Privacy Policy

Information document in accordance with and for the purposes of Articles 13/14 Regulation (EU) 2016/679 (GDPR)

 

This policy applies to the website www.electric-trips.com the "Site" and its users, both visitors and travelers who purchase one or more trips ("Users").

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DATA CONTROLLER

Electric-Trips S.r.l. which has its registered office in Bologna, via Armando Spadini n.9, 40133, Tax code and

VAT 04296151204 (and which we will henceforth refer to as "Electric-Trips" or "Holder").

E-mail contacts: privacy@electric-trips.com

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TYPE OF DATA PROCESSED

· Access and navigation data (for example: information about the browser used by the User, pages visited, date, time and duration of each visit, as well as other parameters related to the User's operating system and computer environment).

· Contact data (email and/or telephone)

· Master Data: First name, last name, place and date of birth, social security number, sex (gender), passport and/or ID (number, date of issue, expiration date)

· Driver's license and willingness to drive

· Other personal data transmitted voluntarily: In some areas of the Site, it is possible to contact the Owner, via email at info@electric-trips.com, via phone or WhatsApp/Telegram, via the Owner's Facebook® group, or via the Owner's Instagram profile, to ask for information or clarification related to Electric-Trips trips and the possibility of creating partnerships.

· Data related to Users' preferences collected as a result of booking a trip and related to age, gender, and purchase preferences shown by Users.

· Payment data such as credit card / IBAN ("Banking Data").

· Data related to the round-trip airline flight purchased by the User

· Image and/or voice

· Contact information in case of emergencies (of a family member/friend)

· Information related to airline flights

· Data contained in surveys

· Data of the recipient of the gift card/voucher

· Data related to facts/incidents that occurred during the trip, including any conduct in violation of the law

· Cookies For all information about the cookies active on the Site and related processing of personal data, we encourage you to review the relevant information in the "Cookie policy" section on our Site.

In some cases we may also process some special data:

· Allergies and intolerances, health status, special needs voluntarily communicated by the User;

· Data contained in the medical certificate in case of cancellation of reservation ("Personal Data").

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PURPOSE AND LEGAL BASIS OF THE PROCESSING

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NAVIGATION ON THE SITE: Personal Data may be processed for the collection of anonymous statistical data on the use of the Site by Users, as well as for monitoring the operation of the Site. The legal basis is the legitimate interest of the Data Controller in operating and monitoring the Site and obtaining data on its use or your consent (Art. 6(1)(f) GDPR). The interest of the Data Controller has been balanced with that of the User, who will thus be able to enjoy an increasingly high-performing and optimized Site. The provision of Personal Data is optional, but failure to provide it, made by disabling cookies in your browser, may prevent you from accessing all functions of the Site. The Data do not persist for more than 36 months and are deleted immediately after their aggregation (subject to any need for investigation of crimes by the competent Judicial Authority). Our cookie policy is available in the "Cookie policy" section on our Site.

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RESPONDING TO CONTACT REQUESTS: You can contact the Owner, by email at info@electric-trips.com, by phone or WhatsApp/Telegram or through the Owner's Facebook® group, to ask for information or clarifications related to Electric-Trips trips and the possibility of creating partnerships and in general in relation to the services offered; to respond, to various requests from Users (e.g. through the services, Newsletters, participation in events). The legal basis is the performance of pre-contractual obligations to which the Data Subject is a party (Art. 6(1)(b) GDPR). The provision is necessary to follow up on the request. If Personal Data is not provided, Electric-Trips will not be able to respond to the request. Electric-Trips will delete the Personal Data processed to respond to the requests within 1 year from the date of closure of the processing of the request. Electric-Trips may retain requests in an anonymous and aggregate form for internal reporting purposes.

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RESPONDING TO AN INFO REQUEST ON A TRIP ("NOTIFICATIONS AND PREFERENCES"): the User can request to receive information about a trip or a specific service and save it in his/her personal area. The legal basis for processing is the performance of pre-contractual and contractual obligations to which the Data Subject is a party (Art. 6(1)(b) GDPR). The provision of Personal Data is necessary to fulfill the request of the Data Subject. If it is not provided, Electric-Trips will not be able to follow up on the Data Subject's request to be notified about the travel confirmation. The data will be kept for as long as necessary to achieve the intended purpose.

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BOOKING A TRIP: Finalization of a travel reservation through the Site and management of the reservation made. The legal basis is the performance of pre-contractual and contractual obligations to which the Data Subject is a party (Art. 6(1)(b) GDPR). With regard to any special data conferred (e.g., health status, any allergies), it is the express consent of the Data Subject (Art. 9(2)(a) GDPR). The provision is necessary to follow up on the reservation request. In case of failure to provide the Data, Electric-Trips will not be able to follow up on the request and finalize the purchase and, with reference to special data, will not be able to follow up on the specific needs requested. The Data shall be kept until the execution of the purchase contract and, in any case, not beyond the statute of limitations provided by law and except in cases of defense in court. Particular Data shall be retained until the execution of the contract and for a further 6 months, unless a further period is necessary to exercise or defend a right.

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USE OF THE PERSONAL AREA "MY Electric-Trips" (henceforth MyET): the user who has booked a trip, has the possibility of accessing a personal area within MyET, protected by a password chosen by the User, which allows, by way of example, to manage and check the status of the reservation and/or modify the data conferred when booking a trip. The legal basis is the performance of pre-contractual and contractual obligations to which the Data Subject is a party (Art. 6(1)(b) GDPR). With regard to any special data conferred (e.g., any allergies and/or intolerances), it is the express consent of the Data Subject (Art. 9(2)(a) GDPR). The provision is optional. If the Data is not provided, the user will not be able to use the personal area. The Data are kept until the Data Subject deletes his/her account. The Owner reserves the right to verify the User's interest in maintaining the account in the case of prolonged inactivity over time. The Owner may delete, upon notice, inactive accounts.

Data subjects can update their data at any time.

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SHARING OF INFORMATION RELATING TO AIR FLIGHTS: Users who have booked a trip have the option of entering their air flight information in their personal MyET area. This information may be shared, anonymously, with participants in the same purchased package and the coordinator of said package in order to facilitate the management of groups, as well as communications between trip participants and the coordinator. The legal bases for processing are the consent of the data subject (Art. 6(1)(a) GDPR), the performance of the contractual and pre-contractual relationship to which the data subject is a party (Art. 6(1)(b) GDPR), or the legitimate interest of the Data Controller (Art. 6(1)(f) GDPR). The interest of the Data Controller has been balanced with that of the data subjects in order to enable them to efficiently and effectively organize travel, depending on the flights of all participants in the various groups. Data entry is always optional. Each data subject may object to the processing at any time by removing the information from the appropriate section within the personal area. There will be no negative repercussions on the user in case of non-inclusion and/or opposition to processing. The data will be kept for the time necessary to pursue the purpose described above.

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BE INSERTED IN THE TELEGRAM CHANNEL: Users who request to be included in the Telegram group will receive trip-related communications. The legal basis for the processing is the legitimate interest of the Data Controller (Art. 6(1)(f) GDPR) to enable better organization of the trip and communications between trip participants and the coordinator. The interest of the Data Controller has been balanced with that of the Data Subject, who will be able to keep up to date through communications within the group. The Data Subject can object to the processing at any time, either by leaving the Telegram group or by sending his or her request to the Controller. There will be no negative repercussions on the user in case of objecting to the processing. The data will be kept for as long as necessary to pursue the purpose described above.

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CONTACTING USERS WHO HAVE ENTERED A TRIP IN THE CART: In case of an unfinished reservation, contact the relevant Users by email. The legal basis is the legitimate interest of the Data Controller (Art. 6(1)(f) GDPR) to contact the User to ask if they still have an interest in finalizing the purchase or if they need more information in relation to a particular destination. A maximum of three communications are sent. The interest of the Data Controller has been balanced against the interest of the User, who can thus finalize, at a later date, a travel reservation that has not yet been completed. The data subject may object to the processing. There will be no negative impact on the data subject in case of objection to the processing. The data will be kept for as long as necessary to achieve the purpose described above.

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CANCELING A RESERVATION: in the event that a user requests a cancellation of a reservation. The legal basis is the performance of pre-contractual and contractual obligations to which the Data Subject is a party (Art. 6(1)(b) GDPR) and the data contained in the medical certificate, consent (Art. 9(2)(a) GDPR). The provision is necessary to follow up on the request for cancellation. Electric-Trips will retain the data within and, not beyond the statute of limitations provided by law and except in cases of defense in court.

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COMMUNICATIONS IN CASES OF EMERGENCY: in order to manage communications for extraordinary cases of emergency. The Data Subject is also invited to submit this notice to his/her family members whose contact details are provided.The data processing is carried out in the legitimate interest of the Data Controller to enable the best management of emergencies, in accordance with Art.6(1)(f) GDPR. Electric-Trips will delete the data once the trip is over and in any case 1 month after the return.

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SENDING COMMUNICATIONS OF A COMMERCIAL/PROMOTIONAL NATURE: for direct marketing purposes, such as sending newsletters, information and commercial communications, updates on the latest launches, offers and promotions related to Electric-Trips services, by newsletter, email or telephone, including by automated means (SMS, social media). The legal basis is the consent of the data subject (Art. 6(1)(a) GDPR). The provision is optional. If the Data is not provided, Electric-Trips will not be able to regularly update the data subject on its offers and promotions. The data subject may revoke the consent given at any time by clicking on the "unsubscribe" link included in the marketing email received or by sending an email to privacy@electric-trips.com. Data processed for this purpose will be retained and processed for 5 years, subject to revocation of consent by the Data Subject.

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In the event that the Data Subject has contacted Electric-Trips, Electric-Trips may contact or send the Data Subject commercial communications relevant to the request received. In this case, the legal basis for the processing is the legitimate interest of Electric-Trips to promote its services to the Data Subjects pursuant to Article 6(1)(f) GDPR. The provision is necessary for the pursuit of the legitimate interest of the Controller which is fairly balanced with the legitimate interest of the data subjects. Processing is not obligatory and the data subject may object to such processing at any time by sending an e-mail to privacy@electric-trips.com. Electric-Trips will delete the Personal Data processed to respond to requests within 1 year from the date of closure of the processing of the request. Electric-Trips may contact the Data Subject again within that period.

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SOFT-SPAM: The email address may be processed to send emails to data subjects related to the promotion of Electric-Trips services similar to the services already purchased. The legal basis is the legitimate interest of the Data Controller to promote its services to existing customers. Data subjects may object to the use of their email address at any time by clicking on the "unsubscribe" link in the email received or by sending an email to privacy@electric-trips.com Electric-Trips will no longer use the email address after 48 months have elapsed from the date of the last business contact with the data subject.

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USER SEGMENTATION: for sending personalized commercial communications based on age and type of travel purchased. The legal basis is the legitimate interest of the Data Controller (Art. 6(1)(f) GDPR) to improve its commercial offer. The interest of the Data Controller has been balanced against the user's interest in being able to receive commercial communications in line with their interests. The provision is optional. There will be no negative repercussion on the user in case of opposition to processing. Data will be kept for 5 years from the date of the last trip.

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DEVELOPMENT OF SATISFACTION SURVEYS: Users who have completed a trip will receive an email communication regarding a satisfaction survey. The legal basis is the legitimate interest of the Data Controller (Art. 6(1)(f) GDPR) to assess and improve the quality and satisfaction with respect to the services offered. The provision is optional. However, failure to provide the Data will not allow the evaluation of customers' expectations and satisfaction with respect to the services offered by the Data Controller. Data will be kept for 36 months from the time of collection and will subsequently be anonymized and aggregated.

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PUBLICATION OF IMAGES OF INTERESTED PARTIES ON ELECTRIC-TRIPS' WEBSITE OR SOCIAL CHANNELS: Images/videos of users shared while traveling with Electric-Trips may be published by the Data Controller on the Site or social channels and/or travelogues. The basis of the processing is the legitimate interest of the Owner to promote its business (Art. 6(1)(f) GDPR). The trip participant is informed of the taking of photographs/videos both in the contractual process and during the trip and has the option to refrain and request not to be photographed during the trip. The interested party can object at any time either by requesting not to participate in the shots/filming, or by requesting the removal of the published content by writing to privacy@electric-trips.com The interest of the Holder has been balanced with that of the user to be part of group filming. Submission is optional. There will be no negative repercussions on the user in case of opposition to processing. The data will be retained for 5 years from the publication of the images unless an opposition request is made and the images are removed.

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REPORTS RELATED TO NON-CONFORMING FACTS/INCIDENTS AND/OR BEHAVIOR: The Data Controller may collect and process data related to facts, incidents, behaviors referable to the User traveler, which are not compliant with the standard . The legal basis is the legitimate interest of the Owner (art. 6, par. 1, lett. f) GDPR) to verify that the travel experience complies with the company's standard and monitor/report facts and/or behaviors not in line with the law. Reporting may be done through the trip coordinator, fellow travelers, and local partners. The trip participant is informed of this possibility as soon as the travel contract is signed. In addition, the participant is notified in case there is a report from the coordinator concerning him or her, and the participant has the opportunity to object and file a complaint. The data will be kept for 48 months after the collection of the report.

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HANDLING OF EVENTUAL CLAIMS AND DEFENSE IN JUDGMENT: the legal basis is the performance of pre-contractual and contractual obligations to which the Data Subject is a party (Art. 6(1)(b) GDPR) as well as the legitimate interest of the Data Controller (Art. 6(1)(f)). The provision is necessary both to enable the Controller to respond to requests made by Data Subjects and to defend its rights against the Data Subject or third parties before the competent authorities. The Data are kept for the duration of the claim and in any case within the statute of limitations indicated by the legislation (as a rule 3 years subject to any longer period if related to personal injury).

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CORPORATE OPERATIONS: sharing personal data in connection with, or during, negotiations of extraordinary transactions of all or part of Electric-Trips' business. The legal basis is the legitimate interest of the Data Controller (Art. 6(1)(f) GDPR). Data processing is necessary for Electric-Trips' legitimate interest in following up the negotiation and execution of corporate transactions. Data retained for this purpose will be deleted when the transaction is completed.

In addition and without prejudice to the above, the Data Controller undertakes to base the processing of Personal Data on the principles of minimization, verifying on an annual basis the need for their retention for a period of time no longer than required by the purposes for which the data were collected and processed. The Data Controller may retain Personal Data to comply with the law or to exercise or defend any right or claim in legal proceedings. Once the purposes for which Personal Data was collected and processed have been achieved, the Data Controller will implement appropriate measures to anonymize it so that the data subject cannot be identified.

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RECIPIENTS OF THE DATA

The Data will be processed by employees and contractors of the Data Controller expressly authorized to process the Data on the basis of instructions and after taking appropriate measures to protect the Data in connection with all of the above purposes.

The following parties may become aware of the Data in connection with the processing purposes set forth in this privacy policy and may process the Data both as autonomous data controllers and as data processors duly appointed by the Data Controller (the list of such data controllers and autonomous data processors is available upon request by e-mail to be forwarded to privacy@electric-trips.com):

· entities that perform activities functional to the achievement of the above purposes, i.e. companies that provide IT infrastructure and IT support and consulting services, companies that provide data analysis and development services, as well as law firms, accountants and auditing firms;

· Other companies that provide services to Electric-Trips;

· hotels and other accommodations, car rentals, airlines, companies that provide travel insurance policies, and other third parties that render services necessary for the realization of the booked trip;

· travel specialist;

· local tourism partners, e.g., local travel agencies, tour guides;

· companies offering payment and reservation services;

· insurance companies.

 

DATA TRANSFER TO A COUNTRY OUTSIDE THE EU

Personal data may be transferred to countries outside the EU, for example, if the travel destination is a country outside the EU.

The Data Controller undertakes to transfer personal data to third countries if it is necessary:

· Ensuring that the country to which personal data will be sent guarantees an adequate level of protection, as required by Article 45 of the GDPR; or complying with the standard contractual clauses approved by the European Commission for the transfer of personal information outside the EEA (these are clauses approved under Article 46 (2) of the GDPR).

 

DATA PROCESSING METHODS

The Data will be processed in accordance with the principles of fairness, lawfulness and transparency, through manual and automated methods and through the use of paper and electronic means, in any case within the limits of the purposes of the data processing(s) established by this notice and, in any case, always ensuring the security and confidentiality of the Data.

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RIGHTS OF INTERESTED PARTIES

The data subject may at any time exercise the following rights under the conditions and within the limits provided by Articles 12-22 of the GDPR by sending an email to privacy@electric-trips.com:

· Right of access: the data subject has the right to obtain confirmation from the data controller that personal data concerning him or her is or is not being processed and, if so, to obtain access to the personal data (Article 15 GDPR);

· Right to rectify inaccurate personal data and to obtain supplementation of incomplete personal data (Article 16 GDPR);

· Right to erasure of personal data: a data subject may request that his or her data be erased if it is no longer necessary for the above purposes, if consent is withdrawn or if he or she objects to processing, if processing is unlawful, or if there is a legal obligation to erase (Article 17 GDPR);

· Right to restriction of processing: the data subject has the right to obtain restriction of processing when one of the following occurs: the data subject disputes the accuracy of the personal data, for the period necessary for the Data Controller to verify the accuracy of such personal data; the processing is unlawful and the data subject objects to the deletion of the personal data and instead requests that its use be restricted; although the Data Controller no longer needs the personal data for the purposes of processing, the personal data are necessary for the data subject to establish, exercise or defend a right in court; the data subject has objected to the processing, pending verification as to whether the Data Controller's legitimate reasons prevail over those of the data subject (Article 18 GDPR);

· Right to object to processing: the data subject may object at any time to the processing of his or her data, unless the Data Controller demonstrates the existence of compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims under Article 6(1) (e) or (f) of the GDPR, including profiling (Article 21 GDPR);

· Right to portability: the data subject has the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her that has been provided to a data controller and has the right to transmit such data to another data controller without hindrance from the data controller to whom he or she has provided it if: the processing is based on consent, or on a contract (Article 20 GDPR);

· Right to complain to the supervisory authority (Article 77 GDPR).

In the event that the data subject believes that the processing of personal data carried out by the Data Controller is in violation of the provisions of Regulation (EU) 2016/679, the data subject has the right to lodge a complaint with the Supervisory Authority, in particular in the member state where he or she normally resides or works or in the place where the alleged violation of the regulation occurred (in Italy, the Garante Privacy https://www.garanteprivacy.it/), or to take the matter to the appropriate judicial instances.

Where the legal basis for processing is express consent, the data subject has the right to withdraw consent at any time. Revocation of consent does not affect the lawfulness of the processing based on the consent before revocation.