Strategy Innovation Wa Limited

Privacy Policy
Strategy Innovation Wa Limited, which manages the website, intends to
accurately describe the management of the processing of personal data of users of the same,
and to provide, moreover, Information Notes, pursuant to Art. 13 of Regulation (EU) 2016/679.
The Information Notes do not apply to other websites eventually accessible through links
present on the website, of which the company is not in any way liable.
Pursuant Article 13 of Regulation (EU) 2016/679, concerning the protection of personal data,
we inform you that following consultation of this site, data relating to identified or identifiable
persons can be processed. The processing of your personal data will be handled at the
registered offices of Strategy Innovation Wa Limited by automated instruments for the period
of time necessary to achieve the purposes for which they were collected. Specific security
measures are taken to prevent data loss, illicit or improper use and unauthorized access.
The sending of e-mails to the addresses listed on this website involves the successive
acquisition of the sender’s address needed to respond to the request, as well as any other
personal data included in the message.

1.Objectives of processing
In a general sense, it should be noted that through the present website, various types of data
collection are carried out and for different purposes:
a) necessary and automatic collection of data of the browser inherent to interaction with the
b) processing correlated to data collection, voluntarily entered by the browser, by registration,
by filling out the appropriate form included on the website pages;
c) processing correlated to sending e-mails to the addresses listed to contact the affiliate;
d) processing correlated to the receipt and management of curriculum vitae submitted
voluntarily by the parties concerned, or for participation in prize contests;
e) processing correlated to the acquisition of data necessary to perform its contractual
obligations assumed with regard to its own users.
f) safety, health, administrative purposes, prevention / detection of crimes: we can also
communicate user data to government authorities or institution in compliance with legal
g) communication with the customer service: sending phone calls to the numbers of the Call
Center indicated in the specific web page involves the processing of personal data of the user
aimed at providing feedback to requests for information.
2.Types of collected data
Strategy Innovation Wa Limited may collect your personal data when or create an account, use
our website and / or the app or when you contact us.
Specifically we could gather the following information:
a) Name, residential address, e-mail address, telephone number, passport number or identity
card details, credit / debit card or other payment details;
b) Information on the use of our website and / or app;
c) Communications exchanged with us or addressed to us via letters, e-mail, chat service,
telephone calls and social media.
d) Location, including the real time geographical location of the computer or device via GPS
and Bluetooth.
e) Information on the use of our website and / or app;
f) Communications exchanged with us or addressed to us via letters, e-mail, chat service,
telephone calls and social media.
g) Location, including the real time geographical location of the computer or device via GPS
and Bluetooth.

3. Recipient categories
Personal data provided can be communicated by Strategy Innovation Wa Limited to
collaborators and employees engaged for this purpose (within the realm of their duties) or to
subjects assigned to perform the activities; in particular, such data can be communicated to
companies subsidiary to or associated or affiliated with Strategy Innovation Wa Limited, police
forces or judiciary authorities in the realm of investigations or enquiries by judiciary police for the
purposes of prevention, ascertainment or repression of crimes, etc., or, in any event, to
third parties for which it is deemed necessary and indispensable (or however, functionally) for
the carrying out of the activities of Strategy Innovation Wa Limited.

4. Rights of data subject
The affiliate are recognized as having the rights set forth in Article 15-22 Regulation (EU), in
particular, they may at any time:
– obtain the confirmation on the part of the existence or not of your personal data, even if not
yet registered, and their communication in an intelligible form, (for the said request, where the
existence of data that concerns the enquiring affiliate is not confirmed, Strategy Innovation Wa
Limited may ask for a contribution to expenses not exceeding the costs actually incurred);
– obtain from the indication of the origin of personal data, the purposes and methods of their
processing, as well as information on the logic applied in the circumstances of processing of
personal data effectuated with the aid of electronic means;
– at the same time, you can obtain the identification of subjects and categories of subjects to
whom the personal data may be communicated or who might become cognizant of it;
-obtain the updating, correction and integration of personal data;
– request cancellation, transformation into anonymous form or blocking of data processed in
violation of the law, including those data whose retention is not necessary in relation to the
purposes for which the data were collected or subsequently processed, as well as obtaining
certification that these operations have been brought to the attention of those to whom the
data have been communicated or disseminated, with the exception of the case in which such
fulfillment is found to be impossible or involves the use of resources manifestly
disproportionate to the protected right;
– obtain the treatment limitation;
– obtain data portability, ie receive them from a data controller, in a structured format,
commonly used and readable by automatic device, and transmit them to another data
controller without impediments;
– obtain, when possible, the retention period of personal data, or the criteria for this period;
– oppose an automated decision-making process concerning individuals, including profiling.
– oppose the processing of personal data concerning him for legitimate reasons or in the case
of use of data for sending advertising or direct sales material or for carrying out market
research or commercial communications, and at the same time be informed , when the data
are communicated and disseminated, the possibility of exercising this right for free.
– Pursuant to Article 77 of the EU Regulation, if the data subject considers that the processing
concerning your personal data violates these regulations, he has the right to lodge a complaint
with the Supervisory Authority.

5. Data controller
The owner of the data processing, for services provided through this website is Strategy
Innovation Wa Limited, based in 40 Gracechurch street, London (England)
Responsible for feedback to the interested party is the Corporate & Compliance function of
Strategy Innovation Wa Limited, which can be contacted at the e-mail address
The complete list of persons in charge of processing personal data related to this website is
available at the request of the interested party at the Corporate & Compliance department who
can be contacted at the following e-mail address:
The contact data of the Data Protection Officer is to forward any
requests related to the processing of data.

6. Location of data processing
Processing related to the web services on this website takes place at the registered offices of
Strategy Innovation Wa Limited and is handled exclusively by technical staff of the offices in
charge of processing or others charged with occasional maintenance operations. No data from
the web service will be communicated or disseminated. The personal data provided by users
who submit requests for the sending of informative material are, however, used only to
perform the service or activity requested and will be communicated to third parties only where
this is necessary for that purpose.

7. International data transferTo ensure a consistent level of protection of personal data,
Strategy Innovation Wa Limited

guarantees the application of the principles established by Regulation (EU) 679/2016 even in
the event of data transfer outside the European Union.

8. Data retention period
Pursuant to Article 5 letter e) of the EU Regulation (679/2016), the data will be kept for a
period of time not exceeding the achievement of the service requested, and in any case no
later than the time necessary to fulfill the legal obligations.

9. Types of data processed
The computer systems and software procedures in control of operation of this website acquire,
during the course of their normal operation, various personal data, the transmission of which is
implicit in the use of internet communication protocols; the data involved is not collected to be
associated with identified, interested parties, but by their very nature could, through
processing and association with data held by third parties, permit the users to be identified (in
this category of data, the IP addresses or domain names of computers used by users to access
the site, the URI – Uniform Resource Identifier are included), of the resources requested, the
time of the request, the method used to submit the request to the server, the size of the file
obtained in reply, the numerical code indicating the status of the response by the server and
other parameters of the operating system and computer environment of the user). These data
are used only to obtain anonymous statistical information on the use of the website and to
check its correct functioning and they are deleted immediately after processing. The data could
be used to ascertain responsibility in case of computer crimes against the site. In any case, the
data on web contacts are not kept for more than seven days. It should be noted that the
navigational data could be used to ascertain responsibility in case of IT crimes against the
Portal:, according to procedures established by the competent authorities.

10. Data provided voluntarily by Users
The optional, explicit and voluntary sending of e-mails to the addresses indicated on this
website involves the consequent acquisition of the sender’s address, necessary for responding
to requests, as well as any other data included in the message. For the purchase and for
signing up for services or loyalty programmed, the data provided by the user will be used for
the inclusion of the personal data of the affiliate in the company IT data base in order to
provide the service requested, to credit the benefits connected to the loyalty program you
choose, to send a regular newsletter, to promote the new offers affiliate (Including those
related to the preselected loyalty programmed) and eventually for statistical activities for
internal use, with processing methods used with regard to the data being such as to prevent
tracing back to the single individual concerned.
Specific Information Notes will be progressively reported or displayed on web pages
dedicated to the varied and special services on request.
Special services on request.
It is necessary to specify that the processing effectuated through the various pages of the
website relate exclusively to common personal data: the user is asked, therefore, not to post
data revealing racial and ethnic origin, religious, philosophical, or other type, beliefs, political
opinions, membership in political parties, trade unions, associations or organizations of a
religious, philosophical, trade union character, nor personal data disclosing the state of health
and sexual orientation, or for information however classified as “sensitive data” pursuant
Regulation (EU). Otherwise, the related message will be immediately destroyed. This will make
it impossible to provide whatever has been requested.
If in any case, data of a “sensitive” nature (i.e. contents of a curriculum vitae) is intended to
be sent to the owner, please submit the relevant message by email:
with the specific declaration of authorization for the processing of the sensitive data it
contains. Please note that, in the absence of such a declaration, the message eventually
received will be destroyed.
The processing related to the services on this website are handled only by staff charged with
processing. Personal data voluntarily provided by users who submit requests for information or
for the sending of informational material or suggestions of various kinds, are used only to
perform the services or activities requested and are communicated to third parties only in the
case where such is necessary to meet the desired end and after informing the person
concerned. The user is free to provide personal data on the application forms included on the
website or to request the sending of any informational material or other communications or to
subscribe to the services available on the website. The failure to confer the same can result in
the impossibility to obtain that which has been requested.
This information refers only to processing operations performed on data collected as specified
above. Therefore, it does not refer to the treatments carried out through other partner sites of
the Strategy Innovation Wa Limited services, to which the user can access through a link from
the website of access and redirect to the social network pages (Facebook,
Twitter, Instagram, Google+ and Youtube). For these treatments must be provided, by their
respective owners, independent information.
It is therefore specified that the processing of the data provided by accessing third party sites,
which can be reached through links published on the site, in specific areas (tour operators,
banks etc.) are carried out by parties other than Strategy Innovation Wa Limited.
Cookie policy of website
We inform you that we use cookies on with the purpose to facilitate the use
and browsing of the website and improve the quality of the same.

What are the cookies?
Cookies are small data files that are set on the user’s computer, smartphone, tablet when
accessing a website, and allow the owner of such website to store or recover specific
information on the relative browsing experience. Therefore, cookies are used to facilitate
website consultation, improve the browsing experience, perform IT authentications, transmit
advertising messages, acquire static information concerning users’ navigation, monitor
sessions and store specific information concerning users that access the server, etc.
Which are the cookies used and how do they work?
Information on different types of cookies and relative uses:

1. Cookies and management
Own (first party) cookies: they are cookies that belong to the website that created them
and they are set on the user’s terminal by website
(Third party) cookies: they are set on the user’s terminal by Strategy Innovation Wa Limited
partners that process data obtained through the cookies. The application, block and
uninstallation of the cookies comply with the conditions and specific procedures of the single
Only Strategy Innovation Wa Limited, in quality of Data Controller, can access first party
cookies installed by its website Third party cookies installed through
Strategy Innovation Wa Limited website can be accessed only by third parties, which cover the
role of independent data controllers (in this case, Strategy Innovation Wa Limited is simply a
technical intermediary between the user and third parties).

2. Cookies and duration
Session cookies: they are used to collect and store data while the user accesses a web page.
These cookies are stored in the user’s terminal until the end of the browsing session.
Persistent cookies: with this type of cookies, data remains stored in the terminal and can be
accessed and processed for a period defined by the cookie manager, that could range from a
few minutes to various years.

3. Cookies and function
Technical cookies: they allow the user to browse the website or another platform and to use
different options or services found in it, such as for example, check the traffic and data
communication, identify the session, access sections with limited access, use safety features
during browsing. They are session and persistent cookies. This type of cookies include
“browsing or session cookies” and “performance cookies” that guarantee regular browsing and
exploitation of the website, and improved experience of the service offered (allowing for example
to purchase a flight or provide authentication details to log in reserved areas),
“functionality cookies” that allow the user to browse according to a series of selected criteria
(e.g. remember specific operations performed by the user such as language, currency, selected
flights for purchase, etc.) and Ajooweb website to work properly; these cookies are also able to
recognize the Country from which the user is connecting.
Statistic cookies (or “cookie analytics”): They allow collecting information on how the user
browses the website, for example, which are the most frequently visited pages, and they
monitor the operation of the same website. They belong to the category of technical cookies
when used directly by the website manager to collect information in aggregated form, and they
are third party cookies since the web analytics service is supplied by Google.
Advertising cookies: they allow creating profiles concerning the user in order to transmit
commercial messages according to the preferences shown when visiting the website or
improve the browsing experience. These are third party commercial cookies, also used to show
Ajooweb advertisements on other websites. This activity is called “retargeting” and varies
according to the user’s actions on Ajooweb website, like the products he/she searched for and/
or displayed and prices shown. In order to use these types of cookies, it is necessary to
previously acquire the user’s consent; therefore, if the parameters are not modified when
browsing, it is assumed that the user grants his/her consent to receive these cookies from
Ajooweb website.
The user can select his/her preferences with regards to the installation of third party profiling
cookies links or through control panel “Manage cookies”. The user can grant his/her consent in
simplified form through “scroll”, through the accept button or X or by clicking one of the
internal links found on the pages of Ajooweb website (by continuing browsing and thus
accessing the contents of Ajooweb website from the home page or any other landing page).
Strategy Innovation Wa Limited does not boast any control or access to third party cookies or
information contained in them. Third parties manage all the information collected through the
cookies installed by them, in compliance with their specific privacy policies.

Use of third party cookies
Third party cookies are set by different companies other than the one that owns the visited
website. This occurs because features may be present on every website (images, specific
scripts, links to web pages of other domains, etc.) that reside on servers other than the visited
one. Therefore, if a user visits a website and a different company sends information exploiting
that website, he/she will experience third party cookies. For example, the website also avails
itself of the following third party services:

Google Analytics:
it is a Google analysis tool that collects anonymous browsing data through the use of cookies
(performance cookies) with the purpose to analyze the use of the website by users, compile
reports on website activities and provide other information, including the number of visitors
and visited pages. Google Analytics uses the necessary cookies for its operation (of “_ga”,
“_gat” or “_utma”, “_utmb”, “_utmc” type and similar), in respect to which we invite you to
visit address Google Analytics – use of cookies to obtain further information about the scopes
of use, operational modes and procedures to refuse installation. Through Google Analytics
cookies (and specifically, Universal Analytics), the following data can be processed in
anonymous form, without direct acquisition by the Data Controller of the user’s personal data:
IP address (that also allows geo-localization), browsing time and origin, any previous visits by
the same user and other parameters concerning the operational system, IT environment and
devices implemented by users. As specified in the policy of the service offered by Google, the
data is processed in anonymous form, since it cannot be linked to any specific information that
relates to the user (Google Analytics does not store any personal information about your
website users).
Every time the retention period changes, Analytics waits 24 hours before implementing the
change. During this period, you can cancel the change and the data will not be changed.
It should be noted that, while for the aggregate data conservation can be considered
indefinitely, this does not apply to the associated data for which it is considered appropriate to
indicate a specific retention period. However, it is possible to reset the retention period of theuser                                                                                                                                                  identifier to each new event of that user by selecting the “reset in case of new activity”
option. In this way, the expiration date will be set to the current time plus the retention period.
– Google (Youtube cookie):
YouTube is a platform owned by Google to share videos, that uses cookies to collect
information concerning users and browsing devices. For additional information, consult the
informative policy on the use of data and relative processing by Google.
Social network cookies (Social plug-in):
The website uses social networks plug-in and buttons to allow social network users to share
links with social networks or favorite contents with their “friends” (and propose other related
functions such as publishing comments) or log in through the selected social network. These
plug-in do not set a cookie, but if this is already present on the user’s computer, they are able
to read and use it according to the setting. The collection and use of information by third
parties are regulated by the relative informative policies to which reference is made. Moreover,
it is reminded that by clicking on these links, these websites could input cookies when
connecting to their services. Social cookies are not necessary for browsing and, as set forth by
the Data Protection Authority, if these belong to profiling cookies, the user’s consent must be
granted to install said cookies on his/her device. However, in the specific case, these are
simple links to third party websites that do not install profiling cookies. In particular, Ajooweb
website uses Facebook, Twitter, Google +, Instagram and YouTube plug-in. For additional
information on social cookies, it is possible to consult the relative privacy policies concerning
the sites to which they belong, such as: Facebook, Google+, Twitter, Instagram, YouTube.

Registration and authentication:
Through registering or authentication to Strategy Innovation Wa Limited services, the user
gives his/her consent to the application to identify him/her and grant access to specific
services. Pursuant to the information provided below, registration and authentication services
could be provided with the aid of third parties. If this takes place, this application can access
certain data stored by the third party service used for registering or identification.

4.How to block cookies
Most browsers are configured to access, control or perhaps disable cookies trough settings.
However, we remind you that disabling browsing or functional cookies may compromise the
optimal operation of the website and/or limit the service that we offer. The user can therefore
accept, block or eliminate cookies set in his/her terminal, configuring the options of his/her
internet browser or modify his/her preference from the “Manage cookies” function. In case
cookies cannot be installed in the browser, it may not be possible to access certain services
and the user’s experience on the website may be less satisfactory.
We inform you that continuing browsing this website and/or exiting this cookie
policy without making a selection (if requested), will be deemed as granting your
generalized consent for the installation of all cookies used by this website.

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