PRIVACY POLICY - MAY 2018

Alfageda srl (hereinafter referred to as "Alfageda"), with registered office in 315, XXIV Maggio street - 86170 in Isernia, as Data Controller, wishes to provide the following information on the processing of personal data provided by the User to Alfageda.

This Privacy Policy, therefore, presents to the User all the s available to him concerning the personal data, their use and their disclosure.

 INFORMATION LECTION

Alfageda lects some information from the User:

- directly at the time of completing the online on the website esta.voyage at the time of acceptance of the Alfageda Terms and Conditions or at the time of its interaction with the Customer Assistance Service by telephone or internet using whatsapp, messenger or live chat on the website. In particular, in order to use the service provided by Alfageda, the User provides the following personal data: name, surname, gender, date of birth, country of birth, citizenship, address, e-mail address, telephone number, city, passport; the User also provides information on the emergency contact inside or outside the United States, information on the trip, information on the workplace, information on the traveler (in particular, it provides sensitive data such as, for example, having reported criminal convictions or having committed crimes or contracting diseases or having abused drugs).

- indirectly, for example through interactions with e-mail messages, whatsapp, messenger or live chat because as a result of every contact of the User with the Customer Support service, all the data related to the user contact will be recorded saving the emails or the conversations occurred.

- through the use of cookies or other technologies such as plug-ins (for more information, see the "Cookies" section)

Furthermore, Alfageda and the platform provider can trace the characteristics of the device and software (type and configuration), connection information, sources of origin, connection date and time, e-mail address and IP address which can indicate the generic position of the User.

 USE OF THE LECTED INFORMATION

Alfageda uses the information lected for:

- analyze, provide, improve and customize the service provided to the User. The lected data are used in order to interact with the User and satisfy his needs regarding the service provided;

- send the User administrative information such as information regarding the services and changes to the terms and conditions signed;

- ensure that the website through which Alfageda provides and manages the service functions correctly and is optimized for the devices used by the User;

- save his information;

- enhance, improve, optimize and modify the platform through which Alfageda provides and manages the service;

- customize the User's experience by presenting campaigns or dedicated business offers tailored to the customer based on the information lected by the customer;

- legal reasons in order to exercise or protect the legal rights of Alfageda or to defend it from legal claims pursuant to the law in force;

- prevent, identify and investigate potentially prohibited or illegal activities such as frauds.

Furthermore, Alfageda lects and uses personal data for the provision of the service, for marketing activities or for sending service or commercial communications. In such cases, the User gives his / her consent in a free, specific, informed and unequivocal manner and the personal data are treated in a lawful, correct and transparent way.

DISSEMINATION OF INFORMATION  

Alfageda may disclose the information lected for specific purposes and to third parties in order to assist the User and optimize the service provided. Therefore, such third parties may have access to the data provided to Alfageda and disclose them for the purposes for which they are required to laborate with Alfageda. It is understood that Alfageda may eventually disclose the User's personal data or other information provided by the same if they reasonably believe that disclosure is necessary for a) to implement the applicable terms of use, including the investigation of potential violations of the conditions ; b) comply with any law, regulation or request of the State and any other State; c) identify, prevent and manage any illegal activities that may occur against the customer; d) protect against damages to the rights, assets or safety of Alfageda, of its Users as required by current legislation.

In the case of mergers, transformations, holdings' transfer and any type of corporate reorganization, Alfageda reserves the right to transfer the personal data of Users as long as the recipient gives his consent to the processing of personal data as established by this Information.  

In case of transfer of personal data outside the European Union to countries that do not comply with the European Data Protection Regulation (GDPR), the data will be transferred according to the European legislation and the treatment will be regulated in accordance with the regulation of the country of destination.  

Using the services provided by Alfageda, the User can choose whether and how to disclose his data: for example, he can publish a review on Alfageda's social media channels and in this way make his information public and accessible to third parties, signing a release for the publication and / or dissemination in any of his reviews / evidences related to the use of the service provided by Alfageda.  

It is understood that each social network has its own conditions of use and its own rules on privacy.

ACCESS TO DATA AND MERCHANT'S RIGHTS 

The User may at any time request the cancellation of his personal data held by Alfageda and may do so by sending a written request to the email address privacy@esta.voyage.

It is understood that in case of request for modification or cancellation of personal data held by Alfageda, the latter will process the request within a reasonable time and in any case no later than 30 days unless the customer is in debt with Alfageda and therefore, in in this case, it will not be possible to delete data concerning the communications and issued invoices.  

RESTRICTION OF PROCESSING

The User may at any time oppose the processing of his personal data held by Alfageda as it may request its transferability. In fact, it is the User's right to revoke the consent given to Alfageda for the processing of his personal data while being aware that such revocation takes effect from the moment of the manifestation of the will and not for the personal data already processed.

The User also has the right to lodge a al complaint with the competent data protection authority in Italy as Alfageda has its registered office in 315 XXIV May street  - 86170 Isernia (Italy).

Alfageda informs the User that he/she undertakes to keep the personal information provided by the same until it is necessary and/or permitted in view of the purposes for which such information was lected. The criteria used to determine the retention period of the User's personal data include the duration of the relationship with the User and the provision of the service to the User. As a general rule, Alfageda will keep the data relating to the User for as long as necessary for the Service to be carried out or in any case until the User requests the cancellation of the same.

SECURITY OF PERSONAL DATA  

Alfageda adopts all technical, physical and management measures to protect the personal data provided by the User, from theft, loss or unauthorized access/use/modification. Alfageda, in fact, adopts all the security measures suitable to provide a level of protection adequate to the risks deriving from the processing of personal data of the User.

MISCELLANEOUS 

The service provided by Alfageda can be offered on platforms owned by third parties or use functionalities managed by third-party platforms that will probably have privacy-related information different from that of Alfageda.  

CHANGES TO THE PRIVACY POLICY

Alfageda informs the User that this privacy statement may undergo further modifications which will be communicated to the same according to the provisions of the law in force.

By using the service provided by Alfageda, the User will consent to the acceptance of the changes made; if the User does not intend to recognize or accept the changes, he/she may withdraw from the Terms and Conditions.  

COOKIES AND OTHER TECHNOLOGIES  

Alfageda uses cookies and other technologies such as plug-ins to allow the User to access the services provided more easily. In fact, in order to make the user's visit to the Alfageda website as convenient as possible and to better explain its services, Alfageda uses cookies. These are small text aggregates recorded locally in the temporary browser memory for variable periods of time depending on the user's need.

Through the cookies it is possible to record in semi-permanent way information related to the User's preferences and other technical data that allow easier navigation and a greater ease of use and effectiveness of the site itself. For example, cookies can be used to determine if a connection has already been made between the User's computer and the Alfageda website. To guarantee the User, it is identified only the cookie stored on the computer. The User has the possibility to read the rules regarding cookies on the Alfageda website.

The plug-in is a non-autonomous program that interacts with another program to widen or extend its original functionality and it is used for purposes similar to those of cookies; many commonly used browsers allow you to erase information stored in the browser through the settings/preferences area.