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Privacy Policy and Information on Personal Data Processing

7.1 BravoNext SA, a Swiss company within the Bravofly Rumbo Group (order no.: CH-501.3.014.881 -1), based in Vicolo de' Calvi 2 - 6830 Chiasso, Switzerland (tel. 0041 916833339), acknowledges the importance of protecting the privacy and rights of Users using its Website and Service. Internet is potentially a very powerful tool for the circulation of personal data; Bravonext and the companies within the Bravofly Rumbo Group are seriously committed to complying with the regulations on personal data protection and security in order to guarantee the Users' safe, controlled and confidential netsurfing. This Privacy Statement may be amended in the future to ensure ongoing compliance with all applicable regulations in the event of their amendment or update. Users are invited to read carefully the rules applied by the company to collect and process personal data and to continue to provide a satisfactory service.

7.2 This Privacy Statement, which is in accordance with personal data protection rules, describes the methods applied by the company to manage and process the personal data of:
(i) Users who consult and use the Website, and
(ii) Users who use the Service.
Users are required to supply accurate, correct and updated personal data in order to establish and manage their contractual relationship with the Data Controller and to duly purchase the selected tourist service. Users acknowledge that the supply of inaccurate, incorrect and not updated personal data prevents the Data Controller from supplying its services.
Pursuant to the Federal Law of 19 June 1992 on Data Protection (LPD) and to Article 45 of the Federal Insurance Supervision Law (LSA), Users are hereby informed that their personal data is stored and processed by Bravonext according to the methods and for the purposes listed below, in accordance with the methods and purposes allowed by LPD and LSA.

7.3 The Data Controllers are BravoNext SA (hereinafter, "Bravonext" or "Data Controller") and the companies that are controlled thereby or affiliated thereto or that are within the Bravofly Rumbo Group (hereinafter, "Data Controllers"). The full and updated list of companies controlled by and affiliated to Bravonext or within the Bravofly Rumbo Group may be requested by sending an email to privacy@bravofly.com

7.4 Users' personal data is collected:
- from Users, via their direct electronic supply through the filling in of the registration form in the Website or on the phone. This data includes Users' name, surname, address, e-mail address, telephone number etc., which is necessary for the purposes of selecting and purchasing a Flight, a Hotel or another tourist service and for the additional purposes provided for in these terms and conditions.
- via the computer systems and software procedures used for the operation of the Website in the course of their normal operation, in an implicit manner, as a result of the use of Internet communication protocols. This information is not collected to be associated with identified Users; yet, it is such that, as a result of its processing and association with data held by third parties, it might lead to the identification of Users. This category of data includes IP addresses or domain names of computers of Users connecting to the Website, the URIs (Uniform Resource Identifier) of the resources requested, the hour of the request, the method used to submit the request to the server, the size of the file received in response, the number code indicating the status of the response given by the server (successful, mistake, etc.) and other parameters related to Users' operating systems and computer environments. This data is used only to obtain anonymous statistical information on the use of the Website and to verify its proper operation. The data may be used to establish liability in case of potential computer crimes damaging the Website.
- by the Website via cookies. Cookies are information, often containing a single, anonymous ID. code, which is sent to the browser by a web server and which is then stored on the hard drive of the User's computer. Cookies are then reread and recognized by the website that sent them in case of subsequent connections. Bravonext may use cookies to store and sometimes track data supplied by Users in order to provide a more accurate Service to the Users themselves.
The data obtained via cookies, if any, is used by the Data Controller either directly or via companies that cooperate therewith, in order to ensure more simple, immediate and fast Website access and use of the Service, as well as Users' easier navigation of the Website and for marketing purposes related to the services provided by the Data Controller. All Users' data that is not collected for direct communications from the Users themselves is used solely for statistical purposes on web traffic and is not associated with single Users.
The receipt of cookies used in this Website may be interrupted at any time by Users by changing the settings of their browser, or may be denied from the beginning of the contractual relationship in the same manner.

7.5 Users' personal data will be processed by hand or by using electronic means that are such as to ensure, in relation to the purposes for which such data is communicated and collected, data security and confidentiality, as well as to prevent unauthorized access to such data, for the time strictly necessary to achieve the purposes of its collection.

7.6 Data will be processed at the legal and operational headquarters of the Data Controllers and at the server farm of the Bravofly Rumbo Group in Haarlem, The Netherlands, and at the offices of the parties to which such data may be communicated.

7.7 Apart from the above specifications on navigation data, Users' personal data will be used for the following purposes:
A. for data collection, storage and processing for the purposes of establishing and managing, in operational and administrative terms, the contractual relationship connected to the supply of the Service
B. to send communications by email, phone or SMS on the contractual relationship, including communications relating to the good progress thereof;
C. to comply with statutory or regulatory obligations;
D. for data collection, storage and processing to carry out anonymous and/or aggregate statistical analyses;
E. sending by the Data Controller, in cases allowed by law and if there is no refusal from the User, of publicity material through email or other equivalent electronic communication medium, relative to analogous products and services or similar to products or services offered on the website; on some occasions and with the exception of the Italian market, the Data Controller may send to the User the cited publicity material in a personalized way;
F. without prejudice to the provision of the above section E), and only with prior explicitly consent of the User, for the sending by the Data Controller through email, phone, mail, SMS or MMS of the best offers on products and services traded by the Data Controller or his partners or commercial collaborators who operate in the following sectors: tourist and free time, leisure, new technology, fashion, decoration and consumer goods, food and drink, finance, banks, insurance, energy, environment, communication, mass communication media, real estate, pharmaceutical sector, clothes and textiles, education and training, energy, publications and editorials, ICT, retail, sports, telecommunications and services in general. On some occasions and with the exception of the Italian market, the Data Controller may inform the User in a personalized way about the best available offers, adapting them to his tastes and preferences.

7.8 Should the User refuse to supply his personal data, he may not obtain the services required in relation to the purposes set out in points A) and B) of Article 7.7; in addition, the Data Controller may be prevented from supplying the Service correctly and from complying with its contractual obligations set out in the terms and conditions. Data processing for the purposes set out in points A), B), C) D) and E) of Article 7.7 does not require the consent of the person concerned.
The supply of personal data for the purposes set out in point F) of Article 7.7 is optional. Data processing for the purposes set out in point F) of Article 7.7 requires the consent of the person concerned. The User's refusal to supply his data or to give his consent to these purposes signifies that, subject to letter E), the Data Controllers will be unable to send their deals referred to in letter F) of Article 7.7 to the User.

7.9 The Data Controller will make sure that all personal data supplied thereto is not disclosed and is processed in such a way as to guarantee its security and confidentiality, as well as to prevent unauthorized access thereto. All personal data and information provided by Users may be communicated, for the purposes set out above, to the following categories of parties:
- the company's employees and/or collaborators who assist and advise the Data Controller on Administration, Products, Legal Affairs, Customer Care, Information Systems, as well as those in charge of maintaining the company's network and hardware/software equipment;
- airlines, hotels, car hire firms, insurance companies, Tour Operators and all other parties to whom data communication is necessary for contract performance. Please note that airline companies are required, in accordance with the regulations introduced in the US and in other countries, to allow the customs and border authorities to have access to flight passenger data. Therefore, information on Users and their travelling collected by Bravonext may be communicated thereby to the competent authorities of the countries touched by Users' travel itineraries, if so required by industry standards.
- parties whose right to access data is recognized by statutory provisions or by orders issued by the competent authorities;
- parties that are delegated and/or appointed by the Data Controllers to carry out activities related to Service supply.
The list of the names of the parties to whom Users' personal data may be communicated is available at Bravonext, by writing to privacy@bravofly.com

7.10 By sending a written request to the Data Controller, the User may: (i) obtain from the Data Controller confirmation of the existence of his personal data; (ii) obtain information about the source of his data, the purposes and methods of data processing and the logics applied where data is processed by electronic means; (iii) obtain the details of the Data Controller and of the Data Processors, if any; (iv) obtain information about the parties or categories of parties to whom his personal data may be communicated or who may become aware thereof in their capacity of designated representative in the Country, data processors or people in charge thereof; (v) obtain the cancellation, transformation into an anonymous form or blocking of data processed against the law, and the updating, correction or, if interested therein, integration of his data and (vi) obtain a certification that the operations referred to in point (v) above have been brought to the knowledge, even as regards their content, of those to whom such data has been communicated or spread, unless this proves impossible or involves a manifestly disproportionate use of means when compared to the right being protected; (vii) object to data processing, in whole or in part, for legitimate reasons; (viii) object to data processing for the sending of advertising or direct sales material or for market surveys or commercial communications. The above requests must be sent to BravoNext SA's address privacy@bravofly.com
By sending an express written request by e-mail, the User may also obtain the correction of any incorrect or inaccurate personal data or obtain its cancellation to the extent permitted by law.
In order not to receive any further commercial or promotional offers from the Data Controllers, the User, in addition to exercising the above rights, may also follow the simple procedure activated by the link "unsubscription" that is available in all commercial communications sent by the Data Controllers.

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