Privacy
Policy
1. General Information
This Privacy Policy describes how personal data is processed for users visiting the website https://www.bbcalagonone.com (hereinafter, the "Site"), owned by ZOSO TECH di Lucio Occhipinti, based in Via Fontana di Scribar 24, 6760 Faido (Switzerland).
The Data Controller is based in Switzerland. Processing is carried out in compliance with the Swiss Federal Act on Data Protection (FADP) and its Ordinance (DPO), in force since 1 September 2023.
The EU Regulation 2016/679 (GDPR) also applies, because the Site offers its services to people located in the European Union (Art. 3(2) GDPR). The two frameworks coexist: where they differ, the Data Controller applies whichever is more favourable to the user.
2. Data Controller
Controller: ZOSO TECH di Lucio Occhipinti
Address: Via Fontana di Scribar 24, 6760 Faido (Switzerland)
Email: occhipintilucio@gmail.com
Phone: +39 366 893 3266
3. Types of Data Collected
3.1 Browsing Data
The computer systems and software procedures used to operate the Site acquire, during normal operation, certain data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified individuals, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes:
- IP addresses;
- URIs (Uniform Resource Identifiers) of the requested resources;
- Time of the request;
- Method used to submit the request to the server;
- Size of the file received in response;
- Numerical code indicating the status of the response given by the server;
- Other parameters relating to the user's operating system and computing environment.
3.2 Data Provided Voluntarily by the User
The optional, explicit and voluntary sending of email to the addresses shown on the Site results in the subsequent acquisition of the sender's address, necessary to reply to requests, as well as any other personal data included in the message. In particular, we collect:
- First and last name — to identify the customer;
- Phone number — for urgent communications and confirmations;
- Email address — to send confirmations and information;
- Booking details — boat type, period, number of people;
- Message — any specific requests.
4. Purposes and Legal Basis for Processing
| Purpose | Legal Basis | Retention Period |
|---|---|---|
| Responding to requests for information (contact form, email, WhatsApp) | Performance of pre-contractual measures (Art. 6(1)(b) GDPR) | 12 months from last contact |
| Handling the booking and passing the data to the operator providing the service | Performance of a contract (Art. 6(1)(b) GDPR; Art. 31(2)(a) FADP) | 10 years (tax obligations) |
| Compliance with legal obligations (invoicing, tax filings) | Legal obligation (Art. 6(1)(c) GDPR) | 10 years |
| Sending marketing communications (only with explicit consent) | Consent (Art. 6(1)(a) GDPR) | Until withdrawn |
| Anonymous statistical analysis (service improvement) | Legitimate interest (Art. 6(1)(f) GDPR) | Anonymised data |
5. Cookies
The Site uses cookies and similar technologies to ensure its features work correctly and to improve the browsing experience. For further details, see our Cookie Policy.
6. Recipients of the Data
Personal data may be shared with:
- The partner boat operator providing the service at sea — name, number of people, date and booked service, in order to organise the trip from Cala Gonone;
- PayPal (Europe) S.à r.l. et Cie, S.C.A. (Luxembourg) — to collect the deposit and online payments;
- Hosting and email providers — for the technical operation of the Site;
- WhatsApp (Meta group) — where communication with the customer takes place on that channel;
- Google Ireland Limited — for advertising measurement (Google Ads);
- Affiliate partners (Booking.com, GetYourGuide, Trip.com, eBay, Travelpayouts, Click&Boat) — limited to the data you enter into their search and booking tools, as described in the Cookie Policy;
- Tax and administrative authorities and accountants — to comply with legal obligations.
Data is never sold or otherwise disseminated to third parties.
6.1 The role of the boat operator
The Data Controller acts as an intermediary: the service at sea is provided by the partner boat operator, who enters into the rental or carriage contract with you. For this reason the operator is neither a mere recipient nor a processor acting on the Data Controller's behalf: it is an independent data controller, using your data for its own performance and answering for it directly, under its own privacy policy.
The Data Controller is responsible for taking the booking, collecting the deposit and passing to the operator only the data needed to organise the trip; for any later processing carried out by the operator you may contact it directly, and the Data Controller will provide its contact details on request.
6.2 Transfers abroad
The Data Controller is based in Switzerland, therefore outside the European Union: data collected through the Site is also processed in Switzerland. The European Commission recognises Switzerland as providing an adequate level of protection, so transfers from the EU require no additional safeguards.
Some providers are based in the United States. Such transfers rely on the adequacy decisions in force: the Swiss-U.S. Data Privacy Framework, recognised by the Swiss Federal Council on 14 August 2024 and effective from 15 September 2024, for flows from Switzerland, and the EU-U.S. Data Privacy Framework for flows from the European Union, both limited to certified companies. For non-certified providers the Data Controller relies on standard contractual clauses (Art. 16(2) FADP, Art. 46 GDPR).
7. Data Subject Rights
Under Articles 25–28 and 32 of the FADP and Articles 15–22 of the GDPR, you have the right to:
- Access — obtain confirmation of whether your data is being processed and access it;
- Rectification — request correction of inaccurate data;
- Erasure — request removal of your data (the "right to be forgotten");
- Restriction — obtain restriction of processing in certain circumstances;
- Portability — receive your data in a structured format and transmit it to another controller;
- Objection — object to processing for legitimate reasons;
- Withdrawal of consent — at any time, without affecting the lawfulness of processing carried out prior to withdrawal.
To exercise your rights, you may contact the Data Controller at occhipintilucio@gmail.com or by phone at +39 366 893 3266.
If you believe the processing breaches the law, you may contact the Federal Data Protection and Information Commissioner (FDPIC), the authority competent for the Swiss Data Controller (www.edoeb.admin.ch).
If you are located in the European Union you may alternatively lodge a complaint with the supervisory authority of your country of residence; for Italy, the "Garante per la protezione dei dati personali" (www.garanteprivacy.it).
8. Data security
The Data Controller applies technical and organisational measures adequate to protect data against unauthorised access, loss and alteration, as required by Art. 8 FADP, Art. 3 DPO and Art. 32 GDPR: encrypted HTTPS connection on every page, credential-protected access to the booking management areas, and time-limited retention as set out in the table under point 4.
9. Data breaches and automated decisions
In the event of a data security breach entailing a high risk to your rights, the Data Controller notifies the FDPIC under Art. 24 FADP and, where the conditions of Art. 33 GDPR are met, the competent European authority within 72 hours, also informing the individuals concerned.
The Site carries out no high-risk profiling and no automated individual decisions producing legal effects concerning you (Art. 21 FADP, Art. 22 GDPR). The automatic quote calculator decides nothing about you as a person: it applies the published rates to the service and number of participants you selected.
10. Changes to this Privacy Policy
The Data Controller reserves the right to make changes to this Privacy Policy at any time, publishing them on this page. We therefore invite you to check this section periodically. Changes take effect from the date of publication.
11. Contact
For any question regarding the processing of personal data, you can write to:
BBCalaGonone
c/o ZOSO TECH di Lucio Occhipinti
Via Fontana di Scribar 24, 6760 Faido (Switzerland)
Email: occhipintilucio@gmail.com
Phone: +39 366 893 3266
