These privacy statements have been developed to provide information on personal data treatment of website users which access to the website www.wanderio.com (the "Website") and to the services or mobile applications (the "Applications") provided by Wanderio S.p.A. through the Website. Personal data treatment shall be compliant to the applicable data protections laws and regulations and according to the following terms.

This Privacy Policy –provided for the purposes set out under sect. 13 of the Italian legislative decree of 30 June 2003 no. 196 (Italian Data Protection Code) – describes the processing of personal data provided, or collected, on the Website and Applications; this privacy policy does not cover links form our Website to other third parties’ websites and accordingly any information collected by the parties who own and control those website and their use of cookies. We strongly recommend that you refer to the specific privacy policy and cookies policy of the third party website prior to access to such website.

1. Data Controller

Data Controller is Wanderio S.p.A., ("Company" or "Wanderio"), having its registered office in V.le Città d'Europa 780 - 00144 Roma (Italia), tax code/P.IVA.: 12303801000, email: [email protected]

2. Types of Information We Collect

Browsing data

Open webpages of this Website do not require you to provide any personal information. Optional, explicit and voluntary messages sent to the addresses shown on this Website involve the subsequent acquisition of the sender’s address, (mobile, home or office) telephone necessary to reply to your requests, and of any other personal data included in the messages. These data are only used to manage your request and may be disclosed to third parties, if necessary and depending on its subject (e.g., carriers who provide shipment services of our marketing materials). Such data shall be retained for the time strictly necessary to provide the requested services to the user and shall not be shared with third parties.

Data provided for the purpose of registering with us and/or by purchasing any travel Solution

Personal data treatment concerns all the processing activities (for example: collection, registration, management, use, storage, processing, amendment, selection, sharing) of the information provided by you for the purpose of registering to the Website and/or by using the services provided by the Website and/or the Applicazions:

1. Contact and identification detail of the user provided by registering and managing the user's account, including:
2. personal data necessary to file the registration form (e.g. name, surname and email);
3. optional information useful to manage the account (e.g. gender, birth date, photos and language);
4. contact and identification data of the user or third parties (in case the travel Solution has been purchased on their behalf), provided by the user and necessary to buy travel Solution and management of orders, including:
5. name, surname, address, city, country;
6. fiscal code/ tax code for the invoice;
7. date of birth, number and expiry date of the identity card (e.g., identity card, passport) if required by the travel service providers, for example flight companies;
8. e-mail and phone number for service related announcements;
9. information concerning selected travel arrangements (e.g. departure and destination, means of transport, requests of assistance or claims), and payment solutions including, and depending on the opted payment method, number of credit card, expiration date or card security code, if necessary to obtain pre-authorization for payment;
10. in case the user accesses to the Website through social applications (e.g. Facebook Connect), some data posted by the user on his/her profile available on the social network (as an illustrative, yet incomplete example: name, surname, gender, city, email address, language, profile photo). Treatment of such data is limited to the type of information requested to complete the standard form of registration to the Website and/or Application and management of the user’s account. We will not pass your personal data to social network;
11. data on user’s habits and preferences (e.g., searches, preferred itinerary and means of transport, travel frequency, preferred destinations). Upon your express consent, we may analyze such information in order to find out more of our user’s preferences and to provide to you a more helpful service;
12. possible data on user’s geo-localization, in order to provide geo-localization services (e.g., locate your starting address, the nearest taxi stand, etc.). In case you expressively authorize geo-localization services, the Applications will receive information on your actual position.

3. Scope of data processing

We collect and process your personal data for the following purposes: 1. to provide the Services requested by the user (e.g.: management of the registration process and access to the Website, management of the Applications, searches and purchase of travel Solutions, user’s account management, assistance and resolution possible users’ complaints); 2. to fulfill applicable legal requirements; 3. upon your express consent, for the following marketing purposes 1. send newsletters by email, mail, phone and/or mobile text messages, social media (e.g. social networks), push notifications, concerning information on our services or services provided by other travel service providers, both intermediaries and carriers. Moreover, with your specific consent to profiling activities as set forth under paragraph (4) below, your personal data may be used analyzed by the Company and used for sending you communications in order to offer you further personalized services and to promote products and/or services in order to enhancing your travel experience; 2. conduct statistical and market analysis, also online, on services provided by the Company; 4. upon specific consent of the user, for profiling purposes, and more precisely to analyze user’s habits, purchase preferences, location and any further information (e.g.: means of transport). Such data may be processed in an aggregate form or in an identifiable way for conducting market researches in order to better enhance our services and/or products.

4. Obligatory or voluntary nature of providing the requested data

In respect to the purposes outlined under paragraphs (1) and (2), information required to complete the registration process are essential to complete the process and to use the service provided the Website and Application. Failure or refusal to provide such information will prevent us to satisfy your request. In particular, further information that is essential for us to provide to you our services is properly market as such on the Website. For such data processing purposes, it is not necessary your consent or the consent of third parties to whom the purchased travel Solution refers.

Related to the purposes outlined under paragraphs (3)-(4), your consent is not essential and your refusal does not impede you to use the services provided on the Website. However, in this case the Company could not be able, e.g., to send you personalized promotional and marketing materials that, according to Wanderio, could be interesting for the user and provide a more helpful service. In any case, it is understood that personal data treatment for such purposes shall be processed exclusively upon express and specific consent of the user.

5. Navigation data – Cookie – Social features

Navigation data

During normal functioning, the computer systems and software procedures designed for the operation of this Website acquire some personal data, which transmission is implicit when using Internet communication protocols (e.g., IP addresses or domain names of the computers used by users who connect to the Website, URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the digital code indicating the status of the reply given by the server (OK, NOK, etc.) and other parameters regarding the user’s operating system and computer environment of the user). This information is not collected in order to associate it with the persons identified but, due to its nature, could permit identification of users through processing and association with data held by third parties.

The data indicated are used only to obtain anonymous statistical information regarding use of the Website and in order to verify correct functioning and therefore they are immediately deleted after their processing. The data could be used to ascertain responsibility in the case of hypothetical computer crimes that damage the Website: except this case, these data are not stored for more than seven days.

Cookie

What cookies are. A cookie is a small text file sent to your browser by a website you visit and subsequently memorized on the hard disk of the user’s computer. If you connect to the website again, the cookies are then reread and recognized by the website that sent them. While you are visiting a website, you may receive cookies of third party website (so called, “third party” cookie), like links to webpages of other domain names.

Cookies may be used for different purposes; they can be used to allow a website to recognize a user’s device, monitor sessions e memorize specific information on users that access to the server. Type of cookies. Strictly necessary cookies (“technical” cookie): these are necessary in order for the Website to function properly and to enable you to use its service (e.g., memorize travel Solution, remembering your language preferences, etc.).

The Website uses another type of cookie, the “analytics" cookies, in order to collect information on how the Website is used, the pages visited and any errors that may occur when surfing. These cookies do not gather information that could identify your computer. All information these cookies collect is aggregated and therefore anonymous. However, at any time the user can disable cookie analytics following the instructions below. For further information, please refer to privacy policy of Google Analytics and Mixpanel.

The Website uses also "functionality" cookies (these are used to make it easier to move around the Website, to memorize the settings that you have chosen and to provide you with personalized functionality, including passwords) and "targeting" cookies (these are used to gather useful information about your browsing habits that are statistically analyzed by the Company in order to make advertising (also real-time advertising) relevant to you and your interests). For these type of cookies is required your consent.

At any time, you can accept or disable cookies and eliminate all the cookies installed by managing settings of your browser. Each browser has a different procedure for managing settings. Here are the specific instructions for each browser:

How to manage cookies in Internet Explorer How to manage cookies in Firefox How to manage cookies in Chrome How to manage cookies in Safari web and iOS If you disable cookies, the Company cannot guarantee that the Website will work properly.

Social features

In case the user (i) connects to the Website through other social networks (e.g. Facebook or google+, hereinafter also defined “Social Media”) or (ii) links his/her own account to other accounts on Social Media, the Company can receive from such Social Media, including Twitter, information on the user according to the terms of use and privacy policy of the Social Media. The Company can add such information to the collected personal data. If the user chooses to share his/her personal information with such Social Media, Wanderio will transfer the data according to the user’s settings. Personal data that have been shared with the Social Media will be processed pursuant to the general terms of use of such Social Media.

6. Data communication recipients

Your personal data will be processed by the authorized staff of the Company, mainly in the relational marketing, assistance, management and marketing departments. This may include staff of our service providers, also acting as our data processor, or with other third parties (e.g. information technology service providers with reference to the services of hosting and maintenance of the web platform, analyses and implementation of the features of the Website and Applications, or database management service providers).

Moreover, information necessary to provide the services you have asked for (e.g., booking and delivering travel tickets) can be passed by the Company to the travel service providers, insurance companies, credit and charge card companies, banking and credit verification entities.

We will not pass your personal data to third parties for their own purposes; it is hereby understood that in case of extraordinary corporate transactions that should affect the Company (e.g. lease or transfer of business units), your data can be transferred to the lessor/purchaser or third party assignee.

Your data will not be transferred to other third parties.

7. Users’ right

Section 7 of the Legislative Decree no. 196/2003 grants to the subjects holder of personal data (in such case, the users), the right to obtain at any time confirmation of the existence of such data and to know their content and origin, to verify their accuracy and to request their integration, updating and correction.

According to the same section, the users have the right to request to the Company cancellation, transformation into anonymous form or blocking the data processed in violation of applicable law and to oppose to their treatment for legitimate causes.

Requests should be addressed to the Company to the contact detail provided under paragraph (1).

Last update: June 2014