PRIVACY POLICY
The company Travel Open Day S.R.L., (Italian Fiscal Code no: 13119651001) whose registered head office is located in Via Aosta, 30 – 00182 Rome (RM), Italy, and on whose behalf its pro tempore legal representative (hereinafter referred as “Data Controller”), acting as Data Controller for the processing of personal data pursuant to the Articles no. 1 of the Italian Legislative Decree of the 30th of June 2003, no. 196 – Privacy Code (hereinafter referred as “The Code”) and pursuant to the articles no. 4. no. 7) and no. 24 of the REGULATION (EU) 2016/679 of the 27th of April 2016 related to the privacy of the natural persons with regard to the processing of personal data (hereinafter referred as “the Regulation”) informs that, in pursuance of the Article no. 13 of the Regulation, it shall manage the processing of personal data related to the users of its website.
1. Subject of the service
Although the GDPR is not applied to the users other than the natural persons and, therefore, do not fall within the definition of “interested party” it is possible however that during the filling of one or more fields, the persons shall insert their own personal data. In this case, all the protections provided by the GDPR and by the Italian legislative Decree no. 196/03 shall be applied.
The personal data processed within the sections of the website dedicated to the Newsletter and Travel Deals are: personal data, billing data included VAT number, head office and address and contact information (e-mail and telephone number).
2. Purposes of processing and legal basis
The data shall be lawfully and correctly processed and with the utmost confidentiality, in compliance with the appropriate security measures as set out in the Code and the Regulation.
NEWSLETTER AND COMMERCIAL INFORMATION:
The legal basis for processing is normally the data subject’s consent. In the event of a subscription to the Newsletter through the relevant section of the website or a purchase of travel offers displayed in the "Travel Deals" section pursuant to the Article no. 130 paragraph no. 4 of the Italian Legislative Decree no. 196/03, the e-mail address may be included in a CRM system for the purpose of sending commercial communications regarding the products and/or services of Travel Open Day S.r.l. and the Newsletter, subject to the user’s explicit consent.
The opt-out option shall be exercised at any time.
INDIRECT MARKETING:
Subject to the data subject’s explicit consent, newsletters containing offers from commercial partners may be sent. An opt-out option will always be available. Consent for direct or indirect marketing purposes is optional; the sole consequence of a refusal to provide such consent will be the impossibility of receiving newsletters or direct email marketing (DEM).
REGISTRATION – RESERVED AREA (for end customers and international travel operators):
Registration on the website via the Travel Deals section is intended to enable the purchase of the products displayed therein.
Travel Open Day S.r.l., as the owner of the website Italiabsolutely.com, assumes no liability whatsoever for the products sold, the handling of transactions, or the processing of any personal data provided by users during the purchase process.
Responsibility for bookings, payment processing, and data management lies with Arcadia Emme Viaggi S.r.l., with registered office at Viale Roma 61, 47042 Cesenatico, Forlì-Cesena (Emilia Romagna – Italy), VAT No. 01196430407.
Travel Open Day S.r.l. is solely responsible for the processing of personal data provided during registration on the website and/or where the user has explicitly consented to receive newsletters or commercial communications from third parties.
PURCHASE PROCEDURE – Travel Deals
The Travel Deals section of the website Italiabsolutely.com serves solely as a showcase for travel offers managed by Arcadia Emme Viaggi S.r.l.
At the time of purchase, the user will be redirected to the seller’s platform, which will independently manage the processing of personal data and invoicing. In such cases, Arcadia Emme Viaggi S.r.l. will process the user’s personal and purchase data in accordance with the provisions of the General Data Protection Regulation (GDPR).
The data controller will provide appropriate information to the purchaser pursuant to Article 14 of the GDPR.
The provision of personal data is optional. However, refusal to provide data for purposes related to website registration will result in the impossibility to register and to access the services offered by Arcadia Emme Viaggi S.r.l.
The processing of data shall be made by digital and analogical means. The data shall not be subject to public disclosure.
3. Processing methods
The Data Controller shall process the personal data for the time which is necessary and in order to fulfil the purposes mentioned above and in any case for the duration of:
For the selling of commercial information (direct or indirect marketing), the Data Controller shall process the data for 1 years from the last communication sent. It shall be always possible to exercise the opt-out option. In case the email shall not be opened, the Data Controller shall ask to the interested party if he/she intends to go on receiving commercial information or shall proceed to a cancellation.
For the registration to the website, The data will be processed until the consent is revoked. In the event that the account remains inactive for 3 years, we will send you an email to find out if you are still interested in keeping it active; alternatively, the account will be deleted.
For the purchase, the data will be deleted after 10 years from the fulfillment of the contract.
In any case, to be accessed singularly and depending on the level of critical issues, the Data Controller has no prejudice to process the data for a longer period of time when he has justified reason to retain possible that a legal dispute may ensue and based on the Data Controller’ legitimate interest to be defended in a legal proceeding.
4. Data Disclosure
The data provided by purchasers during registration in the Travel Deals section may be shared with:
• third-party companies acting as independent data controllers for the provision of the requested service;
• payment systems (payment gateways), also acting as independent data controllers;
• entities to whom disclosure is required by law.
For the performance of its activities, the company makes use of third-party partners and service providers who are duly appointed as data processors. A full list of such processors is available at the company’s registered office.
Pursuant to Recital 48 of the GDPR, personal data provided by users who have given their consent to receive newsletters and third-party commercial communications may be disclosed to other companies affiliated with Travel Open Day S.r.l. for internal administrative purposes.
In the event of a transfer or sale of the medium ItaliAbsolutely, the data controller may transfer user data to the transferee/purchaser.
5. Storage and Data Transfer
The management and storage of personal data shall be performed on the Data Controller’s servers located within the European Union and/or third party companies’, entitled and duly appointed as Data Supervisors. Currently, the servers are located in Europe. For the sending of newsletters, the Data Controller informs he has decided to use a company which transfers the data to non-EU countries; the data are in USA and the standard contract clauses have been stipulated.
6. Rights of the interested party
In his/her capacity as an interested party, the User has the rights pursuant to the article no 15 of the Regulation and precisely:
1. the interested party has the right to obtain the confirmation of the existence or not of personal data related to him/her, even if they are not yet registered and their communication shall be made in a human readable form.
2. the interested party has the right to obtain the indication of:
a) the origin of the personal data;
b) the purposes and the methods of processing;
c) the logic applied in case a processing is carried out by electronic instruments;
d) the specification related to the Data Controller’s, the Data supplier and the person in charge of the processing
e) the persons or the categories of persons to whom the personal data shall be communicated or who may become aware of it as Authorised Representative in the territory of the State, as responsible person or person in charge.
3. The interested party has the right to obtain:
a) the updating, the rectification, or, where interested, the data integration;
b) the cancellation, the transformation into anonymous form or the blocking of data in breach of law, as well as those data whose retention is unnecessary, in relation with the purposes for which the data was collected or subsequently processed;
c) the attestation that the operations set out in the letters a) and b) have been informed, even as regards to their contents, to those whom the data have been communicated or disclosed, unless the case where such fulfilment shall be impossible or may result in a clearly disproportionate use of means towards the protected right.
4. The interested party shall have the right to oppose, in whole or in part:
a) for legimate reasons to the processing of personal data related to him, even if pertinent to the scope of the collection;
b) to the processing of personal data related to him for the fulfillment of the purposes that are not provided by the Article no. 2
Even pursuant to the articles no. 15 et seq. of the GDPR, the user shall have the right to ask at any time, the access to his personal data, the rectifications or the cancellation of the same, the limitation of the processing in the cases provided by the article no. 18 of the GDPR, obtain the data related to him in a structured format that is commonly used and readable by an automatic device, as set in the cases provided by the article no. 20 of the GDPR. The user shall withdraw at any time his consent, pursuant to the former article no.7 of the GDPR, lodge a complaint to the competent Supervisory Authority as set in the former article no. 77 of the GDPR, in case he retains the processing of his data shall be in contrast to the relative laws and regulations in force.
The user shall send a request for opposition to the proceeding of his/her personal data, as set in the former article no. 21 of the GDPR where he puts in evidence the reasons that justify such opposition. The Data Controller reserves the right to evaluate the request that shall not be accepted in the event of legimate binding reasons in order to proceed with the processing that prevails over the interests, rights and freedoms of the user.
The data subject may exercise their rights in relation to the Newsletter/DEM service at any time by writing to:
- a registered letter with return receipt to: TRAVEL OPEN DAY S.R.L., Via Aosta 30 – 00182 Rome (RM), Italy;
- an e-mail to: This email address is being protected from spambots. You need JavaScript enabled to view it..
The data subject may also exercise their rights in relation to the purchased product, as displayed in the Travel Deals section, by contacting the data controller, Arcadia Emme Viaggi S.r.l., with registered office at Viale Roma 61 – Cesenatico (FC), by writing to: This email address is being protected from spambots. You need JavaScript enabled to view it..
1 Agosto 2025