Legal
Privacy Policy
Last updated: 11 June 2026
1. Data Controller
VOLARÉ — Private Aviation & Luxury Travel Concierge, based in Milan, Italy, is the data controller for personal data processed through this website and through concierge communications. For any privacy request you may contact us at volareluxuryclubitalia@gmail.com.
2. Data we collect
- Contact data you provide when submitting a concierge request (name, email, phone, language, travel preferences, dates, party size).
- Conversation data exchanged with our concierge through the chat widget, email or messaging apps.
- Technical data automatically collected by your browser (IP address, user agent, pages visited, referrer, timestamps).
3. Purpose and legal basis
- Replying to your requests and arranging private aviation, yacht, villa and bespoke travel services — legal basis: performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR).
- Operating and securing the website — legal basis: legitimate interest (Art. 6(1)(f) GDPR).
- Analytics and traffic measurement — legal basis: your consent (Art. 6(1)(a) GDPR), collected through the cookie banner.
- Compliance with legal, accounting and anti-money-laundering obligations — legal basis: legal obligation (Art. 6(1)(c) GDPR).
4. Sharing of data
To fulfil your travel requests, your data may be shared with certified aviation operators, licensed brokers, yacht companies, villa custodians, hotels, restaurants and ground transport partners strictly to the extent needed to deliver the service. We also use trusted technical processors (hosting, email, analytics, chat platform) acting as data processors on our behalf.
5. International transfers
Where data is transferred outside the European Economic Area, we rely on adequacy decisions or Standard Contractual Clauses approved by the European Commission.
6. Retention
Concierge correspondence and booking records are retained for the time strictly necessary to deliver the service and for the legal terms required by Italian law (typically up to 10 years for accounting records). Analytics data is retained for a maximum of 26 months.
7. Your rights
You have the right to access, rectify, erase, restrict or object to the processing of your personal data, to data portability and to withdraw consent at any time. You may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali — www.garanteprivacy.it). To exercise your rights, write to volareluxuryclubitalia@gmail.com.
8. Cookies
See our Cookie Policy for details on the cookies used by this website and how to manage your preferences.