Privacy Policy Newsletter 

Last updated July 2019 

We recognise the importance of protecting your privacy and your rights with regards to data protection. The Internet is a very powerful medium when it comes to transmitting personal information; for that reason, we and all other companies belonging to the lastminute.com group (“lm group”) undertake the serious task of respecting the current laws regarding the protection of personal data and the security of the same, with the aim of guaranteeing secure, controlled and confidential navigation for its users and customers who visit and/or use the Website and/or use our Comparison Service (you as a "User") or then purchase or register on our services, download our app and/or give us their consent for a specific purpose (you as a "Customer"). 

This Privacy Policy describes how we collect, use, process, and disclose your personal data in conjunction with your access to and use of our Website and services and, specifically: 

1. Who is the controller of your data?
2. What categories of your data do we collect and use?
3. Why and how do we collect your data?
4. Who sees, receives and uses your data and where?
5. How long do we retain your data?
6. What are your data protection rights and how can you exercise them?
7. Contact details of the data controller
8. Contact details of our data protection officer
9. Information about cookies
10. Privacy notice for Facebook
11. Update and old versions of this privacy policy 

It also informs you of how you can exercise Your Rights (including the right to object to some of the data handling we carry out). More information about your rights and how you can exercise them is set out in the section below. 

If you see an undefined term in this Privacy Policy (such as “Service” or “Website”), it has the same definition as in our Company contractual service conditions.

1. Who is the controller of your personal data? 

When this Privacy Policy mentions “Company”, “we,” “us,” “our” or “Data Controller”, it refers to: 

BravoNext, S.A., a Swiss company belonging to the lm group, listed in the Ticino business register under no. CHE - 115.704.228 and with registered office at Vicolo de’ Calvi 2 - 6830 Chiasso, Switzerland, which is responsible for the processing of Users’ and/or Customers’ personal data under this Privacy Policy (hereinafter, referred to as the “Company”, “we”, “us”, “our”, “Data Controller”). Furthermore, we inform you that, for compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) purposes only (Art. 27 GDPR), Bravonext has designated as its EU representative Viaggiare SRL., an Italian company belonging to the lm group, listed in the Italian Chamber of Commerce - Milano under VAT identification no. IT04403760962 and with registered office at Via Melzo 12, 20129 Milan, Italy. 

We, being an entity located in Switzerland, are subject to Swiss law regarding the protection of personal data. For that reason, we undertake to comply with the obligations imposed by the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Swiss Federal Act on Data Protection of 19 June 1992 (FADP). In the same vein, we inform our Users and/or Customers that the Decision of the Commission of 26 July 2000 in accordance with Directive 95/46/CE of the European Parliament and the Council relating to the adequate level of protection for personal data in Switzerland declared that, in Switzerland, the laws guarantee an adequate level of protection in accordance with Directive 95/46/CE. In accordance with Swiss Federal Act on Data Protection of 19 June 1992 and with Article 45 of the Swiss Federal Act on the Supervision of Insurance Companies of 17 December 2004 (FASIC) we inform our Users and/or Customers that their personal data is processed and kept by the Company in the manner and for the means as follows, in accordance with the LPD and LSA. 

2. What categories of your data do we collect and use? 

When you visit the Website and use our Comparison Service (you as a "User") or then purchase or register to our services (you as a "Customer") we collect the categories of personal data as follows:

2.1. Personal data provided by you 

• The personal data that you share with us including when you register for an account, subscribe to marketing communications and which you provide to us when using our services, downloading our app, including the information entered into our booking platform and included in your comments, reviews or messages sent via telephone to our Customer Care Team, or through the Live Chat or through social media channels.
• More specifically:                    
• When you subscribe to the personalised marketing services you may provide us with: Your personal details (email address), information about when you click on our adverts, the way you access the website, including IP address, online identifiers and browsers details. You may also provide us with your browsing behaviour or your personal interests. Please note that some of this information might be collected automatically in accordance with p. 2.2

The provision of the above personal data, where requested, is necessary for the adequate performance of the requested service and to allow us to comply with our legal obligations except when we rely on consent as legitimate basis for processing and or our legitimate interest. Without it, we may not be able to provide you with all the requested services. 

It is important that all the personal data you give us is correct and accurate. This includes, by way of example only, ensuring that we have your correct contact (including email) details at all times. 

2.2. Personal data collected automatically from our Website, from communication we send, and/or from third parties 

• We collect information about your visits to and use of the Website, such as information about the device and browser you are using, your IP address or domain names of the computers connected to the Websites, uniform resource identifiers for requests made, the time of request, the method used to submit the request to the server, the size of the archive obtained as a response, the numerical code indicating the status of the response given by the server (correct, error, etc.) and other parameters relative to the operating system and the computer environment used, the date and time that you visited, the duration of your visit, the referral source and website navigation paths of your visit and your interactions on the Website including the Services and offers you are interested in. Please note that we may associate this information with your account. See the cookies section of this Privacy Policy (9. Information about cookies) for further information on the purposes for which we collect and use this information. Please note that, your personal information may also be linked to Cookies to i.e. to collect information on how you use our product and services 
• We may use this style to also understand how you engage with communication material that we send to you, such as emails, including the action you take such as any links in them that you click on, your duration and frequency of your engagement with the email. 
• To the extent permitted by the applicable law wherein we receive additional information about you, such as fraud detection information and warnings from third party service providers and/or partners for our fraud prevention activities.

3. Why do we collect your data? 

In general terms, we use your personal data to provide you with the services you request, send you marketing and promotional communications, notify you about important changes to our Website and to deliver our content and ads which we think may be of interest to you. More specifically:

• To meet the legal, regulatory and compliance requirements and to respond to requests by government or law enforcement authorities conducting an investigation.

On which legal basis? To comply with the law (i.e. to share personal data with regulatory authorities)

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• To carry out aggregative statistical analyses on anonymised groups or to analyse identifiable individuals behaviour so that we can see how our Website, products and services are being used and how our business is performing.

On which legal basis? To pursue our legitimate interest (i.e. improving our Website, its features and our products and services)

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• To send you personalised and profiled marketing communications Only with your previous consent, to share with you via email, and on our website or third party ones (e.g. using ads) the best deals and offers on products and services we think you might find interesting because they are suited to your interests. The individualised service or the offers can be marketed by us or our partners or business partners operating in the following sectors: tourism, leisure, entertainment, high technology, fashion, decoration, consumer goods, food and beverage, finance, banking, insurance, energy, environment, communication, mass media, real estate, pharmaceuticals, clothing and textiles, education and training, energy, publications and publishing, information and communications technology, retail, sport, telecommunications and general services. For this purpose we may: - analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. - combine the information you give us via cookies with information related to your purchases and information we receive from third parties that collect your data through various means agreed by you. You can find information about third parties on this link. - analyse information about the way you engage with communication material you receive from us, such as data on when emails have been opened or to determine if you have viewed or interacted with an ad, to record the number of times you have viewed each ad, to prevent a single ad being shown to you too frequently etc. - temporarily share an encrypted version of your email address, with carefully selected partners who may combine this information with other forms of online identifiers or other personal data in order to present you with our offers cross device or cross channel, for example on social networks (Facebook, Pintrest, Instagram, twitter ). - use automated decision making to segment and target product offers based on your demands and needs. This allows us to be more focused, efficient and cost effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant. You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you. For further details, you may contact our Data Protection Officers whose details are provided in this privacy policy. 

On which legal basis? Where you give your consent  

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• To keep our Website and systems secure and to prevent and detect fraud, security incidents and other crime.

On which legal basis? To pursue our legitimate interest (i.e. ensuring the security of our Website)

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• To verify compliance with our terms and conditions and for the establishment, exercise or defence of legal claims.

On which legal basis? To pursue our legitimate interest (i.e. compliance with our terms and conditions, protection of our rights in the event of any dispute or claim) 

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• To tailor and personalise online marketing notifications and advertising for you based on the information on your use of our Website, products and services and other sites collected through cookies (please see the Cookies section of this Privacy Policy for further information). 

On which legal basis? Where you give your consent (i.e. through the cookie banner or by your browser's settings)

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Where we rely on legitimate interest as a basis for processing your personal information, we carry out an assessment to ensure that our interest in the use of your data is legitimate and that your fundamental rights of privacy are not outweighed by our legitimate interests (‘balancing test’). You can find out more information about the balancing test by contacting our Data Protection Officer at to dpo.en@lastminutegroup.com . 

4. Who sees, receives and uses your data and where? 

4.1. Categories of recipients of your data 

We share your personal data, for the purposes described in this Privacy Policy, to the following categories of recipients:

• Our authorised employees and/or collaborators that assist and advise us on administration, products, legal affairs, and information systems, as well as those in charge of maintaining our network and hardware/software equipment; 
• Our third-party service providers (including other entities of the lmastminute.com group), which process your personal data on our behalf and under our instructions for the purposes described hereinabove acting as data processors, such as those providing us with IT and hosting services and customer support, analytics and administration services etc. 
• Our business partners who are social media platforms when it is explicitly requested by you (e.g. when you share information generated from our website onto those platforms), when using social media authentication methods or downloading our App whereby you agree either with our privacy policy or with the platforms that we may share information about your online activity with these partners even when you are not logged in to the social media platform). or when these business partners that provide us with functionality capabilities request information about the specifications of the device that the App has been installed on, which they have obtained the right to do. The information you share will be governed by the social media's privacy policy. Please check clause 2.3 of this Privacy Policy for more information.
• Competent authorities when we are required to do so by the current law. 
• Competent authorities and Law and enforcement third parties when this is necessary so that we can enforce our terms of use and protect and defend our rights or property or the rights or property of any third party. 
• Third parties that receive the data (e.g. business consultants, professionals for delivering due diligence services or assess value and capabilities of the business) when it is necessary in connection with any sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners. 

The complete list of parties to which your personal data may be disclosed is available at our registered office and may be requested by writing to privacy.en@lastminutegroup.com.

4.2. International transfer of your data 

Users’ and/or Customers’ personal data is processed in at the Data Controller’s registered office (see point 1), on the lm group servers, and at the offices of other entities to which data may be provided in order to provide the services requested of the Data Controller. 

Given the fact that we are an international travel company, we also transfer your personal data to: 

• non-European Economic Area (EEA) countries offering an adequate level of data protection such as Switzerland in accordance with the “Adequacy decisions” of the EU Commission that recognises some countries as providing adequate protection;
• non-European Economic Area countries where data protection laws may be less protective than the legislation in the EEA. This happens when:
• we disclose your data to our service providers who act as data processors on our behalf that might be located in a country outside the EEA, including Morocco, Albania, UK, India and Tunisia. When such a transfer happens, we ensure that it takes place in accordance with this Privacy Policy and is regulated by standard contractual clauses approved by the European Commission as ensuring adequate protection for data subjects. Our providers, acting as data processor, may be engaged in, among other things, the fulfilment of your service request,, the provision of advertising and marketing services on our behalf.

Should you want to obtain further details about the safeguards put in place, you can contact us by writing to privacy.en@lastminutegroup.com.

5. How long do we retain your data? 

We retain your personal data for as long as is required to achieve the purposes and fulfil the activities as set out in this Privacy Policy, otherwise communicated to you or for as long as is permitted by applicable law. Further information about the retention period is available here:

DATA USED FOR MARKETING PURPOSES (CRM) 

Data used for marketing activities to customers/users subject to the consent.
Retention period: 5 years from the consent or the renewal of the consent via interaction with marketing communications

DATA COLLECTED VIA TAG 

Technical cookies 
Retention period: Max 3 years from the date of browsing on our websites

Non-Technical cookies
Retention period: Max 1 year from the date of consent

6. What are your data protection rights and how can you exercise them? 

You can exercise the rights provided by the Regulation EU 2016/679 (Articles 15-22), including the right to:

Right of access - To receive confirmation of the existence of your personal data, access its content and obtain a copy.

Right of rectification - To update, rectify and/or correct your personal data.

Right to erasure/right to be forgotten and right to restriction - To request the erasure of your data or restriction of your data which has been processed in violation of the law, including whose storage is not necessary in relation to the purposes for which the data was collected or otherwise processed; where we have made your personal data public, you have also the right to request the erasure of your personal data and to take reasonable steps, including technical measures, to inform other data controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Right to data portability - To receive a copy of your personal data you provided to us for a contract or with your consent in a structured, commonly used and machine-readable format (e.g. data relating to your purchases) and to ask us to transfer that personal data to another data controller.

Right to withdraw your consent -Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes.

Right to object, at any time - You have the right to object at any time to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement , or where we are using your data for direct marketing.  

Right not to be subject to a decision based solely on automated processing, including profiling -You can always request a manual decision- making process instead, express your opinion or contest decision based solely on automated processing, including profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you. 

You can exercise the above rights at any time by:

• Contacting us via email at privacy.en@lastminutegroup.com. 
• As for direct marketing, please note that you can also object at any time by clicking the unsubscribe link which we provide in each communication sent to you 
• As for online targeted ads and the withdrawal of your consent please refer to our Cookie section of this Privacy Policy. 

In case you exercise any of the above rights provided by GDPR, please note that we will attend your request considering the personal information held by all the companies within the lm group where BravoNext, S.A. holds, directly or indirectly, 100% of the shares. 

Your rights in relation to your personal data might be limited in some situations. For example, if fulfilling your request would reveal personal data about another person or if we have a legal requirement or a compelling legitimate ground we may continue to process your personal data which you have asked us to delete. 

You also may have the right to make a complaint if you feel your personal information has been mishandled. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Data Protection Supervisory Authority. 

7. Contact details of the data controller 

The contact details of the Data Controller of the data processing described hereinabove are: 

BravoNext, S.A., a Swiss company belonging to the lm group, listed in the Ticino business register under no. CHE - 115.704.228 and with registered office at Vicolo de’ Calvi 2 - 6830 Chiasso, Switzerland. 

8. Contact details of our data protection officer (DPO) 

Our Data Protection Officer (or "DPO") is available at: 

• dpo.en@lastminutegroup.com 
• Vicolo de’ Calvi 2 - 6830 Chiasso, Switzerland.

9. Information about cookies 

Cookies are small files which are stored on your computer, they hold a modest amount of data specific to you and allows a server to deliver a page tailored to you on your computer, hard drive, smartphone or tablet (hereinafter referred to as, “Device”). Later on, if you return to our Website, it can read and recognise the cookies. Primarily, they are used to operate or improve the way our Website works as well as to provide business and marketing information to the website owner. 

In accordance with the notice of cookie usage appearing on our Website’s homepage and our Cookie Policy you opt for and consent to the use of non-essential cookies, when you accept the cookie notice on the landing page. 

What follows is a description of the type of cookies used in the website: 

9.1 Types of cookies according to the managing entity 

Depending on what entity manages the computer or domain from which the cookies are sent and processed, there exist the following types of cookies:

• First party cookies: these are sent to your Device from a computer or domain managed by us and from which the service you requested is provided.
• Third party cookies: these are sent to your Device from a computer or domain that is not managed by us, but by a separate entity that processes data obtained through cookies.

Depending on the amount of time you remain active on your Device, these are the following types of cookies:

• Session cookies:these are designed to receive and store data while you access the Website. These cookies do not remain stored on your Device when you exit the session or browser. 
• Persistent cookies: these types of cookies remain stored on your Device and can be accessed and processed after you exit the Website as well as when you navigate on it for a pre-determined period of time. The cookie remains on the hard drive until it reaches its expiration date. The maximum time we use persistent cookies on our Website is 2 years. At this point the browser would purge the cookie from the hard drive. 

Cookies can be grouped as follows: 

a) Technical cookies: these cookies are strictly necessary for the operation of our Website and are essential for browsing and allow the use of various features. Without them, you cannot use the search function, compare tool or book other available services on our Website. 
b) Personalisation cookies: these are cookies used to make navigating our Website easier, as well as to remember your selections and offer more personalised services. When you select the use of this we may allow advertisers or other third parties to place cookies on our Website to provide personalised content and services. If cookies are blocked, we cannot guarantee the functioning of such services. 
c) Analytical cookies for statistical purposes and measuring traffic: these cookies gather information about your use of our Website, the pages you visit and any errors that may occur during navigation. We also use these cookies to recognise the place of origin for visits to our Website. These cookies do not gather information that may personally identify you. All information is collected in an anonymous manner and is used to improve the functioning of our Website through statistical information. Therefore, these cookies do not contain personal data. In some cases, some of these cookies are managed on our behalf by third parties, but may not be used by them for purposes other than those mentioned above. 
d) Advertising and re-marketing cookies: these cookies are used to gather information so that ads are more interesting to you, as well as to display other advertising campaigns along with advertisements on the Website or on those of third parties. Most of these cookies are “third party cookies” which are not managed by us and, because of the way they work, cannot be accessed by us, nor are we responsible for their management or purpose. Our Privacy Policy contains more information about the way third party cookies work, their purpose and how they are used. To that end, we can also use the services of a third party in order to collect data and/or publish ads when you visit our Website. These companies often use anonymous and aggregated information (not including, for example, your name, address, email address or telephone number) regarding visits to this Website and others in order to publish ads about goods and services of interest to you. Please note that, depending on the cookie configuration you elect, we may also use cookies to monitor your behaviour on our own and third party websites in order to determine if you have viewed or interacted with an ad, to determine if you you have purchased a product or a service following your viewing of or interaction with an ad. 
e) Social cookies: these cookies allow you to share our Website and click “Like” on social networks like Facebook, Twitter, Google+, and YouTube, etc. They also allow you interact with each distinct platform’s contents. The way these cookies are used and the information gathered is governed by the privacy policy of each social platform, which you can find in Paragraph 5 of our Cookie Policy. 

To see the list of cookies used on this Website, click here. 

The information contained in the above list of cookies has been provided by the other companies which generate them. 

These companies have their own privacy policies in which they set forth both their own declarations as well as applicable disabling systems. 

The lm group is not responsible for the contents and accuracy of third party cookie policies contained in our Cookie Policy. 

You must keep in mind that if your Device does not have cookies enabled, your experience on the Website may be limited, thereby impeding the navigation and use of our services. 

There are a number of ways to manage cookies. By modifying your browser settings, you can opt to disable cookies or receive a notification before accepting them. You can also erase all cookies installed in your browser’s cookie folder. Keep in mind that each browser has a different procedure for managing and configuring cookies. Here’s how you manage cookies in the various major browsers: 

MICROSOFT WINDOWS EXPLORER
GOOGLE CHROME
MOZILLA FIREFOX
APPLE SAFARI 

If you use another browser, please read its help menu for more information. 

If you would like information about managing cookies on your tablet or smartphone, please read the related documentation or help archives online. 

We do not install third party cookies. They are installed by our partners or other third parties when you visit our Website. Therefore, we suggest that you consult our partners’ Websites for more information on managing any third party cookies that are installed. However, we invite you to visit the following website http://www.youronlinechoices.com/where you can find useful information about the use of cookies as well as the measures you can take to protect your privacy on the internet.

10. Privacy notice for Facebook 

10.1. Facebook Custom Audiences - Facebook pixel 

We use the remarketing function “Custom Audiences” of Facebook Inc. (1601 Willow Road, Menlo Park, California 94025) or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. This function allows us to show our Users and/or Customers of our website interest-based ads when they visit Facebook (“Facebook ads”), and to analyze such Facebook ads for statistical and market research purposes, which helps us optimize future advertising. This allows us to serve more relevant advertising. 

For this purpose we use the so-called Facebook pixel for our website. 

When a User or a Customer visits our website and takes an action (for example, buying something), the Facebook pixel is triggered and reports this action. This way, we will know when a customer took an action after seeing our Facebook ad. We will also be able to reach this customer again by using a Custom Audience. Therefore, this pixel allows user behavior to be tracked after they have been redirected to our Website by clicking on a Facebook ad. This way, we will know when a customer took an action after seeing our Facebook ad. We will also be able to reach this customer again by using a Custom Audience. 

Therefore, this enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy. Such data may allow Facebook and its partners to show ads on or off Facebook. A cookie may also be stored on your computer for these purposes. 

11. Update and old versions of this privacy policy

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on our Website and update the “Last Updated” date at the top of this Privacy Policy.