Privacy policy

This is a translation: in case of differences, the Italian text prevails. Italiano

Last updated: October 27, 2026

Data controller

Exclusive Journeys di Reitano Giovanni Igor
Head office: Viale San Teodoro 12, 95121 Catania (CT)
VAT no. 06285870876
Email: info@exclusivejourneys.it
Phone: +39 329 615 9238

What data we process

Browsing data: IP address, browser and device type, pages visited, date and time. They are collected automatically by the systems that run and protect the website.
Form data: full name, email, service, number of people, notes and requests, ship, date and times of the port call, pickup location, child seats and, if you indicate it, that a wheelchair user is traveling in the group.
WhatsApp messages: your number, your profile name and what you write to us, including attachments.
Emails and phone calls: your email address or your number, and what you write or say to us.

In your messages, write only what the request requires: apart from the wheelchair, if any, no health data or other special categories of data, such as religious beliefs or political opinions.

Why we use the data and on what legal basis

For each use, we state the legal basis, that is, the point of Art. 6(1) GDPR that permits it.

Responding to your requests and, if you ask, preparing a quote or an offer for you: pre-contractual measures taken at your request (point b).
Organizing the trip of a wheelchair user, if you indicate it in the form: this is health data, which we use only for this purpose and with your explicit consent, given by ticking the box (Art. 9(2)(a) GDPR).
Managing the contract arising from the request: performance of a contract (point b).
Responding to other messages, for example a report or a job application: legitimate interest in replying to those who write to us (point f).
Complying with legal obligations, for example tax and accounting obligations: legal obligation (point c).
Protecting the website from abuse and automated programs: legitimate interest in security (point f).
Asserting or defending a right: legitimate interest (point f).

Mandatory and optional data

Providing your data is your choice: without the data we need, however, we cannot reply to you.

In the form, you must fill in your full name, email, service and number of people; the other fields are optional.

The request data are necessary: without them, we cannot organize or confirm the service.

When we ask for your consent, giving it is optional: if you say no, the website and the service work all the same.

How and for how long we keep the data

We process the data with IT tools and, when necessary, on paper. Only authorized persons can see them, and we protect them with appropriate security measures.

Browsing data are kept by the provider hosting the website for as long as security requires, according to its own rules.
Requests and messages that do not lead to a contract are kept for as long as needed to reply and follow the negotiation, and in any case no longer than 6 months from the last contact.
If a contract arises from the request, we keep the data for its entire duration and then for 10 years, as the law requires for accounting and tax records (Art. 2220 of the Italian Civil Code).

Who receives the data

The data are not sold or disclosed. Only the following parties may receive them, each for its own part:

OnlinePerTutti.com (T.H.K. Consulting Limited, Hong Kong), which built and manages the website: it processes the data on our behalf, solely for the technical management of the website;
Cloudflare, Inc. (United States), which hosts and protects the website and provides the technical tools described on this page: it processes the data on behalf of OnlinePerTutti.com, as its provider;
WhatsApp Ireland Limited, if you write to us on WhatsApp: it processes the messages as an independent controller (WhatsApp privacy policy);
the accountant and other advisers, banks and public authorities, when required by law or by the contract.

Data outside the European Union

Some of the providers listed are based outside the European Union, for example in the United States, and may process part of the data there. They do so with the safeguards provided by the GDPR (Arts. 44-46):

for US companies that participate in the EU-U.S. Data Privacy Framework, the European Commission's adequacy decision of July 10, 2023 (Implementing Decision (EU) 2023/1795);
in other cases, the standard contractual clauses approved by the European Commission (Implementing Decision (EU) 2021/914).

OnlinePerTutti.com (T.H.K. Consulting Limited) is based in Hong Kong, which is not covered by an adequacy decision of the European Commission. The data are stored on the systems of the providers listed above: T.H.K. Consulting Limited accesses them only for the technical management of the website, on our behalf.

For information about these safeguards, or a copy of them, write to info@exclusivejourneys.it.

Your rights

At any time, you can ask us:

to see your data and receive a copy (access, Art. 15 GDPR);
to have them corrected or completed (rectification, Art. 16);
to have them erased, when they are no longer needed or the law does not require us to keep them (erasure, Art. 17);
to restrict their use (restriction, Art. 18);
to receive them in a machine-readable format, to take them elsewhere (portability, Art. 20);
to object to use based on our legitimate interest and, always, to promotional use (objection, Art. 21).

If you have given us your consent, you can withdraw it whenever you wish: withdrawal does not affect what we did before (Art. 7(3)).

To exercise your rights, write to info@exclusivejourneys.it. We will reply within one month. In more complex cases, this period may be extended by a further two months: if so, we will tell you within the first month (Art. 12(3)).

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you (Art. 22).

Complaint to the Garante

If you believe that your data are being processed in a way that does not comply with the GDPR, you can lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority), Piazza Venezia 11, 00187 Roma, www.garanteprivacy.it (Art. 77 GDPR).

Which cookies and similar tools the website uses, and how you can manage them, is explained in the cookie policy.

Changes to this policy

This policy may change, for example if the website adds a feature or a regulation changes. The version in force is always this page, with the date at the top.