Last update: 07/06/2020

TOURMAKE S.r.l., with registered office in C.da Monopoli, 3 - 70013 Castellana Grotte (BA), SSN and VAT 08043360729 (hereinafter referred to "Holder") , as data controller, informs you according to art. 13 D.Lgs. 30.6.2003 n. 196 (hereinafter, "Privacy Code") and art. 13 EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed as follows:

1. Object of treatment

The Holder processes personal data and contact details such as name, surname, company name, address, telephone number, e-mail address, bank and payment details) - hereinafter, "personal data" or other "data" submitted during a contract agreement with the Holder, service provider.

2. Processing purpose

Your personal data are processed:

  1. without your express consent, Article 24 (a),(b),(c) of Privacy Code and Art. 6 (b),(e) of GDPR, for the following Service Purposes:
    • to conclude contracts for the Holder’s services;
    • to fulfill the pre-contractual, contractual and fiscal obligations arising from our mutual relations;
    • to fulfill the obligations imposed by the law, statute, by community legislation or by the Authority (as for example for anti-money laundering);
    • to exercise the Holder’s rights, for example the right of defense;

    The Holder provides users a service platform whose purpose is the interaction between visitors and the manager/ owner of a place and/ or commercial activity.

    A non-exhaustive list of examples:

    • Booking services
    • Contact forms filling
    • Comments and reviews inclusion

    The Holder is a link between the visitor and another person, indicated by a Partner for receiving data sent by visitors through the filled forms. The Holder can keep the data sent by visitors in order to ensure the service requested by visitor; those data will not be used by the Holder for commercial, marketing or profiling purposes.

    However, the Holder can not ensure the proper use of data by third parties, sent to provide a service. The visitor who wants to use one of the services listed above will be informed before data sending about extra purposes of data processing. These modalities will be defined by the Partners during service creation, through the provided means. The visitor fully accepts all the purposes listed to use the services.

    Using these services, the visitor is aware that the data will be sent to third parties. Without any modalities related to the use of data by third parties for service supplying, the visitor has the right to ask the Holder the destination and methods of sending data. The Holder is not responsible for incorrect use of data by third parties.

  2. Only by specific and separate agreement (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following Marketing Purposes:
    • to send via e-mail, letter and / or sms and / or telephone contacts of newsletters, commercial communications and / or advertising material on products or services offered by the Holder and customer satisfaction surveys regarding the quality of the services provided;
    • to send via e-mail, letter and / or sms and / or telephone contacts of commercial and / or promotional communications of third parties (for example, business partners, insurance companies, other companies of the Tourmake group).

    Please note that if you are already our client, we may send you commercial communications relating to similar services you already used, unless otherwise expressly dissent (Article 130 (4) of the Privacy Code).

3. Processing methods

The processing of your personal data is carried out according to art. 4 of the Privacy Code and art. 4 (2) of GDPR, namely: data collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction. Your personal data are subject to both paper and electronic and / or automated processing.

The Holder will process the personal data for the time needed to fulfill the above mentioned purposes and in any case for no more than 10 years from the end of Service Finality and for no more than 2 years from the data collection for Marketing Purposes.

4. Access to data

Your data may be available for the purposes under art. 2.A) and 2.B):

5. Data communication

Without express consent (ex art. 24 (a),(b), (d) Privacy Code and art. 6 ( b) , (c) of GDPR, the Holder may share your data for the purposes referred to in art. 2.A) with Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of the above mentioned purposes. These subjects will process the data in their capacity as independent data controllers.

Your information will not be diffused.

6. Data transfer

Personal data are stored on servers located within the European Union, in Roubaix (France) and in Strasbourg (France). In any case, the Holder, if necessary, may replace servers outside the EU. In this case, the Holder hereby ensures that the data transfer outside UE will be carried out in compliance with the law, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of data provision and consequences of refusal to answer

The provision of data for the purposes under art. 2.A) is mandatory. In their absence, we can not ensure the supply of services.

The provision of data for the purposes under art. 2.B) is optional. You can therefore decide not to give any data or to deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services provided by the Holder. However, you will continue to be entitled to the Services under art. 2.A).

8. Subject’s rights

As data subject, you have the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights of:

  1. to obtain confirmation of the existence of personal data concerning him/her, even if not yet recorded, and its communication in an intelligible form;
  2. obtain the indication: a) of the origin of personal data; b) of the purposes and modalities of processing; c) of the logic applied in case of processing by electronic tools; d) of data details related to the managers and the representative designated pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) of the subjects or the categories of subjects to whom personal data can be communicated or who may be made aware as appointed representative in the State, of managers or agents;
  3. obtain: a) data updating, rectification or, integration; b) data cancellation, transformation into anonymous form or the blockage of the data processed in breach of the law, including those whose retention is not necessary in relation to purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in points a) and b) have been brought to the attention – also by virtue of their content - of those to whom the data have been communicated or disseminated, except in the case in which such fulfillment is impossible or involves a manifest use of means disproportionate to the protected right;
  4. to object, in whole or in part: a) for legitimate reasons, to the processing of your personal data, even fullfilling the purpose of the collection; b) to the processing of your personal for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the subject can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, the subject also has the rights referred to in Articles 16-21of GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. Method of exercising the rights

You can exercise your rights at any time by sending:

10. Holder, responsible and agents

The Holder is Tourmake s.r.l. with registered office in C.da Monopoli, 3 - 70013 Castellana Grotte (BA) Italy.

The updated list of data processors is located in the Holder’s registered office.

11. Third-party Services Integration

Tourmake allows integration of Social Media Platform such as YouTube, Facebook, Twitter and Instagram within virtual tours in the form of Widgets. The integration of a YouTube Channel is done by using YouTube API Services, specifically YouTube Data API. By adding a YouTube Channel, users agree to be bound by YouTube Terms of Service. Reference to Google Privacy Policy. Tourmake requires YouTube Channel IDs in order to get the Name of the Channel and list of the latest videos. These information are not used for statistical and marketing purpose and are not shared with third parties.

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