Dear Sir/Madam,
please find below some information about the processing of your personal data, which will be collected during the registration process and whilst you are using the loyalty programme known as “Navigo Per Te”.
The data controller is Caronte & Tourist S.p.A. (hereafter, “Company”), which can be contacted at:
- e-mail address: privacy@carontetourist.it;
- telephone number: 090/9038201.
The Company has appointed a Data Protection Officer, in accordance with articles 37 and following of Regulation (EU) 2016/679 (hereafter, “GDPR”), who can be contacted at the data controller's head office or by e-mail at dpo@carontetourist.it.
Type of data collected
When you apply to join the loyalty programme, the Data Controller collects the following personal data referred to in Art. 4, no. 1, GDPR.
Data collected directly from the data subject:
- personal data (name, surname, date of birth);
- contact data (telephone number, certified electronic e-mail, e-mail address);
- billing data (tax code/VAT number, billing address, recipient code);
- registration number(s) of their motor vehicle(s);
- profile picture;
- full residential/domicile address;
- Telepass device number;
- valid ISEE certificate;
- certificate of residence;
- copy of identity document;
- personal data spontaneously provided by the user through the data controller’s contact channels (e-mail address, telephone number, social networks, etc.), in order to request assistance and/or information.
Data collected directly from the data subject, where consent has been given for profiling:
- usual destinations, vehicles used for travel, gender, behavioural preferences and interests.
Data collected automatically:
- data relating to journeys made (e.g. frequency of travel) and any additional services purchased;
- data relating to rewards provided under the programme (e.g. bonuses and benefits received).
Data collected through the use of email tracking tools (tracking pixels):
- user ID;
- whether the user has opened promotional emails;
- any interactions with the content of promotional emails (clicks on links contained in the message);
- date and time of interactions with the e-mail message.
Purpose and legal basis of processing
Your data are processed for the following purposes:
| Purpose | Legal basis for processing | |
| a) | Issuing of the loyalty card, participation in the loyalty scheme, provision of related services and sending of communications in this regard. | Processing necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR). |
| b) | Photographic verification of the identity of programme members (e.g. when purchasing tickets at the ticket office, when travelling, or when applying for or using bonuses and benefits). | Processing necessary for the purposes of the legitimate interests pursued by the controller (Art. 6(1)(f) GDPR). |
| c) | Sending advertising and promotional communications regarding the services offered by the companies of the Caronte & Tourist Group, known as direct marketing (e.g. newsletters, text messages, telephone calls, social media, social chat, etc.), and conducting customer satisfaction surveys not related to the provision of the service (market research) | Processing based on the data subject’s consent (Art. 6(1)(a) GDPR). |
| d) | Sending advertising and promotional communications (e.g. newsletters, text messages, phone calls, social media, social chat, etc.), based on the data you have provided, your preferences and the purchases you have made, regarding the services offered by the companies of the Caronte & Tourist Group, known as profiled marketing. | Processing based on the data subject’s consent (Art. 6(1)(a) GDPR). |
| e) | Sending of advertising and promotional communications by third parties (Navigo Per Te partners). | Processing based on the data subject’s consent (Art. 6(1)(a) GDPR). |
| f) | Carrying out aggregated statistical analyses on an individual basis to measure the number of conversions generated by a given advert, with the aim of optimising advertising campaigns (Google Enhanced Conversions). | Processing is necessary for the purposes of a legitimate interest pursued by the Data Controller, which has been found to take precedence over and be balanced against the data subject’s interests, rights and fundamental freedoms requiring the protection of personal data (Article 6(1)(f) of the GDPR), based on the Data Controller’s assessment of the impact on that legitimate interest. The activation of the tool is subject to consent to analytical cookies, given via the CMP. |
| g) | Improved accuracy in conversion tracking and the attribution of advertising results through the use of digital marketing tools (Meta Pixel). | Processing based on the data subject’s consent (Art. 6(1)(a) GDPR). The activation of this tool is subject to consent to profiling cookies, which is given via the CMP. |
| h) | Measuring the effectiveness of promotional campaigns using tools to track email interactions (tracking pixels). | Processing based on the data subject’s consent (Art. 6(1)(a) GDPR). |
Necessity or Optional Nature of Processing
The provision of personal data for the purposes set out in points a), b) c) and d) is necessary for the establishment of the relationship with the Company; therefore, any refusal to provide such data, in whole or in part, will prevent you from participating in the loyalty programme.
You must provide the registration number(s) of your vehicle(s) in order to benefit from certain advantages offered by the loyalty scheme (e.g. priority boarding); failure to do so will mean that these advantages cannot be provided.
You must provide your VAT number or tax reference number in order for an invoice to be issued, if requested, when purchasing travel tickets; failure to do so will mean that you will need to provide this information at a later date.
You must provide your full residential or registered address in order for us to send you the physical loyalty card (Platinum level), if requested; failure to do so will prevent the Company from dispatching it.
The submission of the ISEE certificate, the certificate of residence and a copy of your identity document is optional; failure to submit these documents will mean that you will not be able to benefit from the additional advantages provided under the ‘ISEE scheme’.
The processing of data for the purposes referred to in point (f) is based on legitimate interest until the right to object is exercised pursuant to Article 21 of the GDPR; this right is guaranteed by the Data Controller and may be exercised as further described in the section on the rights of data subjects.
The processing of data for the purposes set out in points (c), (d) and (e) above is optional; failure to
provide such data will prevent the company, respectively, from carrying out direct marketing activities, from carrying out profiling and personalised marketing activities, from disclosing contact details to third parties for the purpose of carrying out direct marketing activities, and from conducting market research.
Any consent given in relation to purposes (c), (d) and (e) may be freely withdrawn at any time, without prejudice to the lawfulness of the processing carried out prior to such withdrawal. Consent may be withdrawn by accessing your personal account on the website www.carontetourist.it (see the section ‘Rights of the data subject’) or by contacting the data controller via the channels set out in this privacy policy.
Recipients of personal data
Personal data may be disclosed, strictly in relation to the above-mentioned purposes, to the following subjects or categories of subjects:
- natural persons authorised in writing by the Company pursuant to art. 29 GDPR by reason of the performance of their work duties;
- professionals or firms providing business administration and management services acting on behalf of the Company for its internal purposes (e.g. consultants);
- IT service providers and other technology partners of the Company;
- professionals or companies providing social media and community management services;
- printing professionals or printing companies for the printing of physical loyalty cards;
- Navigo Per Te partners;
- subjects in relation to which current legislation (e.g. tax and accounting) provides for mandatory reporting, including public bodies;
- judicial and law enforcement authorities;
- ticket offices, terminals and other authorised ticket sellers;
- law firms, in case any disputes arise;
- insurance companies both when booking tickets and when making claims;
- experts during complaint procedures;
- companies providing other services that are essential to the provision of the shipping service or the sale of tickets (such as web hosting, auditing services, data analysis).
Limited to the provisions set out in paragraph (f), if you have given your consent to analytical cookies, your personal data will be disclosed to Google Ireland Ltd., which will process it in its capacity as a data processor, solely for the purpose of measuring, on an aggregated basis, the number of conversions generated by a given advertisement, with a view to optimising campaigns. The terms of the Data Processor Appointment Agreement entered into between the Company and Google at the time of purchasing the services can be found at the following link: https://business.safety.google/intl/it/adsprocessorterms/.
Google Ireland Ltd. will not disclose your data to third parties, nor will it carry out any further activities, nor will it enrich the data which, as an independent data controller and on the basis of your consent, it uses to carry out other types of processing.
For further information on how Google processes personal data as an independent data controller in the context of its advertising services, please refer to the relevant privacy policy available at the following link:
https://policies.google.com/privacy.
Limited to the provisions set out in paragraph (g), if you have given your consent to profiling cookies, your data may be shared with Meta Platforms Ireland Ltd., which will process it as a joint controller (pursuant to Article 26 of the GDPR), in accordance with the terms set out in the conditions applicable to Meta’s business tools, the terms of which can be found here https://www.facebook.com/legal/technology_terms, as well as in the Appendix on the data controller referred to therein and available at the following link: https://www.facebook.com/legal/controller_addendum.
For further information on how Meta Platforms Ireland Ltd. processes personal data as an independent data controller, please consult the relevant privacy policy available at the following link:
https://www.facebook.com/privacy/policy.
Processing methods
Personal data is collected via an IT system. The processing is carried out using paper and IT tools, in compliance with the provisions on the protection of personal data and, in particular, with the appropriate technical and organisational measures referred to in Article 32(1) GDPR, and with the observance of all precautionary measures to ensure the integrity, confidentiality and availability of the data.
Personal data stored on computer databases are only accessible to identified persons (authorized under art. 29 GDPR), by means of personal access keys.
Transfer of personal data
The Data Controller, including through its external data processors, may transfer Data outside the European Union. To this end, in accordance with data protection legislation, the Data Controller assesses the impact of data transfers and, where applicable, puts in place the most appropriate safeguards (for example, adequacy decisions or standard contractual clauses). In particular:
- for services provided by Google, any transfers to Google LLC (USA) take place on the basis of the European Commission’s Adequacy Decision of 10 July 2023 (EU–US Data Privacy Framework, DPF) and Google LLC’s DPF certification.
- For services provided by Meta, transfers to Meta are covered by the European Commission’s Adequacy Decision of 10 July 2023 (EU–US Data Privacy Framework, DPF) and Meta Platform Inc.’s DPF certification.
Data retention period
Data processed for the purposes referred to in point (a) will be retained until 31 December of the second year following the date on which the loyalty programme ceases (unless the programme is extended) or, if earlier, until the data subject’s membership of the programme ceases for any reason (withdrawal, exclusion, etc.).
Data processed for the purposes set out in point (b) will be retained until the loyalty programme ends (unless it is extended) or, if earlier, until the data subject’s membership of the programme ceases for any reason (withdrawal, exclusion, etc.).
Data processed for the purpose referred to in point (f) will be retained as follows:
➢ Hash data is retained by Google for the time strictly necessary for matching and measurement purposes and deleted – within a maximum period of 180 days – should the Data Controller delete the aforementioned data.
Contact details and purchase data will be processed by the Company for the purposes set out in points (c) and (e) for a period not exceeding 24 months from the date of collection, unless further processed by Google and Meta, as set out in their respective privacy policies, which can be found via the link provided above.
Contact details and purchase data will be processed for the purposes set out in point (d) for a period not exceeding 12 months from the date of collection, unless further processed by Google and Meta, as set out in their respective privacy policies, which can be found via the links provided above.
Purchase data collected for the purpose referred to in point (h) will be retained for up to 730 days from the date of collection.
In the event of a dispute arising between the data controller and the data subject, the retention periods shall be extended for the duration of such a dispute and for a further 10 years following its final resolution (e.g. a settlement agreement or a final and binding judgement).
Rights of the data subject as set out in Articles 15–22 of the GDPR
In accordance with the relevant legislation, the rights to which you are entitled, as a data subject, and the procedures for exercising them are set out below.
- Withdrawal of consent – the data subject has the right to withdraw any consent given at any time, as follows:
• with regard to the consent given upon registration for the programme, by accessing your profile in the members’ area on the website www.carontetourist.it and clicking ‘edit’ in the ‘My details’ section.
• with regard to consent given for cookies, via the option located at the bottom left of the pages on the Company’s website. - Right of access – the data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed; the evinsaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; he existence of automated decision-making, including profiling.
- Right to rectification – the data subject has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her and/or the integration of incomplete data.
- Right to erasure – the data subject has the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller has the obligation to erase personal data without undue delay if: the purpose of the processing has been fulfilled; consent has been withdrawn; objection to the processing has been made; the data have been processed unlawfully; the data must be erased to comply with a legal obligation under EU or national law.
- Right to restriction of processing – the data subject has the right to obtain from the controller restriction of processing: in the case of inaccurate data, until the Data Controller verifies their accuracy; in the case of unlawful processing; if the purposes of the processing have been fulfilled but the personal data are necessary for the data subject to establish, exercise, or defend a right in court; if the data subject has objected to the processing, pending verification of whether the legitimate grounds of the data controller override those of the data subject.
- Right to portability – the data subject has the right to receive the personal data concerning him or her in a structured, commonly used, and machine-readable format and has the right to transmit those data to another controller without hindrance, where the processing: is based on consent or on a contract; is carried out by automated means.
- Right to object – the data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR.
Methods of the data subject's request
The data subject may exercise the above rights at any time by sending an email to privacy@carontetourist.it.
The data subject is entitled to lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority) on the basis of the indications given at https://www.garanteprivacy.it/garante/doc.jsp?ID=4535524 or to any other supervisory authority.
Caronte & Tourist S.p.A.
TECHNICAL APPENDIX
“NAVIGO PER TE” PROGRAMME PRIVACY POLICY
This Technical Appendix supplements the Privacy Policy and provides detailed information on how the technological tools used by Caronte & Tourist operate in pursuit of the following purposes:
- carrying out aggregated statistical analyses on an individual basis to measure the number of conversions from a given advert, with the aim of optimising advertising campaigns (Google Enhanced Conversions);
- improving the accuracy of conversion tracking and the attribution of advertising results (Meta Pixel);
- measuring the effectiveness of promotional campaigns using tools to track email interactions (tracking pixels).
The information contained in this Appendix should be read in conjunction with the Privacy Policy.
1. Google Enhanced Conversions
To measure the effectiveness of its online advertising campaigns, Caronte & Tourist uses the Google Enhanced Conversions feature.
This tool makes it possible to verify whether a particular action carried out on the website (for example, the purchase of a travel ticket) can be attributed to a specific advertising campaign.
To this end:
- the data subject’s email address, provided when registering for the loyalty programme, is first pseudonymised using SHA-256 hashing;
- the pseudonymised data is transmitted to Google;
- Google carries out a technical comparison with the accounts on its services for the sole purpose of correctly attributing the conversion;
- Caronte & Tourist receives only statistical and aggregated data relating to campaign performance.
The tool is activated only for users who have given their consent to analytical cookies via the consent management platform (CMP).
The tool is not used to create advertising segments or to display personalised adverts.
2. Meta Pixel
The Meta Pixel tool is used by Caronte & Tourist only where the data subject has given their consent to profiling cookies.
The tool enables:
- the measurement of interactions on the website;
- the attribution of these interactions to advertising campaigns run via Facebook and Instagram;
- the improvement of the effectiveness of advertising campaigns.
This tool is only activated for users who have given their consent to profiling cookies via the consent management platform (CMP).
3. Gestione dei consensi e Google Consent Mode v2
Caronte & Tourist uses a consent management platform (CMP) and the Google Consent Mode v2 feature to ensure that advertising and measurement tools operate exclusively within the limits of the preferences expressed by users.
In the absence of the required consents:
- advertising tools are not activated;
- only technical and aggregated signals, devoid of any identifying information, may be transmitted.
4. Tracking pixel
The tracking pixel is used by the Company only if you have given your consent when registering for the Navigo Per Te programme.
This tool enables us to:
- track when users open promotional emails sent to members of the Navigo Per Te programme;
- track any clicks by users on links contained within those communications.
This information is used to measure the effectiveness of the Company’s promotional campaigns and to resend a communication to those who have not opened it.
