Privacy notice
This notice explains how Aurea processes personal data of clients, website visitors and staff, in accordance with Regulation (EU) 2016/679 (GDPR).
Version 1.0 · updated 2026-09-10
1. Data controller
Data controller: [RAGIONE SOCIALE], [SEDE LEGALE], [P.IVA / CODICE FISCALE]. Privacy contact: [EMAIL PRIVACY]. Data protection officer: [DPO — se nominato]. The company details are being formalised and will be completed shortly.
2. Data we process
Contact and enquiry data: name, email, phone, country, preferred language, party size, indicative budget, travel dates, categories of interest and any free-text notes you send us.
Voice recordings and transcripts: if you choose to describe your request by voice, we record the audio and keep the transcript and the extracted details.
Account data: email, name, language, internal roles or capabilities where applicable.
Website usage data: page visited, title, referrer, language, device type, a temporary session identifier and an IP address stored only in irreversible hashed form. We use no profiling cookies and no third-party advertising tools, and we honour the browser 'Do Not Track' signal.
Internal platform usage: staff work sessions, pages visited and an operations (audit) log for security purposes.
3. Purposes and legal bases
Answering enquiries and preparing bespoke proposals: pre-contractual measures and performance of the contract (Art. 6.1.b GDPR).
Running the client area and accounts: performance of the contract (Art. 6.1.b GDPR).
Voice recording of an enquiry: explicit consent, withdrawable at any time (Art. 6.1.a GDPR).
Marketing communications and newsletter: consent, withdrawable at any time (Art. 6.1.a GDPR).
Aggregate visit statistics, platform security and abuse prevention: legitimate interest (Art. 6.1.f GDPR).
Tax, accounting and legal obligations: legal obligation (Art. 6.1.c GDPR).
4. Use of artificial intelligence
We use AI systems to transcribe voice enquiries, extract enquiry details, draft proposals and produce editorial commentary on the news we select.
AI-assisted editorial content is clearly identified as our own commentary and always links to the original source.
No decision producing legal or similarly significant effects is taken solely by automated means: every proposal is reviewed by a member of our team.
5. Recipients
Technology providers hosting the platform, database and file storage, appointed as data processors.
AI service providers for transcription and text generation, limited to the content strictly required.
Experience partners and suppliers (properties, transport, dining, services) only for the data needed to deliver the requested service.
Advisers, professionals and authorities where required by law.
We never sell or rent personal data for advertising purposes.
6. Transfers outside the EEA
Some technology providers may process data outside the EEA. Such transfers rely on adequacy decisions or on the European Commission's standard contractual clauses, with supplementary safeguards.
7. Retention
Enquiries and proposals not converted: up to 24 months from the last contact.
Completed engagements: 10 years for tax and accounting obligations.
Voice recordings: up to 12 months, unless consent is withdrawn earlier.
Visit statistics: up to 24 months in pseudonymised form.
Consent register: for the duration of the relationship and 10 years thereafter, to demonstrate the consent collected.
8. Your rights
You may request access, rectification, erasure, restriction and portability, object to processing based on legitimate interest, and withdraw consent at any time without affecting the lawfulness of prior processing.
Send requests to [EMAIL PRIVACY]: we reply within one month.
You may also lodge a complaint with the Italian Data Protection Authority (Garante, Piazza Venezia 11, 00187 Rome — www.gpdp.it) or with the supervisory authority of your country of residence.
9. Security
We apply appropriate technical and organisational measures: encryption in transit, role- and capability-based access control, an operations log, IP pseudonymisation, and access restricted to authorised staff.
10. Changes
This notice may be updated. The current version is 1.0, last updated on 2026-09-10. Material changes are notified to registered users.