Asian Group Distributor di Khatun Sokhina ("AGD", "we", "us" or "our") is a B2B aggregator platform based in Livorno, Italy, that integrates third-party service providers (including bus, air, and travel operators; hotel booking systems; SIM/eSIM and telecommunication providers; shipment and logistics companies; and mobile/utility bill payment providers) and makes these services available to its network of affiliated agents ("Agents", "Distributors") throughout Italy, who in turn serve their own customers ("End Customers"). This Privacy Policy explains how we collect, use, store, share, and protect personal data, in compliance with Regulation (EU) 2016/679 ("GDPR") and Italian Legislative Decree no. 196/2003, as amended by Legislative Decree no. 101/2018 ("Italian Privacy Code").
1. Data Controller
The Data Controller is:
Asian Group Distributor di Khatun Sokhina
Registered office: Via Terrazzini 5, 57122 Livorno (LI), Italy
Tax Code / VAT Number: 02030760496
REA: LI-227025
Certified e-mail (PEC): sokhina85@pec.it
For any question regarding the processing of your personal data, or to exercise your rights under this Policy, you may contact us at: info@asiangroupdistributor.org or by post at the address above.
2. Categories of Personal Data We Collect
We collect personal data directly from Agents and, where applicable, End Customers, through our onboarding and service application forms, including but not limited to the following:
2.1 Distributor Application Form (Agent Onboarding)
- Company/Shop identification data: company or shop name, business address, postal code, province, city, country, phone and mobile numbers, business license (Company/Shop License)
- Owner identification data: full name, date of birth, resident address, resident city, mobile number, e-mail address
- Fiscal and identity data: Codice Fiscale (Italian Tax Code), residence/identity document details (Carta di Identità / Permesso di Soggiorno / National Identity Card), including document number, issue date, and expiry date
2.2 SIM Application Form (End Customer / Service Application)
- Company/Shop name and Owner name (where applicable)
- Date of birth
- Address, postal code, province, city, country
- Phone number and e-mail address
- Identity and fiscal data: Carta di Identità / Permesso di Soggiorno / National Identity Card, and Codice Fiscale
- Company/Shop License, where the applicant is a business entity
2.3 Data Generated Through Use of Our Platform
- Transaction data relating to bookings and services processed through our platform (bus, air, hotel, SIM/eSIM, shipment, and bill payment services)
- Account and login data (username, access credentials, IP address, device and browser information)
- Communications exchanged with our support and sales teams
3. Purposes and Legal Basis for Processing
We process your personal data for the following purposes and on the following legal bases under Article 6 GDPR:
- Onboarding and verification of Agents/Distributors, including identity and fiscal verification as required by Italian law — legal basis: performance of a contract and compliance with legal obligations (Art. 6(1)(b) and (c) GDPR);
- Provision of aggregator platform services (ticketing, hotel booking, SIM/eSIM distribution, shipment, bill payment) and processing of related transactions — legal basis: performance of a contract (Art. 6(1)(b) GDPR);
- Compliance with tax, anti-money-laundering (AML), telecommunications registration (e.g., SIM activation identity checks required by Italian regulation), and other statutory obligations — legal basis: legal obligation (Art. 6(1)(c) GDPR);
- Customer support, account management, and communication regarding services — legal basis: performance of a contract and legitimate interest (Art. 6(1)(b) and (f) GDPR);
- Fraud prevention, security, and protection of our platform and network — legal basis: legitimate interest (Art. 6(1)(f) GDPR);
- Marketing communications regarding new services or offers, where consent has been given — legal basis: consent (Art. 6(1)(a) GDPR), which may be withdrawn at any time;
- Compliance with confidentiality and data protection obligations under commercial agreements with our partners and integrated service providers — legal basis: legal obligation and legitimate interest.
4. How We Inform Data Subjects
In accordance with Article 13 GDPR, this Privacy Policy is published on our official website at https://asiangroupdistributor.org/legal/privacy-policy and is made available to all data subjects — including our network of Agents and their End Customers — at the time of onboarding (e.g., completion of the Distributor Application Form or SIM Application Form) or at the time their personal data is otherwise collected.
5. Sharing of Personal Data
We may share personal data, strictly to the extent necessary for the purposes described above, with:
- Third-party service providers whose systems/APIs are integrated into our platform (e.g., airline, bus, and hotel booking systems, telecommunication and eSIM providers, shipment/logistics companies, and payment processors), solely for the execution of the requested service;
- Public authorities and regulatory bodies, where required by law (e.g., tax authorities, telecommunications regulators, law enforcement);
- Professional advisors (accountants, auditors, legal counsel) bound by confidentiality obligations;
- IT service providers and hosting providers who process data on our behalf as Data Processors, under a written agreement pursuant to Article 28 GDPR.
We do not sell personal data to third parties. Any transfer of personal data outside the European Economic Area (EEA), if applicable, shall be carried out only where adequate safeguards are in place, in accordance with Articles 44–49 GDPR (e.g., European Commission adequacy decisions or Standard Contractual Clauses).
6. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including to satisfy any legal, accounting, tax, or regulatory requirements. As a general rule:
- Agent onboarding and identity/fiscal data are retained for the duration of the business relationship and for a minimum of 10 (ten) years thereafter, in compliance with Italian tax and civil law record-keeping requirements;
- Transaction data is retained for the period required by applicable tax and accounting regulations;
- Data processed on the basis of consent (e.g., marketing) is retained until consent is withdrawn.
7. Data Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure, including access controls, encryption where appropriate, restricted internal access on a need-to-know basis, and confidentiality obligations imposed on our staff, Agents, and service providers who process personal data on our behalf.
8. Rights of Data Subjects
In accordance with Articles 15–22 GDPR, you have the right to:
- Access your personal data and obtain a copy of it (Art. 15);
- Request rectification of inaccurate or incomplete data (Art. 16);
- Request erasure of your data, where applicable ("right to be forgotten") (Art. 17);
- Request restriction of processing (Art. 18);
- Request data portability (Art. 20);
- Object to processing carried out on the basis of legitimate interest or for direct marketing purposes (Art. 21);
- Withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal (Art. 7(3));
- Lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali — www.garanteprivacy.it), or with the competent supervisory authority in your EU member state of residence.
Requests may be submitted to info@asiangroupdistributor.org or by post to our registered office. We will respond within the time limits set out under Article 12 GDPR (generally within one month).
9. Minors
Our services are intended for use by Agents and End Customers who are at least 18 years old. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor without appropriate parental/guardian consent, we will take steps to delete such data.
10. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. Any material changes will be published on our website with an updated "Last updated" date. We encourage Agents and End Customers to review this Policy periodically.
11. Contact Us
For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact:
Asian Group Distributor di Khatun Sokhina
Via Terrazzini 5, 57122 Livorno (LI), Italy
Email: info@asiangroupdistributor.org