Privacy Policy

Last updated: April 12, 2025

Your privacy is important to us. This Privacy Policy describes how Christian Centi (hereinafter "Promoter", "we", "us" or "our"), as a promoter of tourist services operating through the website etnanordlinguaglossa.it (hereinafter "Site"), collects, uses, shares, and protects your personal information.

By using the Site, you consent to the collection and use of information in accordance with this policy.

1. Data Controller

The data controller for personal data collected through this Site is:

Christian Centi Email: info@etnanordlinguaglossa.it

2. Types of Data Collected

We collect different types of information for various purposes to provide and improve our service.

a) Data provided voluntarily by the User

When you submit a request for information or contact through the forms on the Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). This may include, but is not limited to:

First and Last Name
Email Address
Phone Number
Any other information provided in the request message (e.g., preferred dates, number of participants, specific requests)

b) Usage Data

We may also collect information on how the Site is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

c) Tracking & Cookies Data

We use cookies and similar tracking technologies solely for analytical purposes to track activity on our Site and improve user experience. We do not use essential technical cookies (other than those possibly set automatically by the browser for session management) nor marketing or profiling cookies.

The cookies are files with a small amount of data which may include an anonymous unique identifier. The analytical cookies we use are:

Google Analytics (GA4):
- Main Cookies: _ga, _ga_*
- Domain: google.com
- Duration: Up to 2 years
- Purpose: Collection of anonymous statistical data on site usage to understand how visitors interact with content.
Microsoft Clarity:
- Main Cookies: _clck, _clsk, CLID, ANONCHK, MR, MUID, SM
- Domain: .clarity.ms / microsoft.com
- Duration: Up to 1 year
- Purpose: Anonymous analysis of user interaction through heatmaps and session recordings to identify usability issues and improve site design.

Your consent for the use of these analytical cookies is collected via the cookie banner on the site. You can change your preferences or withdraw consent at any time through the banner settings or your browser settings.

You can manage cookie preferences directly from your browser settings, for example, preventing third parties from installing them. Through browser preferences, it is also possible to delete cookies installed in the past. Disabling all cookies may compromise the functionality of some analytical features of this site.

3. Purpose of Data Processing

We use the collected data for various purposes:

To forward your requests: We use the Personal Data provided through contact forms to forward your information or booking request to the competent Partner Agencies that provide the Tourist Service you requested.
To manage requests efficiently: We may temporarily store request data in our CRM system (Airtable) to facilitate forwarding and tracking.
To provide and maintain the Site: We use Usage Data to ensure the proper technical functioning of the Site, hosted on Vercel.
To improve the Site: We use aggregated and anonymized Usage Data collected through Google Analytics and Microsoft Clarity to analyze how users interact with the Site and make improvements.
To communicate with you: We may use your email address or phone number to respond to your direct inquiries not related to specific bookings forwarded to partners.
To comply with legal obligations.

4. Legal Basis for Processing

We process your Personal Data based on the following legal bases:

Consent: For sending requests to Partner Agencies via contact forms (we will request explicit consent in the form itself).
Legitimate Interest: To ensure the functioning of the Site, improve it, and respond to direct contact requests.
Legal Obligation: Where necessary to comply with legal obligations.

5. Data Sharing

Your Personal Data may be shared in the following situations:

With Partner Agencies: As indicated, we forward the necessary data (First Name, Last Name, Email, Phone, request details) to Partner Agencies to enable them to process your request for Tourist Services. Partner Agencies will use this data exclusively to contact you regarding the specific request, provide details about the excursion, confirm the booking, and manage the organizational aspects of the requested service.
With Service Providers: We employ third-party companies to facilitate and provide services on our behalf. These providers act as data processors and have access to your Personal Data only to perform specific tasks on our behalf, with the obligation not to disclose or use it for other purposes. Key providers include:
- Vercel Inc.: Hosting service provider for the Site.
- Google LLC: Provider of the Google Analytics statistical analysis service.
- Microsoft Corporation: Provider of the Microsoft Clarity behavioral analysis service.
- Airtable (Formagrid, Inc.): Provider of the CRM platform used for managing and organizing data related to requests submitted through the Site.
For Legal Requirements: We may disclose your Personal Data if we believe in good faith that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Promoter, prevent or investigate possible wrongdoing in connection with the Site, protect the personal safety of users of the Site or the public, protect against legal liability.

6. Data Transfer

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside Italy and choose to provide information to us, please note that we transfer the data, including Personal Data, to Italy and process it there (or where our providers' servers are located). Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

7. Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Specifically:

Data provided via contact forms will be retained for the time strictly necessary to forward the request to the Partner Agency and manage any support requests related to the forwarding.
Usage Data may be retained for shorter periods for internal analysis purposes or to improve the security and functionality of the Site.

We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

8. Your Data Protection Rights (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Christian Centi aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You have the following rights:

Right of access: You can request information about the personal data we hold about you.
Right to rectification: You can request the correction of inaccurate or incomplete personal data.
Right to erasure ("right to be forgotten"): You can request the deletion of your personal data under certain circumstances.
Right to restriction of processing: You can request the restriction of the processing of your personal data under certain circumstances.
Right to data portability: You can request to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format.
Right to object: You can object to the processing of your personal data based on our legitimate interest.
Right to withdraw consent: If processing is based on consent, you can withdraw it at any time.

To exercise any of these rights, please contact us at the email address: info@etnanordlinguaglossa.it. We will respond to your request within one month.

You also have the right to lodge a complaint with a Supervisory Authority (Garante per la Protezione dei Dati Personali in Italy).

9. Data Security

The security of your data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

10. Links to Other Sites

Our Site may contain links to other sites that are not operated by us (e.g., Partner Agency sites). If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

11. Children's Privacy

Our Site does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We advise you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. Contact Us

If you have any questions about this Privacy Policy, you can contact us:

By email: info@etnanordlinguaglossa.it