Privacy Policy


Information according to the Code regarding the protection of personal data
 

 This privacy statement is valid to all the services, apps and products of Travel Appeal Spa. (for example chatbot – costumer journey – Travel Appeal Conversation – the SAAS platform etc.) and all the Travel Appeal Spa Mobile Apps. 

 

This document describes how we use and manage your personal data, as well as all the information related to the collection of personally identifiable information while using our website. 

 

Personal identification information refers to all data relating to you personally, such as your name, surname, address, email address or user behavior. The protection of your personally identifiable information is very important to us. If you have any questions or would like more information on data protection collected or processed by Travel Appeal Spa please contact us at privacy@travelappeal.com 

 

Continued technological development, changes to our services or legal status, and other reasons may require corrections to our data protection notice. Therefore, we reserve the right to modify this privacy statement at any time and we ask you to keep informed about updates. 

 

1 Owner of data processing 

 

The owner of the treatment is the company Travel Appeal Spa based in Roncade (TV) Via Sile n. 41 C.F. and VAT number 04633420262 pec travelappeal@legalmail.it – ​​email: info@travelappeal.com. 

 

2 Collection of personally identifiable information while browsing our website 

 

If you are using the website for informational purposes only, that is, without registering or otherwise providing us with information, we will only collect personally identifiable information that your browser transmits to our server. If you want to browse our website, we collect the following data that we technically need to make our website visible and guarantee its stability and security: IP address, date and time of request, time zone difference compared to Greenwich Mean Time (GMT), hardware, software, content of the request (specific page), access status / HTTP status code, volume of data transferred in each case, web site receiving the request, browser, system operating and related interface, language and software version of the browser, display data, navigation and behavior. If you are browsing through a mobile device, data that identifies your device, settings and characteristics of the phone / tablet or other devices used, as well as system activities, including app crashes, will also be collected. 

 

Only in case of suspected improper use, incorrect or fraudulent behavior, we will use the information referred to in this link to facilitate identification of the responsible person, pursuant to art. 6 paragraph I letter f) of the GDPR. 

 

Further information can also be collected through our business partners such as affiliates and independent third parties, which can be combined with those received directly from you. For example: mini-product sites, special project sites, event sites organized in partnership. 

 

When you contact us via email or through any contact form you will be asked for the following information: 

 

  • email address; 
  • name and surname 
  • reason / company name; 
  • telephone number; 
  • role in the company 

 

3 Purposes of the Processing, legal basis and data retention period 

 

The information collected is used for the provision of the following services: 

 

  1. to stipulate and manage the contractual relationship with Travel Appeal from the pre-contractual phase, including customer assistance. For this purpose, Personal Data will also be processed in the context of the activities of: administration, accounting, contract management, services, billing / payments, auditing and certification of mandatory / voluntary financial statements, assignment or advance credits, as well as to fulfill specific requests and comply with the other obligations arising from the Contract with Travel Appeal. The provision of Personal Data is necessary for the establishment and execution of the Contract. Any refusal to provide Personal Data for the pursuit of the aforementioned purposes will result in the inability to establish and continue the contractual relationship;
  2. fulfill the legal and administrative obligations to which Travel Appeal is subject. Any refusal to provide Personal Data for the pursuit of the aforementioned purposes will result in the inability to establish and continue the contractual relationship with the Company;
  3. performanceand development of the institutional activity, involving, for example, statistical processing;
  4. Account: users can create a user account on our site or on the app.
  5. Online groups, forums or social media;
  6. Marketing activities;
  7. Communications to improve the management of the service;
  8. Market research;

 

With regard to the purposes referred to in points a) – b) – c) the need to process personal data for the execution of the contract is used as the legal basis, specifically to finalize and administer the service requested by you. If the necessary personal data are not provided, Travel Appeal cannot follow up the service and / or the operation requested by the customer. 

 

The criteria for determining the retention period of the Data take into account the permitted processing period and the applicable regulations on taxation, the prescription of rights and the nature of legitimate interests where they constitute the legal basis of the processing. Beyond this term the data will be deleted, or, if residual an interest of the holder to further processing, these will take place prior to anonymization of the data themselves, i.e. behind the adoption of appropriate measures to avoid identification of the subject concerned. In accordance with the provisions of current legislation, Personal Data may be stored for a period subsequent to the one originally foreseen, in the event of any disputes or requests by the competent Authorities. 

 

With regard to the purposes d) – e) – f) – g) – h) Travel Appeal relies on its legitimate commercial interest to provide its services, prevent fraud and improve services. 

 

The Data will be kept in compliance with the provisions of current legislation on the subject, for a period of time not exceeding that necessary to achieve the purposes for which they are processed. In the absence of specific rules that provide retention times for the purposes indicated in this Statement, Travel Appeal will take care to use the Personal Data for the aforementioned marketing purposes for a reasonable time in relation to the interest shown by the interested party towards promotional initiatives, evaluated over 10 years. In any case, Travel Appeal will take every precaution to avoid using the same data indefinitely, proceeding periodically to verify in an appropriate manner the effective continuation of the interest of the person concerned to carry out the treatment for marketing purposes, as above clarified. 

 

4 Newsletter 

 

4.1 General information 

 

At the time of registration or on specific request, you can request and authorize Travel Appeal’s sending of our newsletters, which will keep you informed about offers, promotions, events and information related to the travel and hospitality world. 

 

Subscription to our newsletters may take place upon registration to our site or upon request by the user, in this case Travel Appeal will send an email to confirm your wish to receive the newsletter together with our privacy policy. In case of non-acceptance or confirmation of the data processing conditions your information will be blocked and your data deleted within a month. 

 

For the receipt of the newsletter it will be sufficient to provide only one data: e-mail address, while the provision of additional data and marked separately is voluntary. Following the request Travel Appeal Spa will save the IP address used and the registration and confirmation times. The purpose of the procedure is to verify your registration and, if necessary, inform you about the possible misuse of your personal data. 

You can cancel your consent to receive the newsletter at any time and unsubscribe. You can express your revocation by clicking on the link in each newsletter or by contacting the data protection officer at the following address: privacy@travelappeal.com. 

 

4.2 Monitoring of newsletters 

 

Please note that in sending newsletters we evaluate your user behavior. For the purposes of this assessment, emails sent include “web beacons” or tracking pixels, which are stored on our website. For the evaluations, we link the mentioned data and web beacons to your email address and an individual ID. 

 

With the data thus obtained, we generate a user profile to adapt the newsletter to your personal interests. By doing so, we record when you read our newsletters, which links you click on, and deduce your personal interests from them. Then we link this data to the actions you perform on our website. 

 

You can refuse this monitoring at any time by contacting the data protection officer at the following address: privacy@travelappeal.com. The information will be saved only if you subscribe to our newsletters. Once the request for cancellation from the service has been exercised, your data could be saved anonymously and for purely statistical purposes. 

 

Similarly, monitoring will not be possible if you’ve turned off the display of images by default in your email application. In this case, the newsletter will not be displayed completely and you will not be able to use all the features. If you enable the display of images manually, the aforementioned monitoring will be performed. 

 

5 Account 

 

You have the possibility to subscribe to our service and to create a user account. During registration, we collect and save the following data: 

 

  • Email 
  • Password 
  • Name and Surname 

 

Specifying the aforementioned data is mandatory; all other information can be provided voluntarily using our portal. 

 

After registration, you will receive a personal password-protected access and you will be able to view and manage the data you have stored. Registration is voluntary, but may be required as a condition for using our services. 

 

Travel Appeal user accounts and the information contained in them are password protected, so that only the user can access their personal identification information. Users can edit their user profiles at any time. 

 

We save this information until you permanently delete your access. However, we will save the data you provide on a voluntary basis for the time you will use the portal, unless you delete them first. You will be able to manage and edit all the information in your protected user account. 

 

6 Account setting function. 

 

Travel Appeal customers can manage their business profiles through a dedicated section of the software. In order to use this feature, you must first register. During registration, we collect and save the following data: 

 

  • reason – social denomination  
  • Name and surname 
  • Email 
  • Company data (address, VAT number, telephone number) 
  • Password 

 

Specifying the aforementioned data is mandatory; all other information can be provided voluntarily using our portal. 

 

After registration, you will receive a personal password-protected access and you will be able to view and manage the data you have stored. The data collected will be used exclusively for the implementation of the contractual relationship between Travel Appeal and the respective customer. Data will not be shared with third parties. 

 

7 Using social plug-ins 

 

This website uses the provider’s social plug-ins 

 

  • Facebook (operator: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, United States) 
  • Twitter (operator: Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, United States) 
  • Google (operator: Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States) 

 

These plug-ins usually collect your data and send it to the server of the respective provider. We have taken technical measures to ensure the protection of your privacy, thanks to which your data cannot be collected by the suppliers of the respective plug-ins without your consent. These will be initially disabled when you visit a site connected to the plug-ins. The plug-ins will not be activated until you click on the respective symbol and in doing so, you consent to transmitting your data to the respective provider. 

 

Once activated, the plug-ins also collect personally identifiable information, such as your IP address, and send it to the server of the respective provider, where it is saved. Activated social plug-ins also set a cookie with a unique identifier when you visit the respective website. In this way, the seller can also generate a profile based on your behavior as a user. This also happens if you are not registered on the social network of the respective provider. If you are subscribed to the social network of the provider and you are logged in on the website during the visit, the data and information on your visit to the website can be linked to your profile on the social network. We have no influence on the exact extent to which data is collected by the respective provider. For more information about this, and the nature and purpose of data processing and rights and setting options for privacy protection, see the data protection information for the respective social network provider. In this regard, visit the following addresses: 

 

 

8 Facebook Connect 

 

We offer you the opportunity to subscribe and log in via your Facebook account. If you sign up with Facebook, Facebook will ask you for permission to provide us with some data linked to your Facebook account. Such data may include your name, surname and email address so that you can verify your identity and gender, as well as your general location, a link to your Facebook profile, your time zone, your date of birth, your profile photo, your “likes” and your friends. 

 

Facebook will collect such data and send it to us in accordance with the policies outlined in the Facebook Privacy Policy. You can manage the information we receive from Facebook by changing your privacy settings in your Facebook account. 

 

This data will be used to establish, provide and personalize your account. 

 

If you subscribe to our service via Facebook, your account will be automatically connected to your Facebook account and information about the activities you do on our website, if applicable, will be shared on Facebook and published in your diary and in the news. 

 

9 Twitter 

 

You can sign up and log in via your Twitter account. If you sign up via Twitter, you will be asked to provide us with some data related to your account. Such data may include your name, surname and email address so that you can verify your identity and gender, as well as a link to your Twitter profile, your profile photo. Twitter will collect such data and send it to us in accordance with the policies outlined in the privacy policy. 

 

This data will be used to establish, provide and personalize your account. 

 

10 Google 

 

You can sign up and log in using your Google account. If you sign up through Google, it will ask you for permission to provide us with some data related to your account. Such data may include your name, surname and email address so that you can verify your identity and gender, as well as a link to your Google profile, and your profile photo. Google will collect such data and transmit it to us in accordance with the policies outlined in the Google Privacy Policy. 

 

This data will be used to establish, provide and personalize your account. 

 

11 Use of cookies 

 

Cookies are used for different purposes. Cookies allow you to be recognized as a unique user when you visit the different pages of a site, different sites or when you use the app. The types of information we collect via cookies include the IP address; Device ID, pages visited; browser type; navigation data; operating system; internet service provider; time stamp; Reference URL; functions used and activities carried out within websites / apps. Cookies cannot run programs or transmit viruses to your device. They are used to make the website more user-friendly and overall efficient. We also use cookies to identify you on subsequent visits and for marketing applications. 

 

This website uses the following types of cookies, whose purpose and function are explained below: 

 

12 Temporary cookies 

 

These cookies are automatically deleted when the browser is closed. Session cookies are part of this category, which save a “session ID” with which different requests from your browser can be assigned to the joint session. This allows your device to be recognized again when you return to our website. Session cookies are deleted when you exit or close the browser. 

 

13 Persistent cookies 

 

These cookies are automatically deleted after a set duration that may vary depending on the cookie. You can delete cookies using your browser’s security settings at any time. 

 

14 Blocking cookies 

You can configure the browser and settings of the app according to your preferences and, for example, refuse the acceptance of third-party cookies or all cookies. Please note that in this case you may not be able to use all the features of the website. 

 

15 Legal ground and archiving period 

 

The legal ground for any processing of personally identifiable information and its archiving period vary from case to case and are described in the following sections. 

 

16 Analysis 

 

For the purposes of analyzing and optimizing our websites, we use the various services described below. This allows us to analyze, for example, how many users visit our site, what the most requested information is and how users find the website. The data we collect includes the websites from which the user arrives to another website (“referrer”), to which subpages of the website he accesses and with what frequency and the period of time for which he visualizes a subpage. In this way, we are able to develop and improve our website to make it more user-friendly. The collected data are not used to personally identify individual users. Anonymous or pseudonymous data will be collected. 

 

17 Google Analytics 

 

This website uses Google Analytics, a web analytics service provided by Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, United States). This use covers the operating mode of Universal Analytics. In this way, it is possible to assign data, sessions and interactions on several devices to a user ID with a pseudonym and then analyze the activities of a user on all the devices. 

 

Google Analytics uses cookies to analyze your use of the website. The information generated by the cookie through the use of this website is generally transmitted and stored on a Google server in the United States. If IP anonymization is activated on this website, however, your IP address will be truncated in advance in the Member States of the European Union or in other Contracting States parties to the Agreement on the European Economic Area. Only under exceptional circumstances will the full IP address be transmitted to a Google server in the United States and subsequently truncated. The IP address transmitted by your browser in the context of Google Analytics will not be combined with other data from Google. Google will use this information in the order of this website operator to evaluate the use of the website so that reports on website activity and other services related to the website and to use for the website operator. Our legitimate interest in data processing is also justified for these purposes. The legal basis for using Google Analytics is Article 6, par. 1 f of the GDPR. Data sent by us and linked to cookies, user information (such as user ID) and promotional IDs are deleted after 14 months from the last use of our services. Data whose archiving period has expired are automatically deleted once a month. More information on terms and conditions of use and data protection is available at https://www.google.com/analytics/terms/it.html and https://policies.google.com/?hl=it 

 

You can avoid the saving of cookies through the appropriate setting of your browser; however, please note that by doing so you may not be able to fully use all the features of the website. You can also prevent the data generated by the cookie and related to your use of the website (including your IP address) to be collected and processed by Google by downloading and installing the add-on https://tools.google.com/dlpage/gaoptout?hl=it. Deactivation cookies prevent the future collection of your data when you visit this website. To prevent Universal Analytics from being collected on various devices, you must disable it on all systems in use. Set the deactivation cookie by clicking here: Disable Google Analytics 

 

18 Google Tag Manager 

 

For transparency reasons, we inform you that we use Google Tag Manager. Google Tag Manager does not collect any personally identifiable information. Tag Manager facilitates the integration and management of our tags. Tags are small pieces of code that serve, for example, to measure traffic and user behavior, record the effects of online advertising and social channels, set up remarketing, focus on target groups and test and optimize websites. If you’ve disabled them, Google Tag Manager will take them into account. For more information on Google Tag Manager, visit: https://www.google.com/analytics/tag-manager/use-policy/ 

 

19 Hotjar 

 

The data are collected and saved for the purpose of optimizing this service thanks to the technologies of Hotjar Ltd. (https://www.hotjar.com/). This data can be used to generate usage profiles with a pseudonym. Cookies can be used for this purpose. The data collected with the Hotjar technologies are not used for the purpose of personal identification of visitors to this website and will not be incorporated with personally identifiable information on the holder of the pseudonym without the explicit consent of the individual in question. You can deny Hotjar’s consent to collect your information at any time when you visit a Hotjar-enabled site, by visiting the specific Hotjar page to deny consent  https://www.hotjar.com/legal/compliance/opt-out 

and by clicking on “Disable Hotjar” or by enabling the Do Not Track function (DNT, do not track) in your browser. 

 

20 Advertising 

 

We use cookies for marketing purposes in order to reach out to our users with advertisements that are more tailored to their interests. We also use cookies to reduce the likelihood of reproduction of advertisements and to measure the effectiveness of our advertising actions. This information can also be shared with third parties, such as ad networks. The legal basis for this theme is Article 6 of the GDPR. The purposes expressed in the processing of data serve the legitimate interest of direct marketing. You have the right to object to the processing of your data for advertising purposes at any time. We offer the following options to deny consent to their services for this purpose. Alternatively, you can prevent cookies from being configured in your browser and app settings. 

 

We use Google AdSense, a service for the integration of advertisements. Google AdSense uses cookies and web beacons (invisible graphics). These web beacons allow the analysis of information such as visitor traffic on website pages. The information generated by cookies and web beacons through the use of this website (including user IP addresses) and the distribution of ad formats are transferred to a Google server in the United States and stored there. Google may transmit this information to its affiliates. However, Google will not aggregate your IP address to your other stored data. Users can avoid the installation of cookies through the appropriate settings of their browser and the App; however, please note that by doing so you may not be able to fully use all the features of the website. Use of this website implies acceptance by the user of the processing of his data collected by Google in the manner and for the purposes described above. 

 

21 Google AdWords and conversion tracking 

 

To draw attention to our services, we publish ads with Google AdWords and, in this context, we use Google Conversion Tracking for the purpose of customizing your ads online based on your interests and geographic location. The anonymous storage option of IP addresses is controlled by Google Tag Manager, through an internal setting not visible in the source of this page. This internal setting is configured to hide IP addresses, thanks to the anonymous transformation required by privacy laws. 

 

Ads are shown based on search requests on websites in the Google ad network. We have the ability to match our ads to some search terms. With the use of cookies, we are able to post announcements based on previous user visits to our website. 

 

When a user clicks on an ad, Google places a cookie on the user’s device. For more information on the cookie technology used, consult the Google information on website statistics and the related Information on data protection. 

 

Thanks to the use of this technology, Google, and us as its customers, we receive the information of a user who clicked on a particular ad and then redirected to our websites. The information acquired in this way is used exclusively for statistical analysis purposes related to ad optimization. We do not receive information that allows us to personally identify a visitor. The statistics provided by Google include the total number of users who have clicked on one of our ads and, if possible, indicate if they have been redirected to a page on our website that contains a conversion tag. These statistics allow us to monitor which search terms most often lead our ads to receive clicks and which ads lead the user to contact us via the contact form. 

 

If you do not agree, you can avoid the storage of cookies required for this technology, for example by acting on the settings of your browser or your App. If you decide to do so, your visit will not be incorporated into user statistics. 

You also have the option to choose Google’s ad types or opt out of interest-based ads on Google through add settings. Alternatively, you can disable the use of third-party cookies using the Network Advertising Initiative’s  tool to deny consent. 

 

However, we and Google will still receive statistical information on how many users visit this site and at what time. If you do not want to be included in these statistics, you can avoid it by using additional programs for your browser (such as the Ghostery add-on). 

 

22 Google DoubleClick 

 

We use DoubleClick, a service from Google Inc. DoubleClick uses cookies to insert user-based web ads. Cookies detect which ads have already appeared on your browser and if you’ve visited a website after viewing an ad. In this case, cookies do not collect any personally identifiable information and are not able to connect to any information. 

 

If you do not want to receive user-based advertising, you can disable ad insertion using Google’s ad settings. 

 

For more information on how cookies are used by Google, see Google’s privacy policy. 

 

23 Google’s dynamic remarketing 

 

On our website, we use the dynamic remarketing feature of Google AdWords. This technology allows us to insert automatically generated ads oriented towards target groups, after your visit to our website. The ads are geared towards products and services you have clicked on during your last visit to our website. 

 

Google uses cookies to generate ads based on interests. Cookies are small text files stored on your browser when you visit our website. In this process, Google usually saves information such as your web request, IP address, browser type, browser language, and the date and time of your request. This information is only for the purpose of mapping the web browser to a specific device. They cannot be used to identify an individual. 

 

If you do not want to receive user-based advertising from Google, you can disable ad insertion using Google’s ad settings. 

 

For more information on how cookies are used by Google, see Google’s privacy policy. 

 

24 The “personalized public” feature of Facebook 

 

The “personalized public” feature of Facebook (Facebook Custom Audiences 1601 S. California Avenue, Palo Alto, CA, 94304) is also used as part of online advertising based on usage. A non-reversible and non-traceable sum of the user (total hash) is generated essentially by the usage data that can be transmitted to Facebook for analysis and marketing purposes. In this process, a Facebook cookie is set. By doing so, we collect information about your activities on the website (such as browsing behavior, secondary pages visited, etc.). Your IP address is stored and used for geographic modulation. 

 

For more information on the purpose and scope of data collection and further processing and use of data, in addition to privacy settings, see the privacy policy of Facebook. 

 

25 Transmission of data 

 

If this is instrumental to the pursuit of the purposes indicated in paragraph 3, the Data may also be transferred abroad to companies located both within and outside the European Union. Some of these jurisdictions may not guarantee the same level of protection as the Data secured by the country in which the individual resides. In this case, Travel Appeal agrees that the Data will be treated with the utmost confidentiality stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided by the European Commission. 

 

External service providers and affiliated companies, such as online payment service providers or transport companies responsible for delivery, will receive your data only to the extent necessary to process your order. In these cases, however, the scope of the transmitted data is kept to the minimum necessary. If our service providers are in contact with your personally identifiable information, we will ensure that it complies with the requirements of data protection regulations, in the same way as when processing your order, pursuant to Article 28 of the GDPR. See also the respective data privacy policy of the provider. The respective supplier is responsible for the content of third-party services, even if we verify that the services are reasonable to comply with legal requirements. 

 

26 Existence of an automated decision-making process 

 

There is no automated decision-making process in relation to the data. 

 

27 Rights of the interested party 

 

At any time, the interested party will have the right to: 

 

  • obtain from Travel Appeal confirms that it is or is not undergoing the processing of its Personal Data and, in this case, obtaining access to the information pursuant to art. 15 of the Regulations; 
  • obtain the correction of inaccurate data concerning him, or, taking into account the purposes of the processing, the integration of incomplete Personal Data; 
  • obtain the cancellation of your Personal Data, in the presence of one of the reasons set forth in art. 17 of the Regulations, where applicable; 
  • revoke consent at any time in cases where it was previously provided. The withdrawal of consent does not affect the lawfulness of the treatment based on the consent previously given; 
  • obtain the limitation of the processing of your data if one of the hypotheses referred to in art. 18 of the Regulations; 
  • oppose the processing of their Personal Data, for reasons connected with their particular position, where applicable; 
  • receive, in a structured format, in common and automatic way, the Personal Data concerning him provided and transmit such Data to another data controller, in the cases and within the limits set forth in art. 20 of the Rules. 

 

Travel Appeal may request additional information before processing requests if it needs to verify the identity of the individual submitting it. 

 

Under the GDPR, Travel Appeal is not authorized to charge costs to fulfill any of the requests in this paragraph, unless they are manifestly unfounded or excessive, and particularly repetitive. In cases where an interested party requires more than one copy of their personal data or in cases of excessive or unreasonable requests, Travel Appeal may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) refuse to meet the request. In these eventualities, Travel Appeal will inform the interested party of costs before processing the request. 

 

These rights may be exercised by sending: 

 

– a communication by e-mail to the address: privacy@travelappeal.com 

 

Without prejudice to any other administrative or judicial appeal, the person concerned also has the right to lodge a complaint with a Supervisory Authority (for Italy: The Guarantor for the protection of Personal Data), if he considers that the treatment that concerns him is carried out in violation of the General Data Protection Regulation. Further information is available on the website http://www.garanteprivacy.it. 

 

Travel Appeal undertakes to comply with all the obligations set forth in this statement. Interested parties who may decide to propose the appeals or complaints referred to above, are invited to contact us.