We are very pleased that you have shown an interest in our company. Data protection is a particularly high priority for the management of www.benarrivati.com. Visitors can usethe Internet pages of the Benarrivati Travel needing to specify any personal data; however, if a data subject wishes to use special business services via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection and privacy regulations applicable to Benarrivati Travel. By means of this data protection declaration, our enterprise wishes to inform the general public about the nature, scope, and purpose of the personal data we collect, use, and process. In addition, data subjects are informed through this data protection declaration of the rights to which they are entitled.
As controller, Benarrivati Travel has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions can, in principle, entail security gaps, so that absolute protection may not bealways guaranteed. For this reason, each data subject is free to transfer his or her personal data by alternative means, e.g. by telephone.
The data protection declaration of Benarrivati Travel is based on the terms used by the European legislative authority for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be readable and understandable for the general public as well as for our customers and business partners. To this effect, we would first like to explain the terminology used.
In this data protection declaration, we use, amongst others, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is subject who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social profile of that natural person.
b) Subject matter of the data
The data subject is an identified or identifiable natural person whose personal data are processed by the controller for the purpose of processing.
Processing is any operation or set of operations which is performed upon personal data or sets of personal data, including by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise divulgation, alignment or combination, restriction, erasure or destruction.
d) Limitation of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, primarily to analyse or predict aspects of the individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or controller
The controller is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for his or her appointment may be laid down by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
The recipient is a natural or legal person, public authority, agency or other body, to whom personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular investigation in accordance with Union or Member State law are not considered recipients; the processing of such data by such public authorities must occur in accordance with the applicable data protection rules according to the purposes of the processing.
(j) Third part
A third party is a natural or legal person, public authority, agency or entity other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
The data subject’s consent is a freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or clear affirmative action, signifies consent to the processing of personal data concerning him or her.
Name and address of the data controller
The data controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union and other data protection provisions is:
Registred Office: Lungotevere Delle Navi 19 – 00196, Rome (ITALY)
Operational Headquarters: via Flaminia 21 – 00196, Rome (ITALY)
Phone: (+39) 06 3215237
Any interested person may, at any time, contact the data controller directly with all questions and suggestions relating to data protection.
You may, at any time, prevent the setting of cookies via our website by means of the corresponding setting of the Internet browser used, and may then permanently deny the setting of cookies. In addition, cookies that have already been set or enabled can be deleted at any time via an Internet browser or other software program, a common feature on all major Internet browsers. If the person concerned deactivates the cookie setting in the Internet browser used, not all functions of our website can be fully used.
Data collection and general information
The Benarrivati Travel website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server’s log files. The following information can be collected: (1) the browser types and versions used, (2) the operating system used by the access system, (3) the website from which an access system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the access system and (8) any other similar data and information that can be used in the event of hacks on our computer systems.
When using this data and general information, Benarrivati Travel does not draw any conclusions on the subject. Rather, this information is necessary for (1) correctly providing the content of our website, (2) optimizing the content of our website and its advertising, (3) ensuring the long-term viability of our computer systems and website technology, and (4) providing law enforcement authorities with information necessary for prosecution in the event of a cyber-attack. Therefore, Benarrivati Travel statistically analyses anonymously collected data and information in order to increase the data protection and data security of our company and to guarantee an optimal level of protection for the personal data processed. The anonymised data from the server log files are stored separately from all personal data provided by a data subject.
Routine deletion and blocking of personal data
The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is permitted by the European or other legislative authoritys in laws or regulations to which the controller is subject.
If the purpose of archiving is not applicable or if a retention period prescribed by the European legislative authority or another competent legislative authority expires, personal data are regularly blocked or deleted in accordance with legal requirements.
Rights of the data subjec
a) Right of confirmation
Every data subject has the right conferred by the European legislative authority to obtain from the controller confirmation as to whether or not personal data concerning him or her exist. If a data subject wishes to make use of this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of access
Every data subject has the right conferred by the European legislative authority to obtain from the data controller free information about his personal data stored at any time and a copy of this information. In addition, European directives and regulations grant the data subject access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the expected period for which the personal data will be kept or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller the rectification or erasure of personal data, or the restriction of the processing of personal data relating to the data subject, or to object to such processing;
the existence of a right to lodge a complaint with the supervisory authority;
if the personal data are not collected from the data subject, any available information on their origin;
the existence of automated decision-making processes, including profiling, as referred to in Article 22(1) and (4) of the GDPR and, at least in such cases, meaningful information about the logic involved, as well as the significance and expected consequences of such processing for the data subject.
In addition, the data subject has the right to obtain information on the transfer of personal data to a third country or an international organisation. In such a case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to make use of this right of access, he or she may, at any time, contact any employee of the controller.
c) Right of rectification
Every data subject has the right conferred by the European legislative authority to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to complete incomplete personal data, including by submitting a supplementary declaration.
If a data subject wishes to exercise this right of rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (right to be forgotten)
Every data subject has the right conferred by the European legislative authority to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall therefore erase personal data without undue delay if one of the following grounds applies, provided that the processing is not necessary:
Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) of the GDPR, or Article 9(2)(a) of the GDPR, and where there is no other lawful basis for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there is no legitimate reason for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
Personal data have been unlawfully processed.
Personal data must be erased in order to comply with a legal obligation in Union or Member State law to which the controller is subject.
Personal data has been collected in connection with the provision of information society services as referred to in Article 8(1) of the GDPR.
If one of the aforementioned scenarios applies, and a data subject wishes to request the erasure of personal data stored by the Benarrivati Travel, he or she may, at any time, contact any employee of the controller. An employee of the Benarrivati Travel shall immediately comply with the erasure request.
Where the controller has made personal data public and is required pursuant to Article 17(1) to erase those personal data, the controller shall, in view of the available technology and the costs of implementation, take reasonable steps, including technical measures, to inform other controllers of the personal data that the data subject has requested to deleteand to destroy any links, copies or replicas of such personal data, insofar as their processing is not required. An employee of the Benarrivati Travel shall arrange the necessary measures in individual cases.
e) Right to restriction of processing
Every data subject has the right, granted by the European legislative authority, to obtain from the data controller the restriction of processing if one of the following conditions applies:
The accuracy of personal data is contested by the data subject, for a period allowing the controller to verify the accuracy of those personal data.
The processing is unlawful and the data subject objects to the deletion of personal data and instead requests the restriction of their use.
The controller no longer needs the personal data for processing purposes, but is required by the data subject to restrict the use thereof for the establishment, exercise or defence of legal claims.
The data subject objected to the processing pursuant to Article 21(1) of the GDPR pending verification that the legitimate grounds of the controller overridethose of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Benarrivati Travel, he or she may, at any time, contact any employee of the controller, who shall therefore arrange the restriction of the processing.
f) Right to data portability
Every data subject has the right, recognised by the European legislative authority, to receive personal data concerning him or her that have been provided to the controller in a structured, commonly used and machine-readable format. He or she has the right to transmit such data to another controller without hindrance to the controller to whom the personal data have been provided, to the extent that the processing is based on the consent referred to in Article 6(1)(a) of the GDPR or point (a) of Article 9 (2) of the GDPR, or a contract within the meaning of Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to transmit personal data directly from one controller to another where technically feasible, on the condition that he or she does not adversely affect the rights and freedoms of other parties.
In order to assert the right to data portability, the data subject may at any time contact any employee of Benarrivati Travel.
g) Right to object
Every data subject shall have the right, recognised by the European legislative authority, to object at any time on grounds relating to his or her particular situation, to the processing of personal data concerning him or her, which is based on point (e) or (f) ) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Benarrivati Travel shall no longer process personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of claims.
If the Benarrivati Travel processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This shall apply to profiling insofar as it is related to such direct marketing.
In addition, the data subject shall have the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Benarrivati Travel for scientific or historical research purposes, or for statistical purposes pursuant to Article 89. (1) of the GDPR, unless the processing is necessary for the performance of an activity carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the Benarrivati Travel. In addition, the data subject shall be free, in the context of the use of Information Society services and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using specific techniques.
h) Automated individual decision-making, including profiling
Every data subject has the right, granted by the European legislative authority, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on him or her, or significantly affects him or her, provided that the decision (1) is not necessary for entering into or performing a contract between the data subject and a controller or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or performing, a contract between the data subject and a data controller, or (2) is based on the data subject’s explicit consent, the Benarrivati Travel shall implement suitable measures to safeguard the rights and freedoms of the data subject and his/her legitimate interests, or at least the right to obtain human intervention by the controller in expressing his or her point of view and contesting the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of Benarrivati Travel.
i) Right to withdraw data protection consent
Every data subject has the right, granted by the European legislative authority, to withdraw their consent to the processing of their personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact any employee of Benarrivati Travel.
Data protection provisions relating to the application and use of Instagram
On this website, the controller has integrated components of the Instagram service. Instagram is a service that can be qualified as an audiovisual platform, which allows users to share photos and videos and to disseminate these data on other social networks.
The operating company of the services offered by Instagram is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, UNITED STATES.
Every time a call is made to one of the individual pages of this website, which is operated by the controller and on which an Instagram component (Insta button) has been integrated, the Internet browser on the computer system of the person concerned is automatically promptedto download a display of the corresponding Instagram component. During this technical procedure, Instagram finds out which specific subpage of our website was visited by the data subject.
If the data subject has logged in simultaneously on Instagram, Instagram records each call to our website by the data subject and ,for the entire duration of the stay on our website, which specific Internet subpage the data subject visited.This information is collected via the Instagram component and is associated with the respective Instagram account of the data subject. If the data subject clicks on one of the integrated Instagram buttons on our website, Instagram automatically matches this information with the personal Instagram user account of the data subject and stores the personal data.
Instagram receives information- via the Instagram component- that the data subject has visited our website, provided that the data subject is registered on Instagram at the time of the call to our website. This occurs regardless of whether the person clicks on the Instagram button or not. If such a transmission of information to Instagram is undesirable for the data subject, then he or she can prevent this by logging out of his or her Instagram account before a call to our website is made.
Further information and the applicable data protection provisions of Instagram can be retrieved at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.
Legal basis for processing
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, such as when the processing operations are necessary for the supply of goods or the provision of any other service, the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations that are necessary for the performance of pre-contractual measures, for example in the case of requests relating to our products or services. Our company is subject to the legal obligation to process personal data, e.g. for the fulfilment of tax obligations, the processing being also based on Article 6 (1) GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor was injured on our premises and their name, age, health insurance data or other vital information had to be transmitted to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1)(f GDPR. This legal basis is used for processing operations that are not covered by any of the above-mentioned legal grounds, if the processing is necessary for the purposes of the legitimate interests pursued by our company or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject that require the protection of personal data. Such processing operations are particularly admissible as they have been expressly mentioned by the European legislative authority, in that it has been considered that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2, GDPR).
Duration of data storage
The criteria used to determine the retention period for personal data are the respective statutory retention periods. After the expiry of this period, the corresponding data are routinely deleted, provided that they are no longer required for the fulfilment of the contract or the initiation of a contract.
Provision of personal data as a legal or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide personal data; Possible consequences of not providing such data
We underline that the provision of personal data is in part required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner).
Sometimes, in order to enter into a contract,a data subject may be required to provide his/her personal data, which must subsequently be processed by us. The data subject shall, for example, provide us with personal data when our company enters into a contract with him or her. Failure to provide personal data would result in the suspension or non-conclusion of said contract.
Before personal data are provided by the data subject, the data subject shall contact any employee. The employee shall clarify to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of not providing the personal data.
Existence of automated decision-making processes
As a responsible company, we do not use automated decision-making or profiling.
Last updated: September 2021.
Italy travel agency based in Rome. Our native-born travel experts provide high quality custom luxury travel services, respecting every detail of your expectations.
Via Flaminia, 21 – 00196, Roma
(+39) 06 3215237
(+1) 561-710 4485
(+55) 11 974091266
Via Flaminia, 21 – 00196
(+39) 06 3215237
(+1) 561-710 4486
(+55) 11 974091266