Privacy Policy
Last updated: March 2026
At Emotional Sicily, privacy is not just a legal obligation, it is a matter of trust. This Privacy Policy explains how we collect, use, store, and protect your personal data when you interact with us through our website or enquiry channels.
1. Data Controller
The data controller responsible for your personal data is:
Emotional Sicily — Manila Di Maira
Carrer Princesa, 52 — 08003 Barcelona, Spain
Email: info@emotionalsicily.com
Website: www.emotionalsicily.com
Note: A Data Protection Officer (DPO) is not required for this processing activity under GDPR Article 37, as Emotional Sicily does not carry out large-scale systematic monitoring or processing of special categories of data as a core activity.
2. What data we collect
a. Contact and identification data
- Name and surname
- Email address
- Phone number
- Nationality / country of residence
b. Booking and travel data
- Travel preferences and interests
- Requested travel dates and itineraries
- Passport details (only when required for specific bookings)
- Emergency contact information
c. Special categories of data (Article 9 GDPR)
Where you voluntarily provide information related to:
- Dietary requirements
- Health conditions relevant to participation in an experience
- Accessibility or mobility needs
This data is processed exclusively on the basis of your explicit consent (Article 9(2)(a) GDPR) and/or where necessary for the provision of the service in the context of travel arrangements (Article 9(2)(h) GDPR). This data is used solely to deliver your experience and is never shared beyond the service providers strictly involved.
d. Payment data
- Billing name and address
- Transaction references
Payments are processed via secure third-party platforms (e.g. Stripe, PayPal, bank transfer). We do not store full card details.
e. Technical and browsing data
- IP address
- Browser type and version
- Device information
- Website usage data (via cookies — see Cookie Policy)
3. How we collect your data
We collect data when you:
- Contact us by email at info@emotionalsicily.com
- Contact us via WhatsApp or other messaging channels
- Request a proposal, quote, or itinerary
- Confirm a booking and complete payment
- Subscribe to our newsletter
- Browse our website (via cookies and analytics tools)
4. Purposes and legal basis
| Purpose | Legal Basis |
| Respond to enquiries and requests | Pre-contractual measures (Art. 6(1)(b)) |
| Design and manage your travel experience | Contract performance (Art. 6(1)(b)) |
| Coordinate services with suppliers | Contract performance (Art. 6(1)(b)) |
| Process payments | Contract performance (Art. 6(1)(b)) |
| Send relevant service communications | Contract / Legitimate interest (Art. 6(1)(f)) |
| Send newsletter and marketing updates | Consent (Art. 6(1)(a)) |
| Process health/dietary data | Explicit consent (Art. 9(2)(a)) or Art. 9(2)(h) |
| Comply with legal and tax obligations | Legal obligation (Art. 6(1)(c)) |
| Improve our website and services | Legitimate interest (Art. 6(1)(f)) |
5. Data sharing
a. Service providers (travel suppliers)
We share only the data strictly necessary to deliver your experience with:
- Hotels and accommodation providers
- Local guides and activity operators
- Drivers and transport providers
- Event and venue partners
- Suppliers in Sicily and internationally
b. Technical and operational providers
We work with the following third-party platforms that may process your data as data processors:
- Stripe / PayPal — payment processing
- Mailerlite — email marketing and newsletter management
- Ezus — CRM and travel proposal management
- Google Analytics — website analytics (anonymised data)
- WhatsApp (Meta) — direct client communication
All processors are bound by Data Processing Agreements (DPAs) in compliance with GDPR.
c. Legal and regulatory authorities
We may disclose data to competent authorities when required by applicable law.
6. International data transfers
Given the international nature of our services, your data may be transferred outside the European Economic Area (EEA) — for example, to suppliers in Sicily (Italy, within EEA) or to providers such as Google (USA) and Meta/WhatsApp (USA).
When transfers occur outside the EEA, we ensure appropriate safeguards are in place, such as:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Providers certified under applicable adequacy decisions or supplementary measures
7. Data retention
| Data type | Retention period |
| Enquiries (no booking) | Up to 24 months from last contact |
| Booking and travel data | Duration of relationship + 5 years (legal obligations) |
| Invoices and financial records | As required by Spanish and applicable tax law (typically 5–7 years) |
| Passport and identity data | Deleted within 30 days of the end of the trip |
| Health and special categories data | Deleted immediately after service delivery |
| Marketing / newsletter data | Until consent is withdrawn |
| Website analytics data | As configured in analytics platform (typically 14–26 months) |
8. Your rights under GDPR
Under the General Data Protection Regulation (GDPR) and Spanish data protection law (LOPD-GDD), you have the right to:
- Access — obtain a copy of your personal data
- Rectification — correct inaccurate or incomplete data
- Erasure — request deletion of your data (“right to be forgotten”)
- Restriction — limit how we use your data in certain circumstances
- Portability — receive your data in a structured, machine-readable format
- Objection — object to processing based on legitimate interests
- Withdraw consent — at any time, without affecting prior lawful processing
To exercise any of these rights, please contact: info@emotionalsicily.com
You also have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos — AEPD): www.aepd.es
9. Data security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, misuse, or disclosure. These include secure communications channels, restricted access controls, and regular review of our data handling practices.
10. Marketing communications
You will only receive marketing or promotional communications from us if:
- You have given your explicit consent (newsletter subscription); or
- There is an existing client relationship and the communication is directly related to similar services, where permitted by applicable law
You can unsubscribe at any time by clicking the unsubscribe link in any email, or by contacting us directly at info@emotionalsicily.com.
11. Cookies
Our website uses cookies and similar tracking technologies. For full details, please refer to our Cookie Policy below.
12. Third-party links
Our website may contain links to third-party websites. Emotional Sicily is not responsible for the privacy practices or content of those sites. We recommend reviewing their privacy policies before sharing any personal data.
13. Updates to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The most recent version will always be published on this page with the date of the last update.