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Privacy Policy of milanopentour.com

This portal collects some Personal Data of its Users.

This document can be downloaded in PDF format via the following link LINK.

 

Data Controller

MILANOPENTOUR CONSORTIUM LIMITED LIABILITY COMPANY

Via Enrico Fermi n. 9 - 20057 Assago (MI)

Holder's email address: commerciale@milanopentour.com

Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, are: Cookies; Usage Data; email.

Full details on each type of Personal Data collected are provided in the relevant sections of this privacy policy or by means of specific information texts displayed prior to the collection of such Data.
Personal Data may be freely provided by the User or, in the case of User Data, automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users in doubt as to which Data are mandatory are encouraged to contact the Controller.
The possible use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application has 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.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application.

 

Method and location of data processing
Treatment modes
The Controller takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using computer and/or telematic instruments, with organisational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organisation of this Application (administrative, sales, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Place
The Data are processed at the Controller's premises and at any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.
Your Personal Data may be transferred to a country other than the country where You are located. For further information on the processing location, the User may refer to the section on Personal Data processing details.

Storage period
Unless otherwise stated in this document, Personal Data is processed and kept for the time required by the purpose for which it was collected and may be kept for a longer period due to any legal obligation or on the basis of Users' consent.

Purposes of Data Processing
The User's Data are collected to enable the Data Controller to provide the Service, to comply with legal obligations, to respond to requests or enforcement actions, to protect its rights and interests (or those of Users or third parties), to detect any malicious or fraudulent activities, as well as for the following purposes: Hosting and backend infrastructure, Infrastructure monitoring, Statistics, Displaying content from external platforms, Heat mapping and session recording, Contact management and messaging, SPAM protection, Remarketing and behavioral targeting, Advertising and Traffic optimization and distribution.

To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section 'Details of the processing of Personal Data'.

 

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

Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, telephone contacts or contacts of any other kind used to communicate with the User.
These services may also collect data on the date and time the User views the messages, as well as the User's interaction with them, such as information on clicks on links in the messages.

Brevo (Sendinblue SAS)
Brevo is an address management and emailing service provided by Sendinblue SAS
Personal data processed: email, First name, Last name, Company name, Address, Telephone, Sector.

Place of processing: France - Privacy Policy.

Heat mapping and session recording
Heat mapping services are used to identify which areas of a page are subject to cursor or mouse clicks in order to detect which of them attract the most interest. These services make it possible to monitor and analyse traffic data and serve to keep track of user behaviour.
Some of these services may record sessions and make them available for later viewing.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a heat mapping and session recording service provided by Hotjar Ltd.
Hotjar respects generic 'Do Not Track' headers. This means that the browser can instruct the script not to collect any user data. This is a setting that is available in all major browsers. More information on opting out of Hotjar is available here.
Personal Data processed: Cookies; Usage Data; various types of Data as specified by the privacy policy of the service.

Place of processing: Malta - Privacy Policy - Opt Out.

Hosting and backend infrastructure
These types of services have the function of hosting data and files that allow this Application to function, enable its distribution and provide a ready-to-use infrastructure to deliver specific functionalities of this Application.
Some of these services operate through servers located geographically in different places, making it difficult to determine the exact location where Personal Data are stored.

Hetzner Online GmbH
is a hosting and backend service provided by Hetzner Online GmbH

Personal Data processed: various types of Data as specified by the privacy policy of the service.

Place of processing: Germany - Privacy Policy

Infrastructure monitoring
This type of service allows this Application to monitor the use and behaviour of its components, to enable improvement of performance and functionality, maintenance or troubleshooting.
The Personal Data processed depend on the characteristics and mode of implementation of these services, which by their nature filter the activity of this Application.

Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)
Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.
Personal Data processed: various types of Data as specified by the privacy policy of the service.

Place of processing: Turkey - Privacy Policy

SPAM protection
This type of services analyses the traffic of this Application, potentially containing Users' Personal Data, in order to filter it from traffic, messages and contents recognised as SPAM.

Google reCAPTCHA (Google LLC)
Google reCAPTCHA is a SPAM protection service provided by Google LLC.
The use of the reCAPTCHA system is subject to Google's privacy policy and terms of use. For an understanding of Google's use of data, please refer to Google's partner policy.
Personal data processed: Cookies; Usage Data.

Place of processing: United States - Privacy Policy

 

Advertisement
Some of the services mentioned below may use Tracking Tools to identify the User, or use the technique of behavioral retargeting, i.e. displaying advertisements tailored to the User's interests and behaviour, or measuring the performance of advertisements. For more information on this, we suggest that you check the privacy policies of the respective services. Generally, services of this type offer the possibility to disable such tracking. In addition to any opt-out function provided by any of the services listed in this document, you can read more about how to disable interest-based advertisements in the section "How to disable interest-based advertising" in this document.

Meta ads conversion monitoring (Meta pixel) (Meta Platforms Ireland Limited)
Meta ads conversion tracking (Meta pixel) is a statistics service provided by Meta Platforms Ireland Limited that links data from the Meta ad network with actions taken within this Application. The Meta pixel monitors conversions that can be attributed to Facebook, Instagram and Audience Network ads.

Personal Data Processed: Usage Data; Tracking Tools.

Place of processing: Ireland - Privacy Policy - Opt out.

Using Google Ads

Our website uses Google Ads, an advertising service provided by Google LLC. Google Ads uses cookies and similar technologies to show relevant ads to users who have visited our site or other websites. These cookies allow us to collect information about how you use the site, such as the pages you visit and the actions you take.

The information collected by Google is managed in accordance with the  Privacy Policy by Google.
You can opt out of personalized advertising from Google by visiting Settings Google Ads.

Statistics
The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to keep track of the User's behaviour.

Google Tag Manager (Google Inc.)
Google Tag Manager is a statistics service provided by Google Inc.
Personal data processed: Cookies; Usage Data.

Place of processing: United States - Privacy Policy

Google Analytics (Universal Analytics) with anonymised IP (Google Inc.)
Google Analytics (Universal Analytics) is a web analytics service provided by Google LLC or Google Ireland Limited, depending on how the Data Controller manages the processing of the Data, ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualise and personalise ads in its advertising network.
This Google Analytics integration anonymises your IP address. The anonymisation works by abbreviating the IP address of Users within the borders of the member states of the European Union or other countries which are party to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and abbreviated within the United States. For an understanding of the use of data by Google, please refer to the Google Partner Policy.
Personal data processed: Cookies; Usage Data.

Place of processing: United States - Privacy Policy - Opt Out.

Facebook Analytics for Apps
Facebook Analytics for Apps is a statistics service provided by Meta Platforms, Inc. or Facebook Ireland Ltd, depending on how the Data Controller handles the processing of the Data,

Personal Data processed: Usage Data; Tracking Tool; various types of Data as specified in the service's privacy policy.

Place of processing: United States - Privacy Policy; Ireland - Privacy Policy.

Meta Events Manager (Meta Platforms Ireland Limited)
Meta Events Manager is a service statistics service provided by Meta Platforms Ireland Limited. By integrating the Meta, Meta Events Manager can give the Owner information about the traffic and interactions on this Application.

Personal Data processed: Usage Data; Tracking Tools.

Place of treatment: Ireland - Privacy Policy - Opt out.


Information on how to deactivate interest-based advertisements

In addition to any opt-out function provided by any of the services listed in this document, Users can read more about how to disable interest-based advertisements in the appropriate section of the Cookie Policy.

Further information on the processing of Personal Data

Contact Form
Personal data processed: email, First name, Last name, Company name, Address, Telephone, Sector.

Further information for users
Legal basis for processing
The Controller processes Personal Data relating to the User if one of the following conditions is met:

the User has given consent for one or more specific purposes.
the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
processing is necessary to comply with a legal obligation to which the Controller is subject;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.
However, it is always possible to ask the Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Further information on storage time
Unless otherwise stated in this document, Personal Data is processed and kept for the time required by the purpose for which it was collected and may be kept for a longer period due to any legal obligation or on the basis of Users' consent.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the performance of that contract is completed.
  • Personal Data collected for purposes related to the legitimate interest of the 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 processing is based on the User's consent, the Controller may keep the Personal Data for a longer period until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention 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.

User rights under the General Data Protection Regulation (GDPR)
Users may exercise certain rights with regard to the Data processed by the Data Controller.

In particular, within the limits of the law, the User has the right to

  • withdraw consent at any time. The User may revoke his or her previously expressed consent to the processing of his or her Personal Data.

  • oppose the processing of their Data. The User may object to the processing of his or her Data when it takes place on a legal basis other than consent.

  • access to their Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.

  • verify and request rectification. The User may check the correctness of its Data and request that it be updated or corrected.

  • obtain restriction of processing. The User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its storage.

  • obtain the deletion or removal of their Personal Data. The User may request the deletion of his/her Data by the Controller.

  • receive their Data or have them transferred to another data controller. 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 data controller.

  • file a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Users have the right to obtain information about the legal basis for the transfer of Data abroad, including to any international organisation governed by international law or consisting of two or more countries, such as the UN, as well as about the security measures taken by the Data Controller to protect their Data.

Details on the right to object
Where Personal Data are processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are informed that, should their Data be processed for direct marketing purposes, they may object to the processing at any time, free of charge and without giving any reasons. Should Users object to the processing for direct marketing purposes, the Personal Data shall no longer be processed for such purposes. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights
To exercise their rights, Users may address a request to the Controller's contact details indicated in this document. The request is free of charge and the Data Controller will reply as soon as possible, in any case within one month, providing the User with all the information required by law. Any rectification, cancellation or restriction of processing will be communicated by the Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Controller shall inform the User of such recipients if he so requests.

Further information on treatment

Defence in court
The User's Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages to its possible establishment for the defence against abuses in the use of this Application or related Services by the User.

The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

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

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User's IP address.

Information not contained in this policy
Further information in connection with 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 notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the 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 conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
This is the information collected automatically through this Application (including by third party applications integrated in this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, URI (Uniform Resource Identifier) notation 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 server response (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 (e.g. the time spent on each page) and details of the itinerary followed by the User.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of 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 Application who, unless otherwise specified, is the Data Subject.

Interested
The natural person to whom the Personal Data refer.

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

Data Controller (or Owner)
The natural or legal person, public authority, service or other body that, 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 Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Site
The hardware or software tool by which Users' Personal Data are collected and processed.

Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

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

Cookies
Cookies are tracking tools that consist of small portions of data stored within the User's browser.

Tracking Tool
Tracking Tool means any technology - e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that allows Users to be tracked, for example by collecting or storing information on the User's device.

Legal references
Unless otherwise specified, this privacy policy relates exclusively to this site.

Last Modified: September 27, 2024

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