Privacy and cookie policy
Last updated: November 8, 2026
This notice explains what personal data we collect when you use SanctaVia, why, for how long and with whom we share it, pursuant to Regulation (EU) 2016/679 (“GDPR”) and the Italian Personal Data Protection Code (Legislative Decree 196/2003). The second part covers cookies and similar technologies.
1. Data controller
[Ragione sociale o nome e cognome del titolare], [Indirizzo della sede], [Partita IVA / codice fiscale]. For any privacy question or to exercise your rights, write to [Email per la privacy, es. privacy@dominio.it].
2. What data we process, why and on what legal basis
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Email address, account identifier, date of last sign-in; if you sign in with Google, Microsoft or Apple, the name and email the provider shares with us | Creating your account and letting you sign in via the email link or the provider you choose | Performance of the service you requested (Art. 6(1)(b)) | For as long as you keep your account |
| Saved trips: shrine, dates, radius, number and type of participants, group name, rooms, selected services, checklist | Saving and showing you your trips, generating the PDF quote | Performance of the service (Art. 6(1)(b)) | Until you delete the trip or your account |
| Group fare request: name, phone number, routes, dates, group makeup, notes; the address of your internal inbox (firstname.lastname@utenti.sanctavia.org) and the emails received there, including attachments | Requesting the group fare from the partner (from 10 seats) and showing you the reply in the PRO area | Pre-contractual measures taken at your request (Art. 6(1)(b)); disclosure to the partner with your consent (Art. 6(1)(a)) | 24 months from the request; emails until you delete your account |
| Billing and payment data (name, address, VAT number or tax code, subscriptions and passes purchased) | Selling the PRO subscription or trip pass, issuing invoices | Contract (Art. 6(1)(b)) and legal tax obligations (Art. 6(1)(c)) | 10 years, as required by tax law |
| Clicks on links to partners: link, date and time, referring site, browser type and a code derived from the IP address combined with a random value that changes daily (the IP address is not stored) and where the visit in which you clicked came from (campaign UTM parameters, referring site, first page viewed) | Counting clicks, filtering out bots, verifying partner commissions | Legitimate interest in measuring the service and receiving payment (Art. 6(1)(f)) | 24 months |
| Visit statistics with Umami, hosted on our servers and without cookies: pages viewed, referring site or campaign, language, browser, operating system and device type, country and city derived from the IP address (the IP address is not stored), actions in the planner and clicks to partners. No identifier is kept on your device | Understanding how many people use the site, where they come from and where they stop, in order to improve it | Legitimate interest in measuring and improving the service (Art. 6(1)(f)) | 24 months |
| Browsing recordings and heatmaps with Microsoft Clarity: mouse movements, clicks, taps and scrolling, pages viewed, device and browser type, country, page errors and, if you arrive from a link in our emails, the contact's random code (never the address). Text, images and form fields are masked, and participants' data and document photos always are. If you connect from Italy, Clarity is only loaded if you accept cookies; from other countries it records without cookies until you accept | Seeing where the site confuses people or gets stuck (dead clicks, errors, abandoned pages) so we can fix it | Consent (Art. 6(1)(a)) for cookies and for visitors connecting from Italy; otherwise legitimate interest in improving the service (Art. 6(1)(f)) | Recordings 30 days (up to 13 months for those we save), heatmaps and statistics 13 months |
| Technical request data (IP address, browser, requested page, time) in server logs | Operating the site, security, abuse prevention | Legitimate interest (Art. 6(1)(f)) | No more than 30 days, except for incident investigations |
Searches for flights, lodging, transfers and restaurants can be carried out without an account. We send offer providers only the search parameters (places, dates, number and type of passengers, rooms), never your name or email. We do not make automated decisions that produce legal effects concerning you, and we do not sell your data.
Providing your email is necessary to create an account, and billing data is necessary to make a purchase; without them, those features are not available.
3. Who we share data with
Data is processed by us and by providers acting as processors on our instructions:
- [Fornitore del server, es. Hetzner Online GmbH, Germania]: servers running the application, the database and the sign-in service;
- Cloudflare, Inc.: site delivery, content delivery network and protection against attacks;
- Microsoft Ireland Operations Ltd. (Microsoft Clarity): browsing recordings and heatmaps, with page text and images masked;
- [Fornitore SMTP per le email di accesso]: sending the email with the sign-in link;
- Migadu: receiving emails sent to your internal inbox (firstname.lastname@utenti.sanctavia.org), which remain there only until we copy them into your account (about one minute).
Other parties process data as independent controllers, under their own privacy notices:
- Stripe (Stripe Payments Europe Ltd.), for payments: you enter your card details directly with Stripe and we never see them;
- partner sites (airlines, booking platforms, restaurants) you reach by clicking “Book”: from that point on, the partner's privacy notice applies;
- EasyGroupFlights (pelicantravel.com s.r.o., Slovakia), only if you request a group fare and give your consent: it receives your name, phone number, routes, dates and group makeup, and replies to your internal inbox;
- LiteAPI (Nuitée), only if you book a hotel on the site: it receives the lead guest's name, email and phone and one guest name per room, passes them to the hotel and handles the payment;
- Travelpayouts, an affiliate network: some partner links go through its servers, which record the click to attribute the commission to us;
- extra service partners (travel insurance, visas, eSIM) that you reach from the “Before you go” section: they only receive dates, number of people, destination country and the link code, never participants' data. These are affiliate links: if you buy, SanctaVia may receive a commission at no extra cost to you;
- Google, Microsoft or Apple, only if you choose to sign in with their account: they share your name and email with us, in accordance with their privacy notices;
- public authorities, where required by law.
4. Transfers outside the European Union
Some providers (for example Cloudflare, Stripe and Microsoft) may process data in the United States or in other countries outside the European Economic Area. In such cases, the transfer takes place on the basis of an adequacy decision of the European Commission, such as the EU-US Data Privacy Framework for certified companies, or of the standard contractual clauses approved by the Commission.
5. Your rights
You may at any time request access to your data, its rectification or erasure, restriction of its processing, receipt of it in a machine-readable format (portability), and object to processing based on legitimate interest. You may withdraw your consent to cookies at any time, without affecting processing already carried out. Write to [Email per la privacy, es. privacy@dominio.it]: we will reply within one month.
If you believe that the processing infringes the law, you may lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, garanteprivacy.it) or with the authority of the country where you live or work.
6. Security
Connections are encrypted (HTTPS). The database and internal services are not reachable from the Internet; sign-in uses single-use links without passwords. Click IP addresses are not stored in plain text.
8. Changes
If we change this notice, we will update the date at the top. If the changes concern profiling cookies, we will ask for your consent again.