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the privacy policy statement
The company Sisterscom.com S.n.c. (hereinafter, for the sake of brevity, “Sisterscom.com” or the “Company”) is aware of the importance of protecting the right to privacy, with regard to the processing of personal data, of its users. In compliance with European and Italian legislation in the matter and on the basis of both the recommendations of the Working Party formed under art. 29 of Directive 95/46/EC and the documentation and provisions published by the Italian Privacy Authority, Sisterscom.com informs that personal data acquired at the time of subscribing to the newsletter service of the website www.aviontourism.com will be processed in compliance with the law in matters of personal data protection.

With reference to the methods of control and processing of the personal data of users who subscribe to the newsletter of this website, in accordance with article 13, EU Regulation no. 679/2016, Sisterscom.com provides the following information:

1. Type of data collected
Data supplied voluntarily by the user
On sending the contact request in the “Contacts” section, data will be collected that has been entered voluntarily by the user on the form found on the page, including:
- e-mail (mandatory);

2. Purpose and legal basis of the processing
The data supplied by the data subject and collected by Sisterscom.com on the form for subscription to the Newsletter of the website www.aviontourism.com will be processed in order to:
A.    send to the user, who has made a specific request, the Newsletter of Sisterscom.com, the nature of which is informative and promotional, also for third-party products and services. The legal basis for the processing of personal data for this purpose is provided by the provisions of art. 6 paragraph 1, letter b) of EU Regulation no. 679/2016, since the service requested is supplied to the user.
B.    fulfil any legal or regulatory obligations or on the request of the judicial authority. The legal basis for the processing of personal data for this purpose is provided by art. 6 paragraph 1, letter c) of EU Regulation no. 679/2016, since the processing is necessary for compliance with a legal obligation to which the data controller is subject;
C.    to enforce or defend a legal claim. The legal basis for the processing of personal data for this purpose is provided by the provisions of art. 9 paragraph 2 letter f) of EU Regulation no. 679/2016, since the processing is carried out when it is necessary for the establishment, exercise or defence of legal claims.

3.    Data retention 
The personal data collected and processed after being sent together with the contact form of the website www.aviontourism.com will be retained for a maximum period of 2 years, with the exception of those data necessary for compliance with fiscal, accounting and administrative regulations or to fulfil other legal obligations.

4.    Method of processing
The personal data collected will be processed, stored and elaborated with electronic tools and will be saved on both computer hardware and paper format, organised in databases, and on any other suitable format. 
Specific security measures have been observed to prevent the loss of data, its illicit or improper use and unauthorised access. 
The processing of personal data carried out by Sisterscom.com does not involve automated decision-making processes.

5.    Communication and/or conferral of personal data
The communication and/or conferral of data in the form for subscription to the newsletter is a necessary requirement for supplying the service required and therefore mandatory for such purpose: a failure to communicate and/or confer personal data by the data subject shall make it impossible for Sisterscom.com to permit navigation on the website www.aviontourism.com. The communication and/or conferral of data for other purposes is optional: a failure to communicate and/or confer data in this case will not have any consequences for the data subject, but could make it impossible to give the user the feedback requested.

6.    Subjects to whom the personal data may be communicated
The personal data collected will not be disclosed, but may be communicated not only to subjects to whom the right and interest to access your personal data is recognised by law or secondary and/or EU regulations, but also to authorised staff of the Data Controller, as well as companies, associations or professional studios that provide services and activities on behalf of the Data Controller as Processors to fulfil legal obligations, as well as for any organisational and administrative requirements necessary to provide the services requested. 
The names of other subjects to whom your personal data may be disclosed in their capacity as “Data Processors” is provided in the latest list available from Sisterscom.com (to be requested using the contact details given in point 9).

7.    Transfer of data abroad or to international organisations
Sisterscom.com shall not transfer the data subject’s personal data collected from the newsletter subscription form on the website www.aviontourism.com and the tools envisaged therein abroad or to international organisations.

8.    Links to third-party websites or services
This privacy policy applies only to the processing of personal data carried out through this website or the tools envisaged therein, and does not apply to other websites that may be consulted by the user via links, the managers of which are independent data controllers. We therefore invite the users to carefully read their privacy policies before accessing the services of third parties.

9.    Rights of the data subject
In relation to the aforementioned processing of personal data, the data subject has the right to exercise, at any time, his or her rights pursuant to EU Regulation no. 679/2016, including, for example, to right to obtain information on:
- the source of the personal data;
- the purposes and method of processing;
- the logic applied in the case of processing carried out with aid of electronic tools; 
- the identification details of the Data Controller, processors and appointed representative. 
The data subject has the right to obtain:
- the access, updating, rectification or where interested therein, integration of data;  
- the erasure, anonymisation or blocking of data that have been processed unlawfully; 
- the restriction of processing of the data that concerns him or her, that is, request the Data Controller or Processor to limit the purposes or methods with which his or her data are processed. 
The data subject may also request a copy of his or her data in standard form (so-called “Right to data portability”). 

The Data Subject to whom the data refer, lastly, has the right to oppose, at any time and without any cost, in whole or in part: 
- to the processing of his or her personal data for legitimate reasons, even if pertinent to the purpose of collection; 
- to the processing of his or her personal data carried out in accordance with article 6, paragraph 1 GDPR, letter e. (“processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”) or f. (“processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party”) including profiling on the basis of these provisions. 
- to the processing of his or her personal data for the purpose of sending advertising or direct sales material or to perform market research or commercial information (direct marketing), including profiling insofar as it is connected. 

The data subject has the right to withdraw his or her consent to processing, when this is based on the circumstance envisaged by art. 6, paragraph 1, letter a. (when “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”), or by article 9, paragraph 2, letter a. (the data subject has given explicit consent to the processing of those personal data for one or more specified purposes) of EU Regulation 679/2016, at any moment without affecting the lawfulness of the processing based on consent before the withdrawal. 
The data subject, in the event it is deemed that the processing concerning him or her violates current legislation, has the right to make a claim to the control authority, notably in the member state in which he or she generally resides, works or in the place where the presumed violation took place. The Italian Control Authority may be reached at the contact details found on its website.

10.    Data Controller of the processing – Contact data
The Data Controller is Sisterscom.com S.n.c., Via Piave 102, 23879 Verderio Inferiore (LC), VAT number 03248170163, represented by the pro tempore legal representative. The Company can also be contacted at the email address info@sisterscom.com and at the Certified email address  amministrazione@pec.sisterscom.com
To exercise the rights listed above, the data subject may make a request using the email address info@sisterscom.com.
Sisterscom.com reserves the right to update this Privacy Policy.
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