We attach great importance to the protection of your personal data. With this privacy policy we would like to explain in detail what personal data we collect and the purposes for which this data is processed.
1. Data controller and contact
The controller of the user’s personal data is:
- UGo Experience
- HEAD OFFICE: Piano di Sorrento, Via Bagnulo 237
- Email address: www.ugoexperience.it
- VAT No. 10223671214
If you have any questions or suggestions regarding data protection, or if you wish to exercise your rights, please contact us at the following link:https://ugoexperience.it/The Data Protection Officer can be contacted via the following e-mail address: info@ugoexperience.it
This policy also applies as information – pursuant to Article 13 of Regulation (EU) No. 2016/679 (hereinafter the GDPR) – given to those who interact with the Site.
2. Object of Data Protection
The object of data protection is personal data, i.e. all information relating to an identified or identifiable natural person. Personal data are hereinafter also referred to simply as data
3. Automated data collection
- When accessing our website, the user’s terminal device automatically transmits data for technical reasons. The following data is saved separately from other data that the user may transmit to us:
- URL of the access page
- Network connection latency
- Date and time
We save this data for the following purposes:
- for load balancing, i.e. to distribute access to our website across different devices and to be able to offer the fastest possible loading times;
- to ensure the security of our IT systems, i.e. to defend ourselves against specific attacks on our systems and recognise attack patterns;
- to ensure the proper functioning of our IT systems, e.g. where errors occur that we can only rectify by saving the IP address;
- to enable criminal prosecution, prevention of danger or prosecution in case of specific indications of offences.
The user’s IP address will be saved for a period of 30 days only.
In this case, processing will be carried out to ensure security in accordance with Article 32 GDPR, as well as on the basis of our legitimate interest in protecting against abuse of our service (Art. 6 para. 1 lit. f) GDPR.
Reviews and ratings
Our website offers the possibility to rate and comment on tours or activities. After completing a tour booked throughour website, we may ask you to rate it. Of course, submitting a rating will be done on a voluntary basis. Once you have submitted a rating, we will collect the data you have entered to process it in accordance with the function you have used and publish it on our website. You may request to delete an evaluation at any time by contacting our customer service.
The processing of user data for these purposes is done to protect our legitimate interest in providing users with as much information as possible about the tours we offer. User evaluations are also in the interest of all other users. Therefore, the legal basis for the processing is Art. 6 para. 1 lit. f ) GDPR.
Customer care
- Processing of requests
If you send us requests via e-mail, telephone, contact form, WhatsApp, social media channels or via other means, we will process the information you provide in this context to process your request (Art. 6 para. 1 lit. b) GDPR. The further storage of data sent in the context of your request is based on our legitimate interest in documenting our business operations and safeguarding our legal positions (Art. 6 para. 1 lit. f) GDPR) and, where applicable, for the purpose of fulfilling legal obligations (Art. 6 para. 1 lit. c) GDPR.
Your request will be processed by our data controller, Ugo Experience.
- Treatment modes
The processing of Personal Data is carried out by means of computer and/or telematic tools, with organisational methods and logic strictly related to the purposes indicated.
In some cases, subjects involved in the organisation of the Data Controller (such as, for example, personnel management staff, sales staff, system administrators, etc.) or external subjects (such as IT companies, service providers, postal couriers, hosting providers, etc.) may also have access to Personal Data. These subjects may be appointed as Data Processors by the Data Controller, as well as have access to the Personal Data of the Users whenever necessary and will be contractually obliged to keep the Personal Data confidential.
The updated list of Responsible Persons can be requested by emailing info@ugoexperience.it.
Bookings and payments
- Bookings
When you book a tour, activity or similar on our website, we collect the data required to run the tour This generally includes the following information: first and last name, billing address, e-mail address, telephone number, number of participants, date and time. Depending on the type of activity booked, it may be necessary for us to collect additional information, e.g. your age and the facility where you are staying. The processing that takes place in connection with this is based on Art. 6 para. 1 lit. b) GDPR. To the extent necessary,we will transfer your data to the entity responsible for the tour or activity. Insofar as it is necessary to transfer data outside the European Economic Area, this is based on Art. 49 para. 2 lit. b), c) GDPR. In the case of booking via partner sites, we will receive the data provided to make the booking from the partner. - Payments
You have various options for payment of your booking Therefore, we will process the necessary data in each case, depending on the selected payment method. Within this context, the user’s personal data will be processed as described below, on the basis of Art. 6 Para. 1 lit. b) GDPR, and it will be necessary to process this data in order to execute the selected payment method.
Fraud prevention
In order to protect ourselves and the activity providers from fraudulent bookings, we evaluate the information provided by our customers during the booking process, including data technically transmitted by their device, to the extent necessary to protect our legitimate interest and that of the activity providers in reliable bookings (Art. 6 para. 1 lit. f) GDPR.
Cookies We use
so-called “cookies” in order to offer certain functions of our website and to optimise its use. Cookies” are small files that are saved on your device with the help of your Internet browser. Specifically, unless other cookies are specified elsewhere in this privacy policy or in our cookie consent, we use the following cookies:
- Session or navigation cookies: which ensure normal navigation and use of the Site. As they are not stored on the user’s computer/mobile phone they disappear when the browser is closed.
- Persistent cookies: these cookies serve to save data even after the end of the browser session, if that is what the user wishes.
- The legal basis for the use of such cookies is Art. 6 para. 1 b) GDPR, if this is necessary for the use of our website and the functions used. Otherwise, we use cookies (as described below) on the basis of the user’s consent. You may revoke your consent at any time via our CHANGE PREFERENCES LINK
Marketing and remarketing services
Evaluation of advertising on the web or social media platforms.
We place advertisements, widgets, etc. on third-party sites on the web or social media platforms. To measure the success of our advertisements, cookies are installed (after the user has given consent) when the user is redirected from the relevant third-party site to our website, in order to use them to analyse click behaviour for billing purposes. The use of cookies and the analysis of the user’s click behaviour is based on the user’s consent, which we obtain before the respective cookie is set (Art. 6 para. 1 lit. a) GDPR).may revoke your consent at any time via our CHANGE PREFERENCES LINK.However, thiswill notaffect the lawfulness of the processing performed prior to revocation of consent.
Deletion of user data
We delete and make autonomous your personal data as soon as it is no longer needed for the purposes for which it was, collected or used, in accordance with the paragraphs above. We continue to retain your data if we are obliged to do so for legal reasons or if the data is needed for a longer period of time for criminal proceedings or to secure, enforce or legal claims.
What are the user’s rights and options?
You can exercise your right to data protection in various ways. For example, you can withhold consent to the sending of marketing information by clicking on the “unsubscribe” link in e-mails, in your account when applicable, or by contacting our customer service. Our Privacy Policy contains further information on the various options and your data protection rights.
- Right of access
You have the right to receive information from us at any time, upon request, about your personal data processed by us, to the extent and in accordance with the conditions set out in Article 15 GDPR - Right to rectification
You have the right to request the prompt rectification of any inaccurate personal data relating to you - Right of deletion
You may request the deletion of personal data relating to your person in accordance with the conditions set out in Article 17 GDPR These conditions set out in particular the right to delete any personal data if it is no longer necessary for the purposes for which it was collected or otherwise processed, as well as in cases of unlawful processing, objections or the existence of an obligation to delete under Union or Member State law to which we are subject - Right
You have the right to request restriction of processing pursuant to Article 18 GDPR This applies, in particular, in the event of disputes between us and the user regarding the accuracy of personal data, for the duration necessary to verify the accuracy, in the event that the data subject requests a restriction of processing instead of deletion, where there is a right to deletion, in the event that the data is no longer necessary for our purposes but the user requests deletion in order to assert, exercise or defend legal claims, and in the event that the exercise of an objection is still the subject of a dispute between us and the user. - Right to data portability
You have the right to receive personal data relating to you from us in a structured, standardised and machine-readable format, pursuant to Article 20 GDPR - Right to object You have the
right to object at any time, on grounds relating to your specific situation, to the processing of personal data relating to you, as referred to, among other things, in Art. 6 para. 1 lit. e) or f) GDPR, in accordance with Art. 21 GDPR. Each data subject may at any time revoke any consent given or object to the processing of personal data by sending an email to info@ugoexperience.it - Right to lodge
You may lodge a complaint with the Garante per la Protezione dei Dati Personali if you consider that your rights have been violated - Data Processing in the Exercise of User RightsFinally, we would like to point out that we process personal data provided by you in the exercise of your rights pursuant to Articles 15-22 GDPR for the purpose of implementing these rights and providing the necessary evidence The processing of data carried out has as its legal basis § 6 paragraph 1 letter c), in conjunction with Articles 15-22 GDPR.
