PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA
Users and Customers of the Sostravel web platform
Users and Customers of the Sostravel web platform
pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) and Italian Legislative Decree No. 196 of 30 June 2003, as amended by Legislative Decree No. 101 of 10 August 2018 (“Privacy Code”)
Sostravel.com S.p.A. wishes to inform you, clearly and transparently, about how it processes the personal data of those who browse the website www.sostravel.com and its other online platforms (the “Web Platform”), register an Account, purchase or activate the Services, including through the Online Stores and the Points of Sale, or contact Customer Care. Capitalized terms have the meaning given to them in the General Terms and Conditions of the Services published on the Site.
Data Controller is Sostravel.com S.p.A. (Tax Code and VAT No. 03624170126), with registered office at Viale Europa 98, 00144 Rome; certified e-mail (PEC): sostravel@pec.net; e-mail: privacy@sostravel.com.
The Data Controller has appointed a Data Protection Officer (DPO), Dr. Vincenzo Pacelli, who can be contacted at dpo@sostravel.com or by post at the Data Controller’s registered office.
Depending on the Services and features used, we may process the following categories of data:
Third-party data provided by the User. If the User provides data of other persons (for example travel companions or beneficiaries of a Service), the User declares that they have informed those persons and are entitled to provide such data; those persons may exercise the rights set out in section 9 (Art. 14 GDPR).
Minors. Registration is reserved for persons over the age of 18. Registration of a minor requires the prior authorization of the person exercising parental responsibility.
Special categories of data. Sostravel does not request data concerning health or other special categories of data (Art. 9 GDPR). You are asked not to provide such data to Customer Care: if this occurs, the data will be used solely to direct the request to the competent party and will not be retained for longer than strictly necessary.
3.1 Purposes that are necessary and based on legal obligations or legitimate interests
| Purpose | Legal basis | Provision of data |
|---|---|---|
| Registration and management of the Account | Performance of a contract (Art. 6(1)(b) GDPR) | Necessary: without the data, the Account cannot be created |
| Sale, activation and provision of the Services (Lost Luggage Concierge, Dr. Travel, Travel Booking, free services) | Performance of a contract (Art. 6(1)(b)) | Necessary to provide the requested Service |
| Tracing of the Baggage and Active Tracking, including through SITA WorldTracer and airport handlers | Performance of a contract (Art. 6(1)(b)) | Necessary |
| Management of the Procedure and payment of the service guarantee amount | Performance of a contract (Art. 6(1)(b)) | Necessary: without the required documents, the claim cannot be settled |
| Checks on anomalies and prevention of fraud or abuse (e.g. duplicate purchases, limit on the number of events in a three-year period) | Data Controller’s legitimate interest in preventing fraud (Art. 6(1)(f)) | Necessary |
| Assistance through Customer Care, handling of requests and complaints, recording of calls | Performance of a contract (Art. 6(1)(b)); legitimate interest in documenting requests and ensuring the quality of the service (Art. 6(1)(f)) | Necessary to receive assistance |
| Legal compliance (accounting, tax, Consumer Code, tourism legislation), requests from authorities | Legal obligation (Art. 6(1)(c)) | Mandatory |
| Security of the Web Platform and prevention of unauthorized access | Legitimate interest (Art. 6(1)(f)) | Necessary |
| Establishment, exercise or defense of a legal claim in court or out of court | Legitimate interest (Art. 6(1)(f)) | Necessary |
| Sending to the Customer’s e-mail address communications about services similar to those purchased (“soft spam”) | Art. 130(4) of the Privacy Code; legitimate interest (Art. 6(1)(f)) | The Customer may object at any time, including by using the link included in every message |
3.2 Purposes based on consent (optional)
| Purpose | Legal basis | Provision of data |
|---|---|---|
| Sending promotional communications and newsletters about Sostravel products and services by e-mail, SMS, WhatsApp, telephone with an operator or notifications | Consent (Art. 6(1)(a) GDPR; Art. 130 of the Privacy Code) | Optional: failure to consent does not affect the Services |
| Profiling: analysis of preferences and use of the Web Platform in order to send personalized communications | Consent (Art. 6(1)(a)) | Optional: failure to consent does not limit access to the Web Platform or to the Services |
| Non-technical cookies and tracking tools | Consent (Art. 122 of the Privacy Code) | Optional, manageable through the banner and the Cookie Policy |
Consent may be withdrawn at any time, without affecting the lawfulness of the processing carried out before its withdrawal (Art. 7(3) GDPR).
3.3 Dr. Travel Service and partner services
The Dr. Travel Service is provided by Net Medicare S.r.l., which acts as independent controller of the processing of Patients’ data, including health data collected on its own platform and during Televisits. Sostravel, as reseller, communicates to Net Medicare only the data necessary to activate the Service purchased (Art. 6(1)(b) GDPR) and has no access to medical records. Net Medicare’s privacy notice is available on the partner’s website.
When the User chooses to use the services of third-party partners accessible from the Web Platform (for example, flight compensation claims through AirHelp or insurance coverage at preferential rates), the data is collected directly by the partner, which processes it as an independent controller in accordance with its own privacy notice. Sostravel communicates to the partner only the data that may be necessary to recognize the agreement requested by the User.
Customer Care is managed exclusively by operators of Sostravel or of Contact Center companies acting on its behalf as processors (Art. 28 GDPR). It can be reached by telephone, e-mail and WhatsApp at the contact details indicated in the General Terms and Conditions.
Data is processed mainly by electronic means and, to a limited extent, on paper, by authorized and trained personnel (Art. 29 GDPR and Art. 2-quaterdecies of the Privacy Code). Sostravel adopts technical and organizational measures appropriate to the risk (Art. 32 GDPR), including access control, encryption of passwords and communications, backups and periodic verification of the measures. Sostravel will never ask the User to disclose their password.
| Category of data | Retention period |
|---|---|
| Account data | For the duration of the Account. In the event of inactivity for 24 months, the Account is closed, subject to prior notice by e-mail, and the data is deleted, except for data that must be retained for the other purposes indicated in the table |
| Contractual, accounting and tax data (purchases, payments, invoices) | 10 years (Art. 2220 of the Italian Civil Code and tax legislation) |
| Lost Luggage Concierge claims and service guarantee amount, including documents and IBAN | 10 years from the closure of the claim, ordinary limitation period (Art. 2946 of the Italian Civil Code) |
| Recordings of calls to Customer Care | 6 months from the call, unless there are ongoing disputes |
| E-mails, SMS and WhatsApp messages with Customer Care | For the duration of the case and thereafter in accordance with the terms applicable to the case to which they relate |
| Data from the digital Travel Journal | Until deletion by the User or closure of the Account |
| Data for promotional purposes | 24 months from consent or from the last interaction, unless withdrawn earlier |
| Data for profiling purposes | 12 months from collection, unless withdrawn earlier |
| Cookies and tracking tools | As indicated in the Cookie Policy |
Once these periods have elapsed, the data is deleted or anonymized, unless retention is necessary to defend a legal claim or to comply with requests from authorities.
Data is not disseminated. It may be disclosed, to the extent necessary for the purposes indicated, to:
The updated list of processors may be requested using the contact details indicated in section 10.
Some data may be transferred outside the European Economic Area, in particular:
Transfers take place on the basis of an adequacy decision of the European Commission (Art. 45 GDPR), including, for certified U.S. companies, the EU-U.S. Data Privacy Framework; failing that, on the basis of the standard contractual clauses approved by Implementing Decision (EU) 2021/914 and of any supplementary measures identified following a transfer impact assessment (Art. 46 GDPR). Transfers to airlines and handlers that are necessary to trace and redeliver the Baggage are based on the necessity of performing the contract concluded with the Customer (Art. 49(1)(b) GDPR). A copy of the safeguards adopted may be requested using the contact details indicated in section 10.
The data subject may exercise at any time, free of charge, the rights provided for in Articles 15-22 GDPR:
Sostravel responds without undue delay and in any case within one month of receipt of the request; this period may be extended by two months in the case of complex or numerous requests, in which case a reasoned notice will be given within the first month (Art. 12(3) GDPR). For medical records relating to the Dr. Travel Service, requests must be addressed to Net Medicare; Sostravel Customer Care may in any case forward them.
The data subject also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (www.garanteprivacy.it), or with the supervisory authority of the Member State where they reside or work (Art. 77 GDPR), and to seek a judicial remedy (Art. 79 GDPR).
Requests may be sent to:
It may be necessary to verify the identity of the requester. The data subject may be represented by a delegate holding a written proxy and a copy of their own identity document.
For information on the cookies and other tracking tools used on the Web Platform and on the management of the related preferences, please refer to the Cookie Policy. The Web Platform may contain links to third-party websites (for example Net Medicare, AirHelp, insurance partners), to which their respective privacy notices apply.
This notice was updated in November 2026 and replaces the version of 31 July 2023. It may be amended in connection with the evolution of the Services, of the tools used to provide them and of the applicable legislation. In the event of significant changes, notice will be given on the Web Platform and, where appropriate, by e-mail to registered Users.