Privacy Policy

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 by browsing the website www.aviontourism.com will be processed in compliance with the law in matters of personal data protection.
While using the services offered by the website (filling in the contact form, etc.), the user will receive specific information regarding further processing of personal data carried out by Sisterscom.com.

With reference to the methods of control and processing of the personal data of users who consult this website, in accordance with article 13, EU Regulation no. 679/2016, Sisterscom.com provides the following information:
 
1. Types of data collected, purpose and legal basis of the processing
Navigation data
The IT systems and software procedures used to operate the website  ww.aviontourism.com acquire, during normal operation, some personal data whose transmission is implicit in the communication protocols of the Internet. 
This category of data includes IP addresses or domain names of computers used by users connecting to the site, the MAC (Media Access Control), URI (Uniform Resource Identifier) of requested resources, time of request, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the status of response from the server (successful, error, etc.) and other parameters regarding the operating system and computer environment. These data are used only to obtain anonymous statistical information about the site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of computer crimes against the site. 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 it allows the user to use the service requested. The same data may also be used to fulfil legal obligations or requests from 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.
Tool for research “What is your next destination?”, “Which airport will you fly from?”, “Which airline will you use?”, “Travel advice, useful information and news”
By entering data in the forms entitled “What is your next destination?”, “Which airport will you fly from?”, “Which airline will you use?”, “Travel advice, useful information and news”. Sisterscom.com does not process or retain data relating to an identified or identifiable person. These tools act only as a filter to identify information concerning holiday destinations, airlines, airports, useful information for passengers and news recorded by the site with the features indicated by the user. No personal data is processed using this tool.

Data supplied voluntarily by the user
On voluntarily sending email messages to the email addresses on the website, Sisterscom.com may process the email address of the sender and further personal data contained in the message to answer, again via email, any requests from the user. Specific privacy policies will, however, be given when using particular tools envisaged by the site. The legal basis for the processing of personal data for this purpose is provided by art. 6 paragraph 1, letter b) of EU Regulation no. 679/2016, since the service requested is supplied to the user. The same data may also be used to fulfil legal obligations or requests from 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.
The data subject is invited not to enter or send through the tools present on this website “special data”, “biometric data”, “genetic data”, “data regarding health”, “sensitive data”, “judicial data as defined by legislation in force.
These data, if supplied by the data subject, will be immediately deleted.

Cookies
The website uses technical cookies (session and navigation) to guarantee regular browsing and use of the website. It also uses third-party profiling and analytical cookies (with reduced identification potential) to monitor the website’s use by users in order to optimise the web platform and statistics (analytical). For all information regarding the processing of personal data using cookies, please refer to the cookie policy, which can be reached from any page of the website via a link.

2. Data retention
The personal data collected and processed following navigation on the website www.aviontourism.com will be retained for the entire period the service is provided and, in any case, deleted or anonymised at the end of 7 days. Personal data sent independently by users via the tools present on the website will be deleted after the service requested is provided or a response given, and however within the maximum period of 15 days after such activity, with the exception of those data necessary for compliance with fiscal, accounting and administrative regulations or to fulfil other legal obligations and to document the activities performed.

3. 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.

4. Communication and/or conferral of personal data
The communication and/or conferral of navigation data is a necessary requirement for supplying the service (browsing on the website) 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.

5. Subjects to who the 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).

6. Transfer of data abroad or to international organisations
Sisterscom.com shall not transfer the data subject’s personal data collected via the website www.aviontourism.com and the tools envisaged therein abroad or to international organisations.

7. Links to third-party websites or services
This informative statement is applicable only to the processing operations carried out on personal data through this site or the instruments set aside for that purpose by the site, but it is not applicable to other sites that you may consult through links on this site; the managers of said linked sites operate as independent Data Controllers, responsible for the relevant processing operations. You are, therefore, invited – before accessing the services of third parties – to read their privacy statements carefully. In particular, the download of Avion Luxury Magazine is operated by PressReader on an external site. Therefore, users are invited to read PressReader’s privacy policy and terms of service.
 
8. 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 methods of processing;
- the logic applied in the case of processing carried out with electronic tools;
- the identification details of the Data Controller, the 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 for commercial information purposes (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.

9. Data Controller – 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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