Privacy Policy

1. Introduction

This Privacy Policy explains how personal data is collected, used, stored and protected when users visit the Sapuri of Sicily website, contact Sapuri of Sicily, submit a booking request, authorize a reservation deposit, subscribe to promotional communications or interact with the services offered under the name “Sapuri of Sicily”.

Sapuri of Sicily is operated by Ilaria Cassibba, VAT No. 12629160016, based in Italy.

For any privacy-related question, request or concern, users may contact: hello@sapuriofsicily.com

This Privacy Policy is intended to provide clear information in accordance with applicable data protection laws, including Regulation (EU) 2016/679, known as the General Data Protection Regulation (GDPR).

2. Data Controller

The data controller is:

Sapuri of Sicily
Operated by Ilaria Cassibba
VAT No.: 12629160016
Country: Italy
Email: hello@sapuriofsicily.com

The data controller determines the purposes and means of the processing of personal data collected through the website and related communications.

3. Personal Data We May Collect

Depending on how users interact with Sapuri of Sicily, the following categories of personal data may be collected.

Contact data:

• full name;
• email address;
• message content;
• type of request;
• any information voluntarily included in the contact form or email.

Booking and reservation data:

• full name;
• email address;
• number of participants;
• selected session or reservation window;
• booking preferences;
• payment authorization status;
• cancellation or refund requests;
• communication related to the experience.

Participant information:

• dietary requirements;
• allergies or intolerances;
• accessibility needs;
• relevant health or safety information voluntarily provided by the participant.

Newsletter and promotional data:

• email address;
• name, where provided;
• consent status;
• subscription and unsubscribe information.

Technical and website usage data:

• IP address;
• browser type;
• device information;
• operating system;
• pages visited;
• date and time of access;
• technical logs required for security, maintenance and website operation.

Payment-related data: payment details may be processed by an external secure payment provider when users authorize a reservation deposit or make a payment. Sapuri of Sicily does not store full credit card details directly on its website or systems.

4. How Personal Data Is Collected

Personal data may be collected when users:

• fill in the contact form;
• send an email to Sapuri of Sicily;
• submit a booking request;
• authorize a reservation deposit;
• request cancellation or refund;
• subscribe to a newsletter or promotional communications;
• interact with the website;
• communicate with Sapuri of Sicily before, during or after an experience.

Some data is provided directly by the user. Other technical data may be generated automatically when visiting the website.

5. Purposes of Processing

Personal data may be processed for the following purposes:

• to respond to enquiries, requests, quotations or booking interest;
• to manage bookings, reservation windows, participant numbers, session confirmations, deposit authorizations, payments, cancellations and refunds;
• to organize and provide the cultural, language and culinary experience;
• to manage dietary, allergy, accessibility or safety needs voluntarily provided by participants;
• to process payments and reservation deposits through a secure third-party payment provider;
• to send newsletter or promotional communications where the user has provided consent;
• to comply with legal, tax, accounting and administrative obligations;
• to maintain website security, prevent abuse and troubleshoot technical problems;
• to improve the website and services, where analytics tools are activated and subject to applicable consent requirements.

6. Legal Bases for Processing

Sapuri of Sicily processes personal data only where there is a valid legal basis.

• Performance of a contract or pre-contractual steps: when processing is necessary to respond to booking requests, manage reservations, confirm sessions, provide the experience or handle related communications.
• Legal obligation: when processing is necessary to comply with tax, accounting, legal or regulatory obligations.
• Consent: for newsletter subscriptions, promotional communications and certain cookies or analytics tools where consent is required.
• Legitimate interest: to respond to enquiries, manage communications, protect the website, prevent abuse, improve services and maintain records, provided that such interests are not overridden by the user’s rights and freedoms.
• Explicit consent or user-provided information for special categories of data: where users voluntarily provide information about allergies, health needs, dietary restrictions or accessibility requirements, such information is processed only to the extent necessary to organize the experience safely and appropriately.

7. Contact Form and Email Communications

The contact form on the website sends submitted information by email.

The information submitted through the contact form may be received at:

• hello@sapuriofsicily.com;
• icassibba@gmail.com.

At the current stage, the contact form is intended to send email notifications and does not intentionally store submissions in a website database.

Users should avoid including unnecessary sensitive information in the contact form unless it is relevant to their request or participation in the experience.

8. Newsletter and Promotional Communications

Sapuri of Sicily may offer users the possibility to subscribe to a newsletter or receive promotional communications.

Subscription to promotional communications will be based on the user’s consent, where required by law.

Newsletter consent will be separate from other actions, such as submitting a contact form or booking request.

Users may withdraw consent and unsubscribe from promotional communications at any time by using the unsubscribe method provided in the communication or by contacting: hello@sapuriofsicily.com

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

9. Google Analytics and Similar Tools

Sapuri of Sicily may in the future use Google Analytics or similar analytics tools to understand how visitors use the website and to improve content, performance and user experience.

If such tools are activated, Sapuri of Sicily will update this Privacy Policy and, where required, the Cookie Policy and cookie consent banner.

Where analytics tools require user consent under applicable law, they will not be activated before the user has provided the required consent.

10. Marketing Tags and Advertising Tools

At the current stage, Sapuri of Sicily does not use Google Ads tags, Meta Pixel or similar advertising tracking tools.

If marketing or advertising tracking tools are activated in the future, users will be informed through the Cookie Policy and, where required, asked for consent before such tools are used.

11. Google Maps, Embedded Content and External Services

At the current stage, the website does not include embedded Google Maps, YouTube, Vimeo or similar third-party embedded content.

Sapuri of Sicily may provide external links to third-party websites or services, such as Google Maps, social media platforms or payment providers.

When users click external links, they leave the Sapuri of Sicily website and the privacy policies of the third-party services apply.

If embedded maps, videos or other third-party content are added in the future, this Privacy Policy and the Cookie Policy will be updated where necessary.

12. Payment Providers

Reservation deposits and payments may be handled by a secure external payment provider.

The payment provider may process personal data and payment information according to its own privacy policy and terms.

Sapuri of Sicily may receive limited payment-related information, such as:

• payment status;
• authorization status;
• transaction reference;
• amount;
• refund status;
• billing information where applicable.

Sapuri of Sicily does not directly store full credit card numbers or full payment authentication details on its website or systems.

13. Data Sharing and Recipients

Personal data may be shared only where necessary and appropriate.

Possible recipients may include:

• email service providers;
• website hosting providers;
• technical service providers;
• payment providers;
• accounting or tax professionals;
• legal or administrative consultants;
• newsletter or email marketing providers, if activated;
• authorities or public bodies where required by law.

Personal data is not sold to third parties.

14. International Transfers

Some service providers used by Sapuri of Sicily, such as email, payment, analytics or newsletter providers, may process data outside the European Economic Area.

Where this happens, Sapuri of Sicily will rely on appropriate safeguards required by applicable data protection law, such as adequacy decisions, standard contractual clauses or other legally recognized transfer mechanisms.

15. Data Retention

Personal data is kept only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required by law.

Indicatively:

• contact form and enquiry data may be kept for the time necessary to respond and manage the relationship;
• booking and payment-related data may be kept for the time necessary to manage the booking and comply with accounting, tax and legal obligations;
• newsletter data may be kept until the user unsubscribes or withdraws consent;
• technical logs may be kept for a limited period necessary for security and maintenance;
• cancellation, refund and legal correspondence may be kept for the time necessary to protect rights and comply with legal obligations.

Where data is no longer necessary, it will be deleted, anonymized or securely archived where appropriate.

16. User Rights

Under applicable data protection law, users may have the following rights:

• the right to access their personal data;
• the right to request correction of inaccurate data;
• the right to request deletion of personal data;
• the right to request restriction of processing;
• the right to object to processing;
• the right to data portability, where applicable;
• the right to withdraw consent at any time, where processing is based on consent;
• the right to lodge a complaint with a supervisory authority.

Users in Italy may contact the Garante per la protezione dei dati personali where applicable.

To exercise privacy rights, users may contact: hello@sapuriofsicily.com

17. Right to Withdraw Consent

Where processing is based on consent, users may withdraw that consent at any time.

This includes, for example, newsletter subscriptions and certain cookie or analytics consents where applicable.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

18. Security Measures

Sapuri of Sicily takes reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration or disclosure.

However, no website, email system or internet transmission can be guaranteed to be completely secure.

Users are encouraged to avoid sending unnecessary sensitive information by email or contact form.

19. Children and Minors

The Sapuri of Sicily website and experiences are not primarily directed at children.

Where minors participate in an experience, booking and communication should be handled by a parent, guardian, school, organization or responsible adult.

Sapuri of Sicily does not knowingly collect personal data from minors without appropriate adult involvement where required.

20. Social Media Links

The website may contain links to Sapuri of Sicily or Ilaria Cassibba profiles on social media platforms, including Instagram and LinkedIn.

When users interact with social media platforms, the privacy policies and terms of those platforms apply.

Sapuri of Sicily is not responsible for the privacy practices of third-party platforms.

21. Third-Party Websites

The website may contain links to third-party websites, platforms or services.

This Privacy Policy applies only to Sapuri of Sicily and does not apply to external websites or services.

Users should read the privacy policies of third-party services before providing personal data to them.

22. Updates to This Privacy Policy

Sapuri of Sicily may update this Privacy Policy from time to time, for example when new services, analytics tools, newsletter platforms, payment systems or legal requirements are introduced.

The updated version will be published on the website with a revised “Last updated” date.

Users are encouraged to review this Privacy Policy periodically.