Privacy Policy
Data Controller:
Italia My Golf Premium AG, Freienwilstrasse 1, CH-5426 Lengnau – Switzerland
Privacy contact email: info@italiamygolfpremium.com
1. Introduction
This Privacy Policy explains how Italia My Golf Premium AG, a Switzerland-based tour operator specializing in the organization of golf trips and travel packages to Italy for European clients, collects and processes personal data in accordance with the Swiss Federal Data Protection Act (nFADP 2023) and, where applicable, the European General Data Protection Regulation (GDPR – EU Regulation 2016/679).
2. Types of Data Collected
We collect the following categories of personal data:
2.1 Data provided directly by the user
- First name, last name, date of birth
- Email address, phone number, postal address
- Identification document details (when required for bookings)
- Payment information (partial or via external payment providers)
- Travel preferences and personalized requests
- Information required for the organization of golf trips (handicap, club membership, etc.)
2.2 Data collected automatically
- Technical data (IP address, browser type, browser language, operating system)
- Website usage data and cookies (see dedicated section)
2.3 Data received from third parties
- Accommodation providers, golf courses, airlines, or travel partners
- Payment agencies (e.g., credit card gateways)
3. Purpose of Processing
Personal data is processed for the following purposes:
- Organization and management of travel services, including:
- booking hotels, golf courses, tourist services, transportation;
- internal administrative management and responses to information requests.
- Fulfilment of contractual obligations arising from the purchase of travel packages.
- Compliance with legal obligations under Swiss and, where applicable, Italian or EU regulations (e.g., communicating guest information to local authorities).
- Service communications via email, SMS, or phone (confirmations, travel changes, customer support).
- Direct marketing (newsletters, personalized offers) — only with explicit consent.
- Statistical analysis and service improvement, using anonymized and aggregated data.
4. Legal Basis for Processing
The processing of personal data is based on the following legal grounds:
- Performance of a contract or pre-contractual measures
- User consent
- Legal obligations
- Legitimate interests of the Data Controller, within the limits of applicable law
5. Data Sharing and Transfers
To provide our services, personal data may be shared with:
- Hotels and accommodation facilities
- Golf courses and sports clubs in Italy
- Airlines, transport companies, car rental agencies
- IT providers, hosting services, and email services
- Payment service providers
- Legal or tax advisors, when necessary
Cross-border data transfers
As we operate from Switzerland and organize travel to Italy and other EU countries, personal data may be transferred:
- from Switzerland to the EU and vice versa
- from your country of residence to Switzerland
Switzerland is recognized by the European Commission as a country ensuring an adequate level of data protection.
Any transfer to non-EU countries is carried out only if appropriate safeguards are in place (e.g., Standard Contractual Clauses – SCCs).
6. Data Retention
Personal data is retained for the time necessary to:
- complete the organization and management of the trip;
- comply with Swiss or European legal obligations;
- handle any post-travel claims (generally up to 10 years according to Swiss accounting regulations).
7. User Rights
Under the nFADP and GDPR, users may exercise the following rights:
- Right of access
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restrict processing
- Right to data portability (where applicable)
- Right to object to processing
- Right to withdraw consent at any time
- Right to lodge a complaint with:
- In Switzerland: the Federal Data Protection and Information Commissioner (FDPIC)
- In the EU: the supervisory authority of the Member State of residence
To exercise these rights:
Email: [privacy contact email]
8. Data Security
We implement appropriate technical and organizational measures to:
- protect data from unauthorized access, loss, or disclosure;
- ensure secure data transmission;
- limit access to authorized personnel only.
9. Cookies and Tracking Technologies
Cookies may be used for:
- proper website functionality
- anonymous statistical analysis
- marketing — only with the user’s consent
Users can manage their cookie preferences through the banner or their browser settings.
10. External Processors
We may appoint external service providers as Data Processors, compliant with the nFADP and GDPR, under contracts ensuring adequate data protection.
11. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy periodically. The most recent version will always be available on our website.