaires and/or the use of profiling cookies used during navigation on the website.
The processing for Marketing purposes (for both promotional and profiling activities) can only take place with your consent.


Nature of data provision and consequences of any refusal.
The provision of your personal data is optional, however, in the absence of the data required for the purposes indicated in points 1) and 2) (purposes relating to the contract and purposes of the law), the service requested, or part of it, will not be performed and you will not be able to take advantage of the above mentioned opportunities. The provision of optional data will allow IW to improve the offered services in order to make them more responsive to your personal interests. The provision of sensitive personal data is voluntary; however, in the absence of such consent, IW may not be able to fulfil certain contractual obligations related to the processing of such data.


Categories of recipients of personal data.
Your data will not be disseminated. Your data may be communicated, exclusively for the above mentioned purposes, to the following subjects and categories of subjects:
– Viaggimmagine Srl – Via G. Govone 30, Milano – as responsible travel agency (License 371049/2016)
– any possible collaborators of IW designated as controller or if it is necessary for the execution of the tourist package contract;
– suppliers of tourist services included in the tourist packages sold, or providing related services or individual services purchased through IW;

– insurance companies which provide ancillary cover in connection with the tourist package and tourist services purchased;
– persons, companies, associations or firms providing services or assistance and advice to IW in order to protect their rights (for example: accountants, lawyers, tax advisers, auditors, consultants in the area of auditing or due diligence, etc.);
– persons, companies or agencies providing marketing and analysis services or consultancy for IW;

– persons whose right to access to your data is recognized by law and secondary legislation or by provisions of Public Authorities which are legitimised 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 parties belonging or not to the European Unity, only for the above mentioned purposes. In the event of data transfer to countries outside the European Union, these countries will ensure an adequate level of protection based on a specific decision of the European Commission or, alternatively, the recipient will be contractually obliged to provide data protection at an appropriate level comparable to the protection provided by the GDPR.


Storage of personal data.
Personal data will be kept for no longer than is necessary to achieve the purposes for which they were collected and subsequently processed.
Your personal data will be retained for the duration of your contract and also for a later period, namely:
1. within the time limits laid down in the legislation in force;

  1. within the time limits laid down in legislation which also require the retention of data (for example tax returns);
    3. within the period necessary to protect the rights of the data controller in the event of any dispute relating to the contract.
    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 made permanently anonymous.


Data processing controller.

The data controller is Marina Giuliante – Via Colle Calcagno, 31 – Velletri.

Processor – Data Protection Officer (DPD or DPO).
The Data Protection Officer is Marina Giuliante, who can be contacted at the following email address: or by registered mail at the above mentioned address.


Rights of the data subject.
At any time, pursuant to Articles. 15 to 22 of the GDPR, you have the right to (also in relation to the profiling activity):
– ask the controller for access to your personal data and information about them; rectification of inaccurate data or integration of incomplete data; deletion of personal data concerning you (upon the occurrence of one of the conditions indicated in art. 17, paragraph 1 of the GDPR and in compliance with the exceptions provided in paragraph 3 of the same article); limitation of the processing of your personal data (to use one of the hypotheses indicated in art. 18, paragraph 1 of the GDPR);

– request and obtain from the controller – in cases where the legal basis for processing is the contract or consent, and the same is carried out by automated means – your personal data in a structured and readable format for automatic device, also for the purpose of communicating such data to another controller (so called right to the portability of personal data);
– object at any time to the processing of your personal data due to special situations concerning you;

withdraw consent at any time, limited to cases where 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 sensitive data revealing your racial origin, your political opinions, your religious beliefs, your health or your sex life). In any case, the processing based on consent and carried out prior to the revocation of the same maintains its legal validity;
– Complaint to a supervisory authority (Data Protection Authority –

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