Privacy policy
Last modified 14 March 2023
In this space you will find NEWBLUE’s privacy policies. Our website cares about protecting the privacy of our users, and we have developed various privacy policies tailored to the needs of each type of user. Depending on the profile of the user who uses our website, one of the following privacy policies will apply:
I. PRIVACY POLICY FOR WEBSITE USERS OR VISITORS
II. PRIVACY POLICY FOR TRAVELLERS
III. PRIVACY POLICY FOR AGENTS USING THE BOOKING PLATFORM
We encourage you to carefully read the privacy policy applicable to your user profile to understand how we collect, use and protect your personal information on our website.
I. PRIVACY POLICY FOR WEBSITE USERS OR VISITORS
This privacy policy applies to the website https://www.newblue.es/ (hereinafter, the website). Please read it carefully. Here you will find important information about the processing of your personal data and the rights recognised by current regulations on this matter.
We reserve the right to update our privacy policy at any time based on business decisions, as well as to comply with any changes in legislation or case law. If you have any questions or need any clarification regarding our Privacy Policy or your rights, you may contact us through the channels below.
You declare that any data you provide to us, now or in the future, is correct and truthful and you agree to notify us of any modification thereof. If you provide personal data of third parties, you undertake to obtain the prior consent of those affected and to inform them about the content of this policy.
The fields on our forms that are indicated as mandatory must be completed in order to process your requests.
1. Who is the controller of your data?
Unless otherwise specified, the data controller is WORLD 2 MEET TRAVEL, S.L.U., (hereinafter NEWBLUE), with address at Calle General Riera 154, 07010 Palma (Balearic Islands), Spain. NEWBLUE is part of the World2Meet (W2M) tourism group. + group info here .
For more information about the processing of your data or the exercise of the rights recognised by current regulations on the matter, you can send an email to [email protected] or contact the Data Protection Officer of the W2M Group at [email protected].
2. What will we process your data for and on what legal basis?
2.1. Managing the relationship with users : The website makes several forms available to users so they can:
• Generate quotes, receive them via email, and receive notifications to manage them before they expire.
• Receive personalised attention at the selected travel agency to resolve their inquiries and manage their quote in person,
• Receive a call from a travel agent, from the selected travel agency, to resolve their inquiries and manage their quote over the phone.
We process the data users provide in these forms to address requests received.
These types of processing are necessary for the execution of the legal relationship with the users of the website or for the application of pre-contractual measures at their own request.
2.2. Website security management and administration: We process browsing data (IP addresses or logs) to administer and manage website security. This processing is based on our legitimate interest in ensuring the security of the website. This interest is explicitly recognised by recital 49 of the GDPR. For the weighting of said interest with respect to your rights and freedoms, it has been taken into account that this processing represents general security practices and does not pose significant threats to the data subjects.
2.3. Statistical and quality management purposes: In order to evaluate and manage the quality of our services, we draw up statistics based on aggregate data obtained from transaction data and web browsing data, e.g. IP address, weblogs, pages visited or actions taken on the web (+ info in our cookie policy).
These types of processing are based on our legitimate Interest in assessing and managing the quality of our services. For the weighting of this interest with respect to your rights and freedoms, it has been determined that the processing had a limited impact on the privacy of the data subjects, it corresponded to their reasonable expectations and did not pose significant threats.
2.4. Consolidation of data for internal administrative purposes of the W2M group. Personal data, economic data, bookings, and generally, goods and services transaction data generated by the businesses performed by the companies of the group are consolidated into centralised databases for internal group administrative purposes. Below is an overview of these types of processing. For more information, in particular to find out about the companies that make up the group, you can refer to the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP.
The entity W2M SERVICIOS CORPORATIVOS, S.L.U., with address at C/ General Riera 154, 07010 Palma (Balearic Islands), Spain (hereinafter W2M ) is responsible for the administration and security of the consolidated databases; Each of the group companies is responsible for the data communications that it makes to W2M for their consolidation and the use that it makes of the consolidated data of the group. These types of processing are based on the legitimate interest of the W2M group in transmitting personal data within the business group for internal administrative purposes and having a consolidated view of its business for corporate decisions.
Developing a group-level master list of people: The identification and contact details you have provided along with information regarding your identity document (type and number); your gender and language will be consolidated into a unified database at the group level. The purpose is to have a unique record of people to optimise the operational processes common to group companies where it is necessary to identify an individual, for example for payments or service billing or for integration with booking systems. This unified database will synchronise with the systems of the group companies with which you maintain a current relationship.
Business data management and analysis control : We also process the information obtained from the consolidated economic data, bookings and, in general, the data of goods and services transactions generated by the businesses performed by the group companies to generate reports and analyse business data for business intelligence (business intelligence) and management control purposes. These analyses and reports provide results in the form of aggregate data and serve to produce statistics and forecasts, to facilitate business decision-making, optimise processes, measure the performance of tourism products offered by the group, and establish business strategies.
2.5. Consolidation of data for advertising purposes and commercial profiles. W2M group customer and prospect data is consolidated into a commercial database for direct marketing and business profiling purposes. Below is an overview of these types of processing. For more information, please refer to the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.
The data controller of the data included in the commercial database of the W2M group is the entity W2M SERVICIOS CORPORATIVOS, S.L.U., with registered address at C/ General Riera 154, 07010 Palma (Balearic Islands), Spain (hereinafter W2M).
Your inclusion in this database is based on the consent you have been asked to provide. Failure to provide or withdraw your consent is not a condition for the fulfilment of the bookings or the provision of the services that you have contracted. The extent of the data relating to you that will be consolidated into the W2M database and the specific use made of it will depend on the consent you provided at the time of providing your data. At any time, you may revoke this consent or change your preferences according to the mechanisms described in the “What are your rights?” section of the privacy policy applicable to the commercial exploitation of customer and prospect data.
Sending non-personalised business communications and managing distribution lists (segmentation): W2M processes the identification and contact details that you have provided together with the data related to your status as a customer, language and market/source of the data, for the sending, by any means, of non-personalised commercial communications related to the tourist products and services offered under the brands used by the group. + info about the brands of the W2M Group here.
To manage our distribution lists, we perform a segmentation of the recipients of our communications based on data source, market and language. This processing consists of a simple classification according to objective criteria and is not intended to carry out commercial profiles, predictions or behavioural analysis.
The service we use to forward our business communications is outside the European Economic Area. The service has been configured so that which data is stored in a data centre located in the EU. As a supplementary measure, the contractual conditions applicable to this service include the standard clauses approved by the European Commission to ensure an adequate level of protection of the personal data transferred to this processor.
Preparation of a business profile for the personalisation of business communications and group services: The data consolidated in the group’s commercial database is used to perform behavioural analyses and predictive models in order to understand and predict our customers’ wants and needs, actions related to the purchase of our products and services, and the factors that condition them. If you have authorised the customisation of the group’s services and communications, W2M will access the data generated by your bookings to include them in your business profile. This profile will be enriched with the information generated from your interactions with the group's companies and digital media, e.g. your requests for information or quotes or the data generated by your browsing on our websites. + information about the data we include in our commercial profiles and their sources in section 2 of the privacy policy applicable to the commercial exploitation of customer and potential customer data.
Your profile will allow us to determine when to send you a commercial communication and customise our offers based on the type of product that may be of interest to you based on the outcome of behavioural analysis and the application of predictive models.
We will also use the data included in your profile to personalise the treatment and services provided by the group companies with which you interact, for example, to wish you a happy birthday or to take into account the preferences you have expressed when making your bookings or during your use or enjoyment of the contracted tourist products. For this purpose, the group companies with which you interact in the future will access your profile.
+ info on the logic of our business profiles and what is involved in personalising our services in section 3. b) of the privacy policy applicable to the commercial exploitation of customer and potential customer data.
3. How long will we keep your data?
We generally retain your data for the duration of the relationship you have with us and in any case for the periods established in the applicable legal provisions and for the time necessary to address possible liabilities arising from the processing. We will cancel your data when it is no longer necessary or relevant for the purposes for which it was collected. The information related to the browsing will be cancelled, once the web connection is completed and the statistics are collected.
Consolidated customer data for internal group administrative purposes will be retained according to the criteria outlined in the W2M GROUP’S INTERNAL ADMINISTRATIVE DATA CONSOLIDATION PRIVACY POLICY.
The data processed by W2M for commercial purposes, including commercial profiles, will be kept as long as you do not object to the processing or request its deletion, applying the retention criteria indicated in the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP
4. Who can we communicate your data to?
Your data will only be communicated to third parties by legal obligation, with your consent or when your request involves such communication.
In the latter case, more specifically:
- When you have filled in the “come and see us” form, the name, email and quote indicated will be communicated to the selected agency to receive personalised in-person attention to resolve your queries and manage your quote;
- When you have filled in the “we call you” form, the name and phone number indicated will be communicated to the agency you have selected to resolve your queries and manage your quote by phone.
5. What are your rights?
You have the right to obtain confirmation as to whether or not we are processing your personal data and, in such case, to access it. You can also ask for your data to be rectified when it is inaccurate or for incomplete data to be completed, as well as requesting its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request the restriction of processing of your data. In such a case, we will only process the affected data for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions and for reasons related to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that prevail over your interests or rights and freedoms, or for the formulation, exercise or defence of claims. Likewise, under certain conditions, you may request the portability of your data so that it can be transmitted to another controller.
You can revoke the consent you have provided for certain purposes, without this affecting the lawfulness of the processing based on the consent prior to your withdrawal.
You may at any time revoke your consent to the processing of your data for commercial purposes, including business profiles, or change your preferences in this regard according to the mechanisms described in the section “What are your rights?” of the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.
To exercise your data protection rights, you can send a request by mail or email indicating the right or rights you wish to exercise to: W2M Group – For the attention of: The party responsible for servicing GDPR rights, C/General Riera 154, 07010 Palma (Balearic Islands), Spain. Email: [email protected]
You can learn more about your rights and how to exercise them on the W2M Group privacy portal, on the Spanish Data Protection Agency page or by contacting the W2M Group Data Protection Officer at [email protected].
II. PRIVACY POLICY FOR TRAVELLERS
This privacy policy applies to the processing of traveller data included in combined travel bookings organised by NEWBLUE for the management of such bookings.
We reserve the right to update our privacy policy at any time due to operational decisions, as well as to comply with any changes in legislation or case law. If you have any questions or need any clarification regarding our Privacy Policy or your rights, you may contact us through the channels below.
1. Who is the controller of your data?
Unless otherwise specified, the controller of the personal data of travellers included in the combined travel bookings requested by travel agencies or tour operators is WORLD 2 MEET TRAVEL, S.L.U., (hereinafter NEWBLUE), with registered address at Calle General Riera 154, 07010 Palma (Balearic Islands), Spain. NEWBLUE is part of the World2Meet (W2M) tourism group. + group info here .
For more information about the processing of your data or the exercise of the rights recognised by current regulations on the matter, you can send an email to [email protected] or contact the Data Protection Officer of the W2M Group at [email protected].
2. What personal information do we obtain?
The traveller data we process is obtained from bookings communicated by tour operators and/or travel agencies that market our tourism services or products to end customers.
The data that tour operators and/or travel agencies communicate to us for bookings to the Caribbean is as follows:
Identification and contact details: first name and surnames of the booking holder, address, telephone, email, number, date and country of issue of the passport and expiry date of the passport.
Personal characteristics data: nationality.
Booking details: dates, itinerary, services included.
The data that is provided to us in order to manage bookings to the Islands is as follows:
Identifying information: first name and surnames of the booking holder, and, if applicable, mobile phone number and email.
Booking details: dates, itinerary, services included.
3. What will we process your data for and on what legal basis?
We process the personal data of travellers included in the combined travel bookings we organise for the purposes described below:
3.1. Execution of the trip and provision of the requested services
Traveller data provided by travel agencies or tour operators will be processed to in order to manage the booking and the services it includes. These types of processing are necessary for the execution of the combined travel contract, the provision of the requested services or for the application of pre-contractual measures at the request of the data subjects.
3.2. Consolidation of data for internal administrative purposes of the W2M group.
Personal data, economic data, bookings, and generally, goods and services transaction data generated by the businesses performed by the companies of the group are consolidated into centralised databases for internal group administrative purposes. Below is an overview of these types of processing. For more information, in particular to find out about the companies that make up the group, you can refer to the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP.
The entity W2M SERVICIOS CORPORATIVOS, S.L.U., with address at C/ General Riera 154, 07010 Palma (Balearic Islands), Spain (hereinafter W2M ) is responsible for the administration and security of the consolidated databases; Each of the group companies is responsible for the data communications that it makes to W2M for their consolidation and the use that it makes of the consolidated data of the group. These types of processing are based on the legitimate interest of the W2M group in transmitting personal data within the business group for internal administrative purposes and having a consolidated view of its business for corporate decisions.
Developing a group-level master list of people: The identification and contact details you have provided along with information regarding your identity document (type and number); your gender and language will be consolidated into a unified database at the group level. The purpose is to have a unique record of people to optimise the operational processes common to group companies where it is necessary to identify an individual, for example for payments or service billing or for integration with booking systems. This unified database will synchronise with the systems of the group companies with which you maintain a current relationship.
Business data management and analysis control : We also process the information obtained from the consolidated economic data, bookings and, in general, the data of goods and services transactions generated by the businesses performed by the group companies to generate reports and analyse business data for business intelligence (business intelligence) and management control purposes. These analyses and reports provide results in the form of aggregate data and serve to produce statistics and forecasts, to facilitate business decision-making, optimise processes, measure the performance of tourism products offered by the group, and establish business strategies.
4. Who can we communicate your data to?
Your data will only be communicated between W2M group companies in the situations described in this policy. We will communicate the data of travellers due to legal obligation, with their consent or when necessary for the correct processing of the booking or the provision of the requested services. Specifically:
The identifying data (your first name and surnames) and the data related to the booking of services will be communicated to the providers of the tourist services included in the trips contracted and to companies managing global booking systems, such as the entity AMADEUS GLOBAL TRAVEL DISTRIBUTION.
If they have consented to this at the time of requesting the booking from their travel agency, the telephone number and/or email that travellers have provided will be communicated to the airlines participating in the itinerary of the contracted trip, so that they can contact the interested party directly in case of an issue in the operation of the flight.
If they take out travel insurance, we will communicate the details of the policyholder and beneficiary to the insurance contracted.
Please note that where the requested services are required to be provided outside the European Economic Area, these communications may involve the transfer of your data to countries that do not offer the same level of protection as the EU with regard to personal data.
These international data transfers and communications are necessary for the execution of the combined travel contract or for the application of pre-contractual measures at the request of the data subjects.
The set of data relating to the passenger's journey that includes the information necessary for the management of their booking will be included in the Passenger Name Register (PNR) when the contracted package includes flights, both inside and outside the EU, whose departure or arrival are on Spanish territory, or that make a stopover on it, or domestic flights that the Council of Ministers has determined in an extraordinary manner. The data included in the PNR is communicated to the Passenger Information Unit of the Intelligence Centre against Terrorism and Organised Crime, which reports to the Secretary of State of Security of the Ministry of the Interior for the purposes of the prevention, detection, investigation and prosecution of terrorism crimes and other serious crimes.
These types of processing are carried out in compliance with the obligations provided for in Organic Law 1/2020 (https://www.boe.es/diario_boe/txt.php?id=BOE-A-2020-10776). You can see the details of the data that make up the PNR in Art. 5 of the aforementioned Law. You may contact the Passenger Information Unit Data Protection Officer for all questions regarding the processing of your PNR data.
Likewise, the border control and security regulations of the countries of destination, stopovers or in some cases overflights, may require airlines to communicate passport information (Advanced Passenger Information or API data) and PNR data to the customs or immigration authorities of such countries. For more information on the communication of this data by the airlines included in the contracted package, you should consult the privacy policies provided by said companies.
5. How long will we keep your data?
Personal data of travellers associated with a booking will be cancelled one year after the end of the service. In any case, we will keep the data for the periods established in the applicable legal provisions, for example, on accounting and tax matters, and for the time necessary to address possible liabilities arising from the processing. We will cancel your data when it is no longer necessary or relevant for the purposes for which it was collected.
Consolidated customer data for internal group administrative purposes will be retained according to the criteria outlined in the W2M GROUP’S INTERNAL ADMINISTRATIVE DATA CONSOLIDATION PRIVACY POLICY.
6. What are your rights?
You have the right to obtain confirmation as to whether or not we are processing your personal data and, in such case, to access it. You can also ask for your data to be rectified when it is inaccurate or for incomplete data to be completed, as well as requesting its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request the restriction of processing of your data. In such a case, we will only process the affected data for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions and for reasons related to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that prevail over your interests or rights and freedoms, or for the formulation, exercise or defence of claims. Likewise, under certain conditions, you may request the portability of your data so that it can be transmitted to another controller.
You can revoke the consent you have provided for certain purposes, without this affecting the lawfulness of the processing based on the consent prior to your withdrawal.
You also have the right to lodge a complaint with a data protection authority. The list and contact details of the European Data Protection Agencies can be found on the European Commission website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
To exercise your data protection rights, you can send a request by mail or email indicating the right or rights you wish to exercise to: W2M Group – For the attention of: The party responsible for servicing GDPR rights, C/General Riera 154, 07010 Palma (Balearic Islands), Spain. Email: [email protected]
You can learn more about your rights and how to exercise them on the W2M Group Privacy Portal on the Spanish Data Protection Agency page at www.aepd.es, on the data protection authority page of your country or by contacting the W2M Group Data Protection Officer at [email protected]
III. PRIVACY POLICY FOR AGENTS USING THE BOOKING PLATFORM
This privacy policy applies to the B2B website https://www.newblue.es/ (hereinafter, the website). Please read this policy carefully. Here you will find important information about the processing of your personal data and the rights recognised by current regulations on this matter.
We reserve the right to update our privacy policy at any time due to operational decisions, as well as to comply with any changes in legislation or case law. If you have any questions or need any clarification regarding our Privacy Policy or your rights, you may contact us through the channels below.
If you provide personal data of third parties, you undertake to obtain the prior consent of those affected and to inform them about the content of this policy.
1. Who is the controller of your data?
Unless otherwise specified, the controller of your personal data is WORLD 2 MEET TRAVEL, S.L.U., (hereinafter NEWBLUE), with registered address at Calle General Riera 154, 07010 Palma (Balearic Islands), Spain. NEWBLUE is part of the World2Meet tourism group . + group info here .
For more information about the processing of your data or the exercise of the rights recognised by current regulations on the matter, you can send an email to [email protected] or contact the Data Protection Officer of the W2M Group at [email protected].
2. What will we process the data of users of the Website for and on what legal basis?
We process personal data in the circumstances and for the purposes described below:
2.1 Administrative and commercial management of the relationship with your agency
We will process the identification, position and professional contact data provided by the head of the agency or, where appropriate, directly by the agents of your agency, to process your registration, provide a user name and password to access the NEWBLUE website, and for the administrative and commercial management of the relationship with the agency. All such processing is necessary for the execution of the contractual relationship with the agencies that have subscribed to NEWBLUE. The processing of data of legal representatives and contact persons of the agencies is based on the existence of the legitimate interest recognised by Art. 19 Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights.
The economic and transaction data of goods and services will be processed for accounting and administrative management purposes in compliance with our legal accounting and tax obligations.
All this data is consolidated into databases at the group level. + info in the section “Consolidation of data for internal administrative purposes of the group” of this policy.
2.2 Metrics
In order to evaluate and manage the quality of our services and products, we gather statistics based on aggregate data obtained from transaction data and web browsing data, e.g. IP address, weblogs, pages visited or actions taken on the web (+ info in our cookie policy). This processing is based on your consent to the installation of cookies, which you can revoke at any time by using the website settings panel or changing the privacy options of your web browser or terminal.
We also gather anonymous statistics from aggregate booking data to measure the performance of our routes and services. These types of processing are based on our legitimate interest in evaluating and managing the quality of our services and products. For the weighting of this interest with respect to your rights and freedoms, it has been determined that the processing had a limited impact on the privacy of the data subjects, it corresponded to their reasonable expectations and did not pose significant threats.
2.3 Consolidation of data for internal administrative purposes of the W2M group.
Personal data, economic data, bookings, and generally, goods and services transaction data generated by the businesses performed by the companies of the group are consolidated into centralised databases for internal group administrative purposes. Below is an overview of these types of processing. For more information, in particular to find out about the companies that make up the group, you can refer to the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP.
The entity W2M SERVICIOS CORPORATIVOS, S.L.U., with address at C/ General Riera 154, 07010 Palma (Balearic Islands), Spain (hereinafter W2M ) is responsible for the administration and security of the consolidated databases; Each of the group companies is responsible for the data communications that it makes to W2M for their consolidation and the use that it makes of the consolidated data of the group. These types of processing are based on the legitimate interest of the W2M group in transmitting personal data within the business group for internal administrative purposes and having a consolidated view of its business for corporate decisions.
Developing a group-level master list of people: The identification and contact details you have provided along with information regarding your identity document (type and number); your gender and language will be consolidated into a unified database at the group level. The purpose is to have a unique record of people to optimise the operational processes common to group companies where it is necessary to identify an individual, for example for payments or service billing or for integration with booking systems. This unified database will synchronise with the systems of the group companies with which you maintain a current relationship.
Business data management and analysis control : We also process the information obtained from the consolidated economic data, bookings and, in general, the data of goods and services transactions generated by the businesses performed by the group companies to generate reports and analyse business data for business intelligence (business intelligence) and management control purposes. These analyses and reports provide results in the form of aggregate data and serve to produce statistics and forecasts, to facilitate business decision-making, optimise processes, measure the performance of tourism products offered by the group, and establish business strategies.
2.4 Consolidation of data for advertising purposes and commercial profiles.
W2M group customer and prospect data is consolidated into a commercial database for direct marketing and business profiling purposes. Below is an overview of these types of processing. For more information, please refer to the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.
The data controller of the data included in the commercial database of the W2M group is the entity W2M SERVICIOS CORPORATIVOS, S.L.U., with registered address at C/ General Riera 154, 07010 Palma (Balearic Islands), Spain (hereinafter W2M).
Your inclusion in this database is based on the consent you have been asked to provide. Failure to provide or withdraw your consent is not a condition for the fulfilment of the bookings or the provision of the services that you have contracted. The extent of the data relating to you that will be consolidated into the W2M database and the specific use made of it will depend on the consent you provided at the time of providing your data. At any time, you may revoke this consent or change your preferences according to the mechanisms described in the “What are your rights?” section of the privacy policy applicable to the commercial exploitation of customer and prospect data.
Sending non-personalised business communications and managing distribution lists (segmentation): W2M processes the identification and contact details that you have provided together with the data related to your status as a customer, language and market/source of the data, for the sending, by any means, of non-personalised commercial communications related to the tourist products and services offered under the brands used by the group. + info about the brands of the W2M Group here.
To manage our distribution lists, we perform a segmentation of the recipients of our communications based on data source, market and language. This processing consists of a simple classification according to objective criteria and is not intended to carry out commercial profiles, predictions or behavioural analysis.
The service we use to forward our business communications is outside the European Economic Area. The service has been configured so that which data is stored in a data centre located in the EU. As a supplementary measure, the contractual conditions applicable to this service include the standard clauses approved by the European Commission to ensure an adequate level of protection of the personal data transferred to this processor.
Preparation of a business profile for the personalisation of business communications and group services: The data consolidated in the group’s commercial database is used to perform behavioural analyses and predictive models in order to understand and predict our customers’ wants and needs, actions related to the purchase of our products and services, and the factors that condition them. If you have authorised the customisation of the group’s services and communications, W2M will access the data generated by your bookings to include them in your business profile. This profile will be enriched with the information generated from your interactions with the group's companies and digital media, e.g. your requests for information or quotes or the data generated by your browsing on our websites. + information about the data we include in our commercial profiles and their sources in section 2 of the privacy policy applicable to the commercial exploitation of customer and potential customer data.
Your profile will allow us to determine when to send you a commercial communication and customise our offers based on the type of product that may be of interest to you based on the outcome of behavioural analysis and the application of predictive models.
We will also use the data included in your profile to personalise the treatment and services provided by the group companies with which you interact, for example, to wish you a happy birthday or to take into account the preferences you have expressed when making your bookings or during your use or enjoyment of the contracted tourist products. For this purpose, the group companies with which you interact in the future will access your profile.
+ info on the logic of our business profiles and what is involved in personalising our services in section 3. b) of the privacy policy applicable to the commercial exploitation of customer and potential customer data.
3. Who can we communicate your data to?
Your data will only be communicated between W2M group companies in the situations described in this policy, or to third parties due to legal obligations, with your prior consent or when necessary for the management and control of the contractual relationship, for example, with your agency.
4. How long will we keep your data?
We will keep your data for as long as you maintain your status as a user of the Website, the data generated by the transactions carried out on the Website will be kept according to the deadlines established by current accounting and tax regulations, and in any case we will keep the data for the time necessary to address possible liabilities arising from the processing. We will cancel your data when it is no longer necessary or relevant for the purposes for which it was collected.
Consolidated customer data for internal group administrative purposes will be retained according to the criteria outlined in the W2M GROUP’S INTERNAL ADMINISTRATIVE DATA CONSOLIDATION PRIVACY POLICY.
Data processed by W2M for business purposes, including business profiles, will be retained as long as you do not object to the processing or request its deletion, applying the retention criteria indicated in the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.
The data included in the W2M group master list of people will be kept as long as you maintain a relationship with the group and in any case for the periods established in the applicable legal provisions and the time necessary to address possible liabilities arising from the processing.
5. What are your rights?
You have the right to obtain confirmation as to whether or not we are processing your personal data and, in such case, to access it. You can also ask for your data to be rectified when it is inaccurate or for incomplete data to be completed, as well as requesting its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request the restriction of processing of your data. In such a case, we will only process the affected data for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions and for reasons related to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that prevail over your interests or rights and freedoms, or for the formulation, exercise or defence of claims. You have the right to obtain confirmation as to whether or not we are processing your personal data and, in such case, to access it. You can also ask for your data to be rectified when it is inaccurate or for incomplete data to be completed, as well as requesting its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request the restriction of processing of your data. In such a case, we will only process the affected data for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions and for reasons related to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that prevail over your interests or rights and freedoms, or for the formulation, exercise or defence of claims. You also have the right to object to the adoption of automated individual decisions that produce legal effects on you or significantly affect you in a similar way, when this right occurs in accordance with the provisions of Article 22 of Regulation (EU) 2016/679.
Likewise, under certain conditions, you may request the portability of your data so that it can be transmitted to another controller.
You can revoke the consent you have provided for certain purposes, without this affecting the lawfulness of the processing based on the consent prior to your withdrawal.
You may at any time revoke your consent to the processing of your data for commercial purposes, including business profiles, or change your preferences in this regard according to the mechanisms described in the section “What are your rights?” of the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.
In order to request your de-registration as a customer or to exercise your data protection rights, you can send a request by mail or email indicating the right or rights you wish to exercise: W2M Group – For the attention of: The party responsible for servicing GDPR rights, C/General Riera 154, 07010 Palma (Balearic Islands), Spain. Email: [email protected]
You can learn more about your rights and how to exercise them on the W2M Group privacy portal, on the Spanish Data Protection Agency page or by contacting the W2M Group Data Protection Officer at [email protected].
You also have the right to lodge a complaint with a data protection authority. The list and contact details of the European Data Protection Agencies can be found on the European Commission website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
6. What are your obligations?
The use of the Website implies the unconditional acceptance by users of the terms of use and privacy policy thereof, as well as their commitment to fully complying with the obligations imposed on them by the General Data Protection Regulation (REGULATION (EU) 2016/679) and/or the personal data protection regulations applicable to the agency (hereinafter and jointly the Data Protection Regulation).
With regard to the processing of data of the persons for whom bookings are processed, users are especially bound to comply with the duty of information established in the Data Protection Regulation, in order to grant efficacy to the rights of the data subject and to maintain full confidentiality with respect to the personal data that is the subject of the processing.
We remind you that under Resolution 830 d) IATA, you must actively ask each passenger, at the time of issuance of the air tickets or before, if they want their contact details (mobile phone number and/or email) to be provided to the airlines participating in the travel itinerary so that the airlines can contact them in case of any impact on the operation of the flights.
The personal information available through the Website may only be accessed or used for the purposes of managing bookings and providing the services contracted by the end customers.