Privacy policy
Version: 1.0.0
Operational text. Final legal wording must be verified by a professional before it can be considered fully compliant. Not legal advice.
1. Data controller
Controller: Pizzo Matteo Mario — UP101 VAT: IT02815530064 Fiscal address: Corso Crimea 35 15121 Alessandria (AL) Italia Privacy contact: info@up101.dev PEC: matteomariopizzo@pec.it UP101 TravelOS is the product/platform name. UP101 is the trade name. Tenerife is the current operational market. UP101 Tenerife is the market operating name and does not denote a separate Spanish company.
2. Purposes of processing
We process personal data to: • Handle free audit requests, contact forms, and authorised commercial communications. • Manage the B2B relationship with clients and qualified prospects. • Maintain system security, record consents, and comply with legal obligations. • Handle data subject rights requests (access, rectification, erasure, etc.). • Operate internal scoring and commercial eligibility rules without automated legal effects on you.
3. Legal basis
Applicable bases include: • Art. 6(1)(b) GDPR — pre-contractual steps or contract at your request. • Art. 6(1)(a) GDPR — specific, informed, non-pre-ticked consent for marketing. • Art. 6(1)(c) GDPR — legal obligation. • Art. 6(1)(f) GDPR — legitimate interest in security and prudent B2B relationship management. For B2B prospect data obtained without a prior form, see /privacy-prospect (Art. 14 GDPR).
4. Categories of data
We may process: identity and contact data, business data, language preference, consent records, technical metadata (IP, user agent) for consent proof and security, and operational service data.
5. Retention
We keep data as long as needed for the stated purpose, the business relationship, and accountability obligations. Marketing consents are reviewed periodically.
6. Recipients
Data may be accessed by authorised UP101 staff and, where necessary, processors under contract (hosting, email, infrastructure). We do not sell personal data.
7. International transfers
We prefer providers within the EEA. Any future transfers outside the EEA will use appropriate safeguards under GDPR and an updated policy.
8. Your rights
You may exercise access, rectification, erasure, restriction, objection, portability, and withdrawal of consent by emailing info@up101.dev or using /privacy-rights. You may also use PEC matteomariopizzo@pec.it for certified communications. We respond within one month, extendable under GDPR. We do not require ID unless there is reasonable doubt about your identity.
9. Supervisory authority
You may lodge a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es. Depending on the case, you may also contact the authority of your habitual residence.
10. Marketing
Commercial communications require a valid legal basis. Marketing consent on forms is optional, specific, and not pre-ticked. You may opt out anytime via unsubscribe links or info@up101.dev.
11. Audit and contact forms
Public forms collect only necessary data. Privacy consent is required to submit. Technical metadata may be logged for consent evidence and abuse prevention.
12. Internal scoring and automated decisions
UP101 uses internal scores and eligibility rules. They do not produce legal effects or similarly significant automated decisions under Art. 22 GDPR: they do not deny public services or make binding decisions without human review.
13. B2B service
UP101 Tenerife provides B2B direct booking, automation, and growth services. UP101 TravelOS is the product/platform name. UP101 is the trade name. Tenerife is the current operational market. UP101 Tenerife is the market operating name and does not denote a separate Spanish company. Client contracts may include specific terms, DPAs (when UP101 acts as processor for the client), and retention policies.
Document subject to external professional review. Not legal advice or a guarantee of absolute compliance.