Guidalia
For Tourists For Guides For Creators For Tourism Boards For Museums | Support Contact

Privacy Policy

Version 2026-10-09, effective 2026-10-09

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 or if you write to us from the website: 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 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 and purchases from the web application go through Stripe. In no case do we see or store your card details.

  • 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 or redeem a QR code without registering) Sections 4–6 limited to device data, 7, 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

Guidalia is reserved for natural persons over 14 years of age. 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; in the Guidalia web application, an anonymous identifier (guidalia_anon) for content unlocked without an account, with a QR code or a shared link Automatically from the app or the browser
Location GPS coordinates while you use the features that need them and, during an active guide booking, also with the app in the background; meeting point with the guide; operating areas (guides) 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, free-text notes, messages exchanged with the guide, meeting point From you and from the guide
Payments For in-app purchases: transaction and store receipt identifier, product purchased, amount, date, credit balance. For bookings and purchases from the web application: Stripe customer identifier, amounts, transaction outcome. We do not receive the card number 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) From you via Apple or Google (in-app purchases) and via Stripe (bookings and purchases from the web application)
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 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. Legal person: name, registered office (street, postcode, city, country), tax identification number, business register number and place of registration. In both cases: 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, 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 (including the replies that guides leave about travellers) 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 Automatically, if you have consented to analytics
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 health, religion, sexual orientation or other special categories (art. 9 GDPR). 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. 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)
Crediting in-app purchases and those made from the web application, 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 Account, use of the artificial intelligence services used, credit balance Performance of the contract (art. 6.1.b)
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 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 through which you discovered Guidalia Device, source campaign 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 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, 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 (fallback: OpenAI, 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)
Translation (live audio sessions only) The text is translated into the chosen language Microsoft Azure (fallback: OpenAI, Google Gemini)
Speech synthesis The response or the translation is spoken by a synthetic voice Microsoft Azure (fallback: 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. 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 and your location 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 while you use the features that need it; with the app in the background only during an active booking, for the approach to the meeting point, and only if you have allowed it in your phone's settings, which in that case notify you of it. Outside an active booking we do not collect location in the background. Coordinates and searches are transmitted to Google's map services to calculate routes and search for places. Location is not stored as a history of movements: only the meeting point of the booking remains recorded.

During an active booking, if you have granted the app permission to access your location, your location is shared with the guide, and the guide's location with you, to facilitate the meeting; outside an active booking location is not shared. If you do not want to share it you can deny or revoke the permission. You can revoke the permission at any time from your phone's settings: some features will not be available.

5.3 Payments

Payments follow three distinct channels, in none of which Guidalia receives or stores your card details.

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 amount and the outcome. The amount is blocked on the card when you send the request and charged only at the end of the tour. 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).

Purchases from the web application - when you buy credits or content from the Guidalia web application, payment is made with Stripe Checkout, on Stripe's payment page and with any authentication by your bank (3-D Secure). In this case too we receive only an identifier, the amount and the outcome.

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

When you book, the guide sees your name, the messages you write to them, the booking notes and the meeting point. You see the guide's public profile (name, photo, tagline, biography, languages spoken, rates, reviews, specialities, available times 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 - name, messages, booking notes, meeting point, any shared location - 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) and to campaign measurement (AppsFlyer). Until then, and if you do not consent, these tools remain disabled and collect nothing: they are not even started. 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 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. The buttons to download the app on the https://guidalia.com website and the links we publish in campaigns, for example on social networks, take you to the store via an AppsFlyer link that contains only information about the campaign: the source, the campaign name and the channel you come from. The website does not load AppsFlyer scripts and does not save anything on your device; as happens when opening any link, AppsFlyer receives from your browser the IP address and the type of device and browser, in order to direct you to the right store. The click is linked to the installation and to your registration only if, in the app, you consent to campaign measurement: until then the AppsFlyer SDK is not started and, if you do not consent, the click is never linked to you or to your device. We use the results only in aggregate form, to know how many installations and registrations each campaign brings.

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, together with the average rating and the number of reviews. 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, chat, notifications, 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, place search, routes United States
Google (Gemini) AI services for concierge, audio guides, planning, transcription, translation and speech synthesis (fallback provider, section 5.1) United States
OpenAI AI services for concierge, audio guides, planning, transcription, translation and speech synthesis (fallback provider, section 5.1) United States
LiveKit Transmission of live session audio European Union (Germany)
Stripe Execution of payments for bookings and purchases from the web application Ireland / United States
AppsFlyer Campaign measurement (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).

  • 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).

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;

  • 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 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.

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 sign-ins we notify you; if you do not reply within 30 days we close it and, after a further 7 days, we delete or anonymise it. If you have purchased credits, 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
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
Bookings, payments, store receipts, invoices 10 years from the end of the financial year (accounting and tax obligations, art. 2220 of the Italian Civil Code)
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
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
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
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;

  • 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 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 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 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 content without registering, for example with a QR code or a shared link, the Guidalia web application saves an anonymous identifier (guidalia_anon) in the browser 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 (chosen language, duration, device identifier) to make the service work.

  • The session closes after 5 minutes of inactivity.

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: the payment goes through Stripe Connect together with the payment for the guide's services (section 5.3).

Providers acting on our behalf: LiveKit (audio transmission), Microsoft Azure, OpenAI and Google Gemini (transcription, translation and speech synthesis, as indicated in section 5.1). 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. 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) and the content of the message. 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. 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 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).

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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Guidalia SRL | Via Livorno 54/2 - 50142 Firenze | P. IVA: 07560660487 | Capitale sociale: €60.000 i.v. | www.guidalia.com | info@guidalia.com