INFORMATION ON DATA PROCESSING

We consider the protection of the data that you provide us to use the services offered by our Group to be of fundamental importance and we intend to make the best use possible in order to ensure at the same time security and excellent service.

The trust in our users is of fundamental importance and for this reason we wanted to here explain in the clearest and most exhaustive way the process of treatment and storage of personal data provided to us.

The present document is an integral part of the conditions of sale of our services. By accepting these conditions of sale, you expressly accept the provisions contained in this document.

HOLDER OF THE TREATMENT

Gruppo MilanoCard – Tourist Point srl

Piazza Cavour 3, Milano

privacy@milanocard.it

touristpointsrl@pec.it

TO WHOM THIS DOCUMENT IS REFLECTED

The MilanoCard Group has drawn up this document and the guidelines given here for the collection, processing, storage, modification and deletion of data of users who are not in business and not employees of the Group. For the consideration of the data processing policy of the subjects operating in the company and employees, we invite you to make an explicit request to privacy@milanocard.it

TERMS

• Data Controller: The entity that has arranged this document and that collects, preserves, treats, uses, modifies and cancels the data. In this case, the Data Controller is the MilanoCard Group through its own companies that from time to time are indicated as data controllers in the specific information. On this website (milanocard.it) the data controller is Imprese Falcon srl with offices in Milan, Piazza Cavour 3, touristpointsrl@pec.it
• Data Holder (s): The natural person who directly and / or indirectly provides his data to the Data Controller.
• Customer (s): Data Holder (s)

REASONS FOR THE TREATMENT OF THE COLLECTED DATA

We collect your personal data in order to:

1. Comply with our obligations to customers.
2. Perform the services booked and / or purchased
3. Creation and conservation of legal documents in compliance with accounting standards
4. Manage the use of the Service

• Keep list of special requests
• Verify that the customer has actually used the service
• Keep a list of Customers who have violated the Terms and Conditions of Purchase or the Rules for using the Service.

1. Improve our Services, in particular:
   • processing of your personal data as part of our customer marketing program for the purpose of conducting marketing
   • activities, promoting brands and obtaining a better understanding of your needs and desires;
   • satisfaction analysis (both anonymous and clear)
   • adaptation of our products and services in order to better meet your needs;
   • personalization of commercial offers and promotional messages that we send to you;
   • sending communications relating to special offers and new services created by the MilanoCard Group.
2. Manage the relationship with customers before, during and after the use of the Service:
   • provision of data for the customer database;
   • execution of segmentation operations based on the booking history and on customers’ interests in order to send targeted communications;
   • prediction and anticipation of future behavior;
   • development of statistics and commercial scores and execution of reporting activities;
   • provision of context data for the bid submission tool when a customer visits a group website or makes a reservation;
   • knowledge and management of the preferences of new or loyal customers;
   • sending newsletters, promotions and offers both from the MilanoCard Group and from third-party partners;
   • management of requests for cancellation of newsletter subscription;
   • evaluation of the right of opposition;
3. Improve the services of the MilanoCard Group, in particular:
   • conducting surveys and analyzing customer questionnaires and comments;
   • management of claims / complaints;
4. Comply with local legislation, for example regarding the conservation of accounting documents.

WHAT DATA WE COLLECT

• contact details (eg surname, name, telephone number, e-mail address);
• personal information (eg date of birth, nationality);
• information on the composition of the family unit (quantity of components, presence of children, etc.)
• credit card number (to execute transactions and reservations);
• date of use of our services
• questions / comments before, during and after the use of our services.

Information relating to minors is dealt with only with the prior consent of an adult who exercises effective rights over the minor. Not all of our data collection systems can guarantee that the data holder is actually of age.

We don’t voluntarily collect information of a confidential nature concerning, for example, race, ethnicity, political opinions, religious and philosophical beliefs, membership of trade unions, or information about health or sexual orientation.

Furthermore, in accordance with applicable local laws, other information such as your credit card number, hobbies, personal and recreational activities, the fact that you smoke or not, and so on can be considered confidential information. The MilanoCard Group may need to collect this information to meet its needs or to provide it with an appropriate service, as in the case of specific food regimes.

In this case, according to the laws in force in some countries, your prior consent may be requested with reference to the collection of confidential information.

HOW THE DATA IS COLLECTED

• The data is collected via
• dedicated electronic forms on the reference internet sites, created and managed by the Data Controller (also through
• specialized suppliers). The data is inserted in the dedicated form directly by the data owner or by the operators appointed
• by the data controller on the indication of the data holder.
• customer email contact to the Group’s email addresses
• telephone contact of the customer to the Group’s call centers
• The possibility of collecting and / or keeping the data in paper form is not provided for in the company procedures issued.
• The data is collected during contact (request for information by email or telephone or social network); during the booking and / or purchase of the services of the MilanoCard group; during the execution of the Service; at the end of the use of the Service for marketing purposes.

This document is applied to all channels and methods for collecting and retaining data, directly attributable to the MilanoCard Group.

HOW TO BE PRESERVED AND PROTECTED THE DATA

The MilanoCard Group implements strict prevention and protection rules in order to guarantee the security of data processing. The data controller who is interested in deepening these rules can request the address privacy@milanocard.it copy of the document for the identification of risks and protection and prevention rules.

USE OF THE DATA IN AUTOMATIC PROCESSES

• The treated data is not used in an automated way.
• The data is used for the purposes of macroscopic analysis aimed at providing the customer with information and proposals in line with their interests and behavior.
• The analyzes carried out on the collected data provide the data controller mainly with the following information:
• User interests in relation to certain categories of products and services, in particular in the field of culture, entertainment and leisure.
• Frequency of purchase and return rate on the initiatives proposed by the MilanoCard Group
• Composition of the core of users of the service
• User’s attention regarding the proposals of the MilanoCard Group
• Age
• Area of residence

This information allows the data controller to define, primarily, offers and communication strategies ad hoc for the user but never exclude it from offers and initiatives in their entirety.

SHARING OF THE DATA

• The data can be shared with third parties if such sharing is necessary in order to provide the service purchased / booked by the customer. In such cases, and if the transfer is not clear to the data holder, the customer is informed in advance about the sharing and the subject to which they are transmitted. The subject to whom the data is transmitted has been requested to copy his data management plan in order to be able to verify its validity.
• Within the Group, the Data may be processed by

1. Group personnel;
2. IT departments;
3. marketing services;
4. legal office;
5. tax and labor consultants;

in general, any person, at the entities of the MilanoCard Group, in charge of processing specific categories of personal data. All personnel involved in the treatment process are trained and informed about the correct procedures to implement for the protection of the treatment process (see VDR)

• Local Authorities: MilanoCard Group may also be required to send its information to local authorities if required by law or as part of an investigation and in accordance with local regulations.

DATA ACCESS AND CANCELLATION

• The holder of the data can request the data controller at any time by email at privacy@milanocard.it information about their data processed by the data controller, the methods and purposes of treatment, their correction and / or cancellation.
• The cancellation of the data may make it impossible for the data controller to provide all or part of the service purchased and / or booked. In these cases there is no refund for the customer. The cancellation will not be possible if the conservation of the data is necessary for the purposes of the law.
• With regards to cancellation, the MilanoCard Group reserves the right to evaluate individual requests and their compatibility with the conservation obligations to be paid by the data controller. The MilanoCard Group also reserves the right, as envisaged by the current GDPR, to refuse in whole or in part the request for access to data if the same is objectively unfounded or requires an unjustified relevant commitment from the data controller.

EXPOSED

• The data holder may at any time present the relevant privacy authority (Privacy Authority) if he or she believes that there is a violation of their rights.

UPDATE

• The data controller reserves the right to modify and / or update this document on a regular basis. To this end, the data holder is invited to view it on a regular basis.

Last updated: Novembre 11, 2021.