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Privacy Policy

Italia Golf & More AG (‘we’) is responsible for collecting and processing your personal data in connection with its activities. Our job is to offer our customers a comprehensive range of travel services.

In this privacy policy, we explain how we process your personal data and how you can control and manage it. Our data processing may be covered by additional data protection notices, such as those contained in the General (Travel) Terms and Conditions, or may be apparent from the circumstances or regulated by law.

This privacy policy complies with the requirements of Swiss data protection law and, where applicable, the General Data Protection Regulation (GDPR) of the European Union.

1. Are you affected by this notice?

This privacy policy applies to you if you:

  • you are one of our customers or have a contractual relationship with us;
  • you are a fellow traveller of one of our customers.
  • you are interested in our products or services and therefore provide us with your personal data (e.g. at an agency, on our websites and apps, or at events) so that we can contact you.

If you provide us with personal data relating to other individuals, please ensure that you inform them of the disclosure of their personal data and encourage them to read this privacy policy. We will ensure that we do the same whenever possible (e.g. if we have the contact details of the individual concerned).

2. How can you control our processing of your personal data?

You have rights that enable you to effectively control your personal data and the way we process it. Below, we explain your rights in relation to your personal data.

If you wish to exercise the rights listed below, please submit a request by email to info@golfandmore.com or by post to the following address:
Italia Golf and More AG
Aussergrütstrasse 2
6319 Allenwinden
Schweiz

If you have any questions regarding the use of your personal data within the scope of this privacy policy, please address them to the following address: info@golfandmore.com

2.1 You may request information about your personal data.

If you wish to obtain information about your personal data, we will provide you with a copy of the personal data you have requested and information about how it is processed.

Your right to information may be restricted in cases provided for by law.

2.2 You may request the correction of your personal data.

If you believe that your personal data is inaccurate or incomplete, you may request that this personal data be amended or completed accordingly. In some cases, you may be required to provide supporting documentation.

2.3 You may request the deletion of your personal data

If you wish, you may request the deletion of your personal data, insofar as this is legally permissible.

2.4 You may object to the processing of your personal data on the basis of legitimate interests.

If you do not agree with processing based on a legitimate interest, you can object for reasons arising from your individual situation. In this case, please inform us in detail about the processing in question and the reasons for your objection. We will cease processing your personal data unless there are compelling legitimate grounds for doing so or the processing serves to assert, exercise or defend legal claims.

2.5 You may object to the processing of your personal data for direct marketing purposes.

You have the right to object to the processing of your personal data for direct marketing purposes at any time. This also applies to profiling insofar as it is related to such direct marketing.

2.6 You may request the restriction of the processing of your personal data.

If you dispute the accuracy of the personal data we use or object to the processing of your personal data, we will review or revise your request. You may request that we restrict the processing of your personal data while we review your request.

2.7 You have rights against automated individual decision-making

You have the fundamental right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. However, we may automate such a decision if it is necessary for the conclusion or performance of a contract with us, is permitted by law, or if you have given your consent.

In any case, you have the right to contest the decision, to express your point of view and to request the intervention of a competent person to review the decision.

2.8 You may withdraw your consent

In cases where processing is based on your declared consent, you may revoke this consent at any time.

2.9 You may request the portability of some of your personal data

You may request a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format. Where technically feasible, you may request that we transfer this copy to a third party.

2.10 Complaints to the Federal Data Protection and Information Commissioner

In addition to the above rights, you may lodge a complaint with the competent supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern.

3. For what purpose and on what legal basis do we use your personal data?

3.1 Contract processing and legitimate interest

In this section, we explain the purpose for which we process your personal data and the legal basis for doing so. We primarily use your personal data to execute a contract to which you are a party or to take pre-contractual measures at your request. However, we may also process your personal data to fulfil our legitimate interests or those of third parties.

Your personal data will be processed in particular if this is necessary for the conclusion or fulfilment of a contract in order to:

  • Conclude a (travel) contract with you. We may process personal data in order to register you as a new customer, conclude a contract and fulfil it with you;
  • Provide you with products and services that you have purchased under the respective contract;
  • Carry out billing, invoicing and collection;
  • provide you with services in connection with the preparation and execution of a trip;
  • for insurance purposes;
  • offer consulting services;
  • provide assistance in case of difficulties during the trip, if necessary;
  • provide you with access to our digital platforms. We may process personal data when you use our digital platforms for various purposes (e.g. to manage your personal information or to access travel information);
  • to grant access to our premises and facilities. We may process personal data when you visit our premises in order to carry out appropriate access and security checks;
  • to communicate with you. We may process personal data when you wish to contact us, when you request information about our company or our services, or when the contract needs to be updated;
  • to respond to your enquiries and provide you with support;
  • to manage the termination of the contract.

When we base a processing activity on a legitimate interest, we weigh this interest against your interests or fundamental rights and freedoms to ensure that they are proportionate. As part of our business activities as a travel provider, we also use your personal data to:

  • to further develop our products and services;
  • to improve cybersecurity, manage our platforms and websites, and ensure business continuity;
  • to implement IT solutions;
  • to perform maintenance on IT systems during ongoing operations;
  • improve the automation and efficiency of our operational processes and customer services (e.g. automatically filling out complaints, tracking your enquiries and improving your satisfaction based on personal data collected during our interactions with you, such as telephone recordings, emails or chats);
  • Enabling the assertion of legal claims and defence in connection with legal disputes and regulatory proceedings;
  • Organising competitions, promotions and conducting opinion polls and customer satisfaction surveys.

3.2 Advertising and marketing

If you are a customer and unless you object, we may send you offers for our products and services. We ensure that these commercial offers relate to products or services that are relevant to your needs and complement the offers you have already taken advantage of. You can object to this at any time.

3.3 Consent

We will inform you specifically about certain processing of personal data and ask for your consent. You can, of course, withdraw your consent at any time.

In particular, we ask for your consent for:

  • The transfer of sensitive personal data to third parties;
  • The customisation of our offers, products or services based on a complex profile in order to predict your needs and behaviour;
  • All electronic offers for products and services that are not similar to those you have purchased, or for products and services from our trusted partners.

If necessary, we may ask you for further consent to process your personal data, but this will not affect any data processing that has already taken place.

4. What types of personal data do we collect?

We collect and use your personal data, i.e. any information that identifies you or enables you to be identified.

Depending on the type of product or service we offer you and the interactions we have with you, we collect different types of personal data about you:

  • Contact information, (private or professional) postal address, email address, telephone number;
  • Personal details, e.g. gender, date of birth and age, marital status, nationality, passport details, etc.
  • Lifestyle, e.g. hobbies and interests, travel;
  • Travel details, such as travel dates, itinerary/destination, airline, hotel, price, customer preferences, information about your fellow travellers, frequent flyer programmes, etc.;
  • Health data, e.g. information about special health-related needs or illnesses and accidents during a trip;
  • Financial information, e.g. payment information, credit card number, account details;
  • Data about your habits and preferences in relation to the use of our products and services (e.g. food preferences);
  • Data from our interactions with you, e.g. your comments, suggestions, needs collected during our exchanges with you in person at our locations and during telephone communications (call notes or call recordings), communications via email, chat, chatbot, exchanges on our social media channels and any complaints you may have made. Your connection and tracking data (e.g. collected via cookies for non-advertising or analytical purposes on our websites), online services, other applications;
  • Data about your devices (mobile phone, computer, tablet, etc.), such as IP address, technical data and unique identification data;
  • Personalised login details or security features used to connect you to our website and apps.

5. From whom do we collect personal data?

We usually collect personal data directly from you. However, we may also collect it from other sources.

Sometimes we collect data from public sources:

  • Publications/databases provided by official authorities or third parties (e.g. the Swiss Official Gazette of Commerce or the Commercial Register);
  • Websites/social media pages of legal entities or corporate clients that contain information you have disclosed (e.g. your own website or social media page);
  • Public information, e.g. information from the media.

We also collect personal data from third parties:

  • from our customers (e.g. as fellow travellers);
  • from our business partners (e.g. tour operators, service providers abroad);
  • from third parties such as credit reference agencies and fraud prevention agencies;
  • from address research service providers who are themselves responsible for collecting the relevant information in a lawful manner.

6. Who do we share your personal data with and why?

In order to fulfil some of the purposes described in this privacy policy, in particular the execution of a journey, we may share your personal data with others. These may include the following:

  • Our service providers in the destination country (e.g. agencies, tour guides, hotel reservations, transfer and excursion services), transport service providers (airlines, trains, car rental companies, etc.) and accommodation operators (hotels, hostels, etc.);
  • Processors who provide services on our behalf (e.g. IT services, logistics, printing services, telecommunications, debt collection, consulting and sales, and marketing);
  • Certain regulated professional groups such as solicitors, notaries or auditors, if this is necessary under certain circumstances (legal disputes, auditing, etc.), as well as our insurers;
  • Partners for advertising, market and opinion research;
  • Partners for assistance in the investigation of criminal offences (e.g. fraud), the assertion, exercise or defence of legal claims;

7. International transfers of personal data

International transfers from Switzerland and the European Economic Area (EEA) to a non-EEA country (third country) may involve the cross-border transfer of your personal data. In particular, you should expect your data to be transferred to the countries you are travelling to. But also to countries in Europe, the USA and worldwide where the service providers and contractors we use are located. If the EDÖB or the European Commission has recognised that a third country offers an adequate level of data protection, your personal data may be transferred on this basis.

For transfers to a third country whose level of protection has not been recognised as adequate by the EDÖB and the European Commission, we either rely on an exception applicable to the specific situation (e.g. if the transfer is necessary to fulfil our contract with you) or apply one of the following appropriate safeguards to ensure the protection of your personal data:

  • Standard contractual clauses approved by the EDPS and the European Commission;
  • Binding corporate rules.

To obtain a copy of these warranties or information about where they can be obtained, you may submit a written request in accordance with section 2.

8. How long do we retain your personal data?

We will retain your personal data for as long as necessary to fulfil our contractual obligations and comply with applicable laws and regulations, or for any other period necessary to satisfy our legitimate business interests, such as proper accounting and responding to legal claims or regulatory inquiries.

9. Data security

We use appropriate technical and organisational security measures to protect your personal data stored with us against manipulation, partial or complete loss and unauthorised access by third parties (e.g. encryption of data transmission, access controls, etc.). Our security measures are continuously improved in line with technological developments.

We take appropriate precautions to protect your data. The transmission of information via the internet and other electronic means always involves certain security risks, and we cannot guarantee the security of information transmitted in this way.

10. How you can follow the development of this privacy policy

In a world where technologies are constantly evolving, we regularly review this privacy policy and update it as necessary.

The current version published on our website applies. We recommend that you view the latest version of this document online. We will inform you of any changes via our website or our usual communication channels.