Privacy policy

The “EasyWays” App requires access to the position in the background so the device can keep track of the user’s position on the routes and warn him if he strays from the track even when the device is in stand-by mode.
 

Data Controller
In the person of the Legal Representative of ItinerAria, Alberto Conte
email address: info@itineraria.eu

Types of Data Collected
The Personal Data collected by this site, either independently or through third parties, include: Cookies and Usage Data. Full details on each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific information texts displayed prior to the collection of the data itself. Personal Data can be freely provided by the User. Users who may have doubts as to which Data is mandatory are encouraged to contact the Data Controller. Any use of Cookies – or other tracking tools – by this Site or by the owners of third party services used by this Site, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available. The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Site and warrants that he/she has the right to communicate or disseminate them, releasing the Owner from any liability to third parties.

MODALITIES AND LOCATION OF DATA PROCESSING

Treatment modalities

The Owner adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The treatment is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Website may have access to the Data if necessary (administrative, sales, marketing, legal, system administrators), who are the Data Processors of the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis for processing
The Controller processes Personal Data relating to the User if one of the following conditions exists :- the User has given consent for one or more specific purposes; Note: in some jurisdictions the Controller may be authorized to process Personal Data without the User’s consent or any of the other legal bases specified below, until the User objects (“opts-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
– the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
– the processing is necessary to comply with a legal obligation to which the Data Controller is subject;
– the processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;
– the processing is necessary for the pursuit of the legitimate interests of the Data Controller or third parties.
However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.

Location
The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller. The User’s Personal Data may be transferred to a country other than the one in which the User is located. You may refer to the section on details of the processing of Personal Data for further information on the location of processing. You are entitled to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as the security measures taken by the Controller to protect the Data.

In the event that one of the transfers just described takes place, the User may refer to the respective sections of this document or request information from the Controller by contacting him at the contact details given at the beginning of this document.

Period of conservation
Data are processed and kept for the time required by the purposes for which they were collected. Therefore, Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller. When the processing is based on the User’s consent, the Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the storage period, the Personal Data will be deleted. Therefore, at the end of this period the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purposes of Data Processing collected
The User’s Data are collected to allow the Data Controller to provide its Services. To obtain further detailed information on the purposes of the processing and the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.

Personal Data Processing
Details Personal Data is collected for the following purposes and using the following services:

Contacting the User
Mailing list or newsletter (this Web Site) By registering for a mailing list or newsletter, the User’s email address is automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information, about this Web Site may be sent. The User’s email address may also be added to this list as a result of registering with this Web Site or making a purchase.
Personal data collected: last name, email and first name. Contact Form (this Website)The User, by filling out the contact form with his or her Data, consents to their use to respond to requests for information or any other nature indicated in the header of the form. Personal Data collected: last name, email, name and phone number.

Tag management
This type of service is functional to the centralized management of tags or scripts used on this Website. The use of these services involves the flow of User Data through them and, where appropriate, their retention.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Cookies and Usage Data.
Place of processing: USA – Privacy Policy.

User Rights
Users may exercise certain rights with reference to the Data processed by the Data Controller. In particular, the User has the right to:
– revoke consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed.
– pose the processing of their Data. The User may object to the processing of their Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
– cess your Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
– rify and request rectification. The User may verify the correctness of its own Data and request its update or correction.
– tain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
– tain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
– ceive their Data or have it transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another owner. This provision is applicable when the Data is processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.
– opose complaint. The User may propose a complaint to the competent data protection supervisory authority or take legal action.

Details on the right to object
Where Personal Data is processed in the public interest, in the exercise of public authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation. Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights
In order to exercise their rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.

Cookie Policy
This website makes use of cookies. To learn more and to view the detailed information, the User may consult the Cookie Policy.

FURTHER INFORMATION ON TREATMENT

Defense in court
The User’s Personal Data may be used by the Data Controller in court or in the preparatory phases of a court case to defend against abuse of this Website or related Services by the User. The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific information
On request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details in the possession of the Data Controller. Therefore, please consult this page regularly, referring to the date of last modification indicated at the bottom. If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references
Personal Data (or Data) Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
The information collected automatically through this Website (including by third party applications integrated into this Website), including: IP addresses or domain names of the computers used by the User who connects with this Website, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various time connotations of the visit (for example, the time spent on each page) and details of the itinerary followed by the visitor.) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User
The individual using this Website who, unless otherwise specified, is the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Manager)
The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set forth in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Web Site.

This Website
The hardware or software tool by which Users’ Personal Data is collected and processed.

Service
The Service provided by this Website as defined in the relevant terms (if any) on this Website.

European Union (or EU)
Unless otherwise specified, any reference in this document to the European Union shall be deemed to include all current member states of the European Union and the European Economic Area.

Cookie
Small piece of data stored on the User’s device.

Legal references
This privacy policy is drafted on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy policy relates exclusively to this Website.

Alberto Conte
Legal Representative of ItinerAria

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