The website www.elite-luxury-tours.com (hereafter “Site”) is owned and managed by Elite Luxury Tours srl (hereinafter ELT srl), with registered office in Turin (TO), Italy, via Valle della Torre n. 35 CAP 10149, Fiscal Code and VAT Number 11959490019.

Trust is at the foundation of our company reality. This is why we believe that the trust of our users, customers, prospects and suppliers in the protection of personal data is essential. For this reason we are committed to complying with applicable data protection laws. We are always working to stay compliant.

This information according to EU Regulation 2016/679 (GDPR) informs you about the processing of your personal data in relation to the website www.elite-luxury-tours.com.

WHAT DATA DO WE COLLECT?

When you use our services and / or voluntarily fill out a form and / or send a request by mail and phone showed in our site and / or participate in some applicative activity in our site, you accept that our company collects some of your personal data . This page is intended to tell you what data we collect, why and how we use it.

We treat two types of data:

– Data provided by the user

– Data that we collect automatically.

DATA SUPPLIED BY THE USER

If you are a private person

If you are a private individual, when you register, enter or reply to an announcement, we ask you to provide us with some data to be able to receive our service, get an appointment or advice, send us a request, stay updated with products / services and information about our company.

As example, the data we may ask for are the following:

• First name
• Surname
• Age range
• Sex
• Telephone contact
• Email
• City of residence
• Country of residence
• Interest relating to favorite tourist locations or accommodation facilities
• Credit and Debit cards references requested as collateral security for the balance
• Arrival and departure dates
• Any additional services purchased

Exception made for the Credit and Debit Cards which are necessary only for formal procurement, these Data are necessary for request for quote and with the aim to manage third party data.

If you provide personal data of third parties, such as those of your family or friends, you must be sure that these subjects have been adequately informed and have allowed to the related data protection directive described in the present document.

CHILDREN’s UNDER 14

If you are under 14 years old, you cannot provide us with any personal data and you cannot register yourself on our website, and in any case we do not assume any responsibility for any false statements that you provide.

In the event that we realize the existence of untruthful declarations, we will proceed with the immediate cancellation of any personal data acquired.

IF YOU ARE A LEGAL ENTITY

If you are a Legal Entity we may ask you to provide us with the following information:

• Company name
• Company registered office
• Telephone contact
• Contact Names to refer to
• Email
• VAT number
• Events of interest
• Accommodation facilities for which you have an interest
• Information regarding the participants to the stay/venue similar to those indicated for private

individuals.

AUTOMATICALLY COLLECTED DATA

By using our services, we may collect the following data:

• Technical data: for example IP address, type of browser, information on your computer, data relative to the current (approximate) position of the instrument you are using;
• Data collected using cookies or similar technologies: for more information, please visit the “Cookies” section.

HOW WE USE PERSONAL INFORMATION WE COLLECT?

We use the data collected to provide the service selected by you, to inform you about our business activities or offer a more personalized service in line with your interests.

Personal data are used (see Article 6 (b) of the GDPR):

1. a) to allow navigation on the website and
2. b) if necessary to perform the service or provision requested as part of the normal activity carried out by ELT srl (ATECO code 79.12.00 – Tour Operator activities).

Furthermore all personal data may be processed:

1. c) for purposes connected to obligations established by law, as well as by instructions given by the authorities authorized by the law (see articles 6 (c) and 9 (b, g, h) of the GDPR);
2. d) for the ascertainment, the exercise or the defense of a judicial and extrajudicial right to legitimate interest of ELT srl (ref.Article 6 (f) and 9 (f) of the GDPR);
3. e) for direct marketing purposes according to the legitimate interests of the Owner in particular; for cookies, advertising ids used to show advertisements and ads; for e-mail addresses for sending the newsletter; for navigation and usage logs to protect site and service from cyber-attacks; in these cases the interested party can always refuse consent so that the Data Controller will abstain from processing (see Article 6 (f) of the GDPR);
4. f) for functional purposes for which the interested party has the right to express his consent or not, such as subscribing to the newsletter to receive information messages and to promote and sell products and services, measure satisfaction, favor the interests of the person concerned outside the services required, etc. (see Article 6 (a) of the GDPR);
5. g) with the consent of the interested party, in the case of sensitive data (see Article 9 (a) of the GDPR);
6. h) with the consent of the interested party, by profiling the person concerned (see Article 6 (a) of the GDPR);

IS DATA RELEASE COMPULSORY?

The provision of data collected from the interested party is optional but essential for the purpose of processing them for the purposes of letters a) and b). In the event that the parties do not communicate their indispensable data and do not allow the processing, it will not be possible to carry out and put in place the proposed services and to follow the contractual obligations undertaken, with a consequent prejudice for the correct fulfillment of regulatory obligations, such as accounting, tax and administrative, etc.

Apart from that specified for navigation data, the user is free to provide personal data for cookies and specific requests via forms e.g. on products and / or services. Failure to provide such data may make it impossible to obtain what has been requested. For all non-essential data, including sensitive data, conferment is optional. In the absence of consent or incomplete or incorrect conferment of certain data, including sensitive data, the required obligations may be so incomplete as to cause injury or in terms of penalties or loss of benefits, and for the impossibility of ensuring the adequacy of the processing same to the obligations for which it is performed, and for the possible mismatch of the results of the treatment itself to the obligations imposed by the law which it is addressed, intending to exonerate the writing organization from any and all liability for any penalties or measures afflicting.

WHO ARE THE SUBJECTS OF THE TREATMENT?

HOLDER OF THE TREATMENT

The data controller is ELT SRL in the nominated person of Angelo Amore, with registered office located in Turin (TO), Italy, Via Val della Torre 35, C.F. and VAT number 11959490019.

We remind you that you can contact the Owner at any time and send any question or request regarding your personal data and respect your privacy by writing to dataprotection@elite-luxury-tours.com.

SUBJECTS TO WHICH PERSONAL DATA MAY BE DISCLOSED

The Data collected as part of the provision of the service may be communicated to:

• Partner r suppliers (such as hotels, rental and transport companies, restaurants, tour guides, airline companies)
• companies that perform functions that are strictly connected and instrumental to operations such as suppliers that provide services for the review and verification of the service provided, suppliers of direct marketing services and customer care, companies that provide archiving, administrative, payment and billing, IT infrastructure providers, hosting and domain we support;
• bodies and administrative and judicial authorities by virtue of legal obligations

Your personal data may be transferred outside the European Union to be processed by some of our service providers. In this case, we make sure that this transfer takes place in compliance with the legislation in force and that an adequate level of personal data protection is guaranteed based on an adequacy decision, on standard clauses defined by the European Commission or on Binding Corporate Rules.

Under no circumstances we transfer or sell personal data to third parties.

DATA PROCESSING METHODOLOGY

Web services as described in the website are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected; take place at the server in the EU and are only handled by technical personnel in charge of processing, or by any persons in charge of maintenance and administration. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access and loss of confidentiality. The structure is equipped with anti-intrusion devices, firewall, log and disaster recovery. Specific mechanisms of encryption and segregation of data and authentication and authorization of users are used.

Data processing means the collection, recording, organization, storage, processing, modification, cancellation and destruction or the combination of two or more of these operations. In relation to the aforementioned purposes, the processing of personal data takes place using manual, computerized and telematic tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of personal data will therefore be processed in compliance with the methods indicated art. 5 EU Reg. 2016/679, which provides, inter alia, that the data are processed lawfully and fairly, collected and recorded for specific, explicit and legitimate, exact, and if necessary updated, relevant, complete and not excessive in relation to the purposes of the processing, respecting the fundamental rights and freedoms, as well as the dignity of the person concerned, with particular reference to privacy and personal identity, through measures of protection and security. The undersigned organization has prepared and will further improve the security system for accessing and storing data.

HOW AND HOW LONG YOUR DATA WILL BE STORED?

Storage of personal data will be in paper form and/or electronic/informatic and for the time strictly necessary to fulfill the purposes described in this statement, respecting your privacy and current regulations.

For purposes of analysis directed to the development and improvement of the service, the personal data of the user may be subject to a retention period of 36 months.

For direct marketing and profiling purposes we keep your data for a maximum period equal to that foreseen by the applicable legislation (respectively equal to 24 and 12 months).

Invoices, accounting documents and transaction data are stored for 11 years in accordance with the law (including tax obligations).

In the case of the exercise of the right to be forgotten through the request for explicit cancellation of personal data processed by the owner, we remind you that such data will be stored, in a protected form and with limited access, only for the purpose of ascertaining and suppressing crimes. no more than 12 months from the date of the request and will subsequently be securely deleted or anonymised irreversibly.

Finally, we remind you that for the same purposes, data relating to electronic traffic, excluding the contents of communications, will be kept for a period of no more than 6 years from the date of communication, pursuant to art. 24 of the Law n. 167/2017, which implemented the EU Directive 2017/541 on anti-terrorism.

If you do not exercise any active action (for example navigation, searches and / or any other way of using the service) on ELT srl for a period of 27 months, you will be classified as an inactive user and your personal data will be deleted automatically.

FURTHER INFORMATION

APPLICATIONS

The curricula received for specific selections may be kept and revalued for subsequent searches for professional positions compatible with the candidate’s profile, provided they are implemented within a period of maximum 2 years. The candidate may, at any time, object the processing of his personal data by writing to the data protection@elite-luxury-tours.com box.

If you apply, remember to include in your curriculum vitae the declaration by which you consent to the processing of personal data for the purpose of selection and avoids the insertion of sensitive personal data (such as the state of health, religious beliefs, philosophical or political ) not relevant to the job offer.

HOW CAN YOU HAVE INFORMATION ON THE DATA, CHANGE IT, DELETE IT OR HAVE A COPY?

ACCESS TO PERSONAL DATA IN OUR POSSESSION THROUGH REQUEST AND REVOCATION OF CONSENT (opt-out)

You can, at any time, require and view your personal data by requesting in the appropriate form.

Remember that you can revoke the consent you have provided at any time by making a request in the appropriate form.

EXPORTING AND CANCELLATION OF PERSONAL DATA

To export your personal data (takeout) or request cancellation, you can send a request using the appropriate form.

The cancellation will be carried out in the expected technical times and in accordance with the retention period specified in the section “HOW AND HOW LONG YOUR DATA WILL BE STORED?”

YOUR RIGHTS

Any natural person who uses our service can:

• obtain from the owner, at any time, information about the existence of their personal data, the origin of the same, the purposes and methods of treatment and, if present, to obtain access to personal data and information of which in Article 15 of the GDPR
• request the updating, rectification, integration, deletion, limitation of data processing if one of the conditions provided for in Article 18 of the GDPR occurs, the transformation into anonymous form or blocking of personal data, processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected and / or subsequently processed
• object, in whole or in part, for legitimate reasons, to the processing of data, even if pertinent to the purpose of the collection and processing of personal data provided for the purposes of commercial information or sending advertising material or direct sales or for the purpose market research or commercial communication. Each user also has the right to revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation
• receive personal data, provided knowingly and actively or through the use of the service, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without impediments
• propose a complaint with the Italian Data Protection Authority

We remind you that for any question or request related to your personal data and to respect your privacy you can write to the dedicated address dataprotection#@elite-luxury-tours.com

CAN THE PRIVACY POLICY BE CHANGED OVER THE TIME?

This information may be subject to change. If substantial changes are made to the use of data relating to the user by the Owner, the latter will notify the user by publishing them with the maximum evidence on their pages or through alternative or similar means

COOKIE POLICY

Cookies are small files that are sent to the browser and saved on the user’s device when they visit www.iswebagency.com. Cookies allow the site to function efficiently and improve its performance. They also provide information to the site owner for statistical or advertising purposes, mainly to personalize the browsing experience by remembering user preferences.

Our site uses different types of cookies and related technologies, each of which has a specific function.

Technical cookies

Technical cookies are distinguished in:

1. Navigation or session cookies.

From the first access these cookies allow the site to work properly and allow you to view the contents on your device by recognizing the language and the market of the country from which you chose to connect. Navigation cookies are technical cookies and are necessary for the operation of the site.

2. Cookie analytics

These cookies are used to process statistical analysis on how users navigate on our ELT site. srl processes the results of these analyzes directly and anonymously and exclusively for statistical purposes.

3. Functionality cookies

These cookies allow, on the basis of your express request, to recognize it on subsequent accesses so as not to enter your data at each visit (for example: “Recognize me next time”).

Functional cookies are not essential for the site to function, but improve the quality and the browsing experience. For the installation and use of technical cookies, the prior consent of the interested party is not required. However, it can manage these cookies through the browser settings, or the sites indicated in the section below managing cookies.

Below is a table that shows the cookies on this site:

HOW THE CONSENT (OPT-IN) IS PROVIDED FOR THE USE OF COOKIES?

The consent for the use of profiling cookies is provided by the user through the following methods: closing the banner containing the brief information, scrolling the page hosting the banner or clicking any of its elements and can be revoked at any time.

All technical cookies do not require consent, so they are installed automatically as a result of access to the site or service.

THIRD PARTIES PROFILING COOKIES

Profiling cookies are designed to create profiles related to the user and are used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net.

For the use of profiling cookies, the consent of the interested party is required with the methods provided on the site.

In the case of third-party cookies, the site does not have direct control of individual cookies and can not control them (it can neither install them directly nor delete them). However, it can manage these cookies through the browser settings, or the sites indicated in the section below managing cookies.

Cookies installed on this site

Here is the list of cookies on this site. The third-party cookies present the link to the privacy policy of the relative external supplier, where it is possible to find a detailed description of the individual cookies and the treatment that is made of them.

GOOGLE ADS

Our site uses “GOOGLE ADS”. When accessing our site through Google, Google Ads inserts a cookie in its browser that allows us to make statistical analysis on the use of our site (for example, the number of registrations and / or first purchases on the Site that derive from a specific Ads) .

You can get more information about conversion tracking, especially about how you can limit the collection of data through Google cookies at the following link: http://services.google.com/sitestats/de.html.

GOOGLE ANALYTICS

We use Google Analytics. A Web Analytics service provided by Google.

Google Analytics uses cookies that allow the analysis of the use of the website. The information generated by the cookie on the use of the site is transferred to a Google server and stored. The IP address will not be visible. Only in exceptional cases will the IP address be transferred to Google’s servers and made anonymous later. Google will use this information on behalf of ELT srl for the purpose of examining its use of the Site, for compiling reports on the activities of the Site and for providing other services relating to the activities of the Site and the use of the Internet for site managers. Google will not associate the IP address transferred from your browser as part of Google Analytics to any other data held by Google. You can disable the use of cookies by selecting the appropriate setting on your browser; however, please note that in the case of disabling cookies you may not be able to access all the features provided by the Site. Furthermore, it may prevent the collection of data generated by cookies and related to the use of the Site (including its IP address) and the processing of such data by Google by downloading and installing on your browser the plugin available at the following link (link valid as of June 2015):

https://tools.google.com/dlpage/gaoptout?hl=it.

We also use Google Analytics to analyze Google Ads data for statistical purposes (for example determining how many times a product is displayed / selected). If you want to disable this feature you can do so using the settings on your preferences: http://www.google.com/settings/ads/onweb/?hl=de.

If and to the extent that you have registered on our Site and visit it, we will use Google Analytics to create cross-device reports on its activities on the Site. To this end, we will link your ELT srl username with your usage profile on Google Analytics without linking this profile with its real name or other information that identifies it individually and directly. This ability to analyze also works to a limited extent without cookies, so its behavior on the Internet can be at least partially assessed through Google Analytics Universal if you have disabled cookies in your browser. To avoid this monitoring, please use the following link: https://tools.google.com/dlpage/gaoptout?hl=it.

HOW TO DISABLE COOKIES AND MANAGE PREFERENCES

Most browsers are configured to accept, control or possibly disable cookies through settings. We remind you, however, that disabling cookies or navigation functional ones can cause the site to function and / or limit the service we offer. Below is the path to follow to manage cookies from the following browsers:

IE: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies/.

Safari: http://support.apple.com/kb/PH11913/.

Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en.

Firefox:: http://support.mozilla.org/it-IT/kb/enable-and-disable-cookies-website-preferences/.

To disable analytical cookies and prevent Google Analytics from collecting data on its navigation, you can download the Browser Add-on to disable Google Analytics:: https://tools.google.com/dlpage/gaoptout.

For more information on cookies and to manage your preferences on third-party profiling cookies, please visit http://www.youronlinechoices.com.

To request to cancel profiling through cookies, please write to dataprotection@elite-luxury-tours.com

FURTHER INFORMATION ON COOKIES AND HOW TO EXERCISE OPT-OUT

The Youonlinechoice and Networkadvertising.org platforms offer the possibility to refuse or accept the cookies of many digital advertising professionals.

We recommend using these platforms to manage the revocation of consent to the use of cookies.

To learn more about targeted advertising, you can consult the following pages:

• European Interactive Digital Advertising Alliance (EIDAA)
• Network Advertising Initiative (NAI)
• Interactive Advertising Bureau (IAB)

FACEBOOK https://www.facebook.com/about/privacy/update

Below you can use form for your privacy request