( EU REGULATION 2016/679)

personal data collected as per art. 13 and 14 GDPR

Primopiano viaggi s.r.l., in the person of its legal representative pro tempore Mr. Faralli Sergio, based in Santarcangelo (RN) at via Sancisi no. 4, VAT no. 04316510405 hereinafter referred to as the CONTROLLER, in his capacity of Data Controller, hereby informs you that, pursuant to art. 13 and art. 14 of EU Regulation no. 2016/679, hereinafter GDPR, your personal data will be processed in the manner and for the purposes listed below: 

1) personal details of the data controller and data protection officer: Primopiano viaggi s.r.l., in the person of its legal representative pro tempore Mr. Faralli Sergio, based in Santarcangelo (RN) at via Sancisi no. 4, VAT no. 04316510405, available via email at, via certified email at and/or by telephone 0541.1788120, fax 0541.1788121. No data protection officer nor controller’s representative have been appointed, as it is not required pursuant to EU Regulation 2016/679. You may contact the data controller to exercise your rights granted by the GDPR, and to obtain an updated list of all data processors, both internal and external, sub-processors and any other processors. 

2) data undergoing processing: the controller processes personal data that may identify the users (e.g. name, surname, company name, address, telephone number, e-mail address, facebook account, whatsapp account, bank and payment references, and the address specified for delivery in your order), hereinafter referred to as personal data, which you provided upon concluding service and supply contract with the Controller, who manages agencies and tour operators in the organisation of trips for the end users. 

3) Purposes of the processing and legal basis. 

Your data will be processed: 

A) without your explicit consent, pursuant to art. 6 letter 

b) GDPR for the following sales or service purposes: 

– supplying the services of the Controller, who manages agencies and tour operators in the organisation of trips for end users and for associations and / or tour operators and / or travel agencies. 

– fulfilling any pre-contractual, contractual and tax obligations deriving from the customer-supplier relationship; 

– fulfilling all obligations laid down by Law, regulations, Community legislation or any order of Authorities (e.g. anti-money laundering) 

– exercising the Controller’s rights, e.g. the right of defence before the courts. 

B) Only with your explicit and specific consent (art. 6 letter a) GDPR), that you may at any time withdraw, without affecting the lawfulness of processing based on consent before its withdrawal, for the following marketing purposes: 

-contact you via email, mail and/or sms, and/or by telephone and send you newsletters, commercial communications and/or advertising material on products and services offered by the Controller, and customer satisfaction surveys about the services we provide. 

contact you via email, mail and/or sms, and/or by telephone, and send you newsletters, commercial and/or promotional communications of third parties (for example business partners) Please note that you can withdraw your consent at any time, which shall not affect the lawfulness of processing based on consent before its withdrawal. 

C i ) For a legitimate interest of the Data Controller, for statistical purposes or to ensure a better navigation experience on More specifically, with regard to the statistical purposes, this website uses Google Analytics, with IP anonymisation always turned on. The IP address sent from the user’s browser is not associated with any other data held by Google. Users can stop cookies from being stored by changing their browser settings. The legal basis for the data processing is Art. 6 paragraph 1 letter F) of GDPR. Users can prevent the data generated by the cookies from being collected by downloading and installing the browser plugin at the following link:

C ii) For a legitimate interest of the Data Controller and a better navigation experience on, by using cookies, as further explained on our website. In this case, the legal basis for the data processing is Art. 6 paragraph 1 letter F) of GDPR. Please note that this processing method serves our legitimate interest to make our website easy to use, efficient, and safe. The cookies used by our website are known as session cookies. They are deleted when the user closes the browser. Users may decide not to accept the cookies by changing their browser settings. 

C iii) Facebook page. On our website we use the “custom audience pixel” by Facebook Ireland LTD, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland (FACEBOOK). This tool allows us to track the users who were sent to one of the provider’s web pages by clicking on a Facebook ad. In this way, we can assess the effectiveness of the Facebook ads for statistical and market research purposes. Data collected in this way are anonymous, which means that we do not see the data of individual users. However, we hereby inform you that, to the best of our knowledge, such data are stored and processed by Facebook. Facebook may associate the data with the Facebook account and use them for marketing purposes, pursuant to the following data processing policy: Users may give their consent to Facebook and its partners to show ads on Facebook and outside Facebook. To this end, a cookie may be stored in the user’s computer. The legal basis for this service is Art. 6 paragraph 1 letter F) GDPR. Users may object to the collection of data by Facebook pixel or to the processing of such data to view Facebook ads, by contacting:

D) Only with your prior consent, pursuant to art. 9 paragraph 2 letter A) GDPR, for the processing of your health information, so as to conclude service and supply contracts with the Controller, who manages agencies and tour operators in the organisation of trips for the end users. 

4) Processing methods: your personal data shall be processed pursuant to art. 4 n. 2 GDPR, and the processing shall entail: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, destruction, portability upon request. The processing of your personal data is carried out by printed, electronic and/or automated means. Your personal data shall be processed by automated means for no longer than is necessary for the purposes for which they were collected. In accordance with your rights, the automated processing, including profiling, resulting in legal consequences concerning or affecting you, will not be based solely on said automated processing, unless it is necessary to conclude or perform the contract between the interested party and the Controller, or unless the interested party gives his explicit consent. We also inform you that specific safety measures are adopted so as to prevent any data loss, illegal, or incorrect use and unauthorised access. 

5) potential recipients or categories of recipients of the personal data 

Data may be disclosed only to the interested party or to people or companies explicitly chosen by the interested party. They shall not be disclosed to any other third parties, with the exception of people or companies authorised by the Controller (internal or external processors, sub processors, or any other processors). For the purposes set forth in art. 3 A) of this policy, the Controller may, without your explicit consent, disclose your personal data to Supervisory Bodies, Legal Authorities and any other entities to whom data must be disclosed by law and for the aforesaid purposes. Said entities shall process the data in their capacity as independent controllers. Data shall not be transferred to third countries or international organisations. 

6) Data storage period. 

The Controller shall process the personal data for the time provided for by the applicable legislation, pursuant to art. 13 GDPR: fiscal, accounting and civil documents and data have a retention period of 10 years. As for data processed for marketing or profiling purposes, they shall be retained in accordance with the principle of proportionality or at least until the purpose for their processing is fulfilled, unless the interested party withdraws his/her consent to the processing of such data. 

7) Rights of the interested party 

The interested party has the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability. 

8) Consent and withdrawal of consent 

If you have given consent to the processing of your personal data for one or more specific purposes, pursuant to art. 6 paragraph 1 letter A) or explicit consent, pursuant to art. 9 paragraph 2 letter A), for one or more specified purposes, please note that you have the right to withdraw your consent at any time, which shall not affect the lawfulness of processing based on consent before its withdrawal. 

9) Right to lodge a complaint with a supervisory authority 

The Controller hereby informs you that, were you to notice any unlawful, incorrect or non transparent processing of your data, or any other irregularities pursuant to GDPR, you have the right to lodge a complaint with a supervisory authority (Data Protection Authority) or take legal action. 

10) Providing personal details and consequences of any refusal to do so. 

Providing personal data is not mandatory. Any refusal to provide such data will make it impossible to conclude the supply and service contract and to purchase the Controller’s goods as in point 3 A) of this policy. 

11) Profiling 

The Controller hereby informs you that your personal data will not be subject to decisions based solely on automated processing (including profiling) 

12 ) Further processing for other purposes 

The Controller hereby informs you that your data shall be processed only for the purposes for which they were collected. Further processing for different purposes shall be carried out only with the interested party’s consent. 

13)Advertisement, marketing and user’s preferences in communication: 

In case of specific consent we may adopt direct marketing strategies, via email, telephone, text or mail. For example, users may receive our newsletter via email. We do our best so that our website always communicates clearly our activities and the kind of messages we send to the users, both when it is the user who chooses to receive our newsletter and when filling in the contact form. Users may change their mind at any time and choose to cancel their subscription, as per point B of art. 3. 


By using the website, you consent to the use of cookies in accordance with this policy. If you do not agree to such use of cookies, please modify your browser settings or stop using the website. If you choose to disable cookies, your overall experience on the website may be affected. Cookies are computer files or partial data that can be saved on your computer or other internet-enabled devices (e.g.. smartphones or tablets) when you visit a website. A cookie contains the name of the website it belongs to, its lifespan (i.e. how long it will be stored on your device), and a value, which is usually a randomly generated unique number. Cookies are used to make our website easier to use and/or tailor the website and the services provided therein to the user’s interests and needs. Cookies may also be used to make future navigation on the website easier and faster. Cookies are also used to track users’ interests and to compile anonymous aggregated statistics. More information on the cookies used: When you visit this website, the following four types of cookie may be set on your device: first-party cookies, third-party cookies, session cookies, and persistent cookies. 

Session cookies 

The time that elapses from opening the Internet browser and closing it is called a browsing session. Session cookies are stored on your computer or other device only during a browsing session, and are deleted from the user’s device when the browser is closed.

First-party cookies 

First-party cookies are directly saved to your computer or device. They may include cookies such as the session and persistent ones (further described below). We use first-party cookies to track users when they visit one of our websites, for example for analysis purposes. 

Third-party cookies 

Third-party cookies are managed by third parties who may collect and track certain browsing data. We use third-party cookies set by Google Analytics (described in browsing and statistical data collected by third parties) 

Persistent cookies 

Persistent cookies are stored in the visitor’s computer or other device during a browsing session, but remain on the computer or device when the web browser is closed (e.g. password registration). We use persistent cookies to recognise your computer or device when you access one of our websites again, after the end of a browsing session and at the beginning of a new one, to help you quickly reconnect to our website. 

In compliance with the regulation issued by the Italian data protection authority on 8 May 2014, cookies have been divided into two macro categories: 

Technical cookies; 

Technical cookies are used with the sole purpose of “carrying out the transmission of a communication over an electronic communications network, or as strictly necessary for the provider of a company information service explicitly requested by the subscriber or user to provide this service”. They are not used for other purposes and are normally installed directly by the website owner or manager. They can be divided into browsing or session cookies, which allow the user to browse and use a website (e.g. to purchase items online or authenticate themselves to access certain sections); analytics cookies, which can be integrated with technical cookies when used directly by the website manager to gather aggregated information regarding the number of visitors to the site and how they use the site; and functionality cookies, which allow the user to navigate according to a set of selected criteria (e.g., language, products to be purchased) so as to improve the service provided to the same. The user’s prior consent is not required for the installation of these cookies; however, it is compulsory for the website manager to provide a privacy policy, in such manners as he deems more appropriate, if he uses only this type of device. 

Profiling cookies: 

The aim of profiling cookies is to create profiles of the user. They are used to send advertising messages which match the preferences displayed by the user as they navigate the internet. In the light of the highly invasive nature of these cookies on the users´ private sphere, the Italian and European legislation requires users to be informed appropriately on their use so as to give their valid consent. 

The Italian legislation on cookies provides that “storing information, or accessing information that is already stored, in the terminal equipment of a contracting party or user shall only be permitted on condition that the contracting party or user has given his consent after being informed in accordance with the simplified arrangements”. 

This website only uses technical and third-party cookies. 

Browsing and statistical data collected by third parties. 

This website uses statistical web analytics tools provided and managed by third parties that can collect and “track” some navigation data. Please note that many Italian and foreign websites use third-party technology and tools, however, not all of them clearly say it in their “Privacy Policy”. In this policy, we try to inform you in the most correct and transparent way possible: please contact us if you wish to receive any further information or clarification. Since they are collected by tools and Companies other than the website manager, such data is not physically in the possession of Primopiano viaggi srl., which can only consult them and cannot change or delete them autonomously. 

In order to know more about such operations and the privacy policy applying to such data, users must directly contact the Controller, or the Company providing the statistical service. 

Third parties’ tools used in this website include: 

– Google Analytics (provided by: Google Inc. 1600 Amphitheatre Parkway – Mountain Wiew CA 94043, USA Information on Google Analytics: This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). 

Google Analytics uses “cookies”, which are text files that are sent to your computer so that the website can analyse user behaviour. 

The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google undertakes not to associate your IP address with any other data held by Google. You can refuse cookies at any time by changing your settings, however this may prevent you from accessing all features of this website. By using this website, you consent to the processing of your data by Google, for the purposes set out above. 

Here are a few links to better understand the privacy policy of Google Analytics: 

Please send any enquiry about the processing of your data to the Controller (Google Inc.).