Last modification: April
2018
This privacy policy applies to data processing carried out by
Logitravel travel agencies. Please read it carefully, as it contains important
information about the processing of your personal data and the rights
recognised by current regulations on the subject.
We reserve the right to update our privacy policy at any time due to
corporate decisions, as well as to comply with any legislative or legal
changes. If you have questions or require any clarification about our Privacy
Policy or your rights, please contact us via the channels indicated below.
You declare that the data you provide, now or in the future, is
correct and truthful and you agree to notify us of any changes to this data. If
you provide personal data from third parties, you agree to obtain the prior
consent of the parties in question and inform them about the content of this
policy.
In general, the mandatory fields in our forms must be completed in
order to process your requests.
1.
Who is
responsible for processing your data (the data controller)?
Unless specifically indicated otherwise, the data controller which shall process your data collected on the ww.logitravel.comwebsite (hereinafter, the "Website") is the company Logitravel, Limited, with address at 8th Floor Becket House 36, Old Jerry, London, EC2R 8DD.
We belong to the Logitravel Group. You
may contact the Data Protection Officer of the Logitravel Group at dpo@logitravelgroup.com.
2.
What
personal information do we collect?
The data we process is collected:
-
From the forms that you fill out and from
the requests that you make on the Website; for example, when you register, sign
up to our newsletters, save a quote or purchase a trip. We also process the
data included in requests that we receive by email or via our call centre.
-
From profiles and analytics collected
from users (registered or otherwise) browsing the Website.
-
From your interest in our sales
campaigns; for example, in contests or promotions.
-
From the social media profile which you
decide to use to log into our Website.
The data we collect is provided either directly by you or by third
parties who process requests on your behalf; for example, the person making the
booking, the company for which you work, or other travel agencies.
The data categories which we process typically consist of:
-
Identification and contact details, ID
number or passport.
-
Personal details, such as language,
gender, date of birth and nationality.
-
Financial and transaction-related
details.
-
Data related to your browsing, for
example the IP address from which you connect to the Website, weblogs, pages
visited or actions taken on the Website. For this purpose, we use cookies and
similar technologies which may track your browsing. Further information about
our cookies policy is available at https://cdn.logitravel.co.uk/logitraveluk/pdf/en/cookies_policy.pdf
-
Location: Only if you have given your
consent may we determine your approximate location to tailor the content of the Website according to your
location. This location is deduced by analysing your IP address and/or
the location of your Internet provider, and, therefore, does not enable us to
know your exact location. We do
not associate location data with identified users.
-
Data regarding your booking history and
contact with the group.
-
Sales tracking data and, where
appropriate, data related to your preferences and sales profile.
-
Identification and contact details
collected from the social media profile which you used to log into our Website.
These details are only processed for this purpose.
-
Data
generated by your use of social media networks which you have decided to share
with us (for example, likes and comments).
3.
Why do we
process your data?
We process your data for the following purposes:
-
To manage our relationship with you.
-
To process your requests and provide
contracted services.
-
To assess the quality of our services. In
order to assess quality, we may send you satisfaction surveys, although there
is no requirement to complete them.
-
To comply with our legal obligations; for
example, in accounting and tax affairs.
The data of Website users is also processed for the administration,
management and control of the Website itself and its restricted access areas,
as well as for statistical purposes and the enhancement of the Website and our
services.
For reasons of security and quality control, calls made to our call
centre and our agents may be recorded. If you do not wish the call to be
recorded, please inform the agent attending to you.
We process your data for the following commercial purposes:
-
To send commercial messages to our
customers and users. These messages refer to products or services marketed by Logitravel Group related to the
following industries: tourism, automotive, leisure, art, culture, training,
telecommunications, financial and insurance.
-
With
your consent, we shall create a commercial profile based on your bookings and
the data provided on the Website so that our deals and commercial messages are
tailored to that profile. Automated decisions are not made based on the
profiles of our customers.
-
If you
have requested a quote or have started but not completed a booking process on the
Website or via our Call Centre, the data provided may be used to commercially
follow-up your request. To this
end, our agents may contact you by email or by phone, for example to resolve
possible incidents in the booking process.
-
If you show interest in our promotional
campaigns, your data shall be processed in order to manage and control them.
Interest in our promotions implies your consent to the processing and transfer
of your data to the extent and under the terms and conditions indicated in that
campaign, with said consent being an essential requirement for your interest in
the promotions. Depending on the type of promotion, the data of interested
parties or winners may be published on Logitravel websites, social media
profiles or in the press. In the case of competitions and prize draws, the
personal data of winners required to benefit from the prizes shall be communicated to their suppliers,
with the parties in question thereby consenting to the international transfer
of their personal details when said suppliers are located outside the European
Economic Area.
4.
Who may we
disclose your data to?
In general, we shall only disclose
your information with your prior consent, when it is necessary for the
processing of your requests, the provision of contracted services, or to comply
with our legal obligations.
In particular:
-
For the
correct processing of the bookings requested, the data included in such
bookings shall be disclosed to the
suppliers of the tourist services included in the contracted packages and/or to
companies which manage global booking systems, such as AMADEUS GLOBAL TRAVEL
DISTRIBUTION. This may imply the international transfer of your data, if these companies are located
outside the European Economic Area.
-
We may also disclose data to fraud detection platforms in order
to detect and prevent fraudulent payments or bookings.
-
We disclose data of our customers and users to other Logitravel
Group companies for the following internal administrative purposes:
o
Analysis
of business data and corporate information collected from consolidated customer
data and bookings from group travel agencies, corporate management control,
statistics and group-wide quality assessment. The group-wide data controller is
Toolfactory, S.L., with registered address at Edificio Logitravel, Parcela 3B
(Parc Bit) - Ctra. Palma - Valldemossa km 7.4, 07121 Palma de Mallorca, Spain.
o
The
commercial use of all the commercial databases of Logitravel travel agencies.
The data controller for this processing is Travel Concept, S.L., with
registered address at Edificio Logitravel, Parcela 3B (Parc Bit) - Ctra. Palma
- Valldemossa km 7.4, 07121 Palma de Mallorca, Spain.
We may resort to technological
solutions or services provided by companies which are outside the European
Economic Area for certain functionalities of the Website. In this case, we
shall adopt the appropriate measures to guarantee an appropriate level of
personal data protection. In particular:
-
We use various services provided by
Google (https://policies.google.com/technologies/partner-sites?hl=en) and its affiliates. These companies adhere to the Privacy Shield
agreement between the EU and the USA. Under this agreement, personal data
transferred from an EU company to a company from the United States shall be
processed according to a series of well-defined protection standards and
safeguards, thereby ensuring an appropriate level of protection. You may check
the validity of Google's accession to the Privacy Shield at the following link:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
-
The chat feature incorporated into our
Website is provided by the American company LiveChat, Inc. This company adheres
to the Privacy Shield agreement
(https://www.privacyshield.gov/participant?id=a2zt0000000L16xAAC&status=Active).
-
To send
and manage your commercial messages, our group uses the Oracle Responsys
Marketing Platform Cloud Service platform. This platform is provided by the
Oracle group, which is headquartered in the USA, and companies affiliated with
Oracle which are identified at the following link: https://www.oracle.com/corporate/oracle-affiliates.html. To guarantee an appropriate level of protection of the
personal data transferred to Oracle, the Logitravel Group has signed a contract
with this provider that includes the standard clauses approved by the European
Commission. For any questions about the operation of this service, or about
Oracle's privacy policy, please contact Oracle Ibérica, S.R.L., with registered
address at C/ José Echegaray, 6, Edificio B, 28232, Las Rozas, Madrid, Spain,
Tel. (+34) 902 302 302. If you prefer, you may also contact the group's privacy
department directly via the form available at the following link: https://oracle.ethicspointvp.com/custom/oracle/dp/en/form_data.asp .
Please note that all
information found in the blog, forums or other engagement tools available
on the Website shall become public information,
so users should take special care when deciding to post comments or share their
personal details.
The use of these engagement tools is subject to the conditions listed
below.
You undertake to make appropriate use of the comment posting feature
of the Website, agreeing to refrain from posting details and/or comments which:
-
Engage in unlawful or illegal activities
or those that are contrary to good faith and public order.
-
Disseminate content or propaganda of a
racist, xenophobic or pornographic nature, or any defending terrorism, or that
violates human rights.
-
Contain content entailing an infringement
of intellectual and industrial property rights.
-
Harm the image of third parties.
-
Introduce or transmit computer viruses or
any other physical or logical systems which may cause damage to the company's
computer systems.
-
Use the email accounts or personal data
of other users and modify or tamper with their messages.
We reserve the
right to remove, or not publish, any comments or posts which fail to meet the
abovementioned standards, particularly those which violate the respect for
human dignity, which are discriminatory, xenophobic, racist, pornographic,
which constitute an attack against youth or childhood, public order or safety
or which, in our opinion, are not suitable for publication. We shall not be
held responsible for the information stored at the request of users and, in
particular, regarding the opinions expressed. Neither are we responsible for
the accuracy, quality, reliability and correctness of the information which
users may include. Notwithstanding the foregoing, anyone whose personal data is
included in comments or posts published on the Website may request, at any
time, the removal of such data, as indicated in the section "What are your rights?".
5.
Legal basis
for processing
The legal basis for the processing of
your data is the management of the legal relationship established with you, the
provision of requested or contracted services, and compliance with legal
obligations, especially those applicable to accounting, taxation, tourism or
traveller security and control.
The following data processing is based on a legitimate interest:
-
Management
of the security of the Website and our call centre, as well as the adoption of
fraud detection and prevention measures based on our legitimate interest in
guaranteeing the security of our systems and transactions.
-
The
monitoring of statistics and quality control, including recordings of calls to
our call centre, based on our legitimate interest to assess our services.
-
The
commercial tracking of your requests, the sending of commercial messages and
the consolidation of the commercial databases of Logitravel travel agencies
form our legitimate interest and that of the group to promote the
products or services sold by the
Logitravel Group, as well as your consent for receiving such messages by
electronic means.
-
The
analysis of customer data is based on the group's interest in processing this information for internal administrative purposes.
The following processing items are based on your consent, without the withdrawal of such
consent conditioning the provision of contracted services:
-
The commercial profiling of data for the sending of personalised offers and
commercial messages is based on the requested consent;
-
Browsing profiles based on information
collected from cookies or similar technologies.
6.
For how
long will we retain your data?
In general, we shall keep your data for the duration of the
relationship you have with us and, in any case, throughout the periods provided
in the applicable legal provisions, for example, in relation to accounting and
tax matters, and for the time necessary to meet possible processing-related
liabilities. We shall remove your data when it is no longer necessary or relevant
for the purposes for which it was collected. Specifically:
Access to restricted areas of the Website shall be withdrawn one month
after its creation. Browsing-related information shall be removed once the
website connection has been completed and the statistics compiled.
Recordings of calls to the call centre shall be discarded within a
maximum period of 2 months, unless required otherwise for the time required to
manage possible incidents or deadlines stipulated by legal provisions.
The data processed for commercial
purposes, including commercial profiles, shall remain valid until its deletion
is requested. Consent is recorded, for
example, in electronic form submission logs, and shall be kept for the entire
duration of the processing and the applicable limitation periods.
7.
What are
your rights?
You have the right
to obtain confirmation about whether or not we are processing your personal
data and, in that case, access such data.
Once you are registered on the
Website, you may check your booking history, as well as access your profile and
update the information you provided at the time of registration.
You may also ask
for your data to be rectified if it is inaccurate or incomplete. In addition,
you may request the deletion of your data if, among other reasons, it is no
longer necessary for the purposes for which it was collected.
In certain
circumstances, you may request limitations upon the processing of your data. In
this case, we shall only process the data in question 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 shall
cease to process your data other than for compelling legitimate reasons which
prevail over your interests or rights and freedoms, or for the formulation,
exercise or defence of claims.
Similarly, and
under certain conditions, you may request the portability of your data for it
to be transferred to another data controller.
You may revoke the
consent that you had given for certain purposes, without affecting the legality
of the processing based on the consent prior to its withdrawal.
To request your
withdrawal from processing for commercial purposes you may:
-
Update your preferences in your profile, accessible from
your Website account.
-
Send an
email to the following email address: privacy@logitravel.com.
-
Use the
link provided in our newsletters for this purpose.
At any time you may revoke your consent for geolocation or the
installation of tracking or profiling cookies by modifying the privacy options
of your web browser or your device. You
may learn more about online behavioural advertising and how to manage the
privacy of your browser to refuse such processes at www.youronlinechoices.eu. Further information about our cookies policy is available at https://cdn.logitravel.co.uk/logitraveluk/pdf/en/cookies_policy.pdf
You also
have the right to file a claim with a data
protection authority. You may check the list and contact details of the
European data protection agencies on the European Commission website:
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
To exercise your rights,
you must send us a request accompanied by a copy of your national identity
document, or another valid identity document, by postal or electronic mail, to our Data Protection Officer at the
addresses indicated in the 'Who is responsible for processing your data (the
data controller)?' section.
You may obtain more information about your rights and how
to exercise them on the website of the Spanish Data Protection Agency ('Agencia
Española de Protección de Datos') at http://www.agpd.es or on the website of the data protection authority of
your country.