EWTN Travel Jubilee is the mobile application and published web application for the EWTN Vatican Bureau (“EWTN Vatican”), part of EWTN NEWS (Eternal World Television Network).

This mobile application and also published web application website (ewtntraveljubilee.com – “Website”) is owned by EWTN NEWS INC., with registered office in 5817 Old Leeds Rd. Irondale, Alabama 35210, United States, and operated by FONDAZIONE EWTN NEWS ETS, with its registered office at Via della Conciliazione 3, 00193 – Rome, Italy (tax code: 92139010901) (“Data Controller”, “EWTN”, “we”, “us”, “our”). Unless otherwise noted, any information EWTN collects on this Website will be controlled and processed in Italy, subject to this EWTN Vatican Data Protection and Cookie Policy (the “Policy”) and the applicable consumers’ data protection laws, including the General Data Protection Regulation 2016/679 (“GDPR”) to the extent the Website offers services to users located in the EU.

This Policy explains our practices on the collection, use, maintenance, protection, and disclosure of personal data and cookies on the Mobile Application and Website when you:

Access and visit the Mobile Application and Website;
Send or receive emails, texts, and other electronic messages between you and us (“Electronic Communications”);
Submit an application for employment with us through the Website.

This Policy does not apply to information collected by:

Us through any other means, including any other website operated by us or any third party;
Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

By using the Website, and/or making selections regarding cookies, and/or engaging in Electronic Communications, you are consenting to the use and handling of personal data as described herein. 

This Policy may change from time to time, so we encourage you to review it regularly. Your continued use of this Website after we make changes is deemed acceptance of those changes.

DATA PROTECTION POLICY

This section of the Policy (the “Data Protection Policy”) provides information on the processing of personal data of Website users, including:

Definitions
Data Controller
Personal Data Collection
Purposes, Lawfulness of Processing and Data Retention
Third-Party Payment Platforms
Personal Data Disclosure
Data Subject Choice/Opt-out
Transfer of Data outside the European Union
Security
Rights of Data Subjects and Data Protection Complaints
Social Networks
Contact Information
Privacy Policy Changes

Definitions
Certain terms used in this Policy are defined as follows:
- data subject is an identified or identifiable natural person;
- personal data is any information relating to a data subject.
Data Controller
The Data Controller is FONDAZIONE EWTN NEWS ETS, with its registered office at Via della Conciliazione 3, 00193 – Rome, Italy (tax code: 92139010901).
Users may contact the Data Controller at vatican@ewtn.com.
Personal Data Collection
EWTN collects personal data at several different points on the Website.
1. Data Collected Automatically
  The information systems and software procedures relied upon to operate this Website acquire several data as part of their standard functioning, through:
  Cookies. For a comprehensive description of what cookies are, why we use them, how you can manage them, the specific cookies we utilize, and your rights regarding cookies, please refer to our Cookie Policy below.
  Log Files. For a comprehensive description of what log files are and why we use them, please refer to Section 5 of our Cookie Policy below.
  Web Beacons or Tracking Pixels. For a comprehensive description of what web beacons or tracking pixels are and why we use them, please refer to Section 5 of our Cookie Policy below.
2. Data Provided Voluntarily by Users
  When you interact with us through the Website and by Electronic Communications, you consent to EWTN potentially acquiring the data categories listed below on the basis of your free and voluntary decision. This includes obtaining your contact information, any personal data contained in the Electronic Communications, as well as the data listed below for each purpose you may contact us for.
  - Information Requests
    EWTN collects contact information (such as name, surname, email address) when users request information or services via our contact details provided in the relevant sections of the Website (e.g. in the footer).
  - Online Donations
    EWTN collects contact information (such as name, surname, email, and shipping address) for online donations. Online donations to EWTN will be processed by third-party platforms (please see the following Section 5. “Third-Party Payment Platforms” section).
    Donors may contact EWTN at vatican@ewtn.com with questions or concerns about a donation.
  - Newsletter form
    EWTN collects contact information (such as name, last name and email address) to enable users to subscribe to our newsletter and to send them news about the Vatican, as well as information about our work and how to support our mission.
3. Sensitive Personal Information
  We unavoidably collect some sensitive data about certain persons, and other sensitive information may be inferred about persons who participate in or support our work, including donors. We do not disclose such information outside of EWTN.

Purposes, Lawfulness of processing and data retention

The GDPR requires data controllers to provide data subjects with information regarding the purposes of processing personal data as well as the legal basis for such processing. In this respect, EWTN informs users that personal data will only be used for the purposes listed below, and solely in accordance with the legal basis specified below

Purposes
Cookies	For a comprehensive description of why we use each category of cookies, please refer to Section 7 of our Cookie Policy below.
Log Files	For a comprehensive description of why we use log files, please refer to Section 5 of our Cookie Policy below.
Web Beacons or Tracking Pixels	For a comprehensive description of why we use web beacons or tracking pixels, please refer to Section 5 of our Cookie Policy below.
Other Data Collected	In the case of computer crimes against the Website, data may be used to ascertain liability. We may use software to verify a Website user’s address (“ID Verification”) to avoid session hijacking, hacking attempts, or other attacks.

Legal Basis
Cookies, Log Files, Web Beacon or Tracking Pixels, and Other Data Collected Automatically	The legal basis that legitimizes the processing of this data is the consent of the user (Article 6(1)(a) of the GDPR), as well as the legitimate interest of the Data Controller (Article 6(1)(f) of the GDPR) to ensure the proper functioning of the Website and the available services and to proceed with the investigation of possible crimes.

Data Retention
Cookies, Log Files, Web Beacon or Tracking Pixels, and Other Data Collected Automatically	Data is normally retained for short periods, as further set out in the Cookie Policy below.

Information requests data
Purposes	Personal data related to requests for information, services and more general information requests (concerning, for example, initiatives and events, services characteristics, etc.) is used to manage users’ requests and contact them about the events, information, or services they have inquired about.
Legal Basis	The processing of data, which takes place based on users’ requests, is necessary to provide the services or information requested by the user, and to take necessary pre-contractual measures.
Data Retention	The data collected are normally retained for short periods and, in any case, for the time strictly necessary to process requests and provide the requested service/information.

Donations data

Purposes

Personal data is collected and used for billing purposes, to process donations, or to contact the donor if we have trouble processing a donation. Credit card information is no longer utilized after a transaction is complete unless a donor has agreed to recurring donations. Payments to us are processed via Payment Platforms, as outlined in Section 5 below.

Legal Basis

The legal basis that legitimizes the processing of this data are:

performance of a contract to which the user is party or in order to take steps at the request of the user prior to entering into a contract (Article 6(1)(b) of the GDPR), and, in this case, the management of the donation in all its phases and activities instrumental thereto (such as, for example, reporting, communications on the donation and regularity in its activation or changes communicated by the donor);
compliance with legal obligations to which the Data Controller is subject, such as administrative and other obligations that are mandatory under applicable European Union and national laws (Article 6(1)(c) of the GDPR).

When the processing relates to Sensitive Personal Information, the processing is carried out in the course of the legitimate activities of EWTN, with appropriate safeguards (Article 9(2)(d) of the GDPR).

Data Retention

Donation data will be retained for as long as strictly necessary for the purpose of performing the requested service. For more information, please refer to the Donation Policy available at the following link: [●]

Newsletter data

Purposes

Personal data is used to provide users with news about the Vatican and information from EWTN about their work and how to best support them and to carry out market research. Our newsletters and marketing communications include updates on our latest projects, victories, and giving opportunities. We will send electronic newsletters or other marketing communications only to those who have expressly requested them or granted permission for such contacts.

From time to time, our Website may request information from users via surveys. Participation in these surveys is completely voluntary, and the user, therefore, has a choice whether to disclose the requested information. Survey information generally will be used for purposes of monitoring or improving the use of the Website. By voluntarily participating in the survey, you consent to us processing your survey answers responses.

Legal Basis

The legal basis that legitimizes the processing of this data is the consent of the user (Article 6(1)(a) of the GDPR).

Users may revoke their consent at any time by clicking on the unsubscribe link in any communication they receive or, alternatively, by contacting the Data Controller at vatican@ewtn.com.

Data Retention

The identifying and contact data will be used to communicate with users for twenty-four (24) months after the user has provided consent, unless consent is revoked earlier.

In order for this Website to meet user expectations, it may be necessary for us to supplement the information we receive with information from third-party sources.

Data Collected Automatically
The following chart describes the purposes, legal basis, and data retention period for data collected automatically.
Data Provided Voluntarily by Users
The following chart describes the purposes, legal basis, and data retention period for data provided voluntarily by users.

Third-Party payment platforms
Users are able to make payments through various means provided on the Website. Below, you can understand how your information is processed in case you use Payment Platforms, as defined below.
Online donations to EWTN will be processed by:
- Stripe Payments Europe, Ltd. (hereinafter “Stripe”): Donations made to EWTN will be processed by Stripe and transferred to the bank account of EWTN. EWTN will allocate the funds to the location (country or region), program, or project where they are most urgently needed. Stripe collects financial data (such as card number, expiration date, and CVC) and contact data (email, name, surname) from users making a donation to EWTN. In addition, Stripe can receive a history of completed transactions from EWTN. Where allowed, Stripe may use users’ personal data for its own purposes, such as enhancing security, improving and delivering business services, preventing fraud, loss, and other harm. Financial data related to donations will be processed directly by Stripe and will not be transmitted or shared with EWTN. For more information about how Stripe processes personal data, you can consult the following link: https://stripe.com/it/legal/privacy-center#what-are-your-data-controller-activities
- Apple Inc. (hereinafter “Apple”): Donations made through the Apple Pay service will be transferred to the bank account of EWTN. EWTN will allocate the funds to the location (country or region), program, or project where they are most urgently needed. If your device is compatible with this payment method, you can simply approve the donation using Touch ID or Face ID or, for an Apple Watch, by pressing the side button twice. Apple handles Website users’ financial data when they make a donations. This data will be processed directly by Apple and will not be transmitted or shared with EWTN. For more information about how Apple processes personal data, you can consult the following link: https://www.apple.com/legal/privacy/data/en/apple-pay/ 
(Collectively, the “Payment Platforms”).
Personal Data Disclosure
We will not sell or otherwise share users’ data, as such terms are specifically defined by certain consumer data protection laws. We may disclose your data to the other companies belonging to the EWTN group (including, without limitation, EWTN News Inc.), or to our employees and consultants
- Transfer to Third Parties
  We do not transfer personal data to third parties absent the data subject’s express consent, a legal obligation, or another valid legal basis as provided in the GDPR, and as mentioned in this section. Without your express consent, we will not authorize the use of personal data by any third party external to the EWTN group for any fundraising or solicitation purposes.
  Though we make every effort to preserve your privacy, we may need to disclose personal data to law enforcement and judicial authorities, if we have a good-faith belief that such action is reasonably necessary to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defence against third party claims or charges; (3) protect the security of the Website and of EWTN; (4) exercise or protect the rights, property or security of EWTN, the EWTN Group companies, its affiliates, customers, employees and third parties.
- Aggregate Information (not personal data)
  We may share aggregated demographic information with other companies belonging to the EWTN Group, and/or to third parties. This is not linked to any personal data.
- Third Parties (Intermediaries, Service providers, data processors etc.)
  We may use third-parties, such as, but not limited to, a letter shop to customize mailings, a shipping company to ship orders, a credit card processing company to process donations or to bill data subjects for goods and services, Payment Providers as explained above in Section 5, and a cloud-based system (such as CRM) for customer relationship management. We will make sure that such third parties are bound by contractual agreements and do not retain, share, store, or process personal data for any purposes different from the performance of our contract with them.
- Business Transitions
  In the event EWTN goes through a business transition, such as a merger, acquisition by another company, or sale of a portion of its assets, data subjects’ personal data will, in most instances, be part of the assets transferred.
Data Subject Choice/Opt-out
You are given the opportunity to opt-in to receive our newsletters or other information from EWTN. Individuals who no longer wish to receive our newsletter and informational communications may opt-out of receiving these communications by contacting  vatican@ewtn.com.
Transfer of data outside the European Union
Any transfer of personal data to non-EU countries is done in accordance with Articles 44 et seq. of the GDPR, by setting up appropriate means to ensure adequate data protection guarantees, such as adoption of standard contract clauses approved by the European Commission.
Security
EWTN takes extensive measures to protect your information. Personal data is processed by authorized internal personnel using secure computer and telematic tools. We adopt technical and organizational measures to prevent the risk of destruction, loss, modification and unauthorized disclosure of the data or access, accidental or illegal, to them.
When data subjects submit sensitive information via the Website, we take great effort to ensure their information is protected. Any sensitive information is encrypted and is protected using SSL.
We restrict access to personal data on a need-to-know basis to ministry employees, who are subject to discipline or termination for violating confidentiality, and to contractors or agents who are subject to confidentiality agreements. Finally, the servers that store personal data are situated in a secure environment, further enhancing data protection measures.
While we maintain stringent security measures, it’s essential to recognize the inherent risks associated with transmitting data via electronic networks. Despite our efforts, these measures cannot entirely eliminate the possibility of unauthorized access or dissemination of data, nor can they guarantee the security of information sent to us electronically. Therefore, we recommend ensuring your PC or mobile device is equipped with robust security software, such as an updated antivirus program, for secure online transmission (both inbound and outbound) of data. Additionally, you should ensure that your Internet Service Provider implements adequate security measures, such as firewalls and anti-spam technology, to further bolster the security of your online transmissions.
Rights of Data Subjects and data protection complaints
- Correcting/Updating/Deleting/Deactivating Personal data
  If data subjects’ personal data changes (such as zip code, phone, email or postal address), or if they no longer desire our services or receive Electronic Communications from us, they should visit [●] or email vatican@ewtn.com to correct/update or delete/deactivate their personal data.
- Right to Know What Personal Data EWTN holds and to access
  Data subjects have a right to know what personal data EWTN has about them and to receive it in a format suitable for transfer to another service. Upon receiving a written request for this purpose, EWTN will respond within 30 days to inform a data subject about: (i) what personal data EWTN possesses, (ii) its source (if available), and (iii) whether any personal data is being processed. EWTN will also, where requested: (iv) give a description of the personal data and the reasons it is being processed, (v) provide the data in a portable format. EWTN may require additional information to confirm the identity of the requester, or to locate the data. The information will ordinarily be provided free of charge, but EWTN may request payment under some circumstances, such as repeated requests
- Right to Prevent Direct Marketing
  Individuals have the right to give written notice to prevent direct marketing. Upon receiving such written notice to the addresses indicated in this Policy, EWTN will delete personal data from its marketing list, except to the extent data is necessary to ensure that the data subject’s preferences are respected in the future. If a marketing campaign is already underway when notice is received, there may be a delay between the time of the notice and the time contacts end.
- Right to Restrict Use
  Individuals have a right to restrict the use of their data if it is inaccurate, it was obtained unlawfully, its use is unnecessary, or EWTN does not have a legitimate ground for using it. Data subjects also have a right to provide instructions on what is to be done with their data upon their death. Individuals may make a written request to restrict or direct the use of their information by contacting us at the addresses indicate in this Policy.
- Right to withdraw consent
  Individuals have the right to revoke, at any time, the consents provided and described herein.
- Right to object
  You may, at any time, object, on legitimate grounds, the processing of your personal data based on our legitimate interest
- Complaints
  In the event a person believes their information is being used inappropriately, they may lodge a complaint with the governmental authority that supervises consumer privacy matters in their country.

Social Networks

The social buttons/widgets on our Website, which are those special “buttons” featuring icons of social networks such as Facebook, Pinterest, and Twitter, allow users browsing the Website to interact directly with these social network with just a click. This interaction allows the social network to acquire data about your visit to the Website.

To prevent the data processed on this Website from being linked to your social profile, you should log out of your social accounts. Platforms owned by third parties that can be accessed through the Website are not covered by this Policy. For further information on the processing of personal data by such third parties, the user is invited to consult their applicable Privacy Policy.

Facebook	Meta Privacy Policy – How Meta collects and uses user data \| Privacy Center \| Manage your privacy on Facebook, Instagram and Messenger \| Facebook Privacy
Instagram	Security and privacy on Instagram \| About Instagram
YouTube	Privacy Policy – Privacy & Terms – Google
Twitter	Privacy Policy

Contact Information
To exercise your rights listed under Section 10, to provide a notice, to update your information, or for questions related to this Policy, you may email vatican@ewtn.com or mail a letter to:
Fondazione EWTN News ETS
Via della Conciliazione, 3 – Roma CAP: 00193 (Italy)
Privacy Policy Changes
If we change our Policy, we will post those changes to this privacy statement, the Website home page, and/or other places we deem appropriate so you are always aware of our policies regarding your personal data. Your continued use of this Website after we make changes is deemed acceptance of those changes.
This Data Protection Policy was most recently updated on 15.11.2024.

COOKIES POLICY

This section of the Policy (the “Cookie Policy”) provides information on the cookies used by the Website.

How to disable cookies

When you visit the Website for the first time, you can select which types of cookies you wish to consent to via the provided banner. At any time, you can update your cookie preferences by clicking on the appropriate icon to re-open the Cookie Consent Manager, which can also be accessed here. Please note that technical and functional cookies are installed automatically and do not require your consent, as they are necessary for the proper functioning of the Website.

Please note that you can also decide whether to accept cookies by acting directly on your browser settings and prevent – for example – third parties from installing them, as described at the following addresses:

Microsoft Edge	Microsoft Edge, browsing data, and privacy - Microsoft Support
Mozilla Firefox	La protezione antitracciamento avanzata in Firefox per desktop \| Supporto a Firefox (mozilla.org)
Google Chrome	Clear, allow & manage cookies in Chrome - Computer - Google Chrome Help
Safari	Clear the history and cookies from Safari on your iPhone, iPad or iPod touch – Apple Support (UK)
Opera	Web preferences - Opera Help

For more information on cookies, you can go to www.youronlinechoises.com, to obtain information on how to delete or manage cookies according to the browser used and to set preferences for the use of third-party cookies. Please note that disabling technical cookies may impact the correct navigation within the Website as some features and functionalities may be compromised.

This Cookie Policy was last updated on 15.11.2024.