Online privacy policy in accordance with EU Reg. 679/2016

FOREWORD

Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , cares about the privacy and data protection of its existing or potential clients.

We are committed to offering the highest standards of products and services. Accordingly, we value each of our existing or potential customers and aim to maintain adequate protection of their personal data (hereinafter the "Data").

The Online Privacy Policy of Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , explains how Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it collects and processes your Data when you use our website or other digital platforms (hereinafter the "Platforms"), when you purchase products from Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , through our Platforms, as required by the data protection laws in the countries where we operate, such as the General Data Protection Regulation of the European Union (Reg EU 679/2016).

The country-specific amendments below may in some cases also apply to offline data collection. In that case, the country-specific amendment will make it clear that it applies to online and offline data collection.

Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , has implemented a robust data protection compliance program, including the adoption of internal policies and procedures to ensure compliance with applicable data protection laws and regulations, as well as the implementation of appropriate technical and organizational measures to implement data protection principles

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

The web platforms of Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , and the related data processing are managed/performed by/on behalf of Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it. All online sales in the e-commerce section of the website are made by Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , as indicated in the applicable Terms and Conditions.

2. WHAT DATA DO WE COLLECT AND HOW?

The specific type and extent of Data we collect about users depends on their activity and interaction with the Platform (e.g., whether they browse only through our Platform or purchase a product or sign up for our marketing communications). The following Data may be collected through our Platform:

1. Website Usage Information (hereinafter "Log Data"): When users use our Platform for informational purposes only (e.g., they do not register, purchase, or otherwise transmit their data through the Website), their Internet browser automatically collects, and transmits to us, certain basic information related to their use of the Website. Such Log Data may include:

• The browser type and version,
• The operating system and interface,
• the device used,
• language preference,
• The website from which our website was accessed (referring URL),
• The web pages consulted by the user on our platforms,
• The date and time of access,
• part of the IP address,
• the actions taken on the Platforms, and
• The name of the user's provider.

2. Information processed by external social media providers (hereinafter "Social Media Data"): Our Platform contains share buttons that allow you to share content with friends through third-party media platforms and/or social networks (such as Facebook, hereinafter "External Platforms"). Simply using our Platform generally does not involve any data processing activities (including data transfer) in connection with the External Platforms. However, when you use the Share button, the External Platforms may collect and otherwise process your personal data. For more information about the scope and purpose of the data processed by the External Platform provider, including your rights and setting option to protect your privacy, we recommend that you consult the privacy policy of the External Platform provider.

3. Information processed through cookies (hereinafter "Cookie Data"): We use cookies and similar technologies during the operation of our Platforms. The processing of Data based on cookies is subject to Section 9 below. 

4. Information collected when purchasing a product from Rosy Smart City Tours By Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it, (hereinafter "Purchase Data"): If you purchase a product of Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , through our Platform, we collect Data through the purchase form to process your purchase order. If you purchase a product Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , through your account, we also process your purchase history.

5. Information collected when you create an account on the Platform (hereinafter "Account Data"): If you create an account on the Platform in order to be able to order faster, track your order, create and maintain your wishlist, and/or receive exclusive product news Rosy Smart City Tours by Maria Rosaria Castaldi - - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , (where required), we collect Account Data through the account creation form.

6. Information collected when subscribing to the newsletter of Rosy Smart City Tours di Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , or to other marketing communications ("Marketing Data"): If you subscribe to our newsletter or other marketing communications through the Platforms to receive information about products, campaigns or other events of Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , we collect Marketing Data through the Newsletter subscription form.

7. Information collected when you otherwise interact with us through the Platforms ("Required Data"): The Platforms enable or facilitate contact with us, including exercising your rights under Section 8 (as applicable), or sharing your opinion about Rosy Smart City Tours di Maria Rosaria Castaldi products and services - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , in many ways other than those described above, for example by e-mail, telephone, letter or request for data access. The collection of Data depends on how you interact with us and what information you provide to us.

A. If you contact us via the contact form available on the Platforms, we collect the following Data:

• first name (first and last name),
• e-mail address,
• telephone number,
• object,
• message.

B. If youcontact us to exercise your data subject rights (where applicable)., we usually collect the following Data, depending on how the request for data subject rights is made:

• type of relationship with Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , (e.g., customer, employee or other),
• first name (first and last name),
• Type of request (e.g., request for rectification or deletion),
• contact information,
• country of residence, 
• additional request details necessary for processing the user's request (e.g., identification data), and
• The content of the user's request.

8. Information collected about the user by third-party partners: From time to time we may collect Data about you from third party partners (in order to enrich our databases) or engage such third party partners to provide Data about you held by them to external platforms (hereinafter "Third Party Data") in order to provide you with tailored information about our products, services and events on or through such third party platforms.

Important General Notice: When we collect personal data through forms, including but not limited to electronic forms, we will indicate required fields by asterisks. Failure to provide data marked with an asterisk may prevent you from accessing our products and/or services. When submitting any Data, including multimedia content (photographs, videos, etc.), please make sure that it is done accurately and do not transmit sensitive data, such as health information, political opinions, religious or philosophical beliefs, information about your sex life or sexual orientation, racial or ethnic origin, or any content not expressly requested through a questionnaire or any other method of collection (such as commercial information, advertisements, personal creations, ideas or concepts), unless this is required in exceptional cases (e.g. to report any allergies).

Our website is not focused on minors. Should we nonetheless inadvertently collect such information, the child's legal representative may exercise the child's rights on their behalf and in their name at any time (see below).

3. WHY DO WE COLLECT AND PROCESS PERSONAL DATA?

If you are an existing or potential customer of Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , or otherwise interacts with Rosy Smart City Tours di Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , through the Platforms, we may use your data for the following purposes (hereinafter "Purposes of Processing"):

• enable you to browse our Platform and use your personal online account ("Platform-Related Purposes"),
• enable you to obtain information about our products and services from our Help Center, for example in our "Contact Us" section ("Request-Related Purposes"),
• enable the user to purchase the products Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , through our Platform ("Purchase Related Purposes"),
• Enable the user to access our extensive after-sales services on our products Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , ("Purposes Related to After-Sales Support"),
• comply with our legal obligations, including, among others, regulations on the type of products for sale the protection of our distribution networks, the fight against money laundering, credit card fraud, the fight against counterfeiting, and the processing of data subjects' requests for rights ("Regulatory Related Purposes"),
• Collect user opinion about products and services, particularly through surveys and questionnaires ("Product Improvement Purposes"),
• Keep you informed about our products, promotional campaigns and other events by sending you relevant communications from Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , (via email, MMS mail and third-party media platforms; "Marketing Purposes"),
• improve our understanding of your interests and preferences so that we can propose personalized offers and other services that better match your needs and desires.("Preference-Related Purposes"),

4. HOW DO WE JUSTIFY THE PROCESSING OF PERSONAL DATA?

Any processing of Data is legally based on your consent, the need to enter into a contract with you, a legal obligation, and/or our overriding legitimate interest depending on the purpose of the processing.

Details of the legal basis justifying data processing are set out below.

PLATFORM USERS  

5. TO WHOM CAN WE DISCLOSE PERSONAL DATA?

Within the organization Rosy Smart City Tours By Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it

To the extent permitted by law and taking into account the protection of personal rights and freedoms in relation to the processing of Data, Data will be accessible only to a limited and defined number of recipients within Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , as described below. Such access to the Data will take place exclusively on a "need to know" basis, so that the recipients can fulfill the Purposes of the Processing as data controllers. We may transfer Personal Data to another legal entity for purposes of collaboration, joint venture, corporate reorganization, change of legal form, or other similar events. In the event of a merger or sale, the Data will be permanently transferred to the successor company.

Third parties outside the organization Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it

In limited cases, we may transfer Data to government agencies and regulatory authorities (e.g., tax authorities), courts and government authorities in accordance with applicable law, and to outside consultants (e.g., attorneys, accountants, auditors, etc.) as Data Processors. In this context, Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , may also be required to transfer Data to third parties when it receives a request from an authority expressly authorized by law, pursuant to applicable rules and regulations.

Service providers (inside and outside of Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it): Data will generally not be disclosed to recipients outside the Organization Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , In some cases, however, Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , makes use of external service providers who act on behalf of the company on the basis of contractual agreements that include strict data protection obligations. In particular, we will provide Data to service providers as part of our normal business operations, to carry out certain IT-related activities and for them to assist us in managing our Platforms, carrying out our normal activities, assisting us or protecting the security and integrity of our business (including IT maintenance, security and support service providers, hosting providers, payment providers, business and advertising partners, mailing or e-mailing service providers or service centers).

6. INTERNATIONAL DATA FLOWS.

The disclosure of the Data referred to in Section 5 above may result in the transfer of the same Data to countries that do not provide the same level of data protection. Applicable legal and regulatory requirements are considered prior to any cross-border transfer of Data.

Any transfer of Data outside of the user's country that does not offer an adequate level of protection for the same Data will be secured by appropriate contractual safeguards, which must comply with applicable laws and regulations, such as the EU Model Contractual Clauses;

The transfer of Data may also be based on your prior consent. Please note that if you are a citizen of the European Union such a transfer may involve possible risks if the European Union and United Kingdom authorities consider that the country to which the data is transferred does not provide a sufficient level of data protection (absence of an adequacy decision) and adequate safeguards.

7. HOW LONG DO WE KEEP PERSONAL DATA?

I General Interest Data (with the exception of applicant data):

• In order to ensure high quality standards of services and products, we may need to retain Personal Data for as long as necessary to provide those services. Purchase Data will be retained until the last use or purchase of our services or goods, as required or permitted by applicable local law, or where we have a legal or legitimate purpose for doing so.
• For each product sold on our website, we may retain Personal Data for as long as necessary to comply with the law regarding product warranty and safety and to follow up with you on product results and offer ongoing advice. Additional Data will be retained for as long as required by applicable local law or to the extent that we have a legal and legitimate purpose for retaining it. Please note that the period of data retention required by law may vary from country to country.

8. WHAT ARE THE USER'S RIGHTS?

You may have the following rights, to the extent and in accordance with applicable law, which you may exercise through the contact information in Section 10):

• Right of access and information: the user has the right to be informed in a concise, transparent, understandable and easily accessible form of how the Data is processed. He/she also has the right to obtain (i) confirmation of the existence or non-existence of Data concerning him/her and, if so, (ii) to access and obtain a copy of such Data.
• Right of rectification: You have the right to have your Personal Data rectified. You also have the right to have incomplete Data completed.
• Right to cancel: In some cases, you have the right to have your Personal Data deleted. However, this is not an absolute right and Rosy Smart City Tours of Maria Rosaria Castaldi -73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , may have legal or legitimate reasons to retain such data.
• Right to restriction of processing: in some cases, the user has the right to obtain the limitation of the processing of Personal Data
• Right to data portability: you have the right to receive the Data you have provided to Rosy Smart City Tours di Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , in a structured, commonly used and machine-readable format, and has the right to transmit such Data to another data controller without hindrance by Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it . This right applies only when the processing of Data is based on the user's consent or on a contract and is carried out by automated means.
• Right to object to processing: The user has the right to object to the processing of Data when such processing is based on the legitimate interest of Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it .

Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , may, however, invoke imperative and legitimate reasons for the continuation of the processing. The user also has the right to object at any time to the processing of Data for marketing purposes.

To unsubscribe from our "Newsletter" you can use the channels above or simply click on the "unsubscribe" link at the bottom of each Newsletter.

You have the right to file a complaint with the appropriate supervisory authority.

9. WHAT COOKIES DO WE USE AND HOW CAN YOU OBJECT TO SUCH USE?

Cookies are pieces of information that any website or other Platforms can transfer to your browser and that are stored in your computer system. For example, depositing cookies enhances your online experience by allowing us to save your preferences. When you use the Platforms, we send one or more cookies, small text files containing a string of alphanumeric characters, to your device. We use both session and persistent cookies. A session cookie disappears after the browser is closed. A persistent cookie remains after the browser is closed and can be used by the browser during subsequent accesses to our Platforms. Your web browser may provide certain options regarding cookies. Please note that if you delete, or choose not to accept, cookies, you may not be able to use the full functionality of the services provided through the Platforms. We also use third-party cookies in connection with the services provided through the Platforms. For example, we use Google Analytics to collect and process certain analytical data. We do not process or respond to "do not track" signals from web browsers or other similar transmissions that indicate a request to disable online tracking of users accessing our Platforms or using the services provided through our Platforms.

How we use cookies and similar technologies, particularly for services that fit your profile:

We use cookies and automatically collected information to:

• personalize our site and the services provided through it, e.g. we store User Data so that you do not have to re-enter it during your use or subsequent use of our site and the services provided through our site;
• To provide personalized advertising, content and information tailored to the user's profile;
• Monitor and analyze the effectiveness of our Platform and the services provided through our Platform and third-party marketing activities that fit your profile;
• Monitor aggregate site usage metrics, such as total number of visitors and page views;
• keep track of user subscriptions, mailings, and the status of any promotions or other activities offered through our site and the services provided through it(services that fit the user's profile). This can help us, for example, track the amount of emails opened. Tracking technology also helps us to manage and improve the usability of the site, and to identify the most popular sections of the site.

We may also collect your abbreviated IP address on a non-readable basis, which does not allow us to identify you directly.

The following link to Cookie Settings may provide additional information about the cookies used by Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , as well as specific consent settings if the user does not wish that Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , use all or part of the above cookies.

You can also disable the installation of "cookies" by configuring your browser appropriately. For more information, click here.

Please note that restricting cookies may affect the quality of your user experience and may prevent you from using parts of our Platform or services

10. HOW TO CONTACT Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it

FOR PRIVACY QUESTIONS:

To exercise your rights, you may send your request to our Customer Service Department as below and provide the following information: your first name, last name, e-mail, and any other information necessary to confirm your identity in order for us to process your request (such as your mailing address).

• via e-mail: privacy@rosysmartcitytours.com
• via telephone at +(39) 351 6264327

If you have any questions or comments regarding this Privacy Policy or the manner in which Rosy Smart City Tours of Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it , collects and uses Personal Data, you can contact our Data Protection Office at the following address:

Rosy Smart City Tours by Maria Rosaria Castaldi - 73019 Trepuzzi (LE) - P.IVA 04861750752 - PEC: mr.castaldi@pec.it

Attn: data protection officer
Via e-mail: privacy@rosysmartcitytours.com