Privacy notice

1. Data controller

The data controller is Trinova S.r.l.s., trading as Weltweg, registered office Via Sant’Efisio 24, 09028 Sestu (CA), Italy, VAT no. 04201390921. For any question about your data or to exercise your rights, write to hello@weltweg.com or by post to our registered office.

We have not appointed a data protection officer (DPO), because our business does not fall within the cases in which art. 37 GDPR makes one mandatory.

2. Where the data come from

You give us almost all the data yourself: when you write to us, use the trip configurator, accept a proposal, fill in the “My trip” area or sign up for the newsletter. Some data about other people reach us from the lead traveller, who enters the names and details of fellow travellers, or from a traveller who names an emergency contact: so we ask whoever enters them to inform the people concerned and show them this page.

We receive other data from third parties only as far as the service requires: from Stripe the outcome of card payments, from our bank the credit of bank transfers, from travel suppliers the booking confirmations.

3. What data we process, why and on what basis

For each activity we state the data, the purpose and the legal basis, i.e. the reason that makes the processing lawful under art. 6 GDPR (and art. 9 for health data).

Browsing and website security

Data: IP address, date and time, page requested, browser and operating system, any errors. Requests pass through Cloudflare’s content delivery network, which protects the website from attacks, before reaching our servers. To limit abuse of forms and of logins to the client area we keep only a fingerprint of the IP address, i.e. a code from which the address cannot be derived. Why: to run the website, defend it against attacks and unauthorised access, and find faults. Basis: legitimate interest in the security of the service (art. 6(1)(f)).

Quote requests, contacts and configurator

Data: name, email, telephone, language, message and details of the trip you would like (period, length, participants, budget, interests), when you write to us from the website, use the configurator, email us, call us or message us on WhatsApp. Together with the request we record the page you arrived from and whether you came from a campaign (parameters such as utm_source or gclid), which your browser keeps only for the duration of the visit. Why: to reply, prepare quotes and proposals, and understand which channels bring us enquiries. Basis: pre-contractual steps taken at your request (art. 6(1)(b)); for the source of the visit, legitimate interest in assessing our channels (art. 6(1)(f)).

Proposal, contract, booking file and “My trip” area

Data: first name, surname, email and telephone of the lead traveller; first name, surname and age group of each participant; content of the proposal and of the contract; messages and change requests; the record of acceptance (date and time, typed name, ticked boxes, version of the terms, IP fingerprint, sha256 fingerprint of the document); logins to the area (date, IP fingerprint, browser), the technical session cookie and the single-use tokens of the login links sent by email. Why: to conclude and perform the contract, prove how and when it was concluded, and protect the area against unauthorised access. Basis: performance of the contract (art. 6(1)(b)), legal obligations (art. 6(1)(c)) and legitimate interest in proving the contract and in security (art. 6(1)(f)).

Traveller data for performing the trip

Data: type, number, expiry and nationality of the travel document, date of birth, name, telephone and relationship of the emergency contact, dietary preferences. Why: to issue flight tickets, park permits and insurance policies, book accommodation and local services, and handle an emergency. Basis: performance of the contract (art. 6(1)(b)) and, for checks required by border authorities and carriers, legal obligations (art. 6(1)(c)).

Health data (allergies, intolerances, medical conditions, assistance or mobility needs) are a special category of data. We process them only if the person concerned gives explicit consent in the area, through a separate box (art. 9(2)(a)), and only to pass them on to the suppliers who need to take them into account. In the dietary preferences field please state only the preference (for example vegetarian or vegan): anything relating to health belongs in the dedicated field, protected by consent. Consent can be withdrawn at any time in the area or by writing to us; withdrawal does not affect the past, but may prevent us from adapting the trip to your needs. In an emergency where the person concerned cannot give consent, we may pass the necessary data to rescuers to protect their life (art. 9(2)(c)).

These data are stored encrypted, only the staff working on the booking can see them, every access is logged and they are deleted automatically 30 days after return.

Payments

Data: amount, date, instalment and payment method; for cards, the outcome, card type and last digits that Stripe gives us; for bank transfers, the payer’s name, bank, date of credit, transaction reference and payment reference. You enter your full card details on Stripe’s page and they never reach our servers. Why: to collect deposit and balance, issue receipts, and handle refunds and disputes. Basis: performance of the contract (art. 6(1)(b)) and legal obligations (art. 6(1)(c)). Stripe also processes card data as an independent controller, for its own legal obligations and to prevent fraud, under its own privacy notice.

Invoicing and accounting

Data: first name and surname or company name, tax code, VAT number, address, recipient code or certified email address, amounts and dates of payments, which you give us when accepting the proposal. Why: to issue the electronic invoice and keep our accounts. Basis: tax and accounting obligations (art. 6(1)(c)).

Assistance, service messages and complaints

Data: the content of your communications with us by email, phone, WhatsApp or through the area, calls to the 24-hour assistance number, reports during the trip and complaints. We also send you automatic messages about the trip: confirmations, documents, payment reminders, pre-departure notices and, after your return, a welcome-back message with an optional invitation to leave a review. Why: to assist you before, during and after the trip and to handle complaints. Basis: performance of the contract (art. 6(1)(b)), legal obligations (art. 6(1)(c)) and, for the review invitation, legitimate interest (art. 6(1)(f)).

Newsletter and messages to clients

Data: email, language, page where you signed up, version of the consent wording, date and IP fingerprint of sign-up and confirmation. You sign up only by ticking a box and confirming through the link we email you (double opt-in); every message has a one-click unsubscribe link. Why: to send you travel ideas, news and offers. Basis: consent (art. 6(1)(a)).

If you have already travelled with us, we may write to the address you gave us to suggest trips similar to the one you bought, even without a newsletter subscription (art. 130(4) of the Italian Privacy Code). You can object at any time, free of charge, through the link in every message or by writing to us. Basis: legitimate interest (art. 6(1)(f)).

Weltweg app

If you link your trip to the app with booking code and surname, the app receives the itinerary and useful contacts and stores an access token on your phone, which expires 183 days after return; our server keeps only a fingerprint of it, with the date of last use. Everything else, such as sightings, stamps or the packing list, stays on your phone. Basis: performance of the contract (art. 6(1)(b)). Details are in the app privacy notice.

Statistics and measurement

We collect basic website statistics with Umami, installed on our own server: it counts visits, page views and actions such as submitting a form in aggregate form, without cookies and without identifying you, and it respects your browser’s “Do Not Track” setting. Basis: legitimate interest in understanding how the website is used (art. 6(1)(f)).

Only if you accept them in the cookie banner do we activate the Google tag for Google Analytics (statistics) and for measuring Google Ads campaigns (marketing). Basis: consent (art. 6(1)(a)), which you can withdraw at any time from “Manage cookies”. We record your choice with a random code, the date, the page and an IP fingerprint, so that we can demonstrate it (art. 7(1) GDPR).

Protecting our rights

We may use the data needed to establish or defend a right of ours, for example in the event of a card payment dispute, a complaint or legal proceedings. Basis: legitimate interest (art. 6(1)(f)) and, for health data, art. 9(2)(f).

4. Do you have to give us your data?

No, but without some data we cannot do what you ask. Without a contact we cannot reply; without traveller and document details we cannot issue tickets, permits and policies, and therefore cannot perform the contract; without invoicing details we cannot meet our tax obligations. Health data and newsletter sign-up are entirely optional.

5. Who we share data with

Within Trinova, data are handled only by authorised and trained staff, each as far as their work requires. Outside the company we share them only with:

• travel suppliers: local ground handlers, accommodation, guides, airlines, consolidators and flight booking systems, park authorities, who receive the data needed for their services and process them as independent controllers;
• the insurer of the policy included in the trip, named in the proposal, as independent controller for managing the policy and claims;
• providers processing data on our behalf, appointed as processors under a contract (art. 28 GDPR): Hetzner Online GmbH (servers in Germany hosting website, client area, back office, email and statistics); Cloudflare, Inc. (content delivery and website protection network); a European email delivery provider (France), our email delivery service provider; the accounting firm that keeps our books, for accounts and invoices;
• Stripe Payments Europe Ltd (Ireland), for card payments, partly as processor and partly as independent controller;
• Google Ireland Ltd, only if you accept statistics or marketing cookies, and when you open the map on a trip page, which loads only after you click;
• WhatsApp Ireland Ltd (Meta group), if you message us on WhatsApp: in that case WhatsApp’s terms and privacy notice also apply;
• our bank, for transfers and refunds;
• authorities and public bodies, where required by law, and our legal advisers in the event of disputes.

We do not sell or pass on your data to anyone for marketing purposes.

6. Transfers outside the European Union

A trip to Africa can be organised only by passing participants’ data to suppliers located outside the European Economic Area, for example in Tanzania, Kenya, Madagascar or the other countries on your itinerary, and to the airlines that carry you. For many of these countries there is no European Commission adequacy decision: the transfer takes place because it is necessary to perform the contract you requested (art. 49(1)(b) GDPR) and concerns only the data essential for each service.

Cloudflare, Stripe, Google and Meta may also process data in the United States or other countries. In these cases the transfer is based on the European Commission adequacy decision for companies certified under the EU-US Data Privacy Framework (art. 45) or on the standard contractual clauses adopted by the Commission (art. 46). You can ask us for information about these safeguards at hello@weltweg.com.

7. How long we keep data

• enquiries and quotes that do not become a trip: 24 months from last contact;
• booking files, contracts, acceptance records, payments, invoices and accounting records: 10 years from closure of the booking, as required by Italian civil and tax law (arts. 2220 and 2946 of the Civil Code);
• travel document, date of birth, emergency contact, dietary preferences and health data: until 30 days after return, then deleted automatically;
• login links to the area: 7 days or until first use; area session: 30 days; app token: 183 days after return;
• newsletter: until you unsubscribe; proof of consent and of unsubscribing for 24 months afterwards;
• record of cookie choices: 24 months, to demonstrate consent;
• server technical and security logs: for as long as needed for the security and proper operation of the service, normally no more than 30 days, unless needed to investigate abuse;
• backups: kept for a limited period and overwritten on a rolling basis; deleted data also disappear from the backups at the end of the cycle.

If a dispute is pending we keep the necessary data until it is resolved. At the end of the period, data are deleted or anonymised.

8. How we protect data

Website, client area, back office, email and statistics run on servers we manage directly, at Hetzner in Germany. All connections are encrypted. Travellers’ most sensitive data (travel document, emergency contact, health data) are stored encrypted in the database, with a key kept separately, and every access by staff is logged. The internal back office can be accessed only with personal credentials and a second authentication factor; IP addresses are never stored in clear.

You enter the “My trip” area without a password, with booking code and surname or with a personal single-use link: for this reason we limit failed attempts and ask you not to share code and link with people unconnected with the trip. We make backups every night and regularly check that they can be restored. We will never ask for your card details by email, phone or WhatsApp, and we never change our IBAN by a simple message.

Should a personal data breach occur that poses a risk to you, we notify the Italian supervisory authority within 72 hours and, where the risk is high, inform you directly (arts. 33 and 34 GDPR).

9. Automated decisions

We do not take decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you, and we do not carry out profiling (art. 22 GDPR). The system’s automatic calculations, such as instalment due dates or reminders, simply apply the rules of the contract and can always be checked by a member of our team.

10. Your rights

At any time and free of charge you can ask us to:

• tell you whether we process data about you and give you a copy (access, art. 15);
• correct or complete them (rectification, art. 16); you can correct much of your data yourself in the area;
• erase them, when they are no longer needed or there is no other basis justifying their retention (art. 17);
• restrict their use while we check a request of yours (art. 18);
• provide them in a structured, machine-readable format, or transmit them to another controller, for data you gave us on the basis of contract or consent (portability, art. 20);
• stop processing based on legitimate interest, on grounds relating to your situation, and in any case stop marketing messages (objection, art. 21);
• withdraw consent already given, without affecting what was done before withdrawal (art. 7(3)).

Write to hello@weltweg.com: we reply within one month, which may be extended by two further months in complex cases, in which case we will let you know. To protect your data we may ask you to confirm your identity before replying.

If you believe the processing breaches data protection law, you can lodge a complaint with the Italian Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, or with the supervisory authority of the EU country where you live or work, or go to court.

11. Minors

The data of minors travelling with us are provided by their parents or those with parental responsibility, who also give any consent for their health data. The website, the newsletter and the app are not intended for children under 14, who should not send us data on their own.

12. Cookies and updates to this notice

Which cookies and similar tools we use, and how to change your choices, is explained in the cookie policy; you can open your preferences at any time from “Manage cookies” at the bottom of every page.

We update this notice when services, providers or rules change. The date of the last update is shown at the bottom of the page; if the changes are significant and concern a trip in progress, we also tell you by email.