Privacy Policy
ABGEN – Luxury Services Intermediary
Last Updated: October 21, 2025
The data controller for your personal information is:
ABGEN – Luxury Services Intermediary
Company Registration: [Your Company Registration Number]
Via Francesco Donati, 34c
Rome, 00126, Italy
VAT Number: IT15867331009
Business Type: Intermediario (Service Intermediary Platform)
Data Protection Officer: [DPO Name] -abgentop@gmail.com
Booking ServicesInformation You Provide
Personal Details: Name, email address, phone number, date of birth
Service Matching: Preferences, requirements, location, travel dates to connect you with appropriate service providers
Payment Processing: Transaction details for intermediary services (processed securely through Stripe)
Communication: Messages between customers and service providers, reviews, customer service interactions
Legal Basis: Contract performance (intermediary services), legitimate interests (platform operations)
AutomaticTechnical Information
Device Information: IP address, browser type, device type
Usage Data: Pages visited, time spent, click patterns
Cookies: As described in our Cookie Policy
Location: General location (country/city level) for service customization
Legal Basis: Legitimate interests, consent (for cookies)
OptionalMarketing Communications
Email Marketing: Updates about new services, special offers
SMS Marketing: Booking reminders, exclusive deals (where consented)
Social Media: Interactions on our social media channels
Legal Basis: Explicit consent (can be withdrawn anytime)
Intermediary Services:
- • Connect customers with vetted service providers
- • Facilitate booking communications and arrangements
- • Process intermediary fees and commissions
- • Provide platform support and dispute resolution
- • Monitor service quality and provider compliance
Legal Compliance:
- • Comply with Italian tax and accounting laws
- • Meet anti-money laundering requirements
- • Respond to legal requests
- • Maintain business records
Business Operations:
- • Improve our services and website
- • Analyze usage patterns and preferences
- • Prevent fraud and ensure security
- • Develop new features and services
Marketing (with consent):
- • Send promotional emails and offers
- • Personalize marketing content
- • Conduct market research
- • Manage loyalty programs
Platform Partners (Data Processors):
Payment Processing: Stripe (secure payment handling for intermediary fees)
Service Providers: Vetted luxury service companies (receive customer details for service delivery)
Email Services: Brevo (platform communications)
Analytics: Google Analytics (platform usage analysis)
Customer Support: [Your support platform] (intermediary support services)
Cloud Hosting: [Your hosting provider] (platform infrastructure)
Legal Requirements:
We may share data when required by Italian or EU law, court orders, or to protect our legal rights and those of our users.
✓ Right of Access
Request a copy of all personal data we hold about you.
✓ Right to Rectification
Correct any inaccurate or incomplete personal data.
✓ Right to Erasure
Request deletion of your personal data (subject to legal obligations).
✓ Right to Restrict Processing
Limit how we use your personal data in certain circumstances.
✓ Right to Data Portability
Receive your data in a structured, machine-readable format.
✓ Right to Object
Object to processing based on legitimate interests or direct marketing.
✓ Right to Withdraw Consent
Withdraw consent at any time where processing is based on consent.
✓ Right to Lodge a Complaint
File a complaint with the Italian Data Protection Authority.
We retain personal data only as long as necessary for the purposes outlined in this privacy policy and to comply with legal obligations.
Platform Data:
- • Active service connections: Until completion + 2 years
- • Cancelled requests: 1 year from cancellation
- • Intermediary transaction records: 10 years (Italian tax law)
- • Platform support: 3 years from last interaction
- • Provider-customer matching data: 5 years
Marketing Data:
- • Email subscribers: Until unsubscribed + 1 year
- • Analytics data: 2 years maximum
- • Cookie data: As per Cookie Policy
- • Inactive accounts: 3 years without activity
Some of our service providers may process data outside the European Economic Area (EEA). We ensure adequate protection through:
Adequacy Decisions:
Data transfers to countries recognized by the EU Commission as providing adequate protection.
Standard Contractual Clauses:
Binding contracts with service providers that include EU-approved data protection clauses.
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.
Encryption
Data encrypted in transit and at rest using industry standards
Access Control
Strict access controls and regular security audits
Compliance
Regular compliance reviews and staff training
Data Protection Queries:
Italian Data Protection Authority:
Garante per la protezione dei dati personali
Piazza di Monte Citorio, 121
00186 Roma, Italy
Parental Consent (Italy)
For users under 16 years old in Italy, parental or legal guardian consent is required to use the platform and for the processing of personal data.
Parental Consent
For users under 16 years old, parental or legal guardian consent is required for platform use and personal data processing.
Age Verification: We reserve the right to request proof of age and parental consent documents when necessary.
We may update this privacy policy to reflect changes in our practices or for legal, operational, or regulatory reasons.
Current Version: 1.0
Last Updated: October 21, 2025
Next Review: October 2026
Material changes will be communicated via email to registered users and prominently displayed on our website.