Privacy Policy
We understand the importance of protection of your personal data, therefore
we collect and process only your data that is connected to our services. We
process your personal data lawfully, transparently, and fairly, for the pre-determined
purposes and only to the extent necessary to achieve those purposes. When we
process your personal data, we make every effort to ensure that they are
accurate, secure, confidential, properly stored and protected.
When processing your personal data, we comply with the requirements of the
Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”).
1. WHAT IS THIS
DOCUMENT?
1.1. This Privacy Policy (the “Privacy Policy”) informs you of
our policies regarding the collection, use and disclosure of data when you use
our website www.travelino.chat AI travel assistant
chatbot integrated in our website and in our WhatsApp, Messenger and Instagram
instant messaging applications; also this Privacy Policy applies to our
Facebook (https://www.facebook.com/Travelino.official), Instagram (https://www.instagram.com/travelino.official/), (jointly – the “Websites” and
each separately – the “Website”) and the choices you have
associated with that data. The Privacy Policy applies to every person who
visits the Websites, as well as to any actions you may take on the Websites.
1.2. Section 6 of this Privacy Policy explains what data we process and how
we do it when you use our AI travel assistant chatbot integrated in the
websites or mobile applications of our partners (but not the Websites, as
defined above).
1.3. Please read this Privacy Policy carefully to find out how we process
your personal data, where we get them from and what your rights as a data
subject are.
1.4. We consider that if you are using any one of the
Websites, you have read and agree with this Privacy Policy and the purpose,
manner, and procedures for processing your personal data set out therein. If
you do not agree with the Privacy Policy, you are not entitled to use the
Websites.
1.5. The term “personal data” as used in this Privacy Policy means any
information which could be used to identify you directly or indirectly.
2.WHO ARE WE?
2.1. The Websites are managed and administered by Threebot Tecnology,
company code 06859200823, registered at p.zza Procopio Cutò n°8, Palermo, Italy.
The person responsible for personal data protection: Federico Lima, contact
telephone number: +39 334 538 8873, email address: info (at) 3bot (dot) it
2.2. In accordance with the legal provisions, we are a controller of your
personal data.
3.WHAT PRINCIPLES DO WE
COMPLY WITH WHILE PROCESSING YOUR PERSONAL DATA?
3.1. While processing your personal data we:
a) will comply with the requirements of the applicable legislation,
including GDPR;
b) will process your personal data lawfully, fairly and in a transparent
manner;
c) will collect your personal data for specified, explicit and legitimate
purposes and will not further process them in a manner that is incompatible
with those purposes, except to the extent permitted by law
d) will take all reasonable steps to ensure that personal data which is
inaccurate or incomplete in regard to the purposes for which it is processed,
are rectified, supplemented, suspended or destroyed without delay;
e) will keep it in a form which permits identification of you for no longer
than is necessary for the purposes for which the personal data are processed;
f) will not disclose your personal data to third parties except as provided
in this Privacy Policy or applicable law;
g) will ensure that your personal data are processed in a manner that ensures
appropriate security of it, including protection against unauthorized or
unlawful processing and against accidental loss, destruction, or damage, using
appropriate technical or organizational measures.
4.HOW DO WE COLLECT
YOUR PERSONAL DATA?
4.1. We process your personal data obtained in the following ways:
a) when you provide personal data to us. You provide us
with your personal data and other information by using the Websites, the
chatbot integrated in it, by writing to us or by communicating with our
customer service team by telephone or e-mail, by submitting your complaints
and/or inquiries, etc.;
b) when you use the Websites. When you are using the
Websites, certain information (such as the type of web browser and/or device
used, the operating system you use, the IP address, the number of visits on the
Websites, the pages of the Websites viewed, etc.) is collected automatically.
4.2. We may combine personal data we receive from you when you use the
Websites with data collected by us from other available sources (for example,
we may combine personal data you provide with data obtained through the use of
cookies on the Website).
5.WHAT PERSONAL DATA WE
PROCESS AND FOR WHAT PURPOSES?
5.1. We process your personal data for the following purposes:
a) To provide the service. You provide us with your personal data when you use the Websites. Personal data that are processed for this purpose:
b) To assure quality and communication. You provide us your personal data by writing to us or by contacting us by phone, submitting your complaints and inquiries about the Websites or our services. Personal data that are processed for this purpose.
c) For direct marketing purposes. With your consent and in order to provide you with newsletters, offers and information about the services and/or goods of us and our partners, or other information, we process your personal data in order to improve our services. Personal data that are processed for this purpose:
Read more about the processing of personal data for direct marketing
purposes in Chapter 7 of this Privacy Policy.
d) To ensure the functionality of the Websites and to
improve them, to offer you better services that are tailored to you. We use your
personal data, including personal data and cookies, which we receive when you
use the Websites in order to improve and develop the Websites and to offer us
better and more personalised services.
For this purpose, we use personal data obtained from you, created for you
using the Websites and/or received from other persons.
You can read more about how we use cookies and similar technologies in
Chapter 8 of this Privacy Policy.
e) To publish and make available your information. When you send, submit, upload or post any content (e.g. photos, videos, blog posts) (the “content”) to the Website, we will process the personal data you include in the content to publish the content and make it available. Personal data that are processed for this purpose:
Also, by submitting the content you warrant that you have the right (i) to
send us the personal data contained in the content and (ii) to give a consent
to use the personal data contained in the content as defined in this Section
5.1(e).
f) For other purposes provided for in our internal
documents, when your personal data is required to be processed by us by law or
there is a legitimate interest.
5.2. We do not collect or process your specific categories of personal data
revealing your racial or ethnic origin, political opinions, religious or
philosophical beliefs or trade union membership, as well as health data or data
about your sexual life and sexual orientation. If you provide this personal
data to us using the Websites or in any other way (in writing, by e-mail,
telephone), this data will be deemed to have been provided with your consent.
Accordingly, we will process this personal data of yours in conjunction with
the other data you provide in Section 5.1 of the Privacy Policy if those
personal data cannot be separated or it would require a disproportionate
effort.
6. HOW DO WE PROCESS
YOUR DATA WHEN YOU USE OUR CHATBOT ON OTHER WEBSITES OR MOBILE APPLICATIONS?
6.1. We enter into agreements with selected partners to allow them to use
our AI travel assistant chatbot on their websites or mobile applications (other
than the Websites, as defined above). In such case, any information you enter
into chat and submit via the chatbot on the partner’s website will be
transferred to us and further to third-party service providers (e.g. travel
service providers). However, we do not collect, process, store and transmit to
third parties any information which might identify you, and therefore we do not
process your personal data.
6.2. You should not input any personal or confidential information into the
chat during the conversation with the chatbot. Your conversation may be stored
for a period of 30 days and may be reviewed by Travelino for the purposes of
improving the chatbot service.
7.DO WE USE YOUR
PERSONAL DATA FOR DIRECT MARKETING?
7.1. Yes, we may use your personal data for direct marketing purposes to
provide you with offers and information about the goods and/or services of us
and our partners that we believe may be of interest to you. However, we
will only use your personal data for this purpose with your additional consent.
7.2. For this purpose, we process your personal data specified in Section
5.1 (c) of the Privacy Policy.
7.3. By granting the right to process your personal data for the purpose of
direct marketing, you also allow us to contact you for this purpose by
appropriate means of communication (e.g. e-mail, telephone, short message
service (SMS) or other means of communication (e.g. Skype, Viber, etc.).
7.4. We may combine available information about you with information held
by third parties.
7.5. If you consent to the use of your personal data for direct marketing
purposes, we may use your personal data to analyze and improve the
effectiveness of the Websites, advertising and market research, and for other
marketing and sales purposes of the company.
7.6. Even if you have given your consent for the processing of your
personal data for direct marketing purposes, you can easily revoke this consent
at any time for all or part of the processing of personal data. To do this, you
can:
a) change the settings on the Website to indicate that you no longer want
your personal data to be used for direct marketing, or
b) notify the waiver in the manner indicated in the newsletters and/or
offers received by e-mail (for example, in newsletters and/or offers by
clicking on the link “unsubscribe from newsletters, offers”, etc.), or
c) send us a request by email info [at] travelino.chat. The request must
clearly state your email which is used for receiving a newsletter and/or
offers.
7.7. If you withdraw your consent, we will make every effort to stop
processing your personal data for direct marketing purposes as soon as
possible.
7.8. Withdrawal of consent does not automatically oblige us to destroy your
personal data or provide you with information about the personal data we
process, so you shall make such a request separately in order for us to perform
these steps as well.
8.HOW DO WE USE
COOKIES?
8.1. .We collect information about you using cookies and similar
technologies. Cookies are small files that are temporarily stored on your
device’s hard drive and allow to identify you during other visits to the
Websites, save your browsing history, options, customize content, speed up
searches on the Websites, create a convenient and friendly Websites
environment, make it more efficient and reliable. Cookies are common web
browsing practices that make it easier to use the website.
8.2. Using cookies we may collect the following information: IP address,
type of web browser used, number of visits to the Websites, pages viewed on the
Websites, time spent on the Websites, demographic data and, if you have
accessed the Websites from a third party website, a link to the page URL, etc.
8.3. We use the information we receive from cookies for the following
purposes:
a) to ensure the functionality of the Websites (e.g. so that you can use
the personalization of the Website);
b) so that we can improve and develop the Websites to better meet your
needs;
c) to develop our services and analyze the use of the Website;
d) after you specifically consent – for marketing purposes.
8.4. We may combine information obtained through the use of cookies with
information obtained about you by other means (e.g., information about the use
of the Websites may be combined with personal data provided by you).
8.5. The following cookies may be used on the Websites:
a) Necessary cookies – necessary for the provision of the
services. These cookies ensure that information and services are provided
securely and optimally.
b) Performance cookies – to monitor visitor behavior and
help us improve information and services.
c) Functionality cookies – help to improve your experience
by providing more personalized services. These cookies “remember” choices such
as language, selected login method, and so on.
d) Targeting cookies – means cookies used to display
offers or other information that may be of interest to you.
8.6. All information about the cookies used on the Websites, their purpose,
validity and data used is provided in the table below:
Strictly necessary
Performance
Targeting
Save
Cookies consent
ID: 9dfa9687-f396-452b-897c-7f4487f578a4
Strictly necessary
|
Name |
Provider / Provider |
Expiration |
Description |
|
CookieScriptConsent |
.travelino.chat |
1 month |
This cookie is used by
Cookie-Script.com service to remember visitor cookie consent preferences. It
is necessary for Cookie-Script.com cookie banner to work properly. |
|
crumb |
www.travelino.chat |
Session |
|
|
__cfduid |
.travelino.chat |
1 month |
Cookie associated with sites using
Cloudflare used to speed up page load times. According to Cloudflare, it is
used to override any security restrictions based on the IP address the
visitor is coming from. It does not contain any user identification
information. |
|
_ga_WJNW6DPPX5 |
.travelino.chat |
2 years |
Cookie is set by Google Analytics.
To store, count and track pageviews. |
Performance
|
Name |
Provider / Provider |
Expiration |
Description |
|
_gid |
.travelino.chat |
1 day |
This cookie is set by Google
Analytics. It stores and update a unique value for each page visited and is
used to count and track pageviews. |
|
_hjTLDTest |
.travelino.chat |
Session |
When the Hotjar script executes we
try to determine the most generic cookie path we should use, instead of the
page hostname. This is done so that cookies can be shared across subdomains
(where applicable). To determine this, we try to store the _hjTLDTest cookie
for different URL substring alternatives until it fails. After this check,
the cookie is removed. |
|
_hjid |
.travelino.chat |
1 year |
Hotjar cookie. This cookie is set
when the customer first lands on a page with the Hotjar script. It is used to
persist the random user ID, unique to that site on the browser. This ensures
that behavior in subsequent visits to the same site will be attributed to the
same user ID. |
|
_hjIncludedInPageviewSample |
www.travelino.chat |
2 minutes |
This cookie is set to let Hotjar
know whether that visitor is included in the data sampling defined by your
site's pageview limit. |
|
_hjAbsoluteSessionInProgress |
.travelino.chat |
30 minutes |
The cookie is set so Hotjar can
track the beginning of the user's journey for a total session count. It does
not contain any identifiable information. |
|
_hjIncludedInSessionSample |
www.travelino.chat |
2 minutes |
This cookie is set to let Hotjar
know whether that visitor is included in the data sampling defined by your
site's daily session limit |
|
_hjUserAttributesHash |
www.travelino.chat |
2 minutes |
User Attributes sent through the
Hotjar Identify API are cached for the duration of the session in order to
know when an attribute has changed and needs to be updated. |
|
_ga |
..travelino.chat |
2 years |
This cookie name is associated
with Google Universal Analytics - which is a significant update to Google's
more commonly used analytics service. This cookie is used to distinguish
unique users by assigning a randomly generated number as a client identifier.
It is included in each page request in a site and used to calculate visitor,
session and campaign data for the sites analytics reports. |
|
visitor_id |
.getyourguide.com |
4 years 11 months |
This is a cookie pattern that
appends a unique identifier for a website visitor, used for tracking
purposes. |
Targeting
|
Name |
Provider / Provider |
Expiration |
Description |
|
MUID |
.bing.com |
1 year |
This cookie is widely used my
Microsoft as a unique user identifier. It can be set by embedded microsoft
scripts. Widely believed to sync across many different Microsoft domains,
allowing user tracking. |
|
fr |
.facebook.com |
3 months |
This cookie contains browser and
user unique ID combination, used for targeted advertising. |
|
_gcl_au |
.travelino.chat |
3 months |
This cookie is used by Google
AdSense for experimenting with advertisement efficiency across websites using
their services |
|
IDE |
.doubleclick.net |
1 year |
This cookie carries out
information about how the end-user uses the website and any advertising that
the end-user may have seen before visiting the said website. |
|
_fbp |
.travelino.chat |
3 months |
This cookie is used by Facebook to
deliver a series of advertisement products such as real-time bidding from
third party advertisers. |
|
_uetsid |
.travelino.chat |
1 day |
This cookie is used by Bing to
determine what ads should be shown that may be relevant to the end user
perusing the site. |
|
_uetvid |
.travelino.chat |
16 days 6 hours |
This is a cookie utilised by
Microsoft Bing Ads and is a tracking cookie. It allows us to engage with a
user that has previously visited our website. |
|
RUL |
.doubleclick.net |
1 year |
Used by DoubleClick to determine
if the website ad was properly displayed. This is done to make their
marketing efforts more efficient. |
8.7. To use targeting cookies we need your separate and
specific consent, which you can give to us by clicking on the “Agree” button in
the link (bar) on the Website.
8.8. You may revoke your consent to use targeting cookies at any time. You
can do this by:
a) visiting https://www.travelino.chat/privacy-policy and changing the
cookies settings there, or by
b) changing your web browser settings so that it does not accept cookies.
How you do this depends on your operating system and web browser. You can find
detailed information about cookies and their use at http://AllAboutCookies.org or http://google.com/privacy_ads.html.
8.9. In some cases, especially disabling, disagreeing with or deleting
technical and functional cookies may slow down the speed of Internet browsing,
restrict the operation of certain functions of the Websites, block access to
the Websites.
9.TO WHOM DO WE PROVIDE
YOUR PERSONAL DATA?
9.1. We guarantee that your personal data will not be sold, provided or
otherwise transferred to third parties without a legitimate basis, as well as
used for purposes other than those for which they were collected. We will not
transfer your personal data in any way other than in accordance with this
Privacy Policy or applicable law. However, we reserve the right to provide
information about you if we were required to do so by law or if required to do
so by law enforcement authorities or prosecuting authorities.
9.2. We may transfer your personal data to companies that help us operate.
From such partners, we require that your data be processed only in accordance
with the instructions given by us and the applicable data protection
legislation. We enter into agreements with these partners that oblige the
parties to adhere strictly to the personal data protection requirements.
9.3. We may disclose the personal data we collect about you to the following
third parties:
a) third party service providers (e.g. travel service providers, third
parties whose goods and/or services you choose when using the Websites, third
party service providers including those who provide us the services for sending
of newsletters or other marketing activities and technical service providers in
the performance of our agreements with these service providers);
b) third party service providers whose services we normally use for data
storage, telecommunications, and website hosting purposes. In some cases, your
data may be transferred to the third countries where other personal data
protection regulations may apply. We have taken appropriate safeguards to
ensure that your personal data remains protected, and we require that our
third-party service providers and partners also have appropriate safeguards in
place.
9.4. The use of your personal data by the above-mentioned service providers
is limited – they may not use this data for purposes other than providing
services to us.
9.5. The list of persons and their categories to whom we transfer your
personal data (non-exhaustive) is provided in Section 5.1 of this Privacy
Policy separately for each purpose of the use of personal data.
9.6. When you choose an offer from our partner – a travel service provider
– offered to you on the Websites, you will be taken to a website operated by
our partner, where their privacy policy applies. Our partners’ privacy policies
can be found here:
• Booking.com: https://www.booking.com/content/privacy.html
• Skyscanner.net: https://www.skyscanner.net/media/privacy-policy
• Kiwi.com: https://www.kiwi.com/en/pages/content/privacy
• Emirates.com: https://www.emirates.com/lt/english/information/privacy-policy
• Priceline.com: https://www.priceline.com/static-pages/privacy-policy.html
• GetYourGuide.com: https://www.getyourguide.com/privacy_policy
• Klook.com: https://www.klook.com/policy/
• Rentalcars.com: https://www.rentalcars.com/PrivacyPolicy.do
• Kayak.com: https://www.kayak.com/privacy
10.HOW LONG DO WE STORE
YOUR PERSONAL DATA?
10.1. We store your personal data for no longer than required by the
purposes of the processing or as required by law if it provides a longer
storage period.
10.2. We strive not to protect outdated personal data, therefore after the
update only up-to-date is stored. Historical information is stored if it is
required by law or for our activities.
10.3. Section 5.1 of the Privacy Policy specifies the terms of storage of
your personal data separately for each purpose of use of personal data.
11.HOW DO WE STORE YOUR
PERSONAL DATA?
11.1. The personal data we collect from you will be located within the
European Union (EU), but may be transferred or stored outside the EU. They may
also be handled by our own or our suppliers’ staff working outside the EU. When
transferring your personal data outside the EU, we will take all necessary
steps to ensure that your personal data is processed securely and in accordance
with this Privacy Policy.
11.2. Unfortunately, the transmission of information over the Internet is
not completely secure. Although we make every effort to protect your personal
data, we cannot guarantee the security of your data when you transfer data to
the Websites – you assume the risks associated with the transfer of data to the
Websites. Once we receive your data, we will apply strict procedures and
security measures to protect your personal data from unauthorized access.
11.3. Should unlikely circumstances arise and we become aware of a personal
data breach that could seriously jeopardize your rights or freedoms, we will
notify you immediately as soon as we become aware of it and determine what
information has been accessed.
12.EXTERNAL WEBSITES
12.1. The Websites may contain links to external websites – websites of our
business partners or websites that promote our services. By following such
links to any of the Websites, please note that these Websites and the services
accessed through them have their own separate privacy policies and we do not
accept any responsibility or liability for these policies or for personal data
collected on these Sites or services, such as contact or location details.
Please review these policies before submitting personal information on these
sites or using any services.
13.WHAT RIGHTS DO YOU
HAVE?
13.1. When processing personal data, we ensure your rights in accordance
with the GDPR. As a personal data subject, you have the following rights:
a) to know (be informed) about the processing of your personal data;
b) to access your personal data that we process;
c) to request the correction or supplementation of incorrect, inaccurate,
incomplete personal data;
d) to require the destruction of your personal data when they are no longer
needed for the purposes for which they were collected;
e) to demand the destruction of personal data if they are processed
unlawfully or if you withdraw your consent to the processing of personal data
or do not give such consent, which is necessary;
f) to object to the processing of personal data or to withdraw prior
consent;
g) to demand the suspension (other than storage) of your personal data
processing in the event of a dispute or verification of the lawfulness of the
processing, the accuracy of the data, as well as in cases when we no longer
need your personal data but you do not want us to destroy them;
h) to require the submission, if technically possible, of your personal
data collected with your consent or for the purposes of the performance of the
agreement in an easy-to-read format or request their transfer to another
controller.
13.2. We will endeavor to guarantee the exercise of your rights as a personal
data subject and to create all conditions for the effective exercise of these
rights, but we reserve the right not to comply with your requirements when it
is necessary to ensure:
a) the performance of the legal obligations imposed on us;
b) national security or defense;
c) public policy, the prevention, investigation, detection, or prosecution
of criminal offenses;
d) important economic or financial interests of the State;
e) the prevention, investigation, and detection of breaches of official or
professional ethics;
f) Protecting the rights and freedoms of you or others.
13.3. You can submit requests related to the exercise of your rights to us
in person, by post, or by electronic means. Upon receipt of your request, we
may ask you to provide proof of identity, as well as any additional information
we require regarding your request.
13.4. Upon receipt of your request, we will respond to you no later than
within 30 calendar days from the receipt of your request and the date of
submission of all documents required for the response.
13.5. If we deem it necessary, we will suspend the processing of your data,
other than storage, until your request has been resolved. If you lawfully
withdraw your consent, we will immediately, but no later than in 30 calendar
days, terminate the processing of your personal data, except as provided in
Section 13.2 of this Privacy Policy and the law, i.e. when we are required to
continue to process your data due to our obligations, court decisions or
binding instructions given to us by the authorities.
13.6. If we refuse to comply with your request, we will clearly state the
grounds for such refusal.
13.7. If you do not agree with our actions or the response to your request,
you may appeal against our actions and decisions to the competent public
authority.
14.TO WHOM CAN YOU MAKE
A COMPLAINT?
14.1. If you wish to make a complaint about our processing of your personal
data, please provide it in writing, providing as much information as possible,
using the contact details indicated at the end of this Privacy Policy. We will
immediately try to resolve any issues.
14.2. If you think that your rights have been violated, you can file a
complaint with our supervisory authority – the State Data Protection
Inspectorate, more information, and contact details can be found on the
Inspectorate’s website (https://www.garanteprivacy.it/). Although, above all, we seek to resolve
all disputes with you promptly and amicably.
15.HOW WILL WE CHANGE
THIS PRIVACY POLICY?
15.1. All changes to our Privacy Policy will be posted on the Websites. We
will notify you of them if necessary. The new terms of Privacy Policy may also
be posted on the Websites and you may need to read and agree with them in order
to continue using the Websites and/or our services.
14.2. If you think that your rights have been violated, you can file a
complaint with our supervisory authority – the State Data Protection
Inspectorate, more information, and contact details can be found on the
Inspectorate’s website (https://www.garanteprivacy.it/).). Although, above all, we seek to resolve
all disputes with you promptly and amicably.
16.HOW TO CONTACT US?
16.1. Please send all documents related to this Privacy Policy or contact
us at the following contacts:
• by post – Threebot Tecnology, address: p.zza
Procopio Cutò n°8, Palermo, Italy.
• by e-mail – info@3bot.it
This Privacy Policy has been published on November 11, 2022