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PRIVACY POLICY
1. Introduction
This Privacy Policy describes how Unconventional Rome Tours S.r.l. collects, uses and protects the personal data of users who access or use the Italy Escape Guided Tours mobile application and the related ItalyEscapeTours.com website, hereinafter collectively referred to as the “Platforms”.
Italy Escape Guided Tours is a mobile application that enables users to discover cities, towns, villages, parks and other locations through interactive routes, riddles, challenges, cultural content and video guided tours.
The use of certain features of the application may require the processing of specific personal data, including, where required by the relevant route, data relating to the location of the user's device.
Personal data are processed in accordance with applicable data protection legislation, including Regulation (EU) 2016/679 (the “GDPR”).
2. Data Controller
The Data Controller responsible for the processing of personal data is:
Unconventional Rome Tours S.r.l. – I Viaggi di Adriano
Via Abigaille Zanetta 18
00143 Rome – Italy
VAT No. 11354461003
Email: info@iviaggidiadriano.it
For any questions regarding this Privacy Policy or the processing of your personal data, or if you wish to exercise any of your rights under applicable data protection legislation, you may contact the Data Controller using the contact details provided above.
3. Personal Data We May Process
Depending on how users interact with the Platforms and Italy Escape Guided Tours services, different categories of personal data may be processed.
3.1 Technical and Usage Data
When using the Platforms, certain technical information relating to the device and connection used may be processed automatically.
Such information may include, by way of example:
- IP address;
- device type;
- operating system;
- application version;
- browser type and version;
- technical information relating to the connection;
- data relating to access to and use of the Platforms;
- information required to diagnose errors or technical malfunctions.
Some of these data may be necessary to ensure the proper operation and security of the Platforms and to identify and resolve technical issues.
3.2 Geolocation Data
Certain Italy Escape Guided Tours experiences may require access to the location of the user's device.
Geolocation may be used, for example, to enable users to identify the starting point of a route, reach individual game stages, verify their position in relation to a location included in the experience, or use other location-based features.
Where required under applicable law, access to location data will take place only after the user has granted the relevant permission through their device.
Users may change or withdraw permission to access their location at any time through their device settings.
However, disabling geolocation may prevent or restrict the proper functioning of certain routes or application features.
3.3 Purchase and Payment Data
Certain routes may be purchased using the payment methods made available through the Platforms or through external services.
Payment-related data may be processed directly by the parties responsible for handling the transaction, which may include, depending on the payment method used, Apple, Google, Stripe or other payment service providers.
Where a transaction is handled entirely by such third parties, Unconventional Rome Tours S.r.l. does not necessarily collect or directly store the user's complete payment card details.
The respective terms and privacy policies of the relevant payment service providers also apply to the processing activities carried out by them.
Unconventional Rome Tours S.r.l. may nevertheless process information relating to the purchase where necessary to verify payment, provide access to the purchased experience, provide customer support and comply with applicable administrative, accounting and tax obligations.
3.4 Data Voluntarily Provided by Users
Where users contact us by email, through a contact form or through other communication channels made available by us, we may process the personal data voluntarily provided by the user.
Such data may include, for example, the user's name, email address and any other information included in the communication.
These data will primarily be used to respond to the user's request and provide any necessary assistance.
3.5 Special Categories of Personal Data
Italy Escape Guided Tours does not intentionally request or collect special categories of personal data within the meaning of Article 9 of the GDPR, including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data processed for the purpose of uniquely identifying a person, data concerning health, or data concerning a person's sex life or sexual orientation.
We also do not intentionally request or collect personal data relating to criminal convictions and offences.
4. Purposes and Legal Bases for Processing
Depending on the circumstances, personal data may be processed for the following purposes:
- to provide access to and enable the use of the Platforms;
- to provide the services and experiences requested by the user;
- to enable the activation and operation of game routes;
- to manage purchases and verify the user's entitlement to access purchased content;
- to provide customer support;
- to respond to requests and communications;
- to ensure the operation, security and integrity of the Platforms;
- to identify and resolve technical issues;
- to prevent fraudulent or abusive use of the services;
- to comply with applicable administrative, accounting, tax and legal obligations;
- to establish, exercise or defend legal claims, whether in judicial or out-of-court proceedings.
Depending on the specific processing activity, the applicable legal basis may be:
- the performance of a contract or steps taken at the user's request prior to entering into a contract;
- compliance with a legal obligation;
- the legitimate interests pursued by the Data Controller, where applicable and provided that such interests do not override the fundamental rights and freedoms of the data subject;
- the user's consent, where required under applicable law.
5. Geolocation and Consent
Where a specific feature requires access to the location of the user's device and consent constitutes the applicable legal basis, users may choose whether or not to grant access to their location.
Consent may be withdrawn at any time by changing the application's permissions through the device settings.
Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal.
Where location data are technically necessary for the operation of a particular experience, disabling access to such data may prevent the user from properly using that specific feature.
6. Disclosure of Personal Data to Third Parties
For the operation of the Platforms and the provision of our services, certain personal data may be disclosed or made accessible to third parties.
Depending on the services actually used, such third parties may include:
- hosting and IT infrastructure providers;
- IT and technical support providers;
- payment service providers;
- email and communication service providers;
- administrative, tax and legal advisers;
- analytics and monitoring service providers, where used;
- public authorities or other parties where disclosure is required by law.
Where such parties process personal data on behalf of Unconventional Rome Tours S.r.l., the relevant relationship will, where required, be governed in accordance with applicable data protection legislation.
Personal data will not be disclosed to third parties for purposes incompatible with those described in this Privacy Policy.
7. Fraud Prevention and Security
We may process information strictly necessary to protect the Platforms, our users and our services against fraud, unauthorised access, unlawful activities or misuse.
Where permitted by applicable law, such information may be shared with specialised service providers or competent authorities where necessary to prevent, detect or investigate fraudulent or unlawful activities.
8. Legal Obligations
Personal data may be disclosed where necessary to comply with an obligation imposed by law, regulation or an order issued by a competent authority.
Personal data may also be processed or disclosed where reasonably necessary to:
- comply with legal obligations;
- respond to lawful requests from competent authorities;
- protect the rights and legitimate interests of Unconventional Rome Tours S.r.l.;
- prevent or investigate fraud, misuse or other unlawful activities;
- protect the safety of users, where necessary;
- establish, exercise or defend legal claims.
9. Data Retention
Personal data will be retained for no longer than necessary for the purposes for which they were collected and, thereafter, for any additional periods required under applicable law.
Retention periods may vary depending on the type of personal data, the purpose of the processing and any applicable legal, tax, accounting or administrative obligations.
When personal data are no longer required for the purposes for which they were collected and there are no further legal obligations or legitimate grounds requiring their retention, they will be deleted or anonymised using appropriate measures.
10. Transfers of Personal Data Outside the European Economic Area
Certain technology service providers used in connection with the operation of the Platforms may process personal data in countries located outside the European Economic Area (“EEA”).
Where personal data are transferred internationally, such transfers will be carried out in accordance with the requirements of the GDPR and other applicable data protection legislation and, where necessary, appropriate safeguards will be implemented to ensure an adequate level of protection for personal data.
11. Data Security
We implement reasonable and appropriate technical and organisational measures designed to protect personal data against loss, misuse, unauthorised access, alteration, disclosure or destruction.
Access to personal data is restricted, where reasonably possible, to persons who require such access for the performance of their duties.
However, no information system can guarantee absolute security. We therefore undertake to maintain and update our security measures taking into account the nature of the personal data processed and the risks that may reasonably arise.
12. Data Subject Rights
Subject to the conditions and limitations provided for under the GDPR, users may exercise their rights in relation to their personal data.
In particular, data subjects may have the right to:
- obtain confirmation as to whether or not their personal data are being processed;
- access their personal data;
- request the rectification of inaccurate personal data or the completion of incomplete data;
- request the erasure of personal data where the conditions provided by law are met;
- request restriction of processing;
- object to processing in the circumstances provided by applicable law;
- receive their personal data in a structured, commonly used and machine-readable format, where applicable;
- withdraw consent at any time where processing is based on consent.
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
To exercise any applicable rights, users may contact:
Unconventional Rome Tours S.r.l.
Email: info@iviaggidiadriano.it
13. Right to Lodge a Complaint
If users believe that the processing of their personal data infringes applicable data protection legislation, they have the right to lodge a complaint with the competent supervisory authority.
For data subjects in Italy, the competent supervisory authority is the Garante per la protezione dei dati personali (Italian Data Protection Authority).
This is without prejudice to any other administrative or judicial remedies available to the data subject under applicable law.
14. Third-Party Services and Websites
The Platforms may contain links to, or integrate services provided by, third parties.
Where such third parties act as independent data controllers, Unconventional Rome Tours S.r.l. does not determine how they collect, use or otherwise process personal data.
Users are therefore encouraged to review the relevant privacy policies before using third-party services.
15. Children and Minors
Italy Escape Guided Tours may offer experiences suitable for families and minors.
Where the processing of a minor's personal data requires the consent or authorisation of a person holding parental responsibility under applicable law, such consent or authorisation must be obtained in accordance with the applicable legal requirements.
Minors should not independently provide personal data through the Platforms where the authorisation or consent of a person holding parental responsibility is required under applicable law.
16. Changes to this Privacy Policy
This Privacy Policy may be amended or updated from time to time, including to reflect changes in applicable legislation, developments in the services offered or changes to the technologies used by the Platforms.
The most recent version will be made available through the Platforms.
Where material changes are made, additional measures may be taken to inform users where required under applicable law.
17. Contact Details
For any questions, requests or further information concerning this Privacy Policy or the processing of personal data, please contact:
Unconventional Rome Tours S.r.l. – I Viaggi di Adriano
Via Abigaille Zanetta 18
00143 Rome – Italy
VAT No. 11354461003
Email: info@iviaggidiadriano.it