123 Transfers (commercial name 123Transfers.com), Via Pastrengo 1, 21019 Somma Lombarda (Va), Italy (“123Transfers”, “we”, “us”) will process your information in its capacity of data controller.
We understand that booking online involves significant trust on your part. We value your trust, and make it a high priority to ensure the security and confidentiality of the personal information you provide to us. Please read this policy to learn about our privacy practices.
• What information we collect from you
• How we use your information
• With whom we share your information
• Right to access your information and other rights
• Your choices with respect to the collection and use of your information
• Cookies and other technologies
• How we protect your information
• External links
• How you can contact us
What information we collect from you
In General. We receive and store any information you enter on our website or give us in any other way. This includes information that can identify you (“personal information”), including your first and last name, telephone number, postal and email addresses, we never store billing information (such as credit card number, cardholder name, and expiration date), payments are made directly on the secure web pages of our Bank Cariparma. We do not see any data of your credit card and we do not absolutely store them in any way. We may also request information about your service preferences. You can choose not to provide information to us, but in general most of the information we request from you is required in order for you reserve a transfer and the lack of such information prevents us from completing the transfer reservation. In any case you can choose whether or not to receive messages of an informative and/or commercial nature such as offers and newsletters.
Travel Companion Information. When you make a reservation for someone else through this website, we will request personal information and transfer preferences about that individual. You should obtain the consent of other individuals prior to providing us with their personal information and transfer preferences, as any access to view or change their information will be available only through your account.
Information from Other Sources. We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources and add it to our account information. Examples of information we may receive include: address information, purchase history, and demographic information.
Automatic Information. We automatically collect some information about your computer when you visit this website. For example, we will collect your IP address, Web browser software (such as Firefox, Safari, or Internet Explorer), and referring website. We also may collect information about your online activity, such as trips viewed and bookings made. Our goals in collecting this automatic information are helping customize your user experience and inhibiting fraud. For more information, please see Cookies and other technologies.
How we use your information
We use personal information for the purpose of completing the transfer reservations you make on our site. We use other information about you for the following general purposes so long as you have given your consent: to provide you with the products and services you request; to provide you with your transfer booking confirmation and updates; to communicate with you in general; to respond to your questions and comments; to measure interest in and improve our products, services, and website; to notify you about special offers on our products or services that may be of interest to you; to publish on our website and the websites of our business partners your voluntary feedback regarding the properties reserved through us; to post your voluntary comments on our blog and to notify you of follow-up comments via e-mail if you have asked us to do so when you subscribed to the blog; to reward you as part of any reward and recognition program you choose to join; to resolve disputes, collect fees, or troubleshoot problems; to prevent potentially prohibited or illegal activities; and as otherwise described to you at the point of collection.
Email Communications. We want to make it easy for you to take advantage of transfer-related opportunities on our website. One way we do this is by sending you email messages that contain information about your transfer related interests if you consented to receiving email marketing communications. Where legally required, we will abide by existing publicly available opt-out lists when sending you marketing communications. For example, (i) if you search for a transfer in Milan on our website but choose not to book a transfer, or (ii) if you open one of our email marketing communications and click on a link (which will direct you to our website) relating to Milan and/or to a transfer in Milan, we may send you an email message telling you about our special deals for transfers in Milan. We believe these email messages will provide you with useful information about transfer-related special offers available through our site. Please note that you will have the opportunity to choose not to receive these email messages in any such email we send.
Please review “Your choices with respect to the collection and use of your information” below.
With whom we share your information
With your consent, we may share your information with the following entities:
• Suppliers such as transfers who fulfil your reservations. Throughout this site, all services provided by a third-party supplier are described as such. Therefore, we encourage you to review the privacy policies of any transfer supplier whose products you purchase through this site. Please note that these suppliers also may contact you as necessary to obtain additional information about you, facilitate your transfer reservation, or respond to a review you may submit. While we may share anonymous reviews with our transfer suppliers, we will not share reviewer names or contact information unless you have explicitly told us that we may. We are not responsible for the transfer deducing your identity from the content of your review and contacting you directly.
• Third-party vendors who provide services or functions on our behalf, including business analytics, customer service, marketing, distribution of surveys or sweepstakes programs, and fraud prevention. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of our website or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose. They are also required to follow the same data security practices that we ourselves adhere to. Please note that these third party service providers may be established in countries that might not offer a level of protection for your personal information that is equivalent to the one offered in your country of residence. However, we will endeavor to protect all personal information we collect from you in accordance with strict data protection standards.
• Business partners with whom we may jointly offer products or services, or whose products or services may be offered on our website. You can tell when a third party is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we may share information about you, including your personal information, with those partners. Please note that we do not control the privacy practices of these third-party business partners.
• Referring websites. If you were referred to this website from another site (for example, through a link you clicked on another site that directed you to this one), we may share some information about you with that referring website. We encourage you to review the privacy policies of any website that referred you here.
• Companies within our corporate family. We may share your personal information with our affiliated companies.
We also may share your information:
• In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this website, our customers, or others; and in connection with our Terms of Service and other agreements.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.
We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our website receives or the most popular transfers and vacation destinations. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.
Right to access your information and other rights
At present will not be created any personal account on our site, to remove your data from our system, please send us an email to: firstname.lastname@example.org. In the future you can access to your personal account (which is created by our system when you reserve through 123Transfers.com) to (i) update your contact information and the related choices (see “Your choices with respect to the collection and use of your information” below) and (ii) visualise and cancel the reservations made through 123Transfers.com. You can close your account by contacting us at the email address listed below. Please note that after you close an account, you will not be able to sign in or access any of your personal information. However, a new account will be opened if you make another reservation through 123Transfers.com.
If you do not hold an account with us or wish to contact us in relation to any personal information that is not displayed in your account you may ask us to access, delete and modify the information that we hold about you by emailing us at the email address listed below.
In particular, you are entitled to exercise all rights provided under article 7 of the Italian Data Protection Code which for your convenience is reproduced in whole below.
Italian Data Protection Code (Legislative Decree n.196/2003) - Article 7
(Right to Access Personal Data and Other Rights)
1. A data subject [i.e. you] shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2) [i.e. the representative to be designated where the Data Controller is an entity established in a territory of a country outside the European Union];
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the right to obtain
a) updating, rectification or, where interested therein, completion/integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part,
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
Your choices with respect to collection and use of your information
• As discussed above, you can choose not to provide us with any information, although it may be needed to book your transfer or to take advantage of certain features offered on this site.
• You also can add, update or delete your information and close your account as described above.
• When you make a reservation through this site, you will be given a choice as to whether you want to receive email messages from us about our transfers deals, special offers and newsletters. If you hold the personal account created when you have reserved on 123Transfers.com you can modify your choice at any time by clicking on the link “Your Reservations“ on this web site. Whether you hold a personal account with us or not, you will also be given the opportunity to unsubscribe from commercial messages in any such email we send. Please note that we reserve the right to send you other communications, including service announcements and administrative messages, relating to your transactions on this site, without offering you the opportunity to opt out of receiving them.
• You may have the opportunity on our website to provide a mobile number in order to receive your transfer confirmation details.
Cookies and other technologies
Cookies are small data text files and can be stored on your computer’s hard drive (if your Web browser permits). This website uses browser cookies for the following general purposes:
• To help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was visiting our site. Please note that account IDs and any other account-related data included in such cookies are encrypted for security purposes. Unless you reserve through us and hold an account with us, these cookies will not contain any personal information.
• To help measure and research the effectiveness of website features and offerings, advertisements, and email communications (by determining which emails you open and act upon).
The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if you refuse to accept cookies, you may not be able to access many of the transfer tools offered on our sites.
This site may also use Web beacons (also known as clear gifs, pixel tags or Web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a Web page. We may use Web beacons to monitor the traffic patterns of users from one page within our sites to another, to deliver or communicate with cookies, to understand whether you have come to our site from an online advertisement displayed on a third-party website, and to improve site performance. We also may allow our service providers to use Web beacons to help us understand which emails have been opened by recipients and to track the visitor traffic and actions on our site. This helps us measure the effectiveness of our content and other offerings.
How we protect your information
We want you to feel confident about using this website to make transfer arrangements, and we are committed to protecting the information we collect. While no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personal information you provide to us. For example, only authorized employees are permitted to access personal information, and they may only do so for permitted business functions. In addition, we use encryption when transmitting your sensitive personal information between your system and ours, and we employ firewalls to help prevent unauthorized persons from gaining access to your information.
How you can contact us
Telephone numbers: (+39) 393.1233.123
Atten. Customer Care
Via Pastrengo 1
21019 Somma Lombarda (Va)
This Privacy Statement is effective as of 28 March 2013