Guidalia
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Privacy Policy

Version 2026-10-29, effective 2026-10-29

Data Protection Officer For questions about your personal data or to exercise your privacy rights, contact our Data Protection Officer at dpo@guidalia.com

Provided pursuant to arts. 13 and 14 of Regulation (EU) 2016/679 (GDPR).

This is an automatic translation of the Italian original. If the translation differs from the Italian text in meaning or content, the Italian version prevails.

This notice explains which personal data we collect when you use Guidalia, why we use it, who we share it with, how long we keep it and what rights you have. It applies to the Guidalia app, the Guidalia for Guides app and all websites in the https://guidalia.com domain. It also applies if you work for a museum, an attraction or an event organiser that uses Guidalia Tickets, if you listen to a live audio session without having an account, if you write to us from the website or if you use Guidalia from an AI assistant through the MCP connector: the specific rules for these cases are in section 13.

1. Who processes your data

Data controller: Guidalia S.r.l., Via Livorno 54/2, 50142 Firenze (FI), VAT No. 07560660487. For any question or to exercise your rights, write to privacy@guidalia.com.

Data Protection Officer (DPO): dpo@guidalia.com.

2. In brief

  • Guidalia is a service for exploring places with audio guides generated by artificial intelligence or curated by itinerary creators, planning itineraries, booking live guides and taking part in tours translated in real time.

  • We use your data to let you use the service. We do not sell your data and we do not use it for third-party advertising.

  • Some features use artificial intelligence providers that process your voice and your requests: we do not keep audio recordings and the providers are contractually bound not to use your data to train their models.

  • In live audio sessions, the translation you hear is spoken by a synthetic voice generated by artificial intelligence, not by the voice of the person speaking.

  • In the apps, statistical analytics (and, in earlier app versions, campaign measurement) start only if you give your consent, which you can withdraw at any time from the section Account → Privacy and consents; in the Guidalia web application, statistical analytics start only with the consent given in the banner; on all websites we measure visits in aggregate form, without cookies and without identifying you (section 12).

  • Geolocation is used to show you what is around you and to let you meet your guide: you control it from your phone's settings.

  • In-app purchases (credits, Trip Pass, creator content) go through the Apple and Google stores; guide bookings go through Stripe. In no case do we see or store your card number: we receive only the brand and the last four digits of the card, to show you which card is used.

  • Your main data is stored in the European Union (Italy); some providers, including those of the artificial intelligence services, also operate outside the EU, in particular in the United States, with the safeguards provided for by the GDPR.

3. Who this notice is for

You are… Of particular relevance to you
Traveller or tourist with an account All sections
Anonymous user (you use the app, redeem a QR code or download an itinerary without registering) Sections 4–6 limited to device data, the content you unlock, plays and use of the artificial intelligence services, 7, 8, 9–11
Professional guide registered on the marketplace All sections and, in particular, 5.4, 5.7, 5.8 and 6.2
Content creator (Creator Studio) All sections and, in particular, 13.4
Staff of a partner organisation (museums, attractions, municipalities, tourism bodies, events) using Guidalia Tickets Sections 1, 7, 9, 10 and 13.1
Participant in a live audio session without an account Sections 1, 5.1, 7, 9, 10 and 13.2
Anyone who writes to us from the forms on the https://guidalia.com website Sections 1, 7, 9, 10, 12 and 13.3
Anyone who uses Guidalia from an AI assistant (for example ChatGPT or Claude) through the MCP connector Sections 1, 8, 9, 10, 12 and 13.5

Guidalia is reserved for natural persons over 14 years of age: by registering you confirm that you are over 14. To receive payments as a guide or as a professional creator you must be of age (18 years). If you travel with children you can indicate this to receive suitable suggestions: the indication refers to the travel group; we do not ask for the children's names, ages or other data and we do not create profiles relating to them. The indication remains in your preferences until you change it or close your account.

4. What data we collect

Category Data How we obtain it
Account and identity E-mail, first name and surname, display name, profile photo (guides only), user identifier, sign-in provider (Apple, Google, e-mail) From you, at registration
Device Installation identifier, model and operating system, language, notification token (for guides on iOS, also the tokens of Live Activities); in the Guidalia app and web application, an anonymous identifier (guidalia_anon) for content unlocked or downloaded without an account, with a QR code or a shared link; a pseudonymised fingerprint of the device identifier, to grant welcome credits only once per device Automatically from the app or the browser
Partner and invitation codes Partner code (for example of a hotel) or invitation code of a friend that you enter or open from a link or a QR code; the partner to which your registration is attributed; on Android, the code read once from the Google Play Store install referrer From you; on Android, from the Google Play Store when you first open the app
Location GPS coordinates while you use the features that need them; meeting point with the guide; operating areas (guides). Guides only: the position shared from the Guidalia for Guides app, also in the background, during an active booking and while "Available now" is switched on (section 5.2) From your device, if you enable it in the operating system settings
Voice and requests Microphone audio when you talk to the concierge, ask an audio guide questions or conduct a live audio session as a guide; text of your questions; chosen language From you, only when you activate the microphone by holding down the button with the microphone icon
Interests and preferences Topics that interest you (art, history, local culture…), indication that children are present in the group, saved itineraries, preferences inferred from use From you and from the way you use the service
Bookings and communications Booking requests, dates and times, group size, booking code, free-text notes, special needs of the group if you choose to indicate them (see "Special categories of data" below), messages exchanged with the guide, meeting point, reports of a problem with the booking or of the guide not arriving, with the guide's reply and the outcome From you and from the guide
Payments For in-app purchases: transaction and store receipt identifier, product purchased, amount, date, credit balance. For bookings: Stripe customer identifier, brand and last four digits of the card, amounts, transaction outcome and, if you dispute a charge with your bank, the data of the dispute. We do not receive the full card number, the expiry date, the security code or the store's billing data. For guides: bank and tax data collected by Stripe to execute payments and, for DAC7 obligations, also by us ("Tax data" row); outcome of payouts, any amounts owed to Guidalia and monthly commission statements From you via Apple or Google (in-app purchases) and via Stripe (bookings)
Professional profile (guides) Biography, tagline, ENGT and/or RNGAE card number, regional registrations, languages, rates, photos, specialities, areas in which you operate; telephone number, which we do not show to travellers From you
Tax data (guides for DAC7; professional creators for payments) Type of entity: natural person, natural person with a VAT number (professional creators only) or legal person. Natural person: first name, surname, residential address (street, postcode, city, country), tax identification number and country that issued it, date of birth and, only if there is no tax identification number, place of birth (city and country). Legal person: name, registered office (street, postcode, city, country), tax identification number, business register number and place of registration. In all cases: VAT number, if any (mandatory for natural persons with a VAT number resident in the EU); IBAN of the account on which you receive payments and account holder, if different; consideration, commissions and number of services provided through Guidalia. For professional creators resident in Italy, also: the declaration that the activity is occasional (art. 67 TUIR), with its date, if you are a natural person without a VAT number; the nature of the income (self-employment or business) and the tax regime (ordinary or flat-rate), if you have a VAT number. For professional creators, also a telephone number for any urgent contacts (which will never be shared with users or third parties) From you, when you register as a guide or as a professional creator; if you are a guide and become a professional creator, from the tax data you have already given us as a guide (section 13.4); amounts and commissions from our records
Reviews Ratings and text of the reviews you write or receive about guides, guided tours and itineraries, and the guides' replies From you and from other users
Images Guides' profile photos, photos you upload or take with the "What is it?" feature From you
Creator content (Creator Studio) Photos, audio, video and texts you upload and publish; documents and web addresses you indicate as sources; texts, translations, transcriptions and voices generated with artificial intelligence; use of artificial intelligence services against the limits of your plan and credits From you and from our systems
Consents and other declarations The choices you make about analytics and marketing; your acknowledgement of this notice; acceptance of the Terms of Use; with date and time, version and fingerprint of the document, channel and method, IP address, browser type (user agent) and device language Automatically, when you choose or accept
Use of the service (only with consent) Screens and pages visited, features used, events in the apps and in the Guidalia web application, user identifier Automatically, if you have consented to analytics
Anonymous use For those who use Guidalia without an account: content unlocked with a QR code or a shared link, itineraries played (also offline, synchronised when the connection returns), use of the artificial intelligence services against the allowance of the content unlocked Automatically, linked to the anonymous identifier
Website visit statistics Page visited, referring site, country, browser type, operating system and device; a daily identifier calculated from IP address and browser, which is not stored Automatically, when you visit the https://guidalia.com websites
Diagnostics App errors, performance, pseudonymous device identifier, IP address in server logs Automatically

Special categories of data. We do not ask for and do not intentionally collect data concerning religion, sexual orientation or other special categories (art. 9 GDPR), with one exception, which is optional: when you request a private tour you can tell the guide about the special needs of your group (for example children, reduced mobility, wheelchair use, visual or hearing impairment, vertigo, claustrophobia, allergies or intolerances, assistance animal, or a short description of your own). This information can reveal data concerning health: we process it only with your explicit consent (art. 9.2.a GDPR), which you give in the same screen in which you indicate it, and only so that the guide can assess the request and organise the tour. It is shown only to the guide you send the request to and appears in the booking e-mails; it is not sent to Stripe or to other providers for their own purposes. You can leave it blank; you can withdraw your consent at any time by writing to privacy@guidalia.com, and we then delete the information (the guide may no longer be able to take it into account). In any case we delete it 30 days after the end of the tour (or after the cancellation or expiry of the request) and in any case when you close your account. Since you can write or speak freely in forms, chats and questions, you might spontaneously share some such data with us: we ask you not to do so. If this happens, that data is processed only to the extent strictly necessary to respond to your request in the same session: questions to the concierge and audio are not stored, chats are deleted when the booking is closed, and we do not use that data to profile you, to personalise content or for any other purpose. If you report to us, or if we detect, data of this kind in content that we store (for example notes or reviews), we delete it. None of our systems is used to identify you by your voice: we do not process biometric data.

Mandatory data. To register we only ask for your first name, surname and e-mail: without this data we cannot create your account. To book a guide you must also provide a payment card, which is saved with Stripe (section 5.3). If you register as a guide you must also provide the professional profile data needed to verify your requirements and the tax data required by DAC7 (section 5.8); if you register as a professional creator to sell itineraries, the tax and bank data needed to pay you (section 13.4). All other data is optional or needed only for the features you choose to use: if you do not provide it, those features are not available.

5. Why we use your data and on what legal basis

Purpose Data used Legal basis
Creating and managing your account, authenticating you Account, device Performance of the contract (art. 6.1.b)
Letting you explore places, generating audio guides and answering the questions you ask Voice and requests, location, interests you indicate to us Performance of the contract (art. 6.1.b)
Suggesting itineraries and content based on the interests you indicate to us and on your location Declared interests, location, saved itineraries Performance of the contract (art. 6.1.b)
Refining suggestions based on the preferences we infer from the way you use the app Preferences inferred from use Consent (art. 6.1.a) - withdrawable
Managing bookings and letting you communicate with the guide Bookings and communications, account, location Performance of the contract (art. 6.1.b)
Letting the guide know the special needs of your group (optional) Special needs you indicate Explicit consent (arts. 6.1.a and 9.2.a) - withdrawable
Crediting in-app purchases, collecting booking / itinerary payments on behalf of guides / professional creators and withholding the commission, managing credits and paying guides and professional creators Payments, account, tax and bank data of professional creators and guides Performance of the contract (art. 6.1.b); legal accounting and tax obligations (art. 6.1.c)
Providing live audio sessions with translation to people who have a Guidalia account and to the guides who conduct them from Guidalia for Guides Voice, language, participant identifier Performance of the contract (art. 6.1.b)
Providing live audio sessions to participants without an account Voice, language, anonymous session identifier Performance of the contract (art. 6.1.b)
Verifying guides' professional requirements and publishing their profile Professional profile Performance of the contract (art. 6.1.b); legal obligations (art. 6.1.c)
Fulfilling the tax obligations of platform operators (DAC7 directive): identifying and verifying guides and reporting to the Agenzia delle Entrate (Italian Revenue Agency) the consideration they receive through Guidalia (section 5.8) Tax data (guides, DAC7), payments Legal obligation (art. 6.1.c; D.Lgs. 1 March 2023, no. 32)
Collecting and displaying reviews (section 5.7) Reviews, account Performance of the contract (art. 6.1.b)
Hosting, processing with artificial intelligence and publishing creator content Creator content, account Performance of the contract (art. 6.1.b)
Measuring the use of artificial intelligence services to apply the limits of your plan and deduct credits from your account or, without an account, from the allowance of the content unlocked Account or anonymous identifier, use of the artificial intelligence services used, credit balance or allowance Performance of the contract (art. 6.1.b)
Giving you the extra welcome credits offered by a partner, recognising who invited you and counting registrations per partner in aggregate (section 5.5) Partner and invitation codes, account Performance of the contract (art. 6.1.b)
Granting welcome credits only once per device Pseudonymised fingerprint of the device identifier, account Legitimate interest in preventing abuse (art. 6.1.f)
Sending you notifications and service e-mails (confirmations, reminders, alerts) Device, account Performance of the contract (art. 6.1.b)
Contacting you about service matters relating to your account, bookings, content or payments (guides and professional creators), also on behalf of users in the event of disputes or complaints Personal details, Address, Email, Telephone number Performance of the contract (art. 6.1.b)
Understanding how the apps and the Guidalia web application are used and improving them (statistical analytics) Use of the service, user identifier Consent (art. 6.1.a) - withdrawable
Measuring, in aggregate form and without cookies, visits to the Guidalia websites (section 12) Website visit statistics Legitimate interest in knowing how the websites are used (art. 6.1.f), with data that cannot be traced back to you
Measuring the effectiveness of the campaigns and invitations through which you discovered Guidalia (earlier app versions only) Device, source campaign or invitation code, user identifier Consent (art. 6.1.a) - withdrawable
Sending you promotional communications Account Consent (art. 6.1.a) - withdrawable
Ensuring security, preventing fraud and abuse, correcting errors Diagnostics, device Legitimate interest in the security and continuity of the service (art. 6.1.f)
Demonstrating the choices you have made about consents, that you have received this notice and that you have accepted the Terms of Use Consents and other declarations Legal obligation (arts. 5.2, 7.1 and 13) for consents and acknowledgement of the notice; performance of the contract (art. 6.1.b) for acceptance of the Terms of Use
Responding to your requests about your data and to complaints Account, content of the request Legal obligation (arts. 12–22)
Defending our rights in the event of disputes, including the evidence of the booking that we send to Stripe if you dispute a charge with your bank (section 6.2) The data necessary for the case Legitimate interest (art. 6.1.f)

We rely on performance of the contract only for processing that is strictly necessary to provide you with the feature you have chosen to use. Ancillary or enhancement features are based on your consent. We rely on legitimate interest only where no other basis is appropriate: security, prevention of fraud and abuse (including repeated claims of welcome credits), technical diagnostics, aggregate cookie-free statistics on website visits and defence of our rights.

Device permissions and legal bases. The permissions you grant to the operating system (microphone, location, notifications) technically enable the feature on your device; they are not the legal basis of the processing, which remains the one indicated in the table. If you deny or revoke a permission, the corresponding feature is not available.

Legitimate interest. For processing based on legitimate interest we have documented a balancing test and verified that your interests and rights do not override our interest; you can request a summary by writing to privacy@guidalia.com. You can object on grounds relating to your particular situation: we assess every request and, for security and proper functioning of the service (including technical diagnostics), prevention of fraud and abuse and defence of rights, we normally continue, as explained in section 10.

5.1 Voice and artificial intelligence

When you activate the microphone, or when the guide talks in a live audio session, the audio goes through these steps:

Step What happens Providers
Transmission (live audio sessions only) The audio travels in real time between the person speaking, our servers and the people listening LiveKit
Transcription The voice is converted into text Microsoft Azure (earlier app versions and fallback: OpenAI; fallback: Google Gemini)
AI processing The text is understood and the response, the audio guide or the itinerary is generated Microsoft Azure (fallback: OpenAI, Google Gemini)
Web search (concierge only) When you ask for up-to-date information (for example today's events, opening hours or closures), the text of the request and the city you are in are used to search the web Google (Gemini with Google Search)
Translation (live audio sessions only) The text is translated into the chosen language Microsoft Azure
Speech synthesis The response or the translation is spoken by a synthetic voice Microsoft Azure (fallback for the concierge and the audio guides: OpenAI, Google Gemini)

We transmit audio to AI providers only when it is necessary for the feature you are using: you do not need the microphone to write to the concierge, and where possible we send the transcribed text instead of the audio. Guidalia does not record or store audio; the providers process the data on our behalf and are contractually bound not to use it to train their own models and not to retain it beyond the time necessary to respond, except for the temporary retention that some of them apply to prevent abuse, within the limits set by their respective agreements. None of our systems is used to recognise your identity from your voice. Concierge sessions close after 10 minutes of inactivity.

Primary provider and fallback providers. As a rule, all artificial intelligence features use Microsoft Azure. OpenAI and Google (Gemini) are fallback providers: we activate them only if the primary service is unavailable or not working properly, under the same contractual conditions, and we keep a record of every activation. There are two exceptions. Earlier versions of the Guidalia app transcribe the voice you speak to the concierge and the audio guides with OpenAI, until you update the app. The concierge's web searches always use Google Gemini with Google Search: we send the text of the request and the city, without any identifier of yours, under the same contractual conditions. When OpenAI or Google Gemini handle the voice in real time, your device connects to them directly with a temporary key that we issue, so they also receive your device's IP address. In the free mode of the app, transcription takes place on your device or on our servers, without third-party providers. In all cases requests may also be processed outside the European Union (section 7).

Photos with "What is it?". When you use the "What is it?" feature, the photo you take or upload, your position and the city you are in are sent to the artificial intelligence provider to recognise what you are framing and answer you, only for the current session: the photo is not stored. Avoid framing recognisable people.

AI-generated content. Audio guides, concierge responses and translations are generated by artificial intelligence systems, and we also indicate this in the app at the point where you use each feature, at the latest at the first interaction. In live audio sessions the translation you hear is spoken by a synthetic voice and does not correspond to the natural voice of the guide. They may contain inaccuracies: they do not replace official information on opening hours, prices and safety of places.

5.2 Location

We use your precise location to show you what is around you, adapt audio guides, calculate routes and, if you have a booking, help you and the guide meet. We collect it only while you use the features that need it: the Guidalia app does not collect location in the background. Coordinates are sent to Google's map services only to display maps and calculate walking and public transport routes: when you view a route or ask the concierge how far a place is or how to reach it on foot or by public transport, our servers send Google Routes your coordinates and those of the destination (or the destination you asked for), without any identifier of yours. When you ask the concierge for a nearby service (for example a pharmacy), our servers send the coordinates of that search and the type or name of the service searched, without any identifier of yours, to the public OpenStreetMap Overpass service. Place names, descriptions and photos come from the open sources listed in section 6.3, not from Google. Location is not stored as a history of movements: only the meeting point of the booking remains recorded.

Meeting the guide. During an active booking (confirmed or in progress) the guide can share their position with you to help you meet: you see it on the map and the app calculates the distance on your phone. Your own position is not sent to the guide. Outside an active booking, the guide's position is not shared with you.

Guides. The Guidalia for Guides app uses location, also with the app in the background, only if you have allowed it in your phone's settings, which in that case notify you of it, and only in two cases: (a) during an active booking, to share your position with the traveller; we keep only your last position, which we delete when the booking ends; (b) while you have switched on "Available now", to show travellers your approximate position on the map; we keep only your last known position, which is no longer shown when you switch availability off. Outside these cases we do not collect your location in the background.

You can revoke the permission at any time from your phone's settings: some features will not be available.

5.3 Payments

Payments follow two distinct channels, in neither of which Guidalia receives or stores your card number.

In-app purchases - credit packs, Trip Pass and creator content are purchased from the app via App Store (Apple) or Google Play (Google). Apple or Google is the seller (Merchant of Record): it handles payment with the method registered in your store account, issues the receipt, applies taxes and handles any refunds according to its own terms and its own privacy notice (Apple: https://www.apple.com/legal/privacy; Google: https://policies.google.com/privacy). Guidalia receives from the store only the confirmation of purchase - transaction and receipt identifier, product, amount and date - which we use to credit credits or content to you, verify the validity of the purchase and keep track of it for accounting purposes. We do not receive your payment method or your billing address.

Live guide bookings, live audio sessions and payments to guides - these are handled by Stripe. When you book a tour, the seller is the guide: the payment is made in the guide's name, and the guide's name appears on your card statement. Guidalia, as an intermediary, collects the payment on behalf of the guide via Stripe Connect, withholds its own commission and transfers the remainder to the guide. Card details go directly to Stripe: we receive only an identifier, the brand and the last four digits of the card, the amount and the outcome; the guide does not see your card details.

How a booking is paid:

  • when you send the request, your card is verified (with authentication by your bank, 3-D Secure, if required) and saved with Stripe for the booking, in your Stripe customer profile;
  • about 4 days before the tour (immediately, if the tour is sooner) the maximum amount of the booking is blocked on the card; if the block cannot be placed at least 49 hours before the start, the booking is cancelled;
  • the amount actually due is charged at the end of the tour and the rest is released;
  • with the authorisation you give when booking, Stripe may also charge the saved card without you being present for: the cancellation penalties provided for by the cancellation policy, amounts still due, extensions of the tour, changes in the size of the group and live audio services you request, or a new charge if the block has expired;
  • the card remains saved in your Stripe customer profile until you close your account.

If you book from the Guidalia web application, the card is saved on Stripe's payment page (Stripe Checkout); extensions of the tour paid with a QR code also use Stripe Checkout. Stripe executes the payment as our provider and, for its own legal obligations (verification of guides' identity, anti-money laundering, fraud prevention), is an independent controller and applies its own privacy notice (https://stripe.com/it/privacy).

Live audio sessions - real-time translation and subtitles are a Guidalia service, not a service of the guide: the related amount is collected by Guidalia in its own name, blocked together with the price of the tour and charged according to the minutes actually used. The guide pays Guidalia for the transmission of the session.

5.4 Guides and travellers: who sees what and who is responsible

When you book, the guide sees your first name, the size of your group, any special needs you indicate, the booking code, the language of your app and of the tour, the messages you write to them, the booking notes, the meeting point, the payment status (without your card details), any reports of a problem you send about the tour, with their outcome, and whether you have reported that the guide has not arrived. In shared tours, the other participants see your first name and the size of your group. You see the guide's public profile (name, photo, tagline, biography, languages spoken, rates, reviews, specialities, available times, any "Founder Guide" badge and an indication of their registration in the Italian National Register of Tourist Guides (Elenco Nazionale Guide Turistiche) or the National Register of Environmental Hiking Guides (Registro Nazionale Guide Ambientali Escursionistiche)). The guide's telephone number and their card and registration numbers are not shown to travellers.

Guides are independent professionals. We allocate roles as follows:

  • Guidalia is the controller of the platform: of the account, of the management of the booking and chat, of the management of payments through the platform, of reviews, of security and of all the processing described in this notice.

  • The guide is an independent controller of the data they receive from you to provide you with the tour - first name, group size, special needs, messages, booking notes, meeting point - for the way they use it to organise and conduct the tour and, as seller of the tour, of the payment data they need for their own professional and tax obligations (amount, date, booking reference), and for any direct relationship with you outside the platform. The guide is responsible for this processing and can be contacted directly to exercise your rights; the Terms for guides prohibit them from using your data for purposes other than the booked tour.

Chats are deleted at the end of the booking.

5.5 Analytics, campaigns and promotional communications (only with consent)

In the apps, after you have started using Guidalia and have seen its main features, we ask whether you consent to statistical analytics (Firebase Analytics). Until then, and if you do not consent, this tool remains disabled and collects nothing: it is not even started. We never use analytics data for advertising: the advertising features of Firebase are always disabled. Earlier versions of the apps also ask for consent to campaign measurement (AppsFlyer), with the same rules; the current versions no longer contain AppsFlyer. If you consent and you are signed in, we link the data to your user identifier, so that we can count your use across your devices. You can change your mind at any time from Account → Privacy and consents; withdrawal is applied immediately. In the Guidalia web application the choice concerns only statistical analytics (Firebase Analytics), because campaign measurement is present only in earlier versions of the mobile apps, and it is offered to you through the banner described in section 12; the public website https://guidalia.com, Creator Studio and the Guidalia Tickets and Admin consoles do not use tools that require consent. Promotional communications by e-mail require separate consent and always contain a link to unsubscribe.

Links to download the app, partner codes and invitations. The QR codes and links that we give to our partners (for example hotels) and the invitation links that you can share with your friends from the app take you to a page of the https://guidalia.com website that contains only the partner or invitation code and the links to the stores. On Android, the code is passed to the Google Play Store and the app reads it once, when you first open it (install referrer); on iPhone you can scan the QR code again after installing the app or enter the code in the sign-in screen or in Account → Have a code?. Until you sign in, the code is kept only on your device. We use the code only to give you the extra welcome credits offered by the partner, to recognise who invited you and to count, in aggregate form, how many registrations each partner brings. No tracking tool is involved and no consent is required (section 5). In earlier versions of the apps, campaign links and invitation links went through AppsFlyer: opening the link did not save anything on your device; as happens when opening any link, AppsFlyer received from your browser the IP address and the type of device and browser, in order to direct you to the right store; the click was linked to the installation and to your account (user identifier) only if, in the app, you consented to campaign measurement.

5.6 Diagnostics

To keep the apps and websites working we always collect error reports and performance data (Sentry, Azure Application Insights). This channel receives only a pseudonymous device identifier, never your name, your e-mail or your user identifier; we configure the tools to exclude direct identifiers also from the addresses, parameters and contents of the reports, and we verify this with automated tests and checks at every relevant release.

5.7 Reviews

After a tour, the traveller can review the guide and the guide may respond to a review. Reviews of guides and the related responses are public on their profile and on the page of the guided tour, with the reviewer's first name, together with the average rating and the number of reviews. Those who have played an itinerary can review it: the review is public on the page of the itinerary, with the reviewer's name. Guides do not review travellers. Reviews do not produce automated decisions: they help people choose who to take a tour with. Anyone who writes a review must stick to the facts of the tour, without unnecessary personal data or offensive content.

If a review concerns you and you consider it inaccurate, offensive or containing data it should not contain, you can report it by writing to privacy@guidalia.com: we examine it and, if it violates the community rules or your rights, we remove or correct it, and we reply to you in any case. You can also request rectification of the data concerning you (art. 16). The reviews you write remain visible as long as the reviewed profile exists, and those provided by you become anonymous if you close your account.

5.8 DAC7 tax obligations (guides)

Guidalia is a platform operator within the meaning of Directive (EU) 2021/514 ("DAC7"), transposed in Italy by D.Lgs. 1 March 2023, no. 32. Guides who receive payments through Guidalia are sellers for the purposes of this legislation: for this reason, when you register as a guide, we ask you for the tax data indicated in section 4. If you operate as a legal person (company, association, agency), the data of the legal person is not personal data, but the data of the person who represents it in its relationship with us is.

Providing this data is mandatory by law. If you do not provide it, we cannot complete your onboarding and visitors will not be able to book your services.

Every year, by 31 January, we report this data to the Agenzia delle Entrate together with the consideration you received through Guidalia in the previous year, broken down by quarter, the commissions withheld and the number of services provided. The Agenzia transmits it to the tax authority of the EU Member State in which you reside and, where provided for by international agreements, to that of third countries. By the same date we send you the reported information concerning you, so that you can check it and request its correction.

For this data you can exercise the rights of access and rectification; you cannot object to the processing or obtain its erasure as long as the law requires us to retain it (section 8). We protect the IBAN and the tax number with specific measures: encryption and access limited to the people who handle tax compliance. To receive payments, registration with Stripe also remains necessary (section 5.3).

6. Who we share your data with

We do not sell your data and we do not transfer it to third parties for advertising purposes. We disclose it only to those we need in order to provide the service.

6.1 Providers that process data on our behalf (processors)

Provider For what Where the data is processed
Microsoft (Azure) Database, file storage, service e-mails, monitoring; AI services for concierge, audio guides, planning, translation, transcription and speech synthesis European Union for database, files and e-mails; possible access from third countries for support and security (section 7); the artificial intelligence services may also process data outside the EU, including the United States
Google (Firebase) Authentication, account creation and deletion functions, chat, notifications, remote app configuration, app integrity verification and abuse protection in the web applications (reCAPTCHA), statistical analytics in the apps and in the Guidalia web application (with consent) United States
Google (Maps Platform) Maps, walking and public transport routes (Google Routes) and, in Creator Studio only, address autocompletion United States
Google (Gemini) Web searches for the concierge (Gemini with Google Search); AI services for concierge, audio guides, transcription and speech synthesis as a fallback provider (section 5.1) United States
OpenAI Transcription for earlier app versions; AI services for concierge, audio guides, transcription and speech synthesis as a fallback provider (section 5.1) United States
LiveKit Transmission of live session audio European Union (Germany)
Stripe Execution of payments for bookings, saving of the card for the booking, extensions and live audio sessions Ireland / United States
AppsFlyer Campaign measurement in earlier app versions (with consent) Israel / United States
Sentry (Functional Software) Error reporting European Union (Germany)
Plausible (Plausible Insights OÜ) Aggregate website visit statistics, without cookies European Union (Germany)
Cloudflare Protection of the website against abuse United States

Each provider in turn uses sub-processors, which are identified in the provider's list. The updated list of providers and their sub-processors is available on request from privacy@guidalia.com.

6.2 Other recipients

  • Guides with whom you have a booking, who act as independent controllers for the data necessary to provide you with the tour (section 5.4), and travellers who book a guide (for the guide's public profile).

  • Apple and Google for app distribution, sign-in with an Apple/Google account, notifications and in-app purchases, for which they are the seller (Merchant of Record): they are independent controllers and apply their own privacy notices.

  • Stripe as an independent controller for its own legal obligations (section 5.3) and, if you dispute a charge with your bank, for the dispute: in that case we send Stripe, which forwards it to the card circuit and to your bank, the evidence of the booking (your name and e-mail, the guide's name, the times of the request, of the acceptance and of the tour, the meeting point, your consent to the payment, the brand and last four digits of the card, the amounts and the history of the charges).

  • Agenzia delle Entrate, an independent controller, to which we report the guides' DAC7 data every year and which transmits it to the tax authorities of the State in which the guide resides (section 5.8).

  • Advisors (accountants, lawyers) and authorities when required by law.

  • Museums, attractions and event organisers that use Guidalia Tickets: if you buy or redeem one of their tickets, they are controllers of their own relationship with you and Guidalia processes the ticket data on their behalf (section 13.1).

  • Wikimedia Foundation (Wikipedia), an independent controller: to prepare audio guides and the concierge's answers about a place, the app may request the text of the Wikipedia article directly from Wikipedia, which receives your device's IP address and the article requested, but no account data, and applies its own privacy policy (section 6.3).

6.3 Sources of place information

The names, positions, descriptions and photos of the places in the Guidalia catalogue come from these open sources; places and content added by creators and guides are chosen by their authors and, in Creator Studio, positions can be chosen with Google's address autocompletion (section 6.1). Our servers download the sources' public data and send them no personal data; only the concierge's service searches send the coordinates of the search and the type or name of the service searched (section 5.2). To prepare audio guides and the concierge's answers, the app may also request the text of a Wikipedia article directly from Wikipedia (Wikimedia Foundation, United States): that request carries your device's IP address and the article requested, but no account data (section 6.2).

  • OpenStreetMap: map data © OpenStreetMap contributors, available under the Open Database License (ODbL), https://www.openstreetmap.org/copyright
  • Wikidata: structured data available under Creative Commons CC0, https://www.wikidata.org/wiki/Wikidata:Licensing
  • Wikipedia: article texts available under Creative Commons CC BY-SA, used to write the descriptions of the places, https://en.wikipedia.org/wiki/Wikipedia:Copyrights
  • Wikimedia Commons: photos, each under its own free licence (CC0, public domain, CC BY or CC BY-SA), credited with author and licence next to the photo, with a link to its page on https://commons.wikimedia.org
  • Ministero della Cultura (MiC): open data and images of the "Luoghi della Cultura", credited "Ministero della Cultura" (CC BY 3.0), https://dati.cultura.gov.it
  • GeoNames: names and administrative data of places, available under Creative Commons CC BY 4.0, https://www.geonames.org
  • Esri World Imagery: aerial images used for the photos of the cities, © Esri and its data providers; our servers send only the coordinates of the city centre, https://www.esri.com

7. Transfers outside the European Union

Your account, booking, payment and consent data is stored in Italy, on Microsoft Azure servers in the Italy North region. Some providers process data outside the European Union:

  • Google (Firebase, Maps Platform, Gemini), OpenAI and Cloudflare process data in the United States; when your device connects directly to OpenAI or Google Gemini (section 5.1), they also receive your device's IP address;

  • Wikimedia Foundation (Wikipedia), an independent controller based in the United States, receives directly from your device the requests described in section 6.2 and processes them under its own privacy policy; this is a request from your device to an independent controller, not a transfer made by us, so the safeguards listed below do not apply to it;

  • LiveKit (transmission of live session audio) and Sentry (error reporting) store and process data in the European Union (Germany); they are US companies that may access it from the United States for support and security;

  • AppsFlyer (earlier app versions only) is based in Israel and uses sub-providers in the United States;

  • Microsoft stores data in Italy, but its staff or its sub-processors may access it from third countries for technical support and security, within the limits of its data protection agreement. The Microsoft artificial intelligence services we use (Azure AI Foundry) are configured with global deployment: your requests, including voice requests, may be processed in Microsoft data centres outside the EU, including the United States. The real-time translation of live audio sessions is processed in Microsoft data centres in the United States.

For these transfers we rely on:

  • the European Commission's adequacy decision for Israel (AppsFlyer);

  • the adequacy decision relating to the EU-U.S. Data Privacy Framework, for US companies that are certified on the date of verification (Google, Microsoft, Stripe, Cloudflare, Apple); we verify certification at least once a year;

  • the standard contractual clauses approved by the European Commission (decision 2021/914), for non-certified providers (OpenAI, LiveKit, Sentry), for AppsFlyer's US sub-providers and as an additional safeguard in the Google and Microsoft agreements, supplemented by a transfer impact assessment and by supplementary measures such as encryption, minimisation of the data transmitted and a prohibition on model training.

You can ask us for a copy of the safeguards by writing to privacy@guidalia.com.

8. How long we keep data

Data Retention
Account and profile As long as the account is active. After 24 months without using your account we notify you (and remind you before the deadline); if you do not reply within 30 days we close it and, after a further 7 days, we delete or anonymise it. If you still have purchased credits, or have sales as a creator or payment and tax data as a guide, we do not close it automatically but assess it case by case. If you close it yourself, within 30 days
Anonymous identifier and related data (content unlocked, plays, use of the artificial intelligence services without an account) 12 months from the last use; the identifier saved on your device remains until you delete the app data or the browser data
Pseudonymised fingerprint of the device used for welcome credits 24 months from the grant of the credits
Partner or invitation code and attribution to the partner On the device, until you sign in. On the account, as long as the account exists; when you close it, the link to you is removed and only the anonymous count of registrations per partner remains
Voice audio, transcriptions and translations Not stored by Guidalia: processed only for the time needed for the response or the translation
Questions to the concierge Not saved at the end of the session
Generated itineraries As long as you keep them or as long as the account exists
Preferences and indication that children are present Until you change them or close the account
Messages with the guide Deleted when the booking is closed or expires
Special needs indicated in a booking 30 days after the end of the tour or after the cancellation or expiry of the request; earlier if you withdraw your consent or close your account
Reports of a problem with a booking With the booking; the text you wrote and the guide's reply are deleted when you close your account
Bookings, payments, store receipts, invoices, disputes, monthly commission statements of guides 10 years from the end of the financial year (accounting and tax obligations, art. 2220 of the Italian Civil Code)
Card saved with Stripe for bookings Until you close your account, when we delete your Stripe customer profile
Guides' DAC7 tax data and documentation of checks For the duration of registration as a guide and, after each report to the Agenzia delle Entrate, until 31 December of the fifth following year (D.Lgs. 32/2023); payment data is kept for 10 years as accounting data
Tax and bank data of professional creators, including any telephone number For the duration of registration as a professional creator and in any case until the account is deleted; payment data is kept for 10 years as accounting data
Location Not stored as a history; the meeting point remains with the booking. Guides: the last position shared during a booking is deleted when the booking ends; the last known position for "Available now" is no longer shown when you switch availability off
Reviews As long as the reviewed profile exists; anonymised if you close your account
Profile photos and other images As long as the account exists or until you remove them
Photos taken with "What is it?" Not stored: sent to the artificial intelligence provider only to respond in the current session
Creator content (Creator Studio) As long as you keep it in Creator Studio or as long as your account exists; when you delete content, the linked files are also deleted. If you close your account, published content is immediately withdrawn from publication, remains accessible for 30 days only to those who had already purchased it, and is then deleted
Record of consents (analytics, marketing) and of their withdrawals 5 years from withdrawal, account closure or the last relevant record, to demonstrate your choices; then deleted or anonymised; the IP address and browser data recorded with each choice are deleted when the account is closed
Acknowledgement of the notice 5 years from the end of the relationship
Acceptance of the Terms of Use 10 years from the end of the relationship (ordinary limitation period)
Analytics data in the apps and the Guidalia web application (with consent) 14 months
Website visit statistics (Plausible) Aggregate data only, kept as long as we use the service; the random value used for the daily identifier is deleted after 24 hours and the IP address is never stored
Diagnostics and server logs 90 days
Notification tokens As long as the app is installed and active; removed after 12 months of inactivity. Tokens of iOS Live Activities (guides): deleted 30 days after the activity ends and in any case after 12 months of inactivity
Requests about your data and complaints 5 years from closure
Partner staff access to Guidalia Tickets For the duration of the contract with the Partner; after the profile is revoked or the contract ends, 30 days; log of operations 24 months; unaccepted invitations 14 days after expiry
Technical data of live audio sessions 90 days; then the session events are deleted and the link to you is removed, and only anonymous billing data remains
Messages received from website forms 24 months from the last contact, unless a contract results from it; anti-bot data 90 days

On account closure, the records we must keep for longer (consents, declarations, accounting data) are separated from the profile and pseudonymised; DAC7 tax data remains in the form required for reporting to the Agenzia delle Entrate until the deadline indicated above. Backups are kept encrypted in the European Union and overwritten within the retention cycle; deleted data is not restored.

9. How we protect data

Encryption in transit and at rest, multi-factor authentication for those who administer the systems, access limited to those who need it and logged, development and test environments separate from production and free of real personal data, app integrity verification, backups and restore tests. No measure eliminates every risk: should a breach occur that exposes you to a high risk, we will notify you as required by art. 34 GDPR.

10. Your rights

At any time you can:

  • access your data and receive a copy of it (art. 15);

  • correct it (art. 16) - you can change much of it directly from your profile;

  • delete it (art. 17) - from Account → Delete account, from the page https://guidalia.com/deleteme or by writing to us at privacy@guidalia.com; if you have bookings in progress, you must first complete or cancel them;

  • restrict its processing (art. 18);

  • receive it in a machine-readable format or have it transmitted to another controller (art. 20);

  • object, on grounds relating to your particular situation, to processing based on legitimate interest (art. 21). We will examine your request and reply to you giving the reasons for the outcome: we may continue only when the processing is needed for the security of the service, its proper functioning (including technical diagnostics), the prevention of fraud and abuse or the defence of a right, because in these cases compelling legitimate grounds prevail. You can, however, stop promotional communications at any time, without giving reasons;

  • withdraw consents without affecting processing already carried out (art. 7.3) - from Account → Privacy and consents;

  • lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority; https://www.garanteprivacy.it) or with the authority of the country in which you live.

Write to privacy@guidalia.com from the address associated with your account: we reply within 30 days, extendable by 60 in complex cases (we will let you know). We may ask you to confirm your identity if we have reasonable doubts. Some data cannot be deleted immediately because the law requires us to keep it (for example invoices). For data that a guide processes as an independent controller (section 5.4) you can also contact the guide directly.

11. Automated decisions and personalisation

Guidalia personalises content and suggestions based on the interests you indicate to us, on your location and, with your consent, on the preferences inferred from use. We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (art. 22). Reviews and the order in which guides are presented depend on user ratings and on relevance criteria (language, distance, availability).

12. Cookies, similar tools and preference management

The https://guidalia.com website, its subdomains and the web applications use technical cookies and similar technical storage in the browser (for example to remember the language you have chosen or the itineraries you have downloaded to listen to offline) and, except for the Admin console, Plausible Analytics for visit statistics, without cookies (see below); the Guidalia web application, on the other hand, uses Firebase Analytics (Google), only with your consent, for statistical analytics, while campaign measurement is present only in earlier versions of the mobile apps. The mobile apps do not use cookies but equivalent identifiers and SDKs, which are subject to the same rules. Since the public website https://guidalia.com, Creator Studio and the Guidalia Tickets and Admin consoles use only technical cookies, security tools and, except for the Admin console, Plausible, they do not show any banner: this information can always be reached from the link to the privacy notice in the footer.

Visit statistics (Plausible). To know how many people visit our websites and which pages they read we use Plausible Analytics, provided by Plausible Insights OÜ (Estonia) with servers in Germany. Plausible does not use cookies and does not save anything on your device: at each visit it calculates an identifier from the IP address and the browser, combined with a random value that changes every 24 hours, and it stores neither the IP address nor the browser data. We see only aggregate data (visits, pages, referrer, country, device type, clicks on the buttons to download the app) and we cannot recognise you or link your visits on different days. For this reason we do not ask for your consent: the basis is our legitimate interest in understanding how the websites are used (art. 6.1.f). Since we are not able to identify you (art. 11 GDPR), any objection cannot relate to data already collected; you can prevent future collection by blocking the Plausible script through your browser settings or extensions.

Security (reCAPTCHA). The web applications in which you sign in with an account use Firebase App Check with Google reCAPTCHA Enterprise to verify that requests come from our applications and not from automated programs. reCAPTCHA analyses technical characteristics of the browser and of the interaction and may save a Google technical cookie (_GRECAPTCHA); Google processes this data on our behalf. It is a tool necessary for the security of the service, based on our legitimate interest (art. 6.1.f), and does not require consent.

Access without an account. If you unlock or download content without registering, for example with a QR code or a shared link, the Guidalia app saves on the device, and the Guidalia web application in the browser, an anonymous identifier (guidalia_anon) to remember the content you are entitled to: it is a technical tool and does not require consent.

Your preferences are managed by a consent management system shared by the Guidalia web application and the mobile apps:

  • the first time you access a web application we show you a banner with the "Accept all" and "Reject all" buttons, equally prominent, and the option to choose by category; if you close the banner without choosing, only the technical tools remain active;

  • by default all tools that require consent are disabled and are activated only after you give your consent; Plausible, which uses neither cookies nor persistent identifiers, is always active;

  • your choice is saved in the technical cookie guidalia_consent, valid for 365 days and shared across the https://guidalia.com subdomains, so that we do not ask you in every application; if you reject or close the banner without choosing, we do not show it to you again for at least 180 days;

  • you can reopen and change your preferences at any time from the "Privacy preferences" link on every page of the Guidalia web application and from Account → Privacy and consents in the apps;

  • every choice is recorded in a consent record with date and time, outcome, version and fingerprint of the text we showed you and the channel used; the record distinguishes consents from other declarations (acknowledgement of the notice, acceptance of the Terms) and keeps them for the periods indicated in section 8;

  • if you make a choice before signing in, it is linked to your account when you sign in, so that your preferences follow you across all your devices.

The complete list of tools, with purpose, provider, duration and data processed, is in the Cookie policy (https://guidalia.com/legal/cookie-policy).

13. Special situations

The general rules of this notice (controller and contacts, security, transfers, rights) also apply in the following cases; here you will find only what changes.

13.1 Guidalia Tickets: staff of partner organisations and visitors

This section is addressed to those who, on behalf of a museum, an attraction, a municipality, a tourism promotion body or an event organiser (the Partner), use Guidalia Tickets to issue, distribute or validate tickets and access rights, and to visitors who purchase or redeem those tickets.

Partner staff - what data we process and where it comes from

Data Source
First name, surname, work e-mail, role in the organisation (administrator, cash desk operator, content creator) From you, or from the Partner's contact person who invited you
Access credentials and log of the operations you perform (issues, validations, cancellations, with date and time) Automatically, from use of the console
Identification and tax data of the organisation (company name, address, tax code or VAT number) From the contract with the Partner
Technical data of the device you use to access (identifier, operating system, IP address) Automatically

Partner staff - why and on what legal basis

Purpose Legal basis
Creating and managing your access to the console and attributing operations to the person who performs them Performance of the contract (art. 6.1.b): the console terms of use that you accept when you activate your profile
Sending you service communications (invitations, confirmations, technical alerts) Performance of the contract (art. 6.1.b)
Reporting the activity carried out to the Partner Performance of the contract (art. 6.1.b)
Invoicing and accounting obligations towards the Partner Legal obligation (art. 6.1.c)
Security, prevention of abuse, correction of errors Legitimate interest (art. 6.1.f)

When you activate your profile you accept the Guidalia Tickets console terms of use: the processing necessary to give you access, to attribute to you the operations you perform and to report them to the Partner is based on these terms. We rely on legitimate interest only for security and abuse prevention; you can object on grounds relating to your particular situation, with the effects described in section 10. Unaccepted invitations expire after 14 days.

Roles. For the data of Partner staff and for the operation of the platform, Guidalia is the controller. For the data of visitors relating to the Partner's tickets (issuing, distribution, validation, reporting), the Partner is the controller and Guidalia acts as processor on its behalf, under an agreement pursuant to art. 28 GDPR: the Partner informs its own visitors and is their first point of contact for that data. If the visitor has a Guidalia account, Guidalia remains the controller of the account data and of the use of the app, as described in the other sections.

Recipients. Providers acting on our behalf: Microsoft (Azure - database and service e-mails, European Union), Google (Firebase - authentication and notifications, United States, with Data Privacy Framework and standard contractual clauses). Your Partner sees the operations performed by its own staff. Advisors and authorities when required by law. We do not disclose your data to others and we do not sell it.

Retention. Access data: for the duration of the contract with the Partner and in any case until your profile is revoked by the Partner; log of operations: 24 months; contractual and accounting data: 10 years; technical logs: 90 days. Visitor data processed on behalf of the Partner is retained according to the Partner's instructions and returned or deleted at the end of the contract.

Rights. Those in section 10, by writing to privacy@guidalia.com. To change your role or revoke your access, contact the Partner's contact person. Visitors contact the Partner regarding ticket data; if they write to us, we forward the request to the Partner and assist it in responding.

13.2 Live audio sessions: participants and guides

If you take part, from the Guidalia app or its web version, in a tour with real-time translation, the voice of the guide is transmitted to our providers, transcribed, translated into the language you have chosen and played back on your device with a synthetic voice generated by artificial intelligence, which is not the voice of the person speaking (the steps and the providers are described in section 5.1).

  • We do not record or store the audio, nor the transcriptions and translations of the subtitles: they are processed only for the time needed for the translation.

  • If you do not have a Guidalia account, you take part with an anonymous identifier for the session: we do not ask for your name or e-mail.

  • We store only the technical data of the session (session identifier, chosen language, use of subtitles, time of joining and leaving, duration and, for the booking holder, the reference of the payment) to make the service work and to charge it.

  • If the guide's app stops responding for 5 minutes and the guide does not confirm that the session is continuing, the session ends.

Who speaks. Live audio sessions are conducted only by guides registered with Guidalia, from the Guidalia for Guides app and under their own Terms, as a service ancillary to the guided tour. Translation and subtitles are a Guidalia service: the related amount is blocked together with the price of the tour and charged by Guidalia, via Stripe, according to the minutes actually used (section 5.3).

Providers acting on our behalf: LiveKit (audio transmission) and Microsoft Azure (transcription, translation and speech synthesis; the translation is processed in the United States, as indicated in section 7). Some operate outside the European Union with the safeguards described in section 7 and with the prohibition on using the data to train models.

Legal basis and retention.

Who Legal basis
Participant with a Guidalia account; guide conducting the session Performance of the contract (art. 6.1.b)
Participant without an account Performance of the contract (art. 6.1.b)

Anyone who takes part without an account accepts the applicable Terms of Use when accessing the session. The voice is processed in real time, is not stored and is not used to identify anyone. You can stop at any time by ending the listening. Audio: not stored. Technical session data: 90 days, after which only anonymous billing data remains. If you have a Guidalia account, all the other sections of this notice also apply.

13.3 Contact forms on the guidalia.com website

Data we collect. What you enter in the form: name, e-mail address, organisation (if any), the platform of your device (for registration for the beta) and the content of the message. If you tick the box for promotional communications, we record your consent with date and time, IP address and browser type in our consent record (section 12). To protect the form from automated submissions we use Cloudflare Turnstile, which collects the IP address and technical characteristics of the browser and produces an anti-bot score. We also record the IP address to limit the number of submissions and block automated ones.

Purpose Legal basis
Responding to your request for information or support, managing your registration for the beta, assessing your application as a guide or creator or your collaboration proposal Pre-contractual measures or response to the request you send us on your own initiative (art. 6.1.b)
Protecting the website from automated submissions and abuse Legitimate interest in security (art. 6.1.f)
Sending you promotional communications Only with your consent, which you can give by ticking the dedicated box (art. 6.1.a)

Recipients. Microsoft (Azure and Microsoft 365, European Union) for receiving and managing messages; Cloudflare (United States, Data Privacy Framework and standard contractual clauses) for anti-bot protection. No disclosure to other parties, except advisors and authorities when required by law.

Retention. 24 months from the last contact, unless a contractual relationship results from it (in which case the terms of that relationship apply). Anti-bot data: 90 days. Promotional consent: until withdrawn.

13.4 Creator Studio: content creators

If you create itineraries and audio guides with Creator Studio (https://create.guidalia.com), the following rules apply in addition to the other sections.

Published content. Photos, audio and video that you upload for your content are intended for publication and are saved in a public storage space: anyone who knows the address of a file can open it even without a Guidalia account, while the list of files cannot be browsed. Do not include in your content personal data of other people, such as recognisable faces or voices, without their permission. The documents you use as sources and other private files are saved in private spaces, accessible only to you and to our systems.

Artificial intelligence and sources. To generate texts, translations, transcriptions and synthetic voices from your materials we use the artificial intelligence services described in section 5.1, under the same conditions. If you indicate a web address as a source, our servers read it to extract the information from it.

Use of artificial intelligence services. We record how much you use the artificial intelligence services in order to apply the limits of your plan or deduct the corresponding credits from your account; with the Basic plan, the use of artificial intelligence is paid with your Guidalia credits. You can see your usage and your credit balance from your account.

Personal and professional creators. Every creator starts as a personal creator and can only publish free content: in this case we do not ask you for tax or bank data. To sell itineraries on the marketplace you become a professional creator by completing the professional profile form in Creator Studio as a natural person, a natural person with a VAT number or a legal person, with the personal, tax and bank data listed in section 4 ("Tax data" row) and, if you wish, a telephone number; the switch is immediate. If you are already a Guidalia guide and have completed the tax data required by DAC7, you are enabled as a professional creator without having to enter it again, and the form is prefilled with that data, which you can confirm or change. We use this data to execute payments and for our accounting and tax obligations; the data you provide as a creator is not covered by the DAC7 reporting described in section 5.8. We protect it like the guides' tax data: the IBAN and tax numbers are encrypted and accessible only to the people who handle them.

Legal basis and retention. Performance of the contract (art. 6.1.b); for payments to professional creators, also legal accounting and tax obligations (art. 6.1.c). Content remains as long as you keep it in Creator Studio or as long as your account exists; when you delete content, the linked files are also deleted. If you close your account, published content is immediately withdrawn from publication and remains accessible for 30 days only to those who had already purchased it, and is then deleted. Professional profile data is deleted when your account is deleted; payment data is kept for 10 years as accounting data (section 8).

13.5 Guidalia MCP server: use from AI assistants

The Guidalia MCP server (https://mcp.guidalia.com/mcp, described at https://guidalia.com/mcp) allows AI assistants, for example ChatGPT and Claude, to look up Guidalia's public catalogue: places, self-guided itineraries, guided tours, guides' public profiles and their open start times. It is read-only: it does not book, pay or change anything, and it requires no account, sign-in or API key. In addition to the other sections, these rules apply.

Data we receive. Only the arguments the assistant sends with each request (for example a city name, search words, a language, an item identifier, a date range) and, for technical reasons, the IP address of the server making the call. We do not receive your conversation with the assistant, your identity or your account with the assistant's provider, or any other data of the latter's users.

Purpose and legal basis. Answering the request and protecting the service from abuse. Legal basis: legitimate interest (art. 6.1.f).

How we use the data. The IP address is used only in memory to apply rate limits on requests and is not stored by Guidalia. The search text is not recorded. For operating the service we record only the name of the tool called, the outcome, the number of results, whether the response was served from the cache and the duration, without IP address or search text.

Retention and providers. These operational records are kept like the other diagnostic data and server logs, for 90 days (section 8), on Microsoft Azure (Application Insights), which acts on our behalf (section 6.1).

The assistant you use. Your conversation with the assistant is processed by its provider (for example OpenAI for ChatGPT, Anthropic for Claude) as an independent controller, under its own privacy policy; Guidalia does not control that processing.

Links and cookies. The links in the answers point to guidalia.com pages: what happens on those pages is described in the rest of this notice (in particular in section 12). The MCP server does not use cookies or similar tools.

14. Changes

If we change the way we process your data, we update this notice, increase its version number and notify you in the app or by e-mail. If a change requires new consent, we will ask you for it again. Previous versions are available on request.

Guidalia S.r.l. Via Livorno 54/2 · 50142 Firenze · VAT No. 07560660487 · privacy@guidalia.com · DPO: dpo@guidalia.com

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