隐私政策

Privacy Policy

Last updated: 21 October 2026

This policy explains what personal data Golf Breaks Italy collects when you visit our website, send us an enquiry, subscribe to our newsletter, join our Golf Breaks Club, write a review or travel with us, why we collect it, how long we keep it and what rights you have. It is written to meet the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the Italian Personal Data Protection Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018).

1. Who is responsible for your data

The data controller is Hurray! Italia, which trades as Golf Breaks Italy.

• Address: Via Alfredo Fusco 35, 00136 Rome, Italy
• Email: info@golfbreaksitaly.com
• Phone: +39 339 3478576
• VAT number: IT-11602831007
• Owner and legal representative: Jaana Merasvuo

We have not appointed a Data Protection Officer because the law does not require one for our business.

2. What data we collect and why

2.1 Enquiries through our request form or by email

What: your name, email address, phone number (if you give it), country, the dates, destinations, number of golfers and non-golfers, budget and any other details you choose to write in your message.

Why: to answer your enquiry and prepare a proposal for your golf holiday.

Legal basis: steps taken at your request before entering into a contract (Article 6(1)(b) GDPR). If you write to us for another reason, our legitimate interest in answering messages sent to us (Article 6(1)(f) GDPR).

Fields marked as required on the form are needed to answer you. Without them we cannot reply or prepare a proposal.

If you tick the box to open a free Golf Breaks Club account with your request, section 2.5 also applies.

2.2 Bookings and your trip

What: the names of all travellers, contact details, dates of birth or ages where a supplier needs them, passport or identity card details where a hotel or supplier requires them, golf handicap and home club, room and rental preferences, flight details for transfers, invoicing and payment information (we do not collect or store card details on our website), and the correspondence about your booking.

Why: to make, confirm and carry out your package travel contract, book the hotels, golf courses, transfers and other services in it, give you assistance during the trip, handle changes, cancellations and complaints, and issue invoices.

Legal basis: performance of the contract (Article 6(1)(b) GDPR); compliance with legal obligations, such as tax, accounting and package travel law, and the guest registration that Italian accommodation providers must carry out (Article 6(1)(c) GDPR).

If you make a booking for a group, please make sure the other travellers know that you are sharing their details with us and that this policy applies to them.

2.3 Health information and special requests

What: information you choose to give us about dietary needs, allergies, reduced mobility or medical assistance needs.

Why: so that hotels, restaurants, golf clubs and transfer companies can meet your needs, and so we can give you the extra assistance the law provides for travellers with reduced mobility or who need specific medical assistance.

Legal basis: your explicit consent (Article 9(2)(a) GDPR). You can withdraw it at any time, but we may then be unable to arrange the service you asked for.

2.4 Newsletter

What: your email address, your name if you give it, your preferred language and a record of when and how you subscribed.

Why: to send you news, travel ideas and offers from Golf Breaks Italy.

Legal basis: your consent (Article 6(1)(a) GDPR and Article 130 of the Italian Personal Data Protection Code). Subscribing is optional and not a condition of any booking.

Unsubscribe: every newsletter contains an unsubscribe link. You can also write to info@golfbreaksitaly.com. Withdrawing consent does not affect the lawfulness of what we did before.

2.5 Golf Breaks Club and your account

What: when you join the free Golf Breaks Club (on the Club page, in the welcome pop-up, through your account or with your request) or apply for Riserva membership: your name, email address and country; the optional details you choose to add, such as your home golf club, handicap, preferred travel seasons and interests; whether you want our news and offers by email; and, once you travel with us, your points, level and the trips that earned them. For Riserva membership we also keep your membership and invoicing details.

Why: to create and run your account, record and apply your points and rewards, confirm and invoice a Riserva membership and, only if you choose it, send you news and offers tailored to your golf.

Legal basis: performance of the membership you asked for (Article 6(1)(b) GDPR); compliance with accounting law for Riserva invoices (Article 6(1)(c) GDPR); and your consent for the optional profile details and for emails (Article 6(1)(a) GDPR). Joining is free, optional and not a condition of any booking. Your password is sent directly to the Wix member log-in system; we do not receive or store it. You can change your details, withdraw your consent or ask us to close your account at any time by writing to info@golfbreaksitaly.com. How points work is explained in the Club rules on our Club page.

2.6 Guest reviews

What: the review you write, your rating, your first name and country, the trip and when you travelled, and your email address.

Why: to check your review against our bookings and, if you agree, to publish it on our website with your first name and country. Your email address is not published; we use it only to check your booking.

Legal basis: your consent to publication (Article 6(1)(a) GDPR) and our legitimate interest in making sure reviews come from real guests (Article 6(1)(f) GDPR). You can ask us to remove your review at any time.

2.7 Using our website

What: technical data needed to deliver the website, such as IP address, browser type, device information and the pages requested, which our hosting provider processes in its server logs and security systems; your language choice and your cookie choices, stored in your own browser.

Why: to show the website, keep it secure, prevent abuse and remember your settings.

Legal basis: our legitimate interest in running a secure, working website (Article 6(1)(f) GDPR). Details are in our Cookie Policy.

The headings on our website use the Montserrat font, which your browser loads from Google Fonts. When a page opens, Google receives your IP address and basic browser details with that request. We do not use this for tracking or advertising.

We do not currently use analytics or advertising tools. If we add them in the future, they will only run after you agree in the cookie banner, and we will update this policy and our Cookie Policy first.

2.8 Legal claims and accounting

We keep booking and invoice records to meet our tax and accounting duties (Article 6(1)(c) GDPR) and, where needed, to establish, exercise or defend legal claims (our legitimate interest, Article 6(1)(f) GDPR).

3. How long we keep your data

• Enquiries that do not lead to a booking: 24 months, then deleted.
• Booking records and correspondence: for the duration of the contract and afterwards for as long as claims can be made. Under the Italian Tourism Code, claims for price reduction or damages expire 2 years after your return, and claims for personal injury or a ruined holiday expire 3 years after your return; the general Italian limitation period for contractual claims is 10 years.
• Invoices and accounting records: 10 years, as required by Article 2220 of the Italian Civil Code.
• Health information and special requests: deleted at the end of your trip, unless we need it to deal with a claim or the law requires us to keep it longer.
• Newsletter: until you unsubscribe. We keep a record of your consent and of your unsubscribe request for as long as the consent is valid and for 5 years after it is withdrawn or expires, to be able to prove it.
• Club accounts: until you close your account or ask us to delete it. Invoices for Riserva memberships are kept as stated above.
• Reviews: published until you ask us to remove them. Your email address is kept with the review record for as long as the review is published.
• Settings stored in your browser: see our Cookie Policy.

4. Who receives your data

We do not sell your data. We share it only with the people and companies who need it for the purposes above:

• Travel service providers that make up your package, such as hotels and apartments, golf clubs, transfer and car hire companies, restaurants and guides. They receive only what they need to provide their service and act as independent controllers of the data they receive.
• Our service providers (processors), who act on our instructions under a data processing agreement:
  • Wix.com Ltd. (Israel), which hosts our website and processes the data you send through our forms, member accounts and newsletter tool;
  • our email and IT service providers and our accountant, under data processing agreements.
• Google, which provides the font used for our headings and receives your IP address when the font loads.
• Insurers, if you take out travel insurance through us or if a claim is made under our liability or insolvency protection insurance.
• Professional advisers such as our accountant and lawyers, who are bound by professional secrecy.
• Public authorities, where the law requires it.

5. Transfers outside the European Economic Area

Our website is hosted by Wix.com Ltd. in Israel. The European Commission has decided that Israel provides an adequate level of data protection (Commission Decision 2011/61/EU, confirmed in the Commission's review of January 2024), so no further safeguards are needed for that transfer.

Wix, Google (which provides the website font) and our other providers may use servers or sub-processors in other countries, including the United States. Where data goes to a country without an adequacy decision, the transfer is protected by the EU-U.S. Data Privacy Framework (for US companies certified under it) or by the European Commission's Standard Contractual Clauses. You can ask us for more information about these safeguards using the contact details above.

Your trip itself takes place in Italy, so travel suppliers normally receive your data inside the EU.

6. Your rights

Under the GDPR you have the right to:

• access your data and receive a copy;
• have inaccurate data corrected;
• have your data erased when there is no longer a reason to keep it;
• restrict how we use your data in certain cases;
• receive data you gave us in a portable format (data portability);
• object at any time to processing based on our legitimate interests, and to direct marketing without giving any reason;
• withdraw your consent at any time, without affecting what we did before.

We do not make decisions about you based solely on automated processing, including profiling.

7. How to exercise your rights

Write to info@golfbreaksitaly.com or to Hurray! Italia, Via Alfredo Fusco 35, 00136 Rome, Italy. We will reply within one month. In complex cases this can be extended by two further months, and we will tell you if so. We may ask you to confirm your identity. Exercising your rights is free of charge.

8. Your right to complain

If you think we have not handled your data correctly, you can complain to the Italian data protection authority:

• Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Rome, Italy
• Phone: +39 06 696771
• Email: protocollo@gpdp.it; certified email (PEC): protocollo@pec.gpdp.it
• Website: www.garanteprivacy.it

You can also complain to the data protection authority of the EU country where you live or work, for example the Data Protection Ombudsman in Finland, the Swedish Authority for Privacy Protection (IMY) or the data protection authority of your German federal state. We would be grateful if you contacted us first so we can try to resolve your concern.

9. Children

Our website, request form and newsletter are meant for adults. We do not knowingly collect data directly from children under 14, the age at which Italian law allows a child to consent to online services. Data about children travelling with their families is given to us by a parent or guardian and is used only to book and run the trip.

10. Security

We use appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS) on our website, access limited to the people who need it, and providers bound by data processing agreements.

11. Changes to this policy

We may update this policy when our services or the law change. The date at the top shows the latest version. If a change significantly affects how we use your data, we will tell you on the website or by email before it applies.