Eleutheria S.r.l. (Roads to Rome Private Tours) LIMITED PRIVACY AND COOKIES POLICY (last modified on 12/08/2020)
This Privacy and Cookies Policy (the “Policy“) refers to the website www.roadstorometours.com and www.roadstorome.com and any Eleutheria S.r.l. (Roads to Rome Private Tours) mobile application through which the user (either “you” or “user”) access our website (the “Website“). The Website is operated by Eleutheria S.r.l. (Roads to Rome Private Tours) (“we“, “our” or “Eleutheria S.r.l. – Roads to Rome Private Tours“), whose principal place of business is at via dei Cappuccini, 22, Benevento (Italy).
This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and applies to all of your personal data irrespective of the medium or method by which we obtained/received your personal data.
In this Policy, the term “personal data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).
Please read the following carefully. Entering into this Website and providing your consent to our use of your personal data in accordance with the terms of this Policy indicates that the user has reviewed this Policy and has agreed to be bound by it as well as our Ts&Cs and Data Processing Terms. You will be required to expressly accept and consent to this Policy before we process your personal data. If you do not agree to these terms you must leave the Website immediately. We will keep a record of your consent in this regard. If you no longer consent to our processing of your personal data, you may request that we cease such processing by emailing firstname.lastname@example.org.
WHAT INFORMATION DO WE COLLECT?
We fully respect your right to privacy in relation to your interactions with the Website and endeavour to guarantee to be transparent in our dealings with you as to what information we will collect and how we will use your information.
We only collect and use individual user details where we have your consent to do so, or it is necessary for the performance of a contract between us and you, or it is necessary for our legitimate interests and where we are legally entitled to do so. Where you have provided your consent to our collection and use of your personal data, you are entitled to withdraw such consent by notice to us.
HOW DO WE COLLECT INFORMATION FROM YOU?
We collect IP addresses from visitors to our Website (an IP address is a number that can uniquely identify a specific computer or other network device on the internet). This allows us to identify the location of users, to block disruptive use and to establish the number of visits from different countries. We analyse this data for trend and statistics reasons, such as which parts of our Website users are visiting and how long they spend there. [We may personalise the contents based upon the location of users] .
A cookie is a small text file that is placed on your hard disk by a web server which enables a website and/or mobile app to recognise repeat users, facilitate the user’s ongoing access to and use of a website and/or the mobile app and allows the website and/or mobile app to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising.
Certain cookies are necessary in order for you to use our Websites. These cookies are either ‘in-session’, which expire when you leave the Website, or kept for a short duration of up to 1 week. These cookies do not contain any personal data. However, you can delete them via your browser if you wish to, but this will restrict the functions that you’re able to carry out on our sites.
|myvisit||Essential||Personalise our website, and implement shopping cart feature||At end of session|
|recentlyVisited||Essential||Display recently viewed products||1 week|
|Session||Essential||Store your website preferences||At end of session|
|Live Person||Essential||Provide Live chat features with our customer support team||1 day|
These cookies are usually supplied by our business partners and help us to filter out irrelevant messages or pop-ups and to make sure that we only display information that’s interesting and relevant to you. We also use some non-essential cookies for analytical purposes.
|Google Analytics||Tracking and analysis||Analyse and report on the use of our website||Up to 2 years|
|VWO||Tracking and analysis||Test performance of improvements to the website||1 day|
|Hotjar||Tracking and survey tool||Hotjar is an analytics and feedback tool to help understand how our website is used and improve usability.||1 year|
|Dotdigital||Marketing||Email Marketing Platform||At end of session|
|Steelhouse||Marketing||Display Advertising||1 year|
|Double Click||Marketing||Google Advertising Suite||1 year|
|Bing||Marketing||Search Engine Advertising||1 year|
|Marketing||Social Media Advertising||1 year|
|Marketing||Social Media Advertising||1 year|
|Marketing||Social Media Advertising||1 year|
|Marketing||Social Media Advertising||1 year|
You should also be aware that there are cookies which are found in other companies’ internet tools which we are using to enhance the Website. You may see ‘social buttons’ during your use of the Website, including but not limited to Twitter, YouTube, and Facebook which enable you to share or bookmark certain web pages. These websites have their own cookies, which are controlled by them.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
Applications developed in connection with the Website for mobile devices will operate and capture information as set out above and are also subject to this Policy. Applications developed by us but deployed on other platforms such as social media channels may provide feedback to us on activity and usage specific to a user.
Note: If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to us. Users without this consent are not allowed to provide us with personal information.
HOW DO WE USE THE INFORMATION WE COLLECT?
We collect different types of information about our users for the following reasons:
- to personalise the way our content is presented to you and to ensure that content from our Website is presented in the most effective manner for you and for your computer/device;
- to help us to monitor and improve the services we offer, including the Website. As part of this, we may use and disclose information in aggregate (so that no individuals are identified);
- to carry out any legal obligations arising from your interaction with the Website; and
- to allow you to participate in interactive features of our service, when you choose to do so.
With your consent, we may also use your data to provide you with information about goods and services from third parties which may be of interest to you. By providing your consent, you agree to be contacted by such third parties.
The personal data that we collect from you may be transferred to, and stored by Eleutheria S.r.l. (Roads to Rome Private Tours). It may also be processed by staff of Eleutheria S.r.l. (Roads to Rome Private Tours). By submitting your personal data, you agree to this transfer, storing or processing of your personal data by Eleutheria S.r.l. (Roads to Rome Private Tours) for the purposes set out in this Policy.
ARE THERE CASES WHERE WE MAY USE YOUR INFORMATION TO CONTACT YOU?
We may contact you:
- for administration reasons related to the service to which you have purchased or signed up (e.g. to notify you that a particular service, activity or online content is unavailable, has been cancelled or suspended for maintenance, or in response to a question that you ask us);
- to provide you with information about our services, activities or online content. You should only receive e-newsletters or similar correspondence and updates from citywonders.com if you have agreed to in response to any contact you have made with us, e.g. on the checkout page, or on e-newsletter subscription forms, by email or via the ‘How to contact us’ facility. It will be made clear to you where you have these choices, for example, by providing tick boxes on the checkout page for you to decide whether you wish to receive e-newsletters, or clearly stating on the e-newsletter your subscription preference; and
- to invite you to participate in surveys about our services (participation is always voluntary).
Where we wish to use your personal information in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed in this Policy.
WHAT RIGHTS DO YOU HAVE?
As a data subject, you have the following rights under the Data Protection Legislation:
- the right of access to personal data relating to you;
- the right to correct any mistakes in your personal data;
- the right to ask us to stop contacting you with direct marketing;
- rights in relation to automated decision taking;
- the right to restrict or prevent your personal data being processed;
- the right to have your personal data ported to another data controller;
- the right to erasure; and
- the right to complain to the DPC if you believe we have not handled your personal data in accordance with the Data Protection Legislation.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see ‘How to contact us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Right to access to personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
- a summary of such personal data and the categories of personal data held;
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
- details of the period for which it is held (or the criteria we use to determine how long it is held);
- details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
- any information available about the source of that data;
- whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
- where your personal data are transferred out of the EEA, what safeguards are in place.
Requests for your personal data must be made to us (see ‘How to contact us’ below) specifying what personal data you need access to, and a copy will be retained on your personnel file. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your personal data or correct any mistakes in your personal data
You can require us to correct any mistakes in your personal data which we hold free of charge. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us’ below);
- let us have enough information to identify you (e.g. name, registration details); and
- let us know the information that is incorrect and what it should be replaced with.
If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please email, call or write to us (see ‘How can you contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 5 days for this to take place.
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’
Right to restrict or prevent processing of personal data
In accordance with Data Processing Legislation, you may request that we stop processing your personal data temporarily if:
- you do not think that your data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
- the processing is unlawful but you do not want us to erase your data;
- we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
- you have objected to processing because you believe that your interests should override our legitimate interests.
If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:
- you consent to such processing;
- the processing is necessary for the exercise or defence of legal claims;
- the processing is necessary for the protection of the rights of other individuals or legal persons; or
- the processing is necessary for public interest reasons.
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.
The right to data portability also only applies where:
- the processing is based on your consent or for the performance of a contract; and
- the processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us to erase your personal data where:
- you do not believe that we need your personal data in order to process it for the purposes set out in this Policy;
- if you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
- you object to our processing and we do not have any legitimate interests that mean we can continue to process your personal data;
- your data has been processed unlawfully or have not been erased when it should have been; or
- the personal data have to be erased to comply with law.
We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.
Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the Website or otherwise engage in any disruptive behavior on any Eleutheria S.r.l. (Roads to Rome Private Tours) service, we may remove such content.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
DO WE PROTECT YOUR PERSONAL INFORMATION?
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to personal data to employees, contractors and agents who need to know such personal data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, the Website contains hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of your personal data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Website and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the Website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.
We will notify serious data breaches to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A personal data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your personal data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
- we have implemented appropriate technical and organisational measures that render the personal data unintelligible to anyone not authorised to access it, such as encryption; or
- we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
- it would involve disproportionate effort, in which case we may make a public communication instead.
WHO WE SHARE DATA WITH
We may disclose your personal information to any company or other corporate entity under the control and direction of Eleutheria S.r.l. (Roads to Rome Private Tours).
As stated above, with your consent, we may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these. We reserve the right to access and disclose personal data in compliance with Data Protection Legislation.
We may also use service providers to help us run the Website or services available on the Website. Any third parties who access your data in the course of providing services on our behalf are subject to strict contractual restrictions to ensure that your data is protected, in compliance with Data Protection Legislation.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. The safeguards in place with regard to the transfer of your personal data outside of the EEA are the entry by us into appropriate contracts with all transferees of such personal data.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
RETENTION OF PERSONAL DATA
Any information that you provide to us will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance, and our obligations under Data Protection Legislation.
In general, your personal data will be retained by us for only as long as is necessary for the processing set out in this Policy.
We may collect financial information such as credit card information when a payment is made via the Website. We do not share this information with anyone outside of Eleutheria S.r.l. (Roads to Rome Private Tours), other than other companies and individuals we employ to perform functions on our behalf such as sending mail and processing payments and this information will not be kept for longer than necessary for providing the services. Any such third party service providers will be subject to contractual provisions which safeguard the security of your personal data. Any such company or individual will have access to personal data needed to perform these functions but may not use such personal data for any other purpose.
If you choose not to progress with the order or your payment method fails, we may still hold the details placed with that order.
CHANGES TO THE POLICY
This Policy may be updated from time to time, so you may wish to check it each time you submit personal information to the Website. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use this Website to submit personal information. If material changes are made to the Policy, we will notify you by placing a prominent notice on the Website. We will not process your personal data in a manner not contemplated by this Policy without your consent.
LEGAL INFORMATION AND HOW TO CONTACT US
The data controller (as defined in Data Protection Legislation) for the Website and services provided through the Website is Eleutheria S.r.l. (Roads to Rome Private Tours), located at via dei Cappuccini, 22, Benevento (Italy). If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing to Eleutheria S.r.l. (Roads to Rome Private Tours), via dei Cappuccini, 22, Benevento (Italy) or via email at email@example.com