Terms & Conditions

A) SERVICE CONDITIONS

These general terms and conditions (hereinafter referred to as “Terms”) govern the use of the Service (as hereinafter defined) provided by Edgar SRL via its “Platform”, consisting of www.edgarsmartconcierge.com and www.guidemeright.com (hereinafter referred to as “Website”) and their applications for mobile devices (hereinafter referred to as “Application”), by the end user (as hereinafter defined). Website and application, hereinafter also the Platform.

The User agrees with these Conditions and undertakes to comply with them adopting one of the following behaviors:

The user undertakes not to use the Service and the Platform whether he does not agree with these conditions and to carefully read the Conditions before using the Service and the Platform.

1. DEFINITIONS

Pursuant to and in accordance with these Conditions the following definitions apply. All the terms used in the singular number also apply when used in the plural numbers and vice versa:

2. OPERATION OF THE PLATFORM AND OF THE SERVICE

DG makes available the Service that includes an online Platform with its technology intended exclusively to facilitate the interaction between Users for the creation and booking of Advertisements.

A non-registered user of the Platform may view advertisements. Nevertheless, if you want to book an Advertisement you need to register on the Platform. The booking of Internal Services is based on the association with Booking Codes. The access to the contents of DG’s Affiliates is based on the availability of Accommodation Codes. Only Users who have been entitled by DG may create Advertisements, in accordance with the rules laid down by DG.

3. REGISTRATION

The Platform and the Service are intended for adults and for private and non-professional use. Some features of the Platform and of the Service require the creation of Credentials that must be secret, personal and not transferable to third-parties.

By signing up, the user undertakes to (i) provide truthful and full data and to keep them updated; (ii) preserve with diligence one’s own User ID and password and to prevent its use by unauthorized third parties; (iii) promptly inform DG in the event that third-parties enter into possession of the credentials or use them; (iv) indemnify DG for any and all injury could arise from the breach of the preceding points.

DG has the right to not activate or suspend a user’s account whenever it considers, at its own discretion, that the user’s behavior would cause prejudice to DG or to third-parties.

You may register on the Platform by logging in with your account of a third-party website (hereinafter referred to as “Third-Party Account”). As an integral part of the feature of the Platform and of the Service, you may connect your DG Account with Third-Party Accounts in one of the following ways: (i) by providing your Third-Party Account the DG login data through the Platform or the Services; or (ii) allowing DG to access your Third-Party account under the terms and conditions of use of each of Third-Party account and without requiring DG to pay any commission or imposing on DG a limit to use third-party services. Allowing DG to access a Third-Party Account, the user agrees that DG will access, will make available and will store (where applicable) any User’s Content provided and stored in his Third-Party Account (“Third-Party User Content”), in such a way that it is enjoyable through the Platform and the Services and that shall be considered in the same way as the User’s Content within the meaning of the present Conditions.

4. ADVERTISEMENTS AND LACK OF APPROVAL

Through the features of the Platform:

  • (i) the Local Friends and the Local Providers create Advertisements of Local Providers’ Activities and Services, consisting in a detailed description of the activities and services that the Local Provider offer the Guests and of the period of services. Local Friends and Local Providers in their advertisements specify whether their proposals entail additional costs that cyeart be quantifiable in advance, and which shall be the subject to a separate agreement between the Guest and the Local Friend or the Local Provider when the proposal is used (hereinafter referred to as “Additional costs”);
  • (ii) DG’s Affiliates create advertisements of Internal Services, consisting of the description of the Internal Services that the Guests may request and book via the Platform. In addition, DG’s Affiliates choose individual categories of Advertisements and information to be provided to users who enter the Accommodation Code into the Application;
  • (iii) Users may access a customized application of DG’s Affiliate (“The Affiliate’s Application”) through which they may book Internal Services and advertisements of Service Providers.

Users agrees that DG does not perform a preventive check on Service Providers’ Advertisements. The Affiliate’s Application offers advertisements independently from DG.

5. TRANSACTIONS AND FINANCIAL TERMS

5.1 Determination of the Total Price of the yearuncement

The Advertisement Price of the Service Provider is not fixed by DG but directly by the Service Provider.

The Total Price is given by the Advertisement Price of the Service Provider and any commission costs.

The Guest is able to view the Total Price of the Advertisement before sending the booking request to the Service Provider.

5.2 Booking of the Experience or of the Local Provider’s Service and completion of the transaction

The Guest selects the Advertisement he intends to buy. At the same time, the Guest agrees to provide DG or the third-party that processes the payments (e.g. Pay pal), the billing data and the credit card data by authorizing DG or the third-party to collect the Total Price upon the booking has been confirmed by the Service Provider. The Guest agrees that DG, in the name and on behalf of the Service Provider, reserves the right in its sole discretion to (i) obtain a pre-authorization by means of his credit card for the Total Price of the Advertisement, or (ii) debit on his credit card a nominal amount in order to check the credit card. DG cyeart check any commissions charged to the Guest from his bank, concerning the collection of the Total Price by DG, and in this respect DG excludes any liability for it. In the event that the Guest is directed to a third-party for processing the payment, the latter may be subject to the terms and conditions that govern the use of the services and the acquisition of personal data of such third-party.

Il Guest invia al Prestatore di Servizi, tramite l’apposita funzionalità del Servizio presente nella Piattaforma, una richiesta di prenotazione dell’Annuncio prescelto. Con la richiesta di prenotazione il Guest autorizza il pagamento che verrà eseguito al momento della conferma della prenotazione da parte del Prestatore di Servizi.

The Guest sends the Service Provider a booking request of the advertisement he has chosen via the Service provided on the platform. Upon the request of booking, the Guest authorizes the payment which shall be executed once the Service Provider confirms the booking.

The transaction is finalized only when the Service Provider confirms the booking of the Advertisement within 72 hours from the sending of the booking, through the Service provided on the platform. Otherwise the booking request will be automatically canceled.

Once the booking is confirmed, the Service Provider undertakes to provide the Guest with the Advertisement according to the specifications and any terms contained therein. The booking confirmation is notified to the Users through the platform.

Users agree that the transactions shall be considered as binding on the date on which DG records on its IT systems the booking request, sent by the Guest and accepted by the Service Provider.

5.3 Payments

Users agree that DG is responsible for the payments due to Service Providers for the exclusive purpose of accepting payments by the Guest in the name and on behalf of the Service Provider; any payment obligation towards Service Providers shall expire with the payment of the Total Price.

The payment of the Total Price already authorized by the guest when he sends the booking request is processed by DG, or by the third-party that processes the payments, once the Advertisement booking is confirmed by the Service Provider. As a result of the crediting of the Total Price, DG shall notify the Guest about the transaction. DG shall transfer to the Service Provider making the request for such a transfer, the sums collected for the booking and concluded by at least 48 hours, deducting from the amount:

Despite the foregoing, Users accept that DG is not involved in any Transaction, but plays exclusively a role of intermediary between the Guest and the Service Provider.

Users agree that DG, in exceptional cases, is not responsible for the payments due to the Service Provider, but drives the user directly to the Service Provider, which shall in this case be solely responsible for payments.

5.4 Financial Discount

DG may offer users discounts as credits that may be used within the platform. These credits may be used by the Guest when an experience is purchased. In the event that the Guest obtains a discount, DG undertakes to notify the code and the amount of the abovementioned discount to the Service Provider so that it may (i) issue the invoice/receipt to the Guest gross of any financial discounts borne by DG, i.e. equal to the amount of the money transferred and received and (ii) specify the code and the amount of the financial discount borne by DG.

5.5 Return and cancellation Policy

Whether the Guest cancels the booking request before it is confirmed by the Service Provider, any cost will not be charged nor any Commission to Users.

Whether the Guest wishes to cancel a transaction already completed, the refund and cancelation policy which applies is the one provided by the Advertisement, in the Conditions of the Experience.

In some circumstances, DG may decide at its sole discretion, that it is necessary or better to cancel a booking made via the Platform and the Service. DG may also decide at its sole discretion to refund the Guest part of the expenses incurred as provided by the Guest Refund Policy, available at the following addresses:

6. USE OF THE SERVICES AND OF THE PLATFORM: USER’S DECLARATIONS AND OBLIGATIONS

The user is solely responsible for the use of the Platform and of the Service and undertakes not to use them, making sure that they are not used by third-parties, in such a way as to cause damage to third-parties and in any case in such a way that infringes the third-party rights, as a breach of law or of the terms of these Conditions, consequently assuming all liabilities and obliging to indemnify DG for any claims.

Whether DG discovers that the User makes use of the Platform or of the Service in such a way that breaches the applicable law or the Conditions, or in case of reports made by the public authorities or third-parties, DG may at its sole discretion, implement every useful action to limit any damaging consequences, including the suspension/cancellation of the user’s account, without prejudice to the right of DG to invoke the termination of the contract pursuant to art. 1456 of the Italian Civil Code and to require compensation for the most damage.

By using the Platform and the Service, the User undertakes not to:

  • collect and/or disclose personal data to others;
  • hide his own identity or misrepresenting the identity of a DG’s team member;
  • to carry out propaganda activities, sponsorships, advertising or business-related, activities even indirectly;
  • spread viruses or other files that might damage or prejudice the functioning of the Services or of the Software and Hardware equipment even of third-parties;
  • cause damages to third-parties or to other Users.

7. EXCLUSION OF LIABILITY

Unless otherwise stated on the platform, DG’s liabilities are limited to: (i) make available the Platform and the Service and (ii) act as temporary responsible for collecting payments by the Guests in the name and on behalf of the Service Provider.

DG is a platform aiming at encouraging the meeting between supply and demand of advertisements in which Users meet virtually to trade in Activities, Services of Local Providers, Services of Other providers and Internal Services. DG is neither responsible for the sale of the advertisement, nor for the creation and for the execution of the advertisement. These activities are exclusively attributable to the Service Provider, therefore DG is not liable towards the Guest for the failure to fulfill the obligations relating to the sale, organization and execution of the Advertisement.

Hence, DG does not assume the role of agent or mediator, nor has any liability in respect of the fulfilment of the obligations assumed by Users through the Platform and Service, since it provides solely the Service without being involved in the transactions.

DG does not verify neither the accuracy of the information provided by Users when they sign up nor the advertisements. In the light of the above, the User is solely responsible for determining the identity of other Users and the suitability of the Advertisements accessible via the Website. DG shall not be responsible for any damage or injury resulting from the interactions between Users, including by way of example, the obligations arising from Transactions, prejudice arising from the non-compliance of the Advertisement with what agreed, or for non-completion of the Advertisement.

Any reference in the Platform to the fact that a User is "Verified" or "Logged on" (or similar indications) indicates exclusively that the User completed the checkout procedure aimed at registration. These indications do not constitute any guarantee by DG on any User, on his identity and reliability, but they indicate exclusively that all the mandatory fields to register on the Platform have been filled in. In order to finalize transactions, Users undertake to adopt due diligence and to pay attention when they book and accept advertisements, and in general to the interactions among Users.

Users are aware that the Service may involve the interaction with different Users and that DG cyeart carry out a control on the topics and contents posted or shared. Furthermore, DG declines any and all responsibility in relation to advertisements and transactions completed via the Platform and the Service.

DG does not guarantee that the Platform and the Services are suitable for any person or accessible at any time or in any geographical area, but to the extent reasonably possible, shall undertake to take any necessary action to keep the Platform available and functioning Services, as provided by the present conditions. DG expressly excludes any liability for the case in which the failure of the Services and of the Platform depends on:

The Platform may contain links to other websites which are not under the direct control of DG and whose contents DG is in no way may be held responsible for. The publication of these links on the Platform by Users does not imply DG’s approval of the websites and their contents, nor does it imply any form of guarantee.

The Platform may host services provided by DG’s business partners, which are hence not under the direct or indirect control of DG and whose content, sale and execution DG is in no way may be held responsible for. The publication of the above services provided by DG’s business partners does not imply DG’s approval of its business partners’ activities, their offers and services, nor does it imply any form of guarantee.

8. USER’S CONTENTS

The User shall ensure that the contents published by himself or shared via the Platform or Service:

The User assumes all responsibility regarding the Contents he publishes, obliging to indemnify DG for any third-party’s claim in relation to the same contents.

The publication of the User’s Contents on the Platform occurs without any preventive control by DG, hence the publication does not imply any DG’s approval. DG shall not be held responsible for the User’s Contents, including those present in Advertisements and by way of example of their legality, truthfulness, correctness, respect for other industrial and/or intellectual property rights, and privacy rules. DG shall not be responsible for any loss or deletion of User’s contents.

By publishing User’s Contents on the Platform, the User grant DG a royalty-free, perpetual non-exclusive license to use the User’s Contents also, but not limited to, for business purposes.

9. WARRANTY AND ASSISTANCE

Whether the Services are free of charge, any guarantee related to the good running of the Service is excluded and in case of failure, nothing shall be due by DG to the User.

On the contrary, on payment Services the following warranty shall be applied:

Except as otherwise expressly provided, DG excludes any warranty, condition, undertaking or declaration of any kind whatsoever, express or implied, statutory or other nature or in any other way related to the Services or to the Platform, including without limitation, any implied warranty or implied terms of merchantability, satisfactory quality and fitness for a particular purpose, of conformity or resulting from any behavior, commercial use or practice.

In some Countries/some jurisdictions the exclusion of implied warranties is not allowed; consequently, the above exclusion may not apply to the User, who could hence be the owner of other rights established by law which may vary from Country to Country or in different jurisdictions.

Without limiting the generality of the foregoing, DG does not guarantee that the Services or the Platform shall meet the User’s demands or that their functioning will be uninterrupted or error-free, or that defects in the Service or in the Platform will be corrected.

10. LIMITATION OF LIABILITY

The User uses the Service and/or the Platform at his own risk.

To the fullest extent permitted by applicable law, in no event DG or its licensors, suppliers or partners shall be responsible towards the User or third-parties for any damages, either direct indirect consequential incidental special or punitive damages and loss of any kind whatsoever including, without claiming to be exhaustive, loss of profits loss of contracts business interruption loss or corruption of data, whatever the cause and regardless of the fact that it arises in contract or tort, including negligence, even in the case in which DG has been advised of the possibilities of such loss or damages.

Should a clause in these Conditions (limitation or exclusion or restriction) shall be deemed null for any reason by a competent court and DG becomes consequently liable for loss or damage whose entity may be legitimately limited, this liability, that is in contract or civil or other, may not exceed the amount of 100.000 Euros.

11. DURATION OF THE CONTRACT AND RIGHT TO WITHDRAW

The agreement between the User and DG to use the Service and/or the Platform is for an indefinite term, starting when DG approves the User’s registration.

The User may withdraw from the Conditions by deleting his registration at any time or by sending a written communication to DG via the online special function, where provided for, or by registered letter with return receipt. The notice may even be sent by telegram and e-mail, provided that it is confirmed by registered letter with return receipt within the following 48 hours.

Once the User’s account has been deleted, DG is free to delete all User’s Contents eventually in the Extranet. It is the User’s responsibility to keep a backup copy of his own contents.

12. ANY OTHER BUSINESS

12.1 Transfer of rights

The User may not assign or transfer any of the rights deriving from the acceptance of the Conditions without the prior written consent of DG.

12.2 Comprehensive Agreement

These Conditions supersede any related prior agreement, both written and oral, entered into between DG and the User and having for its object the matter referred to under present Conditions.

12.3 Communications

All communications to DG should be made to the address available on the Contacts Area.

All communications to the user shall be carried out by DG:

The notices published on the Platform will be presumed to have been received at the User’s first access in accordance with the procedure provided by DG.

12.4 Conditions, applicable law and jurisdiction

These terms and the relationship between DG and the User are governed by Italian law.

Whether the User is a consumer, he accepts the non-exclusive jurisdiction of the Italian Courts.

Whether the User is not a consumer, he accepts the exclusive jurisdiction of the court of Sassari.

All this being said, Users accept unconditionally that whenever there is no law requiring to appeal to the Court, any disputes related to interpretation, validity, execution and resolution of the present Conditions - except for the failures of pecuniary obligations that may be appealed on injunction order - shall be regulated according to Arbitration, according to standard procedure and based on the law, after recourse to the Arbitration Chamber of Milan. With reference to any non-performance of pecuniary obligations that may be appealed on injunction order, the jurisdiction concerned shall be that of Sassari.

DG reserves the right at its sole discretion, to change these Conditions, the Platform or the Service Commissions at any time and without prior notification. The use of the Platform and of the Services by the User implies full acceptance of the Terms and Conditions in its up-to-date version.

12.5 Tolerance

To be noted that DG does not require the User to comply strictly with the provisions of these Conditions and/or DG may not exercise all its rights. Nevertheless, this does not imply the loss of such rights or the waiving of rights by DG.

12.6 Integration

Should one or more provisions of these conditions were contrary to mandatory rules of the law or the public order rules, they shall be considered as non-binding and shall not affect the validity of the remaining clauses of the Conditions.

B) CONDITIONS OF SERVICE PROVIDERS’ ADVERTISEMENTS

The following are the conditions governing the provision of Advertisements by Service Providers.

Users undertake to carefully read and accept the Conditions of the Advertisements every time they carry out a transaction.

1. Definitions

Pursuant to and in accordance with the present Conditions of the Advertisements, the definitions contained in the service conditions apply, that User accepts by signing up for the Website/Application (defined therein “Conditions”).

2. Method of payment

The Guest undertakes to pay the Service provider the Total Price according to the Terms and Conditions available on the platform. Any payment alternatives to those covered by the service are expressly excluded.

The Proposal is provided at the Total Price as determined when the User chooses an Advertisement.

Advertisements may contain any Additional Costs which are not predictable when the User books a proposal, and which shall be settled directly between the Guest and the Service Provider when the Proposal is delivered.

3. Conclusion of the Transaction

None of the information contained in the Website may be considered as an offer but only an invitation.

The Transaction is considered completed when the Service Provider confirms the booking of the Advertisement chosen by the Guest.

4. Terms of supply

The Service Provider undertakes to provide the yearuncement in the agreed terms.

5. Warranty and assistance

Without prejudice to the provisions of the law relating to warranty currently in force, the Service Provider provides the User with the following warranties:

  • any discrepancies or defects of the Advertisement will be eliminated at the expense of the Service Provider or the price shall be proportionally reduced as provided for in the Guest Refund Policy;
  • the Advertisement must be published in accordance with Italian rules or those of the country in which publication takes place.

In case of need for assistance the Guest may contact the Service Provider to the contact details provided by it.

6. Right of withdrawal

Whether the Guest intends to delete a Transaction already completed, the deletion may be made on the following conditions:

  • up to 24 hours before the date scheduled for the Advertisement, the Total Price of the Proposal shall be refunded with the exception of the fixed Commission provided by the third-party that processes the payments (e.g. Pay pal);
  • less than 24 hours before the date scheduled for the Advertisement, losing any entitlement to refund of the Total Price of the Advertisement already paid.

The Service Provider may delete the Advertisement confirmed by itself with a notice of at least 24 hours with respect to the date and time of the Advertisement, and it is required to refund the Guest the Total Price of the Advertisement. In case of cancellation less than 24 hours the Guest Refund Policy shall apply.

7. Applicable law

This contract is entered into and performed entirely in Italy and is subject to the Italian law.

C) CONDITIONS FOR SERVICE PROVIDERS

1. Service Providers declare to accept the Service Conditions and the Guest Refund Policy and accept these conditions for Service Providers.

Local Friends undertake within the scope of the use of the Service and towards DG not to carry out professional activities, even whether they are enabled to pursue the profession of Guide, Tour Leader or any other similar professions recognized by current legislation.

2. Service Providers understand and agree to be held responsible for all advertisements published and declare and guarantee that the Advertisements (i) shall not infringe any third-party’s rights, and (ii) shall be in compliance with all current and applicable laws.

3. DG reserves the right at any time, at its sole discretion and without prior notice, to remove or disable access to any Advertisement for any reason or to suspend/terminate the Service Providers’ account.

4. Service Providers, following the publication of the Advertisement on the Platform, undertake to confirm or reject all booking requests of advertisements that receive from other Users within and not later than 72 hours from the request (the aforementioned period shall run from the date on which DG’s IT systems record the sending of the notification to the Service Providers). Service providers are aware that, in the absence of an explicit confirmation or refusal within the term indicated above, the booking request will be automatically canceled.

5. When the User makes a booking request through the platform, DG will share with Service Providers (i) the identity of the Guest who requested the booking, (ii) a link to the Guest’s profile page. Following the booking confirmation of the Advertisement, DG shall send the Guest and Service Providers a notice of the booking confirmation by reporting their phone contacts, which cyeart in any way be shared before using the portal.

6. Service Providers shall appoint DG to collect in their own name and behalf the payments made by the Guest. Service Providers agree that the payment made by a Guest to DG shall be considered as a payment paid directly to Service Providers; the latter undertake to make accessible the Advertisement in accordance with the agreed terms. Service Providers accept the cancellation policy and the terms of the cancellation and withdrawal referred to in the Conditions. DG is not responsible for any actions or omissions of Service Providers towards the Guest with whom it has concluded a Transaction or towards third-parties.

7. When providing advertisements, Service Providers undertake to comply with the features indicated in the booking request accepted. Service Providers expressly indemnify DG for any claim or demand of the Guest or third-party in relation to Advertisements.

8. Minimum Standards of Quality, Service Providers’ Liability and Guest Refund. Service Providers are solely responsible for the completeness and strength of the Advertisements published on the Platform as regards (i) a detailed description of the Advertisement, the expected duration, safety, Guests’ requirements, risks, the potential additional costs to be sustained on the territory, their contact information (ii) the place and time agreed for the meeting with the Guest once the Advertisement has been delivered. Service Providers undertake to make themselves available though the contact details communicated to the Guest at least one hour in advance with respect to the time fixed for the Advertisement.

9. Whether DG detects a problem (as defined in the Guest Refund Policy) in the Advertisement and, in order to settle any dispute, may decide to (i) refund the Guest for any amount up to the Total Price of the Advertisement paid by the Guest or (ii) provide an alternative Advertisement, and Service Providers accept as of now to refund DG the same amount or to waive the amount received by DG in their own name and behalf, even with reference to future cash receipts, up to the sum to be refunded. Whether DG detects more than one problem in the Advertisement, at its own discretion, DG may take any action it may deem necessary in respect of Service Providers (including, but not limited to, adversely affect the placement of advertisements, publish automatic reviews that report the previous Problems in the Advertisement, cancel future bookings, suspend or remove the advertisement/account, imposing penalties or costs required for the resolution of Problems related to Advertisements).

10. Service Providers undertake to deliver the Guest suitable documentation even showing for tax purposes, the receipt of payment, and in any case undertake to fulfill all the tax obligations on them. Service Providers understand and accept to be solely responsible for establishing (i) their tax declaration obligations and (ii) the taxes that should be included and the obligations relating to applicable taxes. Furthermore, the Service providers are solely responsible for the payment to the competent authorities of other taxes imposed. DG cyeart provide any user with tax advice.

11. DG highly recommends Service Providers to have appropriate insurance for Advertisements.

12. Service providers undertake, in order to maximize the promotion of the Service and to allow to check out any offer published on the portal, to provide a free booking and two bookings with a 50% discount. Proposals will be selected by DG among those published on the portal. Whether DG intends to request a promotion to Service Providers, it shall undertake to give at least 72-hours prior notice. DG has the right not to activate or suspend a Service provider’s account whenever it considers, at its own discretion, that the Service provider’s behavior limits the control and promotion activities related to the proposals offered via the Platform.

PRIVACY POLICY

01/06/2018

Hello and welcome to the privacy statement (the “Statement”) by Edgar Srl (“Edgar” or “we”), a company under Italian law controlled by Edgar Inc that has developed and owns the web platform published on the website www.edgarsmartconcierge.com (“DG website”), the mobile apps (the “DG Apps”) and the web platform published on the website www.guidemeright.com (“GMR website”), all together defined as the “Platform”.

Due to the nature of the services Edgar supplies, we deal with different user segments. To better understand which parts of this Privacy Policy are more relevant to you, see the following definitions below, which will be used subsequently throughout this document.

  • Host: you have an account on the DG website that you use to customize the App for your Guests.
  • Provider: you have an account on the GMR website you use to propose and sell experiences and services to Guest
  • Guest: you have downloaded, logged in and used the DG App created by the Hosts via the Platform.
  • Visitor: you visited or are randomly browsing the Platform to find out more about our offer but do not have an account on Edgar.

Edgar, via the DG website and the DG Apps, works as a Guest Management tool. It offers the possibility of accommodation operators to equip themselves with a digital concierge app by which their guests can discover and book services at their destination and request extra services to their host, who will manage the interactions with his guests through a dedicated Extranet. The GMR website, on the other hand, operates as an IT matching tool. It is a marketplace for tours, experiences and tourist services through which users can complete transactions independently. The DG website and the App DG, in particular, allow to:

  • (i) Create and customize the app of your own accommodation facility;
  • (ii) Manage interactions with guests through a dedicated Extranet, by sending automatic and non-automatic messages and a Live Chat;
  • (iii) Integrate your own account with other tourist software such as PMS and Channel Manager;
  • (iv) Ask your own host for extra services, through the app;
  • (v) Book tours, experiences and services at your destination directly on the App;
  • (vi) Access a DB of geolocated Points of Interest;
  • (vii) Send to the structure the personal data needed for the bureaucratic declaration to “Alloggiati” Web Portal by using Fast Check-in;
  • (vi) Access the "add on" services made available on the platform from time to time.

The GMR website, in particular, allows to:

  • (i) Register as a Local Friend or Local Provider to offer tours, experiences and services through the platform;
  • (ii) Register as a user (Guest) to get in touch with Local Friends and book tours, experiences and services through the platform;
  • (iii) Create a personal profile to present yourself to the Community;
  • (iv) Promote events on a specific date;
  • (v) Chat directly with other Community members;
  • (vi) Access to touristic information about the main Italian cities.

Through the Platform we collect some information about you, as a Host, Provider, Guest or Visitor (“you” or the ”User”), which is termed “Personal Data”. Personal Data can be generically defined as any information pertaining to identified individuals or individuals who can also be identified through other information - for example, through a number or an identification code - such as: name, surname or title; address; tax code; an image; a recording of an individual's voice; fingerprint; bank data; etc.

This Statement aims to provide you with all the necessary information so that you can become aware of our policy regarding the collection, disclosure and use of your Personal Data, as a User and together with the Terms and Conditions of Use (the “TOS”) constitutes the contract regulating the relations between you and Edgar.

Edgar, where you activate the Platform services through third party services (by way of example only, and not exhaustively: login via Facebook Connect), your Personal Data may be shared by such third parties

This Statement does not apply to services offered by third parties and their information processing methods. We advise you to carefully read the relevant privacy information on the websites of respective third parties in regards to how they will process information and potentially share it with Edgar.

https://www.facebook.com/policy.php

This Statement does not apply, in particular, to the collection and processing of Personal Data made by third parties other than Edgar that perform management functions within the Platform, such as “properties”: spaces reserved for a specific community that adopt the functions of the Platform for the benefit of a smaller group of people (the "Host") autonomously created by them. The Hosts are autonomous and independent of Edgar. Keep in mind, therefore, that these Hosts will be responsible for processing your Personal Data each in relation to the actual processing carried out in relation to participation in the community to which you decide to subscribe. Contractually, each Host is required by Edgar to adopt policies that are compliant with applicable privacy laws and the transferability of the Personal Data acquired and processed by them is prevented. We therefore recommend that you carefully read these privacy statements in order to understand how the information will be processed by these Communities Managers.

This Information is provided in compliance with Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “General Data Protection Regulation”). In the event that you are under 18 years of age (eighteen), or lack capacity, this Statement is addressed to the person responsible for this by the applicable Italian law, which is the only person authorised to grant the relevant express consent.

This information may be supplemented or amended in order to ensure that it is updated with respect to the law and/or adequate in respect to any technical changes made to the Platform and/or to any changes in the purposes or processing methods of the Information.

We will inform you of any changes with specific and appropriate individual notices, but we advise you to periodically check this document to stay up to date. Any updated versions, which will bear the date on which the update is carried out, will be promptly published on the Platform and will become effective immediately after publication. In particular, they will be considered fully binding upon you from the date of publication on the Platform if you do not decide to unsubscribe from the Platform.

  • 1. Data Controller, Data Processors and Data Protection Supervisors

    The data controller is Edgar Srl, with registered office in Italy, Z.I. Predda Niedda Str 2 ang Str 1 a Sassari (07100), e-mail: info@edgarsc.com, hereinafter also referred to as “Data Controller”.

    The following persons are responsible for processing (hereinafter referred to as “Operators”) for the purposes of statistical analysis, export, control and supervision to guarantee the smooth operation of the Platform:

    The detailed list of data Processors may be requested by sending a simple written request to the Data Controller at the addresses indicated above.

    Responsible for data protection (“Data Protection Officer”) is:

  • 2. Types of data processed and purpose of the processing

    2.1 Data and browsing activities

    The IT systems and the procedures used to operate the Platform may automatically acquire, during their normal operation, some Personal Data related to your browsing, such as, by way of example, the IP address, the amount of accesses, the duration of browsing, the browser used, the pages viewed, and the date and time at which access took place. Personal data relating to your browsing are collected primarily for the purpose of obtaining non-identifying statistical information about the use of the Platform and to check its correct functioning. Personal Data relating to your browsing may also be processed, after the registration necessary for the use of services accessible through the use of credentials as per Article 2.2, for:

    • (i) Profiling activities, i.e. the study and analysis of your interests and requests for the definition of individual and group profiles, after obtaining your express consent, as resulting from the check of the item "I expressly consent to the processing of Personal Data for the purposes of profiling, highlighted in bold in paragraph (i) of Article 2.1 and (ii) of Article 2.2 of the Edgar Privacy Policy". Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even in the event of consent, you will still have the right to object, in whole or in part, to the processing of your Personal Data for profiling purposes, by making a simple request to the Controller, without any formalities.

      How can we actually use your Personal Data for this purpose? We may process Personal Data related to your browsing to better understand your interests and preferences, so as to provide you with an experience consistent with these interests and preferences. For example, we may do so to provide you with access to content for which you have shown the most interest, or send you personalised offers or promotions via email and push notifications (as long as you have consented to receive our communications for advertising and commercial purposes), or offer advertising content related to your interests.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is in line with your choices, it is in our legitimate interest to look at your preferences, extrapolated from your browsing, so that you can better customise our offer.

    To carry out these operations, the Platform currently uses: (i) the Google Analytics service, a service of web analytics provided by Google that sends cookies to your device.

  • 2.1.1 Cookies

    Cookies (“Cookies”) are small text strings that are stored on your own device and which record data related to your browsing activity. These data, if the cookies are not disabled, are communicated to the website or the application that installed them each time you return to visit it.

    Types of Cookies:

    • Technical cookies: allow browsing through the website or application and using options or services. For example, they identify the session, limited access to web sections, remember the elements of an order, make the registration request or participation to an event, use the security features while browsing, and store content for audio or video broadcast. It concerns, in other words, all those Cookies necessary to satisfy the specific request that the user has made at that time and which are not used for further purposes.
    • Profiling cookies: they allow a more effective management of the advertising spaces on the website or application and allow the adaptation of advertising for relevance to the user and to prevent the user from viewing advertisements already seen. These cookies therefore perform actual profiling of user behaviour.
    • Third-party cookies: Third-party Cookies are Cookies, used by the website or application manager, but installed on the device of the user by third parties other than the operator of the website or the application. Third-party cookies are, for example, the statistical services of Google Analytics or the advertising service of Google Adsense.
    • The Platform, in particular, uses:

      • (i) Technical cookies (which store your login credentials in order to make it easier to log in) and for which your specific consent is not required;
      • (ii) Profiling Cookies that keep track of the choices you have made in the navigation and use of the Platform services, so as to ensure a personalised and easier use of the services offered by the Platform, for which your specific consent is required and which we notify to the Privacy Guarantor;
      • (iii)Third-party analytical cookies:
      • (iii)(a) concretely adopted with measures that allow you to eliminate the identifying power and not cross checked by the third party, for which your specific consent is not required;
      • (iii)(b) adopted without any measures that eliminate the identifying power, for which your specific consent is required.

      If you require more information about these cookies, and to understand how to reject or delete them, please take a look at the privacy policies listed below, using the addresses provided.

      Below is the list of Cookies used.

      Nome cookie Dominio Descrizione Durata Ulteriori informazioni
      __cfduid .tawk.to Used by the customer care chat 1 year https://www.tawk.to/privacy-policy/
      JSESSIONID, EXTSESSID www.guidemeright.com Keep the user session between the pages of the website session
      __gat, _ga, __utma, __utmb, __utmc, __utmz .guidemeright.com Stores an unique id used to gather statistical data about the user's behavior on the website 2 years https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
      _gid .guidemeright.com Stores an unique id used to gather statistical data about the user's behavior on the website session https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
      1P_JAR, NID, SSID, HSID, SID, APISID, SAPISID .google.it Third party cookie to store google maps user preferences 10 years https://policies.google.com/technologies/types?hl=en
      CONSENT .google.it Used for the consent of Google services 20 years
      DV .google.it session
      SIDCC .google.it Security cookie used to protect user's data from unauthorized access session https://policies.google.com/technologies/types?hl=en
      vuid .vimeo.com Collect data on which pages the users visit 2 years https://vimeo.com/cookie_policy
      IDE .doubleclick.net used by Google doubleclick to track user's click on ads and measure ads efficacy 2 years https://www.google.it/intl/en/policies/technologies/types/
      __tawkuuid .guidemeright.com third party cookie 6 months https://www.tawk.to/privacy-policy/
      cc_cookie_accept .guidemeright.com used to store the fact that the user accepted the cookie policy 1 year
      cc_cookie_decline .guidemeright.com used to store the fact that the user didn't accepted the cookie policy session
      PYPF .paypalobjects.com used by paypal to recognize the user and minimize the time taken for the login 30 days https://www.paypal.com/it/webapps/mpp/ua/privacy-full
      TawkConnectionTime .guidemeright.com third party cookie session https://www.tawk.to/privacy-policy/
      TawkConnectionTime .guidemeright.com third party cookie session https://www.tawk.to/privacy-policy/
      internationalization .guidemeright.com technical cookie used to store user's preferences about the webisite's language session
      mp_#_mixpanel .guidemeright.com technical cookie used by mixpanel to track the user's behavior for statistical analysis 1 year https://mixpanel.com/legal/privacy-policy/
      _hjIncludedInSample .guidemeright.com technical cookie used by hotjar to track the user's behavior for statistical analysis https://www.hotjar.com/legal/policies/privacy
      ajs_anonymous_id, ajs_group_id, ajs_user_id, mkjs_group_id, mkjs_user_id .mapbox.com technical cookie used by mapbox 6 months https://www.mapbox.com/privacy/
      • (i) Google Analytics (Google Inc.) → Identifying third-party cookies. Google Analytics uses cookies to collect and analyse information on the use behaviour of the Platform. The information collected and processed by Google Analytics allows us to prepare reports regarding the activities carried out on the Platform. We use the Google analysis tool to monitor or collect personal identification and profiling information.

        For more information, please refer to the links below: https://www.google.it/policies/privacy/partners/

        You can selectively disable the action of Google Analytics by installing the opt-out component provided by Google on your browser. We therefore invite you, where you intend to disable the action of Google Analytics, to access the link below: https://tools.google.com/dlpage/gaoptout

      • (ii) Google Adwords & Google Remarketing Cookies (Google Inc.) → Non-identifying third-party cookies The Platform may use Google Adwords and Google Remarketing technology. To help us keep track of sales and other conversions, a Cookie is added to the User's device when the user clicks on an ad. This cookie lasts 30 days and does not collect or monitor information that identifies the User. Users can disable Google conversion monitoring cookies in their Internet browser settings. To learn more about click here
      • (iii) Bing Ads (Microsoft Inc.) → Non-identifying third-party cookies
      • (iv) Facebook Ads (Facebook Inc.) → Non-identifying third-party cookies For more information on Facebook remarketing, you can visit the page https://www.facebook.com/help/1505060059715840

      • The installation of Cookies, which normally occurs automatically with most browsers, can be prevented by simply deactivating, in the functions of your browser, the enabling of cookies.

        For specific and further information about Cookies, click on the link of the browser that you usually use:

        For further information or clarifications, you can contact us by email at: info@edgarsc.com.

        If you decide not to enable Cookies, your experience on the Platform may be limited.

        You can find more information about cookies and how to manage them by consulting the site www.aboutcookies.org or by consulting the provision identification of the simplified procedures for the information and the acquisition of consent for the use of cookies..

  • 2.2 Data processed in relation to the use of services accessible through the use of credentials

    The information we collect from you varies depending on what information/access you require from us. This information may be collected via the DG and GMR Websites, the DG App, through our live chat services (on the Websites), at events/conferences or from direct contact to a member of Information Apss staff (via email/telephone). The information collected may include:

    • Name
    • Surname
    • Email address
    • Phone number
    Some Platform services are reserved for registered Users. To complete the registration process you must provide necessarily, among others, the following Personal Data:
    • Name
    • Surname
    • Email
    • Password
    • Telephone number (only for Hosts and Providers)

    How may we actually use your Personal Data for this purpose?

    Generally, we may need to use the above Personal Data, such as your email address, to set up and manage your account (for example, to send you password reminders or yearunce changes to your account details).

    What is the legal basis that allows us to process your Personal Data in this way?

    We will ask for your consent before processing your Personal Data in this way. The processing of your Personal Data is necessary to set up and manage your account. The provision of any other Personal Data required as part of the registration procedure, unless explicitly indicated as mandatory, is optional and granted entirely at your will. The Personal Data provided for the use of the services accessible through the use of credentials, together with the data communicated to us by third parties that you used to register with the Platform, may also be processed for:

    • (i) Sending communications for advertising and commercial purposes, as well as for direct sales by Edgar also referring to third party products and services, avoiding the communication of your data to such subjects. Subject to the obtaining of express consent, as resulting from the checking of the item "I expressly consent to the processing of Personal Data for the purpose of sending advertising and commercial purposes generally highlighted in bold in paragraph (i) of Article 2.2 of the Edgar Privacy Policy",your Personal Data may be used by Edgar for the purpose of sending advertising and commercial communications (marketing) and/or direct sale of products or services of its own or third parties, by e-mail, fax, telephone and any other communication technology remotely, including social media, possibly taking into account the indications you decide to provide us with by freely answering questions that will enable us to be more familiar with your requests and interests.. Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even in the event of consent, you will still have the right to object, in whole or in part, to the processing of your Personal Data for marketing and/or direct sales purposes, by making a simple request to the Controller, without any formalities.

      How may we actually use your Personal Data for this purpose? We may process Personal Data to send informational and advertising material, including of third parties; send commercial communications, including interactive ones; carry out direct sales or placement of products or services; or for all lawful purposes of a commercial nature.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is in line with your choices in this regard, it is in our legitimate interest to be able to use the Personal Data for sending commercial communications, for the purpose: (i) of offering you the services of the Platform completely free of charge; and at the same time (ii) of making Edgar economically sustainable. We are, in fact, a startup that offers services free of charge, compensating for this gratuity with the monetisation resulting from:

      • The promotion of our PRO service
      • The promotion of Host with which we make "revenue shares" on internal transactions such as registration fees or other forms of payment within the community
      • Discounts and offers on which models of "affiliate marketing" are developed
      • Sponsored initiatives in which business partners support Edgar to promote initiatives, products, opportunities and content

      (ii) Profiling activities, i.e. the study and analysis of your interests and requests for the definition of individual and group profiles, subject to your prior express consent, as resulting from the check of the box "I expressly consent to the processing of Personal Data for the purposes of profiling, highlighted in bold in paragraph (i) of Article 2.1 and (ii) of Article 2.2 of the Edgar Privacy Policy". Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even in the event of consent, you will still have the right to object, in whole or in part, to the processing of your Personal Data for profiling purposes, by making a simple request to the Controller, without any formalities.

      How may we actually use your Personal Data for this purpose? We may process Personal Data to better understand your interests and preferences, so as to provide you with an experience consistent with these interests and preferences. For example, we may do so to provide you with access to content for which you have shown the most interest, or improve and customize the Platform service, or send you personalised offers or promotions via email (as long as you have consented to receive our communications for advertising and commercial purposes), or offer advertising content related to your interests. This includes, for example, adapting our advertising to ensure that certain advertisements are visible when the public is particularly interested in watching them.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is in line with your choices, it is in our legitimate interest to look at your preferences, extrapolated from your browsing, so that you can better customise our offer.

      Additional information gathered by the Guest that use the App DG:: we can also gather information related to your device (Hardware model and version of the operating system), to your navigation (usage of the App, like the page visited but always anonymously), or to uor localization (anonymously) in order to identify and solve potential technical issues, to measure the interest generated by the contents and to provide you the most appropriate touristic information, like ordering them depending on their proximity.


      (iii) Communication of data to third parties for the sending of advertising and commercial messages (marketing) and direct sales by such third parties.. Upon obtaining your express consent, as resulting from the check of the entry "I expressly authorize that my Personal Data be communicated to [community name] for the purposes highlighted in bold in paragraph (iii) of Article 2.2 of the Edgar Privacy Policy", your personal data may be used by Edgar to communicate them to the community (as specified in point 3) for the purpose of sending advertising and commercial communications (marketing) and/or direct sale by said third parties, by e-mail, fax, telephone and any other remote communication technology, including social media. Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even where consent has been given, you will still have the right to object, in the future, in whole or in part, to the communication of your Personal Data to third parties, making a simple request to the Owner, without any formalities.

      How may we actually use your Personal Data for this purpose? If you have expressly consented that the Personal Data be communicated to [community name] for sending advertising and commercial messages (marketing) and direct sale by such third parties, your Personal Data may be transmitted to our business partners so that they can send you offers on their products or services, by e-mail, fax, telephone and any other remote communication technology, including social media. Keep in mind, however, that our business partners are responsible for the processing of data each in relation to their privacy policy.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is consistent with your choices in this regard, it is in our legitimate interest to be able to communicate the Personal Data to our commercial partners, for the purpose of: (i) offering you the services of the Platform completely free of charge; and at the same time (ii) for making Edgar economically sustainable. In fact, we are a startup that offers services free of charge, compensating for this gratuity with the monetisation of Personal Data collected, through communication to our business partners.


      (iv) Any additional purpose necessarily related to the execution of the Platform's services, as illustrated in the TOSs.

      How may we actually use your Personal Data for this purpose? We may need to use your Personal Data, if necessary, to fulfil our contractual obligations to you, for example when you have requested access to the Platform services.

      What is the legal basis that allows us to process your Personal Data in this way? If you have requested the performance of the services of the Platform, as explained in TOS, processing your Personal Data is necessary to fulfil our contractual obligations towards you.

      (v) Any additional purpose that necessarily allows us to comply with the requirements of the law regarding the protection of personal data.

      How may we actually use your Personal Data for this purpose?

      In some cases we may need to process Personal Data to comply with current legislation. For example, you may no longer wish to be contacted by us. For this reason, we keep the list of your preferences ("suppression list") so as not to contact you, if you asked us not to do so. To this end, we may need to process certain personal data.

      What is the legal basis that allows us to process your Personal Data in this way? It is our right to process your Personal Data to comply with current legislation. It is our right to process your Personal Data, for example, to maintain the "suppression list" and not to contact you if you asked us not to do so.

    • 2.2.1 Register of Objections

      The registration of your telephone numbers (the “Telephone Numbers”) in the Register of Objections allows you to cancel and withdraw any consent for telephone contacts that may have previously been granted to third parties for commercial purposes. Any consents granted after registration in the register are excluded from automatic revocation.

      In order to give effect to your rights:

      1. we provide evidence of the fact that we consult the Register of Objections on a monthly basis and update the contact lists accordingly;
      2. we will give you periodic quarterly communication via email of the subjects to whom the Telephone Numbers will be transferred;
      3. we have set up a privileged channel with our third-party business partners so that it is possible for us to report any entry in the Register of Objections made after the transfer of your Personal Data.

    • 2.3 Personal Data which you provide to us voluntarily

      The Personal Data that you provide to us voluntarily and freely on the basis of your autonomous impulse (for example sending e-mails to the e-mail addresses indicated on the Platform for the purpose of obtaining information), will be acquired by us and processed by the Data Controller. In particular, in addition to your e-mail address, necessary to reply to you, any other personal data to which the electronic communication refers or in any case contained in the e-mail message will be acquired. Such Personal Data, if different from those, possibly already in our possession and subject to explicit consent in regards to processing, as per Article 2.2, will not in any way be disclosed or communicated to third parties with respect to the owner's organisation, nor will they be used to define the profiles or personality of the data subject or for direct or indirect commercial or advertising purposes and, in any case, will be kept exclusively for the purposes of the storage of correspondence. Specifically, these are the information you might provide us voluntarily:

      1. As a Guest of the GMR website:
        1. Anagraphic and contact information
      2. As a Provider of the GMR website
        1. Anagraphic and contact information
        2. Copy of your Identification Document
        3. Copy of your Professional certification (potential)
      3. As a Guest on the App DG:
        1. Anagraphic and contact information
        2. Copy of your Identification Document
      4. As a Host:
        1. Bureaucratic and billing information
        2. Customer contact information

    • 2.4 Billing Information

      If you purchase a product from Criton we will seek additional information in order to process the transaction per the contract you have agreed to. We will seek additional information such as: (i) Card Holders postal address (for payment processing; (ii) Bank card information (in order to process the payment). Your card information will be stored securely by Stripe or Paypal on our behalf while you are a contracted customer, we can charge your card as per your wishes but we do not have access to your full card details.. You can cancel your card payments via Stripe or Paypal at any time, this may impact on the services we provide you, including the removal of your app(s) from publication.


    • 2.5 Tag and beacon

      If you complete an Action on our sites such as a form submission to send a request, to download content or sign up for a Free Trial, you will be added to AgileCRM, our CRM system, and the other tools needed to safety transfer your information. The data we capture enables us to offer the best user experience by tailoring communications to your preferences and interests. In order to do this a tracking tag will be added to all emails issued to you via AgileCRM. These tags enable us to analyse how you interact with our communications. You can opt- out of our email communications at any time.


    • 2.6 Geolocation

      The possible acquisition of data on your location will only be possible with your express consent expressed during the use of the Platform. Subject to your consent, we may use this data to provide you with services and/or advertisements available in your geographical area, based on the permissions you have given and based on the settings of your device. You can disable the geolocation function at any time, either from your personal account on the Platform or from your device settings. For more information on how to disable this service on your device, we suggest contacting the manufacturer of your device.

      How may we actually use your Personal Data for this purpose? We may process Personal Data to provide you with an experience that is more targeted to your local area. For example, we can do this by providing you with access to personalised content or promotions by geographical area.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is consistent with your choices, it is in our legitimate interest to look at your local area, so as to better customise our offer.


    • 2.7 Social Network

      We allow you or we will allow you to register and/or use our services using the account of some of the major social networks (purely by way of example and not exhaustively: Facebook). By choosing to use these services to register with the Platform, or to take advantage of our social services, you authorise us to collect your Personal Authentication Data to these social networks (e.g. your username, your login credentials - in encrypted mode -, your profile image, the country you have indicated as your residence, your hometown, your date of birth, the images and the network of your contacts, as well as all the other information that you can make available on, or through, your accounts and your activity on social networks). The Personal Data to which we have access varies depending on your privacy settings and the related consent on the aforementioned social networks. If you decide to connect the account managed by one of the above social networks to your account on the Platform - by authorising access to your Personal Data - you authorise us to acquire, process and possibly communicate the Personal Data present on these social networks, in accordance with current information and for all the specific related purposes.

      We remind you that we do not store or will not store the password of your Facebook account. If you wish to use the social features of the Platform, we warn you that we will use your username and your profile image (if you decide not to authorise the processing of some of these Personal Data, you can change these preferences directly on your personal account on the Platform).


    • 2.8 Protection of Personal Data

      We carefully protect the information in our possession related to EDGAR or our users from unauthorised access, alteration, disclosure or destruction. Specifically:

      • We provide encrypted access to our services using SSL;
      • Browsing in EDGAR solutions uses a secure channel;
      • We review our practices of collecting, processing and storing information, including physical security measures, to protect against unauthorised system access;
      • The data is saved on an architecture that allows it to be backed up daily and in the case of transfer, with prior consent, the sensitive data is encrypted with AES, MD5 or SHA2 algorithms;
      • We restrict access to EDGAR databases and systems to EDGAR’s employees and subcontractors who need them for the performance of their duties and are subject to strict contractual confidentiality obligations whose non-compliance may lead to disciplinary action or termination of contract. However, take note that the use of an open and public telematic system such as the Internet for the transmission of information increases the standard risks of any remote service.


    • 3. Categories of subjects to whom the Personal Data may be communicated and scope of data dissemination

      Unless otherwise specified in relation to the individual purposes of the processing as specified above, the Personal Data collected may be disclosed to - or otherwise communicated to - persons in charge and/or responsible (including external) of the processing, in relation to the skills and functions of each, in order to meet the aforementioned purposes or to implement specific regulatory and/or contractual obligations.

      Your personal data may also be brought to the attention of the following subjects or of the following categories of subjects, to the extent that this is necessary for the fulfilment of regulatory and/or contractual obligations:

      1. The Apps developed by Edgar are associated with an entity that provides services to the users of the App DG. This entity can be a Hotel, Apartment or another that has built and published an App with the platform. By accepting Edgar terms of use and privacy policy, you are consenting to these entities having access to the user data only in the context of the services provided by these entities through the respective App, and the personal data of the users aren’t sold to third parties or used for Marketing purposes without your consent. The personal data of the users are deleted or anonymised after the guest’s check-out or after the data expiration period applied by Edgar (see Data retention period). We may share anonymised information, that is, information that doesn’t contain personally identifiable information, publicly and with our partners, including information to show trends in relation to the general use of our services
      2. Providers that you book through the Platform, only in order to facilitate the meeting between the parties for the providing of the service;
      3. with the services we use to build the Guest solution: the Platform is built using third-party services for software development, software hosting, component access, frameworks, and service access APIs.The entities that we use for this purpose are identified here and don’t have access to users’ personal data or authorization to access them:
        • Amazon - Solution development and hosting support;
        • Google - Solution development and hosting support;
        • Apple - Support for iOS Apps hosting;
        • Crashlytics - Solution development support;
        • Twilio - Support for sms and VoIP calls, not having access to the identification of the users who make the calls;
      4. our authorized employees and/or collaborators who provide assistance and consulting services in the areas of administration, product, legal advice, Customer Service and IT systems, as well as the personnel in charge of maintaining our network and our hardware and software equipment;
      5. our third party service providers who process personal data on our behalf and under our direction for the above purposes acting as data processors, such as those providing the Company with IT and hosting services, call centers and customer support, services analytical and administrative, etc.;
      6. payment service providers and financial institutions (e.g. for chargeback, fraud detection and preventive purposes) acting as independent data controllers;
      7. the social platforms with which we have a commercial collaboration, if it is expressly requested by the User and/or the Customer (e.g. when using methods of identification through social media);
      8. the competent authorities, if it is prescribed by the regulations in force;
      9. the competent authorities and third-party authorities empowered by law, when this is necessary in order to enforce our terms of use and to protect and defend our rights or our property or the rights and property of third parties;
      10. third parties who receive data (e.g. business consultants, professionals in the service provisioning of adequate audit in fiscal matter (“due diligence”) or that estimate the value and capabilities of the business) if necessary in relation to sales of our business or its assets (eventuality in which the data will be communicated to our consultants and consultants of any potential buyer and they will be transferred to the new owners).

      Your Personal Data may then be communicated to companies, which Edgar may contact for the implementation of operations necessary for the performance of the provisions you have received and for the provision of the services requested.

      With your express consent, your Personal Data may be transferred to third-party companies of our commercial partners for their processing for commercial and advertising purposes. These third-party companies will act as independent data controllers, taking all responsibility for the content of their advertising and compliance with the law on the processing of personal data, appointing any data controllers, in the event that they outsource the processing of your data. The commercial communications that may be sent to you via the web, post, e-mail, telephone (sms, mms, telemarketing) may concern the following product categories, concerning processing by third-party companies belonging to the following sectors:

      1. Communications: communications and technology products and services, etc.;
      2. The financial and banking sector: financial entities, insurances, investment, social security, etc.;
      3. Leisure Time: pay TV, editorials, tourism, sports, collecting, photography, pastime, games, transport, navigation, tourism (hotels, tour operators, travel agencies, airlines, etc.), aerospace, publishing, gardening, hobbies, raffles, competitions, collectibles, photography, entertainment, communication and entertainment, art, music, etc.;
      4. Distribution and trade: electronics, information technology, image and sound, fashion, accessories, clothing, textiles, bazaars, cosmetics and sanitary, chemical, pharmaceutical and bio-technology, agro-food, supermarkets, beverages, office equipment, furniture, etc.;
      5. Automotive: products and services related to cars, industrial vehicles, cycles and motorcycles, trucks, mechanics and metallurgy, etc.;
      6. Energy and water: products related to electricity, hydrocarbons, gas, water and utility, etc.;
      7. NGOs and associations: products and services related to non-profit organisations, foundations, etc.;
      8. Education, training, education, university, etc.;
      9. Communication and services: advertising, marketing, events, consulting, advertising, PR agencies, advertising agencies, media centres, telecommunications, market research, etc.;
      10. Ecology and environment;
      11. Building, civil engineering and real estate products/services: construction, decoration, home, design, real estate agencies, etc.;
      12. Exhibitions and events, etc.;
      13. Information technology, Internet, e-commerce sites, etc.;
      14. Casino with Italian administrative license (aams), etc.;
      15. Political communications.

      As of now, we would like to point out that your Personal Data communicated to third-party companies may be used by such third-party companies as provided for in their respective independent statements. In some cases these third-party companies, as independent data controllers, may prefer to contact you directly to inform you in detail about how they will process your Personal Data, what opportunities they have in store for you and how to exercise your rights in this regard. These third-party companies may retain the data communicated for the purpose of sending advertising and commercial communications (marketing) and/or direct sales, by e-mail, fax, telephone and any other remote communication technology, without prejudice to your right to oppose the processing for these purposes at any time, by making a simple request without any formalities to the relevant data controller.

      The disclosure of your Personal Data to these third-party companies is based on contracts between us and these third-party companies, for which that an updated list of such third-party companies is always available on this page.

      In communicating your Personal Data to such third-party companies we will always take care to process your Personal Data according to the principles of lawfulness and fairness, respecting the security parameters required by law.

      None of your Personal Data will be subject to voluntary disclosure where not expressly authorised by you.


    • 4. Processing Method

      The Personal Data held for the purposes set out above is processed by us, in a lawful and correct manner, by the prevalent use of automated or semi-automated tools.


    • 5. Optional provision of data, consent and consequences of refusal

      Except in the cases in which the acquisition of Personal Data is deemed necessary for the purposes of using the services you have requested, the provision of any other Personal Data is entirely optional.

      Failure to provide consent for profiling activities, such as the study and analysis of your interests and requests for the determination of individual and group profiles referred to in Point 2.2 (ii) will not have any detrimental consequences for you, but your experience on the Platform may be limited, by virtue of the fact that it will be impossible for the members of the communities to which you belong to discover the skills and interests you are interested in making available and we will no longer be able to personalise the contents shown in the platform and in the notifications (that includes status shares, events, projects, job offers and any high content) in line with your interests and skills.


    • 6. Duration of the preservation of your personal data

      In accordance with applicable legislation on the protection of personal data, your Personal Data is stored for the period of time strictly necessary for the fulfilment of our obligations and for achieving the purposes for which it was collected. When we no longer need to use your Personal Data, we will remove it from our systems and records and/or take appropriate steps to anonymise it so as to prevent you from being identified (except where we need to keep this data in order to comply with our regulatory obligations).

      If you have given us consent for the processing of your Personal Data for profiling and/or direct advertising purposes in the absence of your explicit new consent to be expressed near the approach of the following specific deadlines, we will delete your Personal Data processed for profiling purposes within 12 months of registration, while if it is processed for direct advertising purposes, then within 24 months of registration.


    • 7. Rights of the data subject

      You have the right to request details about the Personal Data we process, and to revoke your consent to its processing, to correct or delete it and not to be contacted if you have not requested this.

      1. The right to access your Personal Data

        You can request access to your Personal Data by contacting us through the contact details at the foot of the page. The file containing your Personal Data is usually made available within 10 days. It will however be made available no later than 30 days. On occasion, we may be in the position of not being able to consent to access to your Personal Data (for example, if access unreasonably damages someone else's privacy or endangers someone's security). In this case we will provide you with a formal and explicit explanation of the reason for this impossibility. In some cases, we may also charge you an administrative fee to provide access to your Personal Data. Any fees will be reasonable and before we provide access to your Personal Data we will notify you to obtain your consent. If you request a copy of your Personal Data using electronic means, such as email, we will provide you with a copy of your data in electronic format, unless you request otherwise.

      2. The right to modification or cancellation/deletion of your Personal Data

        If you have an account, you can access this account to modify or delete your Personal Data. If you have trouble updating or deleting your data, you can still send an email with your request to info@edgarsc.com and we will solve the problem as soon as possible.

        In the case of exercising the right to be forgotten, we will inform our business partners and any other parties to whom the Personal Data has been communicated of your request.

      3. The right to object to the processing of your Personal Data

        You have the right to ask us to stop processing your Personal Data, even if such processing is necessary for our legitimate interests (for example, when processing is necessary for the commercial purposes we intend to achieve), including for the data we use to send you personalised offers, product recommendations and similar communications. You also have the right to ask us to stop processing your Personal Data for direct advertising purposes. However, we will only send you advertising communications if you have given us your prior express consent. Should you change your mind, you can easily unsubscribe from our advertisements at any time by following the instructions included in them. If you have given your consent to receive offers from our business partners, they are responsible for your rights, including the right to opt-out of receipt of their offers. However, you can opt-out of receiving such offers from third parties at any time by logging into your account and changing your settings. If you have already agreed to receive such offers, your Personal Data will cease to be transmitted to our business partners from the day your request is processed.

      4. The right to have your Personal Data transmitted to another organization (so-called. Portability of Personal Data)

        In regards to the processing of your Personal Data on the basis of your consent or for the performance of a contract, you have the right to request that we provide you with the data concerning you and held by us in a structured format, commonly used and legible, as well, where technically possible, to transmit this data directly to another organisation.

      5. Complaints

        If you believe that the applicable law on the protection of personal data has been breached, you have the right to file a complaint to the Local Data Protection Authority of the European Economic Area (“EEA”).

        The local authority for the protection of personal data will be different depending on the country in which you are located. In the annex to the Privacy Policy, you can find a list of the local authorities concerned with the protection of personal data in the countries of the EEA in which we operate.

        You can exercise the rights mentioned above at any time, by sending us a simple request via e-mail.

      Physical location of Personal Data

      Your Personal Data is stored in the European Economic Area ("AEE"). Specifically, your Personal Data is stored on an Amazon Web Service and/or Google Cloud server machine, located respectively in Ireland and in the Netherlands. The Data may in any case be transferred and stored in a location outside the EEA where these countries are deemed by the European Commission capable of guaranteeing an adequate level of protection. Your personal data may also be processed by staff working outside the EEA, that works for us or for one of our service providers. We will make all reasonable efforts to ensure that your Personal Data is processed in a secure and consistent manner with the Privacy Policy and applicable personal data protection laws, including, if applicable, by adhering to European standard contract terms (or equivalent measures) with legal entities outside the EEA in receipt of personal data.


    • 9. How can we be contacted?

      If you have any questions or concerns about how we process your Personal Data, or you wish to stop the processing or would like to request a copy of this data, please contact us at info@edgarsc.com. Include your reply address when you write to us.