Privacy policy

Pursuant to Regulation (EU) 2016/679 (hereinafter "GDPR") and national legislation on the protection of personal data.

Data controller

The data controller is:

- Company: Top Sicily
- Website: topsicily.com
- VAT number: 03144470840
- Owner contact details: info@topsicily.com

Types of data collected

Depending on the purpose, Top Sicily collects the following categories of data:

- Browsing data: datacollected automatically by the website (e.g., IP addresses, browser type, access time, pages visited), necessary for the proper functioning of the site and for anonymous statistical analysis.

- Data provided voluntarily by the user
  - For reservations and contact details: first name, last name, email address, telephone number, residential address, payment details, passport or ID card information, travel preferences (e.g., food intolerances, special needs), details of family members or companions.
  - For newsletter and marketing subscriptions:email address, name (optional).
- Data collected through cookies

Purpose and legal basis of processing

a) Performance of tourism services and contracts

Management of reservations, payments, voucher issuance, travel-related communications, pre- and post-sales assistance.

Legal basis: performance of a contract or pre-contractual measures (Article 6(1)(b) of the GDPR).

b) Compliance with legal and tax obligations

Billing and communications to the competent authorities.

Legal basis: compliance with a legal obligation (Article 6.1.c GDPR).

c) Response to specific requests

Management of requests for quotes or information sent via the contact form.

Legal basis: pre-contractual measures taken at the request of the data subject (Article 6.1.b GDPR).

d) Sending newsletters and commercial communications

Sending communications relating to Top Sicily services and packages, including personalized communications (direct marketing).

Legal basis: explicit consent of the data subject (Article 6.1.a GDPR).

e) Statistical analysis and service improvement

Anonymous analyses aimed at improving the services offered.

Legal basis: legitimate interest of the controller (Article 6(1)(f) of the GDPR).

Treatment methods

Data processing is carried out using electronic and paper-based tools, adopting appropriate technical and organizational measures to ensure the security, integrity, and confidentiality of the data.

Recipients of personal data

Personal data may be disclosed to the following parties:

- - Tourism service providers (e.g., accommodation facilities, airlines, transportation companies, tour guides, event organizers)
  - Banking institutions for payment management
  - Professionals or companies providing accounting, legal, or IT consulting services
  - Competent authorities in compliance with legal obligations

Transfer of data abroad

Since Top Sicily operates in the international luxury tourism sector, some data may be transferred to entities located in non-EU countries.
In such cases, the transfer will take place in compliance with the GDPR through adequate safeguards, such as standard contractual clauses approved by the European Commission.

Data retention period

Personal data will be stored for the time strictly necessary:

- - Data for contractual and legal obligations: for the entire duration of the relationship and for the following 10 years
  - Data for marketing purposes: until consent is revoked
  - Browsing data: for a limited period according to the web host's policies

Rights of the data subject

The data subject is guaranteed the rights set forth in Articles 15-22 of the GDPR, including:

- - Access
  - Correction
  - Deletion (right to be forgotten)
  - Restriction of processing
  - Data portability
  - Opposition
  - Withdrawal of consent
  - Submit a complaint to the regulatory authority

You can exercise your rights by sending a request to
info@topsicily.com.

Changes to this privacy policy

Top Sicily reserves the right to make changes to this privacy policy at any time.

Last update date: 12/08/2025

Privacy Policy