1. Introduction
VOX S.p.A. (hereinafter, “Vox” or “We”), acting as the Data Controller, processes the personal data of individuals (the “Data Subject”) involved in accessing and using the VoxConnect App (the “App”) and the website www.voxtours.com (the “Website”). Data are provided directly by the Data Subject or, where applicable, by a person exercising parental authority. The purposes for which data are processed include:
- a) Managing access to and use of services on the App and Website
- b) Supporting purchases on the Website, such as digital travel guides or tickets
- c) Conducting statistical analysis on anonymized data
- d) Sending marketing communications about discounts, offers, services, and events from Vox
In addition, data collected on the Website may be processed for further purposes, given the Data Subject’s consent:
- e) Customer satisfaction surveys and feedback
- f) Profiling activities
- g) Commercial and promotional communications from Vox’s selected partners
Legal Basis for Processing
Data processing is carried out on the basis of:
- Execution of a contract for purposes a), b), c), and d) above
- The Data Subject’s consent for purposes e), f), and g)
2. Processing Method
Vox informs you that:
- a) Data processing is conducted using computerized, telematics, paper, and manual tools, following confidentiality and security standards.
- b) If consent for profiling (1.f above) is given, data will be processed automatically to categorize the Data Subject based on previously used services, completed surveys, and demographic class.
3. Optional Data Provision
Providing data is optional; however, refusal to provide data for purposes a), b), or d) will make it impossible to access services on the App or Website. Anonymized data will still be used for statistical purposes (1.c). Refusal to consent to purposes e), f), and g) will have no effect, except that the Data Subject may not receive marketing communications, partner promotions, or customer surveys.
4. Data Access and Disclosure
Data will not be disseminated. Within the Data Controller’s organization, relevant departments (Administration, Marketing, IT) may process data. Vox may also share data with third parties (see Footnote 1), designated as Data Processors, for managing registrations or additional purposes to which the Data Subject has consented. A complete list of Data Processors is available upon request via email (see 7).
5. Data Storage Duration
Data are stored on EU-based servers.
- a) Data for a) is retained during the Data Subject’s registration on the Website or App.
- b) Data for b) is stored as necessary for service provision and for the statutory limitation period thereafter.
- c) Data for e) and g) is stored until consent is withdrawn, except where retention is necessary for legal defense or regulatory compliance.
6. Data Subject Rights
The Data Subject has the following rights:
- a) Object to data processing for direct marketing.
- b) Access details on data processing purposes, duration, and recipients.
- c) Rectify inaccurate data.
- d) Delete data when it is no longer necessary, consent is withdrawn, there is an objection, or processing is unlawful (subject to retention for legal purposes).
- e) Restrict processing in specific cases (e.g., contested accuracy, unlawful processing).
- f) Receive data in a structured, machine-readable format (data portability).
The Data Subject may also contact the Data Protection Authority (Piazza di Monte Citorio n. 121, 00186 ROMA) to assert their rights.
7. Contact Information
Data Controller: VOX S.p.A., Via Pievaiola No. 21, Perugia, Fiscal Code: 2549200547. For requests or concerns, email privacy@voxtours.com. The Data Protection Officer can be reached at the same address.
User Location & Position
To enhance user experience, Vox may collect location information to guide users on nearby points of interest (e.g., museums, monuments). Location data is gathered through:
- GPS
- IP Address
- Device compass
- Wi-Fi access points
These settings can be enabled or disabled within device settings.
Footnote 1: Third-party partners include tourism organizations, museums, hotels, venues, institutions, travel agents, and tour operators. A current list is available upon request from Vox’s registered office or via privacy@voxtours.com.