Privacy Policy
Last updated: 24 March 2026
This Privacy Policy is issued by Mer Lux Transfer in accordance with Article 13 of EU Regulation2016/679 (GDPR) and applicable Italian data protection law (D.Lgs. 196/2003, asamended by D.Lgs. 101/2018). We are committed to protecting your personal data and being transparent about how we use it.
1. Data Controller
Mer Lux Transfer (Italy)
Registered address: [insert address]
VAT number (P.IVA): [insert number]
Email: info@merluxtransfer.it
Note on DPO: Theappointment of a Data Protection Officer is not required for our company underArticle 37 GDPR, as personal data processing is not our core activity and isnot carried out on a large scale.
2. What Data We Collect and Why
We process only the personaldata necessary to provide our transfer services and to fulfil our legalobligations:
Name, phone number and email address — to confirm yourbooking and stay in contact with you (legal basis: Article 6(1)(b) GDPR —performance of a contract).
Trip details (pick-up address, destination,flight/train number) — to ensure your driver meets you on time (legal basis:Article 6(1)(b) GDPR).
Special requests (e.g. child seat, accessibility needs)— solely to ensure your safety and comfort during the journey (legal basis:Article 6(1)(b) GDPR).
Billing information — to issue invoices and comply withItalian tax law, including VAT (IVA) at 10% (legal basis: Article 6(1)(c) GDPR— legal obligation).
3. Sharing Your Data
Your data is not sold ordisclosed to third parties for commercial purposes. It may be shared only withthe following categories of recipients, strictly for the purposes listed above:
Drivers and partner operators — to carry out yourtransfer.
Payment service providers — to process your paymentsecurely.
Accountants and tax advisors — for tax reporting inItaly.
Public authorities — where required by law.
International transfers: Some of our partners (e.g. payment gateways or cloud services) may be locatedoutside the EU/EEA. In such cases, we ensure an adequate level of protectionthrough Standard Contractual Clauses (SCCs) pursuant to Article 46 GDPR, or onthe basis of an EU adequacy decision. Further details are available on request.
4. How Long We Keep Your Data
Trip data (name, contact details, route): retained for12 months after the completion of the journey, then deleted or anonymised.
Financial records and invoices: retained for 10 yearsin accordance with Italian civil and tax law.
5. Your Rights
Under Articles 15–22 GDPR, youhave the right to:
Access your personal data and receive a copy of it.
Rectify inaccurate or incomplete data.
Request erasure of your data ('right to be forgotten'),where no legal retention obligation applies.
Restrict or object to the processing of your data.
Receive your data in a portable, machine-readableformat.
To exercise any of theserights, please contact us at info@merluxtransfer.it.We will respond within 30 days. If you believe your rights have been violated,you may lodge a complaint with the Italian supervisory authority: Garanteper la protezione dei dati personali — www.garanteprivacy.it.
6. Cookies
Our website does not use cookies of any kind (technical, analytical or marketing) to track users orcollect personal data.
7. Security
We implement appropriate technical and organisational measures to protect your personal data in accordance with Article 32 GDPR, including SSL/HTTPS encryption and PCI DSS-certified payment processing. In the event of a data breach posing a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours as required by Article 33 GDPR.
8. Consent
When submitting a booking request, you will be asked to actively confirm your consent to the processing of your personal data by ticking a checkbox (unchecked by default). Booking cannot be completed without providing this consent.
9. Changes to This Policy
We may update this Policy fromtime to time. The date at the top of this page will always reflect the mostrecent version. In the event of material changes, we will notify you by email.