Privacy Policy

The “European Regulation 2016/679 relating to the protection of individuals with regard to the processing of personal data, as well as to the free circulation of such data” (from now on “GDPR”) provides for the protection of people and other subjects regarding the treatment of personal data.
Penelope tour, with registered office in Via Cerda, 4 – 91014 Castellammare del Golfo (TP), in the person of Florinda Maiorana, COD FISC. MRNFRN75T46D423B, as Data Controller (hereinafter, “Data Controller”), informs pursuant to art. 13, Legislative Decree 30.06.2003, 196 (hereinafter, the “Privacy Code”) and art. 13, EU Regulation no. 2016/679 (hereinafter “GDPR”) that your data will be processed in the manner and for the following purposes:

1. Object of the treatment
The Data Controller takes care of the protection of your personal data and respects the applicable personal data protection legislation (Privacy Code and GDPR 12016/679). Your personal data are treated confidentially and are transferred to third parties only on the basis of the provisions of this Policy, or with your consent. We process the personal data you provide to us when using the website and / or after registering on the website.

In particular, we deal with:

the personal, identifying and non-sensitive data (in particular, name, surname, tax code, VAT number, email, telephone number – hereinafter, “personal data” or even “data”) provided by you directly, by registering with the site and / or request to use the individual services offered; strictly nominal data for minor users
 data not directly provided by you – and in any case acquired within the limits of the provisions of art. 14, paragraph 5, GDPR – whose transmission is connected to the use of Internet communication protocols (by way of example, access to the page, amount of data transferred, status message after accesses, session ID numbers, IP addresses , URL addresses, etc.). These data allow you to reconstruct the path of your visits to the site.
2. Purpose of the treatment
Your personal data are processed:
A) without your express consent (art.24, lett. A), b), c), Privacy Code and art. 6, lett. b), e), GDPR), for the following Service Purposes:

process a contract request or a pre-contractual request;
execute pre-contractual measures taken at your request;
to elaborate internal statistics;
fulfill tax obligations deriving from existing relationships;
fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority;
safeguard the vital interests of the data subject or another natural person;
perform tasks of public interest or connected to the exercise of public powers in which the data controller is invested;
prevent or discover fraudulent activities or abuses harmful to the website;
pursue a legitimate interest of the Data Controller or third parties, within the limits and conditions set out in art. 6, letter f), GDPR;
exercise the rights of the Data Controller, (by way of example, the right to defense in court);
B) Only with your specific and unequivocal consent (Articles 23 and 130, Privacy Code and Article 7, GDPR), for the following Marketing Purposes:

send via email newsletters, commercial communications and / or advertising material on products and / or services, different and / or dissimilar from those already purchased, offered by the Owner.
3. Nature of the provision of personal data
The provision of your data for the purposes described in point 2, lett. A), no. i and ii) is necessary in nature. In the absence of the provision, we cannot guarantee your registration on the Site, nor the possibility of processing your requests.
The provision of data for the purposes described in point 2, lett. b), has an optional nature. You can therefore decide not to provide any data or withdraw the possibility of processing by us of data previously provided. In this case, you will no longer receive our newsletters, while it will continue to receive our services and you will retain the right to register on the site.

4. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4, Privacy Code and art. 4, no. 2), GDPR and precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The processing of your data will be based on principles of correctness, lawfulness and transparency and may also be carried out through automated methods suitable for storing, managing and transmitting them and will take place using suitable tools, as far as reason and state of the art are concerned, to guarantee safety and confidentiality through the use of suitable procedures that avoid the risk of loss, unauthorized access, illegal use and disclosure.

5. Data retention period
The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and for no more than 2 years from the collection of data for Marketing Purposes. After this retention period, the data will be destroyed or made anonymous.

6. Access to data
The personal data processed by the Data Controller will not be disclosed, or will not be disclosed to indeterminate subjects, in any possible form, including that of making them available or simple consultation. Instead, they may be communicated to workers who work for the Data Controller and to some external subjects who collaborate with them. In particular, your data may be made accessible to:

employees and collaborators of the Data Controller, consultants authorized to manage the site and provide the related services (for example: customer services, IT department, etc.), in their capacity as internal managers and / or persons in charge of the processing of personal data and / o System administrators;
third-party companies or other subjects (by way of example: credit institutions, professional firms, consultants, insurance companies, etc.) that carry out outsourcing activities on behalf of the Data Controller, in their capacity as external Managers and / or Persons in charge of the processing of personal data.
Your data may also be communicated, within the strictly necessary limits, to persons entitled to access it by virtue of the provisions of the law, regulations, community regulations.

7. Disclosure of data
Without your express consent (pursuant to art.24 letter a), b), d), Privacy Code and art. 6 lett. b), c), GDPR), the Data Controller may communicate your data for the purposes indicated to Supervisory Bodies, Judicial Authorities as well as to all the other subjects to whom the communication is mandatory by law for the accomplishment of said purposes.

8. Data transfer
The management and storage of personal data will take place on the server of the Data Controller and / or third-party companies appointed and duly appointed as Data Processors, located within the European Union, or in accordance with the provisions of art. 45 and following, GDPR. The servers are currently located in the European Union. The data will not be transferred outside the European Union. In any case, it is understood that, if it becomes necessary to transfer the location of the servers, to Italy and / or the European Union and / or non-EU countries, this movement will always take place in accordance with Articles 45 and following, GDPR. In this case, however, the Data Controller ensures as of now that the transfer of non-EU data will take place in accordance with the applicable legal provisions by stipulating, if necessary, agreements that guarantee an adequate level of protection and / or by adopting standard contractual clauses. provided by the European Commission.

9. Navigation data
The computer systems and software procedures used to operate the site may acquire, during their normal activity, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified (ie parameters relating to the operating system and the IT environment). user). These data are used by the Data Controller for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and are deleted immediately after processing. These data can also be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.

10. Cookies
When you use our website:, cookies are stored on your computer. Cookies consist of small text files that are saved on your computer and provide us with certain information. They are widely used in order to make websites work or operate more efficiently to improve the user experience, as well as to provide certain information to the owners of the site. Our site uses cookies that remain on your computer for different times. Some expire at the end of each session and some stay longer so that when you return to our site, you can benefit from a better user experience. Web browsers allow you to exercise some control over Cookies through your browser settings. Most browsers allow you to block cookies or block cookies from certain sites. Browsers can also help you eliminate cookies when you close your browser. However, he should keep in mind that this could mean that any opt-outs or preferences he has set up on the site will be lost. Please consult the technical information relating to your browser for instructions. If you choose to disable the setting of cookies or if you refuse to accept a cookie, some parts of the service may not work properly or may be significantly slower.

11. Rights of the interested party
In your capacity as an interested party, you have the rights referred to in art. 7, Privacy Code and art. 15, GDPR and precisely the rights of:

obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
obtain the indication: a) of the origin of the personal data; b) the purposes and methods of treatment; c) the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, of the managers and of the representative appointed pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;
obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment occurs proves impossible or involves the use of means manifestly disproportionate to the protected right;
object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning him for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by email and / or through traditional marketing methods by telephone and / or paper mail. Please note that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.
Where applicable, it also has the rights referred to in articles 16 – 21, GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

12. How to exercise your rights
You have the right to ask the Data Controller for access to the Data concerning you, their correction or cancellation, the integration of incomplete Data, the limitation of treatment; to receive the Data in a structured format, commonly used and readable by an automatic device; to withdraw any consent given in relation to the processing of your sensitive data at any time and oppose, in whole or in part, the use of the Data; to lodge a complaint with the Authority, as well as to exercise the other rights recognized by the applicable discipline.
You can exercise your rights at any time by sending:
a registered A / R to: Penelope tour, Via Cerda, 4 – 91014 Castellammare del Golfo (TP), or an e-mail to the address:

13. Minors
If the subject who provides the data is under the age of 16, this treatment is lawful only if and to the extent that this consent is given or authorized by the owner of parental responsibility for which the identification data is acquired.

14. Owner, manager and agents
The Data Controller is Penelope tour, with registered office in Via Cerda, 4 91014 Castellammare del Golfo (TP), VAT: in the person of Florinda Maiorana, COD FISC. MRNFRN75T46D423B.
The updated list of data processors and appointees is kept at the headquarters of the Data Controller.

15. Changes to this Policy
This information may change. We therefore recommend that you regularly check this Notice and refer to the most updated version.

16. Place and date
Castellammare del Golfo, 11/05/2020

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