This is a courtesy translation. In the event of any discrepancy, the Italian version prevails.
This notice describes how Zeugma Travel (the "Controller") processes the personal data of users who visit the zeugma-travel.com website and use its services, in accordance with Regulation (EU) 2016/679 (GDPR) and Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018.
1. Data Controller
Zeugma Travel VAT no.: 18315601007 Email: info@zeugma-travel.it
2. Data processed and purposes
2.1 Website browsing
Our IT systems automatically collect certain technical data: IP addresses, browser type, operating system, pages visited, and access times. This data is necessary for the proper functioning of the site and is retained for a maximum of 30 days, except where needed for security investigations.
2.2 Usage statistics (Umami Analytics)
The site uses Umami, a privacy-respecting web analytics service. Umami collects anonymous, aggregated data (pages visited, referrer, browser and operating system type, country of origin) without using cookies and without collecting identifiable personal data (IP addresses, device identifiers). The data is processed anonymously and does not allow users to be identified. The legal basis is the Controller's legitimate interest in understanding how the site is used (Art. 6(1)(f) GDPR).
2.3 Contact forms and quote requests
When you fill in a contact form or request a quote, we process the following data: name, email address, travel destinations and preferences, dates, and number of travelers. Form data is processed by a dedicated service hosted on Cloudflare Workers (the Controller's infrastructure) and forwarded by email through the Resend service (external processor, privacy notice: resend.com/legal/privacy-policy). Data is not stored on Resend's servers beyond the time needed to send the email. The legal basis is the performance of pre-contractual measures at the data subject's request (Art. 6(1)(b) GDPR). Data is retained for 24 months from the request, unless a contract is concluded. To protect the inquiry form from automated submissions, we use Cloudflare Turnstile, which, at the last step of the form, analyzes technical signals from your browser and device (for example, IP address and user agent) to tell people from bots (privacy notice: cloudflare.com/turnstile-privacy-policy). The legal basis is the Controller's legitimate interest in the security of the site and the prevention of abuse (Art. 6(1)(f) GDPR).
2.4 Contract performance
At booking, we process the data required to provide the service (personal details, identity documents where required, travel preferences). The legal basis is the performance of the contract (Art. 6(1)(b) GDPR). Data is retained for 10 years to comply with tax and accounting obligations.
3. Disclosure to third parties
Your data is not transferred to third parties for their own purposes. It may be disclosed to:
- Resend (transactional email delivery) — form data is transmitted solely to send the notification and confirmation emails;
- OVH (website hosting) — processing of technical browsing data;
- technical service providers (email, hosting) bound by confidentiality agreements;
- local partners and tourism service providers, strictly to the extent necessary to deliver the booked service;
- public authorities, where required by law.
4. Transfers outside the EU
Data is processed primarily within the European Union. The Umami Analytics service is hosted in the EU. Cloudflare Workers operates on a global network with EU nodes. Resend is based in the United States and operates in compliance with the EU-US Data Privacy Framework (DPF) and the European Commission's standard contractual clauses.
5. Your rights
You have the right to:
- Access (Art. 15): obtain confirmation of processing and a copy of your data;
- Rectification (Art. 16): correct inaccurate or incomplete data;
- Erasure (Art. 17): request deletion of your data ("right to be forgotten");
- Restriction (Art. 18): restrict processing in certain circumstances;
- Portability (Art. 20): receive your data in a structured, machine-readable format;
- Objection (Art. 21): object to processing for direct marketing purposes;
- Withdrawal of consent: at any time, without affecting the lawfulness of prior processing.
To exercise your rights, write to info@zeugma-travel.it. You also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
6. Cookies
For information about the cookies used by this site, see our Cookie Policy.
7. Changes
The Controller reserves the right to update this notice. The current version is always available on this page, with the date of the last update indicated.