Privacy Policy
Effective 1 January 2026 · Last reviewed 14 February 2026 · Applies to cleverpocketbrowsng.living and all associated subdomains.
Effective 1 January 2026 · Last reviewed 14 February 2026 · Applies to cleverpocketbrowsng.living and all associated subdomains.
This website, cleverpocketbrowsng.living (the "Site"), is owned and operated by Aurelia Travertine Media S.r.l. ("we", "us", "our"), a limited liability company registered in Italy under company number IT-09847213, with its registered and operational office at Via dei Coronari 148, 00186 Roma RM, Italy. For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR") and Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018, we are the data controller of the personal data described in this policy.
Questions about this policy, or any request relating to your personal data, should be addressed to our Data Protection Officer at [email protected] or by post to the address above, marked for the attention of the Data Protection Officer.
We deliberately collect as little personal data as is practical for an editorial publication. The categories we process are:
We do not knowingly collect special category data (racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning sexual orientation). Please do not include such information in contact form messages. We do not collect payment card details, because we do not process transactions: all bookings are made directly with the hotels on their own systems.
We rely on the following lawful bases under Article 6(1) GDPR:
We use personal data to reply to enquiries and provide the editorial guidance requested; to correct factual errors reported by readers; to operate, secure and improve the Site; to measure which articles and hotels readers find useful, in aggregate; to comply with our legal and regulatory obligations; and to administer commercial relationships with syndication partners. We do not sell personal data, we do not share it with advertisers, and we do not use it to build individual advertising profiles.
The Site uses a small number of cookies and browser storage keys. Strictly necessary items load without consent; analytics and functional items load only after you accept them through the consent banner. A complete, itemised breakdown — including names, purposes, providers and retention periods — is published in our Cookie Policy. You may change or withdraw your choice at any time by clearing site data in your browser, which causes the consent banner to reappear on your next visit.
We use a limited number of carefully selected service providers, each engaged under a written data processing agreement meeting the requirements of Article 28 GDPR:
| Processor | Purpose | Data processed | Location |
|---|---|---|---|
| European web hosting provider | Site hosting, CDN, TLS termination | IP address, server logs | EU (Frankfurt, Milan) |
| Privacy-first analytics provider | Aggregate readership measurement | Truncated IP, page URL, referrer | EU (Dublin) |
| Transactional email provider | Delivery of enquiry responses | Name, email, message content | EU (Amsterdam) |
| Unsplash (image delivery) | Serving photography assets | IP address, user agent | USA — SCCs in place |
| Google Maps (contact page) | Embedded office location map | IP address, device data | USA — SCCs in place |
| Google Fonts | Typeface delivery | IP address, user agent | USA/EU — SCCs in place |
We may also disclose personal data to our professional advisers (lawyers, accountants, auditors) where necessary, and to competent public authorities where we are legally required to do so. In the event of a merger, acquisition or asset transfer, personal data may be transferred to the acquiring entity subject to the protections in this policy.
Our primary infrastructure is located within the European Economic Area. Where a processor transfers data outside the EEA — principally the United States, in connection with map, font and image delivery — the transfer is protected by the European Commission's Standard Contractual Clauses (Decision 2021/914) and, where applicable, the EU–US Data Privacy Framework, supplemented by technical measures including encryption in transit. You may request a copy of the relevant transfer safeguards by writing to our Data Protection Officer.
Where data is no longer required, it is deleted or irreversibly anonymised according to a documented schedule reviewed annually.
If you are located in the EEA, the UK or Switzerland, you have the right to: request access to the personal data we hold about you (Art. 15); request rectification of inaccurate data (Art. 16); request erasure, the "right to be forgotten" (Art. 17); request restriction of processing (Art. 18); receive your data in a structured, commonly used, machine-readable format and transmit it to another controller (Art. 20); object to processing based on legitimate interests, including profiling (Art. 21); withdraw consent at any time (Art. 7(3)); and not be subject to decisions based solely on automated processing producing legal or similarly significant effects (Art. 22 — we do not carry out such processing).
To exercise any right, email [email protected]. We will respond within one calendar month, extendable by two further months for complex requests, in which case we will tell you within the first month. We may ask for proportionate information to verify your identity. There is no charge unless a request is manifestly unfounded or excessive.
You also have the right to lodge a complaint with a supervisory authority. In Italy this is the Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Roma (garanteprivacy.it). You may alternatively complain to the authority in your country of residence or place of the alleged infringement.
If you are a California resident, you have the right to know what categories of personal information we collect, the purposes for which they are used, and the categories of third parties with whom they are shared; the right to request deletion; the right to request correction; the right to opt out of the "sale" or "sharing" of personal information; the right to limit the use of sensitive personal information; and the right not to be discriminated against for exercising these rights. We do not sell or share personal information as those terms are defined under the CPRA, and we do not process sensitive personal information for the purpose of inferring characteristics. To submit a request, email [email protected] with the subject line "CPRA Request". Authorised agents may submit requests with written proof of authorisation.
We apply technical and organisational measures appropriate to the risk, including TLS 1.3 encryption for all traffic, encryption at rest for stored enquiry data, role-based access control limited to named personnel, multi-factor authentication on all administrative accounts, regular dependency patching, quarterly access reviews and an annual restore test of backups. No system is completely secure; in the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the Garante within 72 hours and, where the risk is high, notify affected individuals without undue delay.
The Site is intended for adults planning travel and is not directed at children. We do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with personal data, contact the Data Protection Officer and we will delete it promptly.
The Site links to third-party websites, principally the official sites of the hotels we review. Those sites have their own privacy policies and we have no control over, and accept no responsibility for, their content or data practices. Following an outbound link means leaving our Site; we recommend reading the privacy policy of any site you visit.
We may update this policy to reflect changes in law, technology or our practices. The "last reviewed" date at the top of this page will change accordingly. Material changes affecting your rights will be announced with a prominent notice on the Site for at least 30 days. We encourage you to review this page periodically.
Aurelia Travertine Media S.r.l., attn. Data Protection Officer, Via dei Coronari 148, 00186 Roma RM, Italy · [email protected] · +39 06 9876 5432
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