BLU VACANZE – MD VIAGGI PRIVACY POLICY

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)

Service: “MD Viaggi”

This privacy notice describes how personal data of users accessing and using the MD Viaggi service, available via a white-label web platform at www.md-viaggi.it, is processed.

Summary information is also provided on sections of the website that collect personal data through forms or dedicated functionalities.

The website may contain links to third-party websites or platforms. The Co-Controllers are not responsible for the content, privacy policies, or data processing practices of third parties, who act as independent data controllers.

1. DATA CO-CONTROLLERS 

Pursuant to Article 26 of Regulation (EU) 2016/679 (GDPR), personal data of MD Viaggi users are processed under co-controller arrangements by:

Bluvacanze S.p.A.

Registered office: Piazzale Lorenzo Lotto n. 2 – 20148 Milan (MI), Italy

Email: rpdblu@bluvacanze.it

Data Protection Officer (DPO): rpdblu@bluvacanze.it

MD S.p.A.

Registered office: Gricignano di Aversa (CE), Zona Industriale A.S.I., Capannone n. 18

Email: privacy@mdspa.it

MD S.p.A. appoints a Data Protection Officer (DPO), Studio Legale Imperiali e Associati, represented by Avv. Diego Cordua, available for inquiries at: dpomdspa@gmail.com

The Co-Controllers have defined their respective roles regarding data processing connected to the service. Users may exercise their rights by contacting either of the Co-Controllers.

2. CATEGORIES OF DATA SUBJECTS

 This privacy notice applies to:

Users browsing md-viaggi.it;

Users requesting information or making bookings through the service;

Users subscribing to newsletters or promotional initiatives related to the MD Viaggi service.

3. TYPES OF DATA PROCESSED

a) Navigation data

The IT systems and software of the website automatically collect certain personal data during normal operation, including:

IP addresses;

Domain names of devices used;

URI addresses of requested resources;

Information about the user’s operating system and IT environment;

Data about visited pages and time spent on the site.

b) Data voluntarily provided by the user

Voluntary communications or form submissions may include:

Name and surname;

Email address;

Data necessary to manage requests and bookings.

4. PURPOSES OF PROCESSING AND LEGAL BASES

 Personal data are processed for:

Providing the MD Viaggi service, managing user requests and bookings

Legal basis: performance of pre-contractual or contractual measures (Art. 6(1)(b) GDPR)

Technical and functional management of the website, security, prevention of misuse or malfunctions

Legal basis: legitimate interest of the Co-Controllers (Art. 6(1)(f) GDPR)

Statistical and usage analysis of the service, also in aggregated form

Legal basis: user consent or legitimate interest, depending on the tools used

Marketing and promotion of services and offers, including personalized marketing

Legal basis: user consent (Art. 6(1)(a) GDPR)

 Providing data for the purposes above is optional, and refusal does not prevent the use of the service.

5. DATA PROCESSING METHODS

 Data are processed using IT and telematic tools in accordance with the principles of lawfulness, fairness, transparency, minimization, and security, implementing appropriate technical and organizational measures (Art. 32 GDPR).

6. COOKIES AND TRACKING TOOLS

 The website uses technical cookies and, with user consent, profiling and third-party cookies.

For details on cookie types and management, see the Cookie Policy on the site.

7. DATA RECIPIENTS

 Personal data may be shared with:

IT and technological service providers;

Hosting, maintenance, and technical support providers;

Third parties acting as independent data controllers.

Data are not publicly disclosed.

8. DATA TRANSFER OUTSIDE THE EU

If data are transferred to countries outside the EU, transfers will comply with GDPR safeguards (adequacy decisions, standard contractual clauses, or other appropriate guarantees).

9. DATA RETENTION PERIOD

 Data are retained only as long as necessary for the purposes they were collected and in compliance with legal requirements and the Cookie Policy.

10. RIGHTS OF DATA SUBJECTS

 Users may exercise their rights under Articles 15–22 GDPR, including:

Access;

Rectification;

Erasure;

Restriction;

Data portability;

Objection to processing.

Requests can be sent to either of the Co-Controllers. Users retain the right to lodge a complaint with the Italian Data Protection Authority.

11. CHANGES TO THIS PRIVACY POLICY

 The Co-Controllers may update this notice to comply with regulatory or organizational changes. Updates will be published on the website.

Accessibility Act

OUR COMMITMENT TO ACCESSIBILITY

At MD viaggi in collaboration with Bluvacanze, we are deeply committed to providing an accessible and inclusive experience and environment for everyone who interacts with us. We strive to facilitate the inclusion of people with disabilities so that everyone can easily access our services, solutions, and travel opportunities.

Accessibility Solutions for Travelers

Bluvacanze removes access barriers through the following solutions:

Alternative contact channels (high street agencies, call center)

Expert travel consultants trained to approach interactions with empathy

Website Accessibility Features

Compatible with all modern browsers and assistive technologies, such as Firefox, Chrome, Safari, and Edge.

Known Limitations:PDF files may not always be accessible nteractive maps are not accessible to users with visual impairments Some videos lack audio descriptions

Regulatory References

This website is committed to ensuring the accessibility of its digital content in accordance with:

Law No. 4 of January 9, 2004 (known as the "Stanca Law")

Legislative Decree 82/2022, implementing Directive (EU) 2019/882 – European Accessibility Act

WCAG 2.1 Guidelines – Level AA

UNI CEI EN 301549 Technical Standard

Compliance Status:

This website is currently undergoing adjustments and is partially compliant with accessibility requirements.

Alternative Contact Channel:

If you experience any difficulties using the website, please contact the following phone number:

+39 02 2412‌14‌89

Reporting to AgID:

In case of an unsatisfactory response or no response, you may submit a report to the Agency for Digital Italy (AgID) via the official website:

https://www.agid.gov.it

Declaration Date:

09/23/2025

Accessibility Evaluation

This statement is based on internal self-assessment and will be periodically updated according to the progress of the compliance project.