Esprit Libre Data Protection Policy

This page contains information about Privacy Policy which is also extended to the use of cookie (Cookie Policy) updated according to the General Data Protection Regulation (GDPR) n. 679/2016. You can get more information on the GDPR from the European Commission’s data protection page.

At Esprit Libre Snc we are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and the purpose for our collection of it. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

When we refer to “you” in this privacy policy, we mean every person who communicates with us in respect of a booking, booking request, enquiry or for any other reason and all persons for whom a booking or booking request is made.

Data processor

Following access to this website, data pertaining to persons that are identified or identifiable may be processed. The data processor of the personal data collected following a visit to our website or any other data used for providing our services is Esprit Libre Snc, Via Jacopo Palma 30 – 20146 Milan. The updated and detailed list of the individual responsible for processing data will be provided by submitting appropriate request at [email protected].

What information we collect

We may collect and process personal information about you including details:

– you provide by filling in forms on our website, requesting further services or reporting a problem with our website

– you provide when you use our professional services as a client

– received in correspondence that you send to us

– received during calls to and from us

– concerning your visits to our website (including but not limited to traffic data) and the resources that you access

In order to serve you and your travel requirements, we will need to collect personal information which is required to facilitate your travel arrangements: names of all persons traveling, contact details (such as telephone number and e-mail address) of the person making the booking, home address, passport details of all persons traveling, sensitive billing information, relevant health issues which may affect you or anyone traveling with you and dietary requirements, etc. We will assume that you have consented to the collection of all information and understand the uses of this information for the travel management process.

How we collect data

Your personal information is collected directly from you whether it’s in person, by telephone, email, through our website, mobile apps, social media or any other contact we or our business partners may have with you. Your data is collected when you complete your traveler profile, purchase travel and communicate with us.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 1. when we need to perform the contract we are about to enter into or have entered into with you in relation to travel-related services; 2. when it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; 3. when we need to comply with a legal or regulatory obligation.

Our ongoing commitment to developing our service will involve surveys, social media, promotions and competitions so we can create new platforms to best meet your needs and develop a better traveling experience and travel management service for you.

Who we may provide your personal data to

To ensure a seamless travel experience we may be required to share your information with the suppliers of your chosen arrangements together with any other third party who needs this information so that we can arrange for your holiday to be provided. Suppliers and other third parties are likely to include the following, depending on the arrangements booked: in-country transport operators; hotels and the providers of other forms of accommodation; tour managers and guides; excursion and activity operators; travel insurance providers; credit card companies / banks in respect of payments. The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.

We only provide third parties with the personal data they require in order to deliver their services. Third party contractors must only use this information for your travel arrangements and must ensure that the information is suitably protected. Although we only work with reputable suppliers, we recommend you evaluate their Privacy Policies in order to further understand their procedures in relation to the use of your data.

Location in which data are processed

Data processing linked to services of this website takes place in the company premises of the data processor, in the premises of the hosting provider and of the website manager and will be handled by the personnel in charge for data processing only, or by others in charge of occasional maintenance operations.

For more information, please contact the data processor.

Retention of your personal data

We will retain your personal information as so long as is reasonably necessary for the purpose for which it was obtained and in accordance with our legal obligations and follow our data destruction policy and processes thereafter.

How we protect your personal data

We have security procedures in place to protect your personal information. We understand the importance of constantly improving our systems to mitigate risk and our team of technological experts are focused on this task. In-house, we are focused on ensuring your information is safe and only used for your travel needs. Access is restricted and password controlled.


A cookie is a small piece of text sent to your computer’s memory which can later be retrieved by other web pages. Cookies are used to make your interactions online more convenient for you. You can disable cookies using your own browser settings, however, this may affect what material you will have access to on our websites.

Exercise of the User Rights

You have the right, at any time, to obtain confirmation as to whether or not personal data concerning you exist and the logic applied to the processing, the right to ask for their integration, the right to object to their processing on legitimate ground, and the right to request rectification, updating, erasure (right to be forgotten) or blocking of data that have been processed unlawfully, the right to obtain a copy of the personal data being processed as well as the right to data portability, also by sending a written request to the following e-mail address: [email protected].

Changes to this Policy

From time to time, we may change this privacy notice to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you on our website if these changes are material and, where required by applicable law, we will obtain your consent. All update(s) will be effective immediately on posting. You can see when the Privacy Policy was updated by checking the “last updated” date displayed at the bottom of this document.

How to contact us

If you have any questions about how we treat your personal data and protect your privacy, or if you have any comments or wish to seek to exercise any of your rights as outlined above or to complain about our use of your personal data, please send us an email at [email protected].

Last updated on Aug 18, 2020