We are firmly committed to protecting the privacy and confidentiality of personal information and maintain robust physical, electronic and procedural safeguards to protect personal information in our care.
As an Italian company, we are required to comply to:
• EU Directive 95/46/CE issued by the European Parliament
• Legislative Decree n. 196/03, "Protection of personal information"
A. DEFINITION OF PERSONAL INFORMATION
Personal information is information or an opinion, in any form (whether true or not) about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.
B. COLLECTION OF PERSONAL INFORMATION
Information about you and members of your party, including your names, contact details and any special needs, disabilities or dietary requirements, is collected by us when you request information or make a booking with us.
Where practical, we will collect personal information directly from you. Generally, this will be collected by us when you deal with us either in person, by telephone, letter, facsimile, email or when you visit our website. We may request information about you when you purchase or make enquiries about our products and services; when you register for promotions or when you request brochures or other information. We may also collect information when we invite you to complete surveys or provide us with feedback.
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to provide travel services and products to you. For example, we may collect details such as your name, mailing address, telephone number, email address, credit card number and expiry date, passport details, dietary requirements (if any) and health issues relevant to your travel arrangements. We also collect information that is required for use in the business activities of VITOR including, for example, financial details necessary in order to process various transactions and any other information you may elect to provide to us.
We are required by law to obtain your consent to the collection of sensitive information. We will assume that you have consented to the collection of all information which is provided to us for use in accordance with this Policy, unless you tell us otherwise.
C. USE OF PERSONAL INFORMATION
We will use your personal information to provide you with travel and travel related products and services.
We may use and disclose your personal information for the purposes for which it was collected, or for a related or ancillary purpose such as any one or more of the following purposes:
• Identification of fraud or error;
• Regulatory reporting and compliance;
• Developing, improving and marketing our products and services;
• Servicing our relationship with you by, among other things, providing updates on promotions and services we think may interest you or to involve you in market research and
• Internal accounting and administration.
D. DISCLOSURE TO THIRD PARTIES
We may disclose your personal information only:
• as permitted or required by law;
• to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes;
• to public authorities such as customs or immigration for security and anti-terrorism purposes, if required by them, or as required by law;
• to third parties such as hotels, transfer companies and other service providers for the purpose for which the information was collected or for a related purpose, for example, to facilitate and process your travel arrangements.
Where we engage third party contractors to perform services for us, these contractors may be required to handle your personal information. Under these circumstances, the contractors must safeguard this information and must only use it for the purposes for which it was supplied, although we are not responsible for ensuring this. In making this booking, you consent to this information being passed on to the relevant persons.
Other than the above, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
E. REQUEST OF INFORMATION DURING THE TOUR
Please be aware that Italian Laws require registration of personal information by hotel managers, as written in identity documents, for public security reasons. This information is to be transmitted to Police Authorities within 24 hours from arrival.
F. USE OF MATERIAL
You understand that future VITOR advertising or publicity material may include statements made by passengers or their photographs, and you consent to such use of your comments and/or photographic / video likeness.
G. SECURITY OF INFORMATION
VITOR has implemented appropriate physical, electronic and managerial security procedures in order to protect personal information from loss, misuse, alteration or destruction.
H. ACCESS AND CORRECTION OF PERSONAL INFORMATION
In accordance with current Italian legislation (see above) you have a right of access to the personal information we hold about you. If you wish to exercise this right, please submit a request in writing (email is accepted) to:
Attn. Data Protection Manager
Via Aldo Moro 16
25124 Brescia - Italy
Requests by telephone or fax cannot be accepted.
We are not obliged to comply with your request unless sufficient security information is provided to establish the requestor's identity. Please enclose the following with your request:
• A photocopy of your passport or identity card upon which your signature is present;
• Details of any specific documents you require that contain your personal details (if known).
You will receive acknowledgement of your request quoting the date by which you will receive your information pack.
Further correspondence regarding your request should only be made in writing to the Data Protection Manager at the above address.
Information will be sent via email unless otherwise requested. We may recover from you any additional reasonable costs of supplying you with access to this information with different means.
K. LINKED SITES
To allow you to gather more complete information about locations, services and activities provided by us, our website contains links to, or framing of, external websites. We are not responsible for the privacy practices or the content of such sites and therefore, make no warranties and accept no liability in relation to material contained on these. We encourage you to read the privacy statements of any linked or framed website before submitting any personal information.
L. CHANGES TO OUR POLICY
From time to time it may be necessary for us to review and revise this Policy. We reserve the right to change our Policy at any time, should this occur the amendment would be posted on our website.