Privacy Policy

Plain summary: we run our own analytics on our own server. We do not use Google Analytics, Meta Pixel, ad networks or any third-party tracker. We do not sell or share data with anyone. Without your consent we only collect a few anonymous aggregate counters (e.g. how many visits a page received today). If you give consent, we collect a richer per-visit record for 90 days to understand how the site is used, and you can withdraw consent at any time.

1. Who we are (Data Controller)

The Platinum Services is the data controller of the personal data processed through this site. The website is the digital presence of our DMC (Destination Management Company) activity for luxury MICE events in Italy and Europe.

Contact for any privacy matter: [email protected].

2. What data we collect

2.1 Without your consent (anonymous per-visit, no identifiers)

Every page request, regardless of consent, generates an anonymous per-visit record on our infrastructure. The record contains only fields that, in combination, do not identify you and cannot be linked back to a specific person or device:

• Page route: the URL path you visited (e.g. /destinations/florence-and-tuscany), without query string
• Date and time: in Europe/Rome (yyyy-mm-dd HH:MM:SS) and Unix epoch
• Referrer domain: only the host name of the referring page (e.g. google.com), never the full URL
• Referrer class: derived bucket (search / social / messaging / internal / direct / other)
• Country and continent (derived from your IP at the network edge, never more precise than country)
• Device class: desktop / tablet / mobile
• Viewport class: bucket of the browser window width (xs / sm / md / lg / xl), never the exact pixel value
• Browser family: Chrome / Firefox / Safari / Edge / Opera / Other, derived from the User-Agent. The full User-Agent is not stored.
• OS family: Windows / macOS / Linux / iOS / Android / Other
• Connection protocol info: the version of the standard internet protocols your browser used to reach us
• Language family: the primary language of your browser without region (e.g. it, en, de), derived from navigator.language

What is explicitly NOT stored in the anonymous record: IP address, full User-Agent, full Accept-Language, city, region, ASN, persistent visitor identifier, session identifier, server-side fingerprint. The record can be enumerated and analysed but, even in combination, the fields are not sufficient to identify a natural person.

The legal basis is our legitimate interest in operating and improving the site (Art. 6(1)(f) GDPR), limited to fields that, individually and in combination, do not identify the user. Records are kept for at most 18 months and then automatically deleted.

Operational server logs (for security, debugging and abuse prevention) are separate from this and retained for a maximum of 6 months.

2.2 With your consent (per-visit analytics)

If you click "Accept" on the cookie banner, we store a per-visit record on our private analytics database, hosted on our own infrastructure. Each record contains:

• Date and time of the visit (in the Europe/Rome time zone)
• Page visited (URL path only, e.g. /destinations/venice)
• Referrer (the page that linked here, if any)
• IP address (as provided by your network)
• User-Agent (the string sent by your browser)
• Accept-Language and browser language
• Approximate location: country, city, region, continent (derived from your IP at the network edge)
• Network ASN and ISP organisation name
• Connection protocol versions used by your browser
• Viewport size, screen resolution, device class, timezone
• A randomly generated visitor identifier (stored in your browser's localStorage as va_vid), created locally only after you accept
• A randomly generated session identifier (stored in your browser's sessionStorage as va_sid), expires when you close the tab
• A server-side fingerprint computed as SHA-256 of IP | User-Agent | Accept-Language, truncated to 24 hex characters

The legal basis is your consent (Art. 6(1)(a) GDPR), which is freely given, specific, informed and unambiguous, and can be withdrawn at any time without affecting your continued access to the site.

2.3 When you write to us

If you use the contact form at /contact or email [email protected], we store the message you send (name if provided, email, text). The legal basis is our legitimate interest in answering you (Art. 6(1)(f) GDPR), or, if your message asks for a service, performance of a contract (Art. 6(1)(b)).

2.4 Consent record (stored only when you click Accept)

To be able to prove that you have given consent, which is a legal obligation on us under Art. 7(1) GDPR, when you click Accept we store:

• The date and time of your choice
• Whether you accepted or rejected
• The version of this Privacy Policy in force at the time
• The categories of data the consent applies to
• Your IP address, User-Agent, Accept-Language, approximate location, ASN and ISP organisation, required to demonstrate that the consent came from your device at that moment
• The server-side fingerprint described in section 2.2, used as the lookup key so we don't ask you again at every page reload

The legal basis for storing this specific record is our legal obligation to demonstrate consent (Art. 6(1)(c) and Art. 7 GDPR). It would be paradoxical to need consent to record consent itself, and the law explicitly exempts it.

If you click Reject or close the banner without choosing, no record is stored: we simply do not start analytics. The banner will appear again on the next page you open until you accept or stop visiting.

2.5 When you click an outbound link

Every time you click a link that takes you to a different website (for example a partner site or an external news source), we record the click on our own infrastructure. This serves two purposes: understanding which of our pages and recommendations are useful, and verifying the performance of outbound traffic.

• The URL clicked, the destination domain, the category (amazon for affiliate links, external for everything else), and the page you were on when you clicked. These four fields are stored always, regardless of consent.
• If you have given consent to per-visit analytics (see 2.2), the record also includes your visitor identifier, IP address, User-Agent, Accept-Language and approximate location, so we can attribute the click to the rest of your navigation. Without consent these fields are NOT stored.

The legal basis for the always-stored minimal record is our legitimate interest in measuring editorial performance and outbound traffic, Art. 6(1)(f) GDPR. The four fields do not identify you. The additional fields (visitor id, IP, UA, geo) added when you have consented to per-visit analytics share the legal basis of that consent, Art. 6(1)(a) GDPR.

Click records are kept for 18 months and then automatically deleted.

Important: we do not intercept the navigation. When you click a link, your browser navigates normally and the third-party site is reached at the same moment. Our recording is sent in parallel via the browser's standard "beacon" mechanism, designed to deliver telemetry without blocking the page transition.

3. Why we collect it

• Aggregate counters (no consent): to understand which content is useful, detect operational problems, and prioritise editorial work. No individual user can be identified.
• Per-visit analytics (with consent): to analyse navigation patterns (which destinations lead to which services, where readers come from, which devices are common) and improve the site. We never combine this data with external sources and we never profile individuals for marketing or advertising.
• Contact messages: to answer you.
• Consent record: to comply with our legal obligation to demonstrate consent.

4. Who we share data with

No one. Specifically:

• We do not use Google Analytics, Google Tag Manager, Google Ads, Meta Pixel, Facebook SDK, TikTok Pixel, LinkedIn Insight Tag, Hotjar, Mixpanel, Segment, Amplitude or any other third-party analytics or advertising service.
• We do not sell, rent, swap or share personal data with advertisers, data brokers, marketing partners, publishers or any commercial third party.
• We do not embed third-party tracking scripts, social widgets that send data on page load, or external chat widgets.
• We do not integrate any "data clean room" or audience-matching service.

The only third parties that necessarily process data on our behalf are:

• Cloudflare, Inc., provides content delivery, encrypted connection termination and DDoS protection used to serve the site. Cloudflare acts as a data processor under a DPA compliant with Art. 28 GDPR and EU Standard Contractual Clauses. Cloudflare does not use this data for its own purposes.

Where data is processed: our analytics database is hosted on our own private infrastructure inside the European Economic Area. Cloudflare may process requests on its global edge network; EU traffic is routed through EU edge locations whenever possible.

4.bis Third-party assets loaded from external services

Although we do not embed third-party analytics or advertising scripts, the website loads a small number of static assets from external content-delivery networks. When your browser fetches these assets, the third party in question receives your IP address and a User-Agent string as part of the standard HTTP request: this happens for every website that loads external resources of any kind.

Asset	Provider	Purpose
Web fonts (Playfair Display, Roboto)	Google Fonts (fonts.googleapis.com, fonts.gstatic.com)	Typography
CSS framework (Tailwind)	cdn.tailwindcss.com	Layout and styling
Animation library (GSAP + ScrollTrigger)	cdn.jsdelivr.net	Scroll animations
Site delivery (HTML, JS, CSS, images)	Cloudflare	Delivery, encryption, DDoS protection (processor under Art. 28 DPA)

What these providers receive: your IP address, User-Agent, the URL of the asset requested, the Referer header (the page you are on). What they do NOT receive: form data, click events, scroll behaviour, personal identifiers from this site. We do not transmit any data to them on purpose; the data exchange is the minimum required by the HTTP protocol itself.

Note for users in Germany: a 2022 ruling by the LG München declared that embedding Google Fonts via fonts.googleapis.com without prior consent can violate the GDPR because Google receives the user IP. We acknowledge this risk and treat the matter as a known trade-off until we self-host the fonts. If you want to access the site without these third-party requests, you can use a browser extension that blocks them (Decentraleyes, LocalCDN); the site will fall back to system fonts and a slightly different look, but all functionality remains available.

4.ter Advertising

The site does not currently display third-party advertising (Google Ads, advertising exchanges, programmatic ads, retargeting). If in the future we introduce any form of advertising:

• This Privacy Policy will be updated before ads go live, with a clear statement of which provider is used and which categories of data the ad system processes
• A new specific consent category will be added to the cookie banner, separate from the analytics category
• Without consent, no advertising scripts will be loaded
• The previous consent given for analytics alone will NOT be automatically extended to advertising

5. How long we keep it

Data type	Retention
Anonymous per-visit record (no consent, no identifiers)	18 months, then automatically deleted
Per-visit analytics (with consent)	90 days, then automatically deleted by our database
Consent record (accept)	180 days, then automatically deleted
Consent record (reject)	Not stored: refusal is honoured only on the current page; the banner re-appears on the next page until you accept
Contact messages	Until you ask us to delete them, or until the topic is resolved and no further follow-up is reasonably expected
Newsletter subscription	Until you unsubscribe (email [email protected]); deleted within 30 days from request
Outbound link clicks	18 months, then automatically deleted
Operational server logs	Maximum 6 months, then deleted

6. Your rights

Under the GDPR you have the right to:

• Access, ask us what data we hold about you (Art. 15)
• Rectification, ask us to correct inaccurate data (Art. 16)
• Erasure ("right to be forgotten"), ask us to delete data we hold about you (Art. 17)
• Restriction of processing, ask us to stop processing while a complaint is under review (Art. 18)
• Portability, receive your data in a machine-readable format (Art. 20)
• Objection, object to processing based on legitimate interest (Art. 21)
• Withdraw consent at any time, with no negative consequence on your access to the site (Art. 7(3))
• Lodge a complaint with the supervisory authority. In Italy the Garante per la protezione dei dati personali

To exercise any of these rights, email us at [email protected]. We respond within 30 days. To help us find your records, include the approximate date of your visits and any visitor identifier you may have noted (advanced).

7. Cookies and similar technologies

We do not set HTTP cookies for analytics or tracking. The only storage we use is browser localStorage and sessionStorage, and only after you give consent:

• localStorage: va_vid, a random opaque identifier used to recognise you across visits. Created only after you accept. Cleared whenever you clear your browser's site data, or when you ask us to delete it.
• sessionStorage: va_sid, a random opaque identifier used to group page views in the same browser tab. Cleared automatically when you close the tab.

No third-party scripts set cookies on this site.

8. Automated decision-making and profiling

We do not perform automated decision-making producing legal or similarly significant effects (Art. 22 GDPR). We do not profile individual users for marketing or advertising. Analytics are used in aggregate to inform editorial decisions only.

9. Security

Data in transit is always encrypted. The analytics database is reachable only via a private encrypted channel with strong authentication; it is never exposed to the public Internet.

10. Children

The site is not directed at children under the age of 16. We do not knowingly collect data of children. If you believe a minor has provided data, contact us and we will delete it.

11. Changes to this policy

If we change this policy materially, we will publish a new version with an updated version number and date. Consent given under an older version is automatically considered withdrawn for the parts that change; users will be re-prompted.

12. Manage your consent

You can withdraw or change your consent at any time. The banner appears on every page until you click Accept, and re-appears automatically after 180 days from acceptance. To withdraw consent you have already given, clear the site data in your browser's settings (this removes the visitor identifier) and click Reject on the next banner.

Version 1.1, Last updated: 2026-05-18. Changes from 1.0: added section 2.5 "When you click an outbound link" + retention row; consent indexed by browser-resident visitor identifier (vid) instead of server-side fingerprint; rate-limit anti-spam on contact and newsletter forms.