This Application collects some Personal Data from its Users.

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Data Controller

Mara Cresta
Travel Planning Service: Bespoke Routes
Registered address: Via Roma 18 - 14051 Bubbio AT
VAT / P.IVA: 01751540053
Email: info@bespokeroutes.com

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Types of Data Collected

Among the Personal Data that this Application collects, either independently or through third parties, there are: usage data; tracking tools; name; surname; email; and other data voluntarily provided by the User in the travel request form.

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Complete details for each type of Personal Data collected are provided in the dedicated sections of this privacy policy or in specific information texts displayed prior to data collection.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, the Application may be unable to provide the requested Service.
Where this Application indicates certain Data as optional, Users are free to refrain from providing it without affecting the availability or functionality of the Service.

Users who are uncertain about which Data is mandatory are encouraged to contact the Data Controller.

The possible use of Cookies — or other tracking tools — by this Application or third-party service providers serves to provide the Service requested by the User, in addition to the other purposes described in this document.

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The User assumes responsibility for Personal Data belonging to third parties that is obtained, published, or shared through this Application.

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Methods and Place of Processing

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Methods of processing

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.

Processing is carried out using computers and/or telematic tools, following organizational procedures strictly related to the stated purposes.
In addition to the Data Controller, certain categories of personnel involved in the organization of this Application (administrative, legal, IT, marketing, etc.) or external parties (such as technical service providers, hosting providers, IT companies, communication agencies) may have access to the Data if necessary and may be appointed as Data Processors.

An updated list of Data Processors may be requested from the Data Controller at any time.

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Place

Data is processed at the operational offices of the Data Controller and in any other place where the parties involved are located.

Personal Data may be transferred to a country other than that of the User. For more information about the location of processing, Users can refer to the section on details regarding the processing of Personal Data.

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Retention Period

Unless otherwise stated in this document, Personal Data is processed and stored for as long as required by the purpose for which it was collected.
It may also be retained for a longer period due to legal obligations or based on the User’s consent.

At the end of the retention period, the Personal Data will be deleted. Therefore, after that date, the right to access, delete, rectify or port the Data can no longer be exercised.

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Purposes of Processing

User Data is collected to allow the Data Controller to:

• provide the Service (travel planning and itinerary creation),

• comply with legal obligations,

• respond to User requests,

• protect its own rights and interests (or those of Users or third parties),

• detect malicious or fraudulent activity,

• and for the following purposes: contacting the User and displaying content from external platforms (if applicable).

For detailed information on the purposes of processing and the Personal Data used for each purpose, Users may refer to the section “Details on the Processing of Personal Data.”

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Details on the Processing of Personal Data

 

Contacting the User

By filling in the travel request form or contacting the Controller via email or WhatsApp, the User authorises the Application to use these details to respond to requests, provide preliminary outlines, prepare itineraries, and offer support before and during the trip.

Personal Data processed may include: name, surname, email, number of travellers, travel preferences, budget, and any information freely provided by the User.

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Displaying content from external platforms

This type of service allows Users to view content hosted on external platforms directly from the pages of this Application and to interact with such content.
These services are often referred to as widgets, meaning small elements embedded in a website or application. They provide specific information or perform particular functions and often allow interaction with the User.

These services may still collect web traffic data related to the pages where they are installed, even when Users do not actively use the service.

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Google Fonts (Google Ireland Limited)

Google Fonts is a font display service provided by Google Ireland Limited, which allows this Application to integrate such content within its pages.

Personal Data processed: Usage Data; Tracking Tools.
Place of processing: Ireland — Privacy Policy available through the provider.

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Additional Information for Users

 

Legal Basis for Processing

The Data Controller processes Personal Data relating to the User when one of the following applies:

• the User has given consent for one or more specific purposes;

• processing is necessary for the performance of a contract with the User or for pre-contractual measures;

• processing is necessary for the Data Controller to comply with a legal obligation;

• processing is necessary for the pursuit of a legitimate interest of the Data Controller or a third party.

Users may request clarification from the Data Controller regarding the specific legal basis for each processing activity.

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Additional Information on Data Retention

Unless otherwise specified in this document, Personal Data is processed and stored for the time required to fulfil the purpose for which it was collected, and may be retained for a longer period due to legal obligations or based on the User’s consent.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Controller and the User shall be retained until such contract has been fully executed.

• Personal Data collected for purposes based on the Controller’s legitimate interest shall be retained until such interest is satisfied. Users can obtain further information about 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 retain Personal Data for a longer period until such consent is withdrawn. In addition, the Controller may be required to retain Personal Data for a longer period to comply with a legal obligation or upon order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, once this period has expired, the rights of access, erasure, rectification, and data portability can no longer be exercised.

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User Rights Under the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Controller.

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

• withdraw consent at any time. The User may revoke previously given consent to the processing of their Personal Data.

• object to the processing of their Data. The User may object to processing when it is carried out under a legal basis other than consent.

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

• verify and request rectification. Users may verify the accuracy of their Data and request its update or correction.

• obtain restriction of processing. Users may request that the processing of their Data be restricted. In this case, the Controller will not process the Data for any other purpose than storage.

• obtain the deletion or removal of their Personal Data. Users may request that the Controller delete their Data.

• receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transmitted without hindrance to another controller.

• lodge a complaint. Users may lodge a complaint with the competent data protection authority or take legal action.

 

Users also have the right to obtain information regarding the legal basis for the transfer of Data outside the EU — including to any international organisation governed by public international law or set up by two or more countries (such as the UN) — as well as regarding the security measures adopted by the Controller to protect their Data.

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Details on the Right to Object

Where Personal Data is processed for a public interest, in the exercise of official authority vested in the Controller, or for the purposes of the Controller’s legitimate interests, Users may object to such 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 such processing at any time, free of charge and without providing any justification. If the User objects to processing for direct marketing, their Personal Data will no longer be processed for such purposes.
To find out whether the Controller processes Data for direct marketing, Users may refer to the relevant sections of this document.

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How to Exercise These Rights

Any requests to exercise the User’s rights may be directed to the Controller using the contact details provided in this document. Requests are free of charge and will be processed as quickly as possible, and in any case within one month, providing the User with all information required by law.

Any rectification, deletion, or restriction of processing will be communicated by the Controller to each recipient, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves disproportionate effort. The Controller will inform the User of such recipients if requested.

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Additional Information on Processing

 

Legal Defence

The User’s Personal Data may be used by the Controller in court or in the stages leading to possible legal action arising from improper use of this Application or related Services.
The User declares to be aware that the Controller may be required to disclose Personal Data upon order of public authorities.

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Specific Information

Upon 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.

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System Logs and Maintenance

For operational and maintenance purposes, this Application and any third-party services used by it may collect system logs — files that record interactions and may also contain Personal Data such as the User’s IP address.

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Information Not Contained in This Policy

Further details concerning the processing of Personal Data may be requested from the Controller at any time using the contact information provided.

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Changes to This Privacy Policy

The Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, when possible, within this Application and/or by sending a notification to Users via any contact information available. Users are therefore encouraged to check this page frequently, referring to the date of the last modification listed at the bottom.

If the changes affect processing activities based on the User’s consent, the Controller will collect consent again if necessary.

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Definitions and Legal References

 

Personal Data (or Data)

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

Information collected automatically through this Application (or through third-party services integrated into this Application), including:
IP addresses or domain names of the computers used by the User accessing the Application, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s response (successful outcome, error, etc.), the country of origin, the browser and operating system characteristics used by the visitor, the various time details of the visit (e.g. time spent on each page), and details about the path followed within the Application, with particular reference to the sequence of pages visited and parameters related to the User’s operating system and computing environment.

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User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

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Data Subject

The natural person to whom the Personal Data refers.

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Data Processor (or Processor)

The natural or legal person, public authority, agency or other body that processes Personal Data on behalf of the Data Controller, as described in this privacy policy.

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Data Controller (or Controller)

The natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application.
Unless otherwise specified, the Data Controller is the owner of this Application.

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This Application

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

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Service

The service provided by this Application as described in the relevant terms on this website/application (if available).

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European Union (or EU)

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

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Cookie

Cookies are Tracking Tools consisting of small sets of data stored in the User’s browser.

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Tracking Tool

Tracking Tool refers to any technology — e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags, or fingerprinting — that enables the tracking of Users, for instance by accessing or storing information on the User's device.

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Legal References

Unless otherwise specified, this privacy statement applies exclusively to this Application.