W2M Travel - Politica de privacidad

Last revision: 17 February 2023

W2M PRO is an independent tourist intermediary specialised in the distribution of accommodation and other tourist services at the destination, such as transfers or excursions.

This privacy policy applies to bookings processed by W2M PRO and serves to inform travellers whose personal data are included in the same about the processing of their personal data and their rights under current legislation on the subject.

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 can contact us through the channels indicated below.

Who is responsible for the processing of your data?

Unless otherwise specified, the party responsible for the processing of the personal data of travellers included in the reservations of tourist services requested from W2M PRO by travel agencies or tour operators is WORLD 2 MEET, S.L.U., (hereinafter W2MPRO), with registered office at Calle General Riera 154, 07010 Palma (Illes Balears), Spain. W2M PRO is part of the World2Meet (W2M) tourism group. More information about the Group here. For further information on the processing of your data or to exercise your rights under current legislation on the subject, please send an email to dataprotection@w2m.com or contact the Data Protection Officer of the W2M Group at dpo@w2m.com.

What personal information do we collect?

The data we process are those obtained from bookings communicated by tour operators and/or travel agencies that market tourist services or products to end customers

The categories of data that we process for the purpose of handling bookings consist of the following:

Identification and contact details: Name, address, e-mail address, telephone number if available; ID card/passport details (document number, expiry date and country of issue). 
Data on personal characteristics: if applicable, nationality, gender and language. 
Booking data (dates, itinerary, services included, etc.)
Transaction data on goods and services.

What will we process your data for and on what legal basis?

We process the personal data of travellers included in bookings for the purposes described below:

Processing of reservations
Consolidation of data for internal administrative purposes of the W2M Group
Establishment of a master database of individuals
Management control and business data analysis

Processing of reservations and management of the booking system

Traveller data provided by travel agencies or tour operators will be processed to handle the booking and the services it includes. These processing operations are necessary for the execution of the reservation, the provision of the requested services or for the implementation of pre-contractual measures at the request of the data subjects.

Consolidation of data for internal administrative purposes of the W2M Group.

Personal data, economic data, reservations and, in general, data on transactions of goods and services generated by the businesses developed by the Group companies are consolidated in centralised databases for Group-internal administrative purposes. An overview of these data processing activities can be found below. For further information, in particular to find out which companies make up the Group, please refer to the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP. WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., with registered office at C/ General Riera 154, 07010 Palma (Illes Balears), 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 it makes to W2M for consolidation and for the use it makes of the consolidated group data. These processing operations are based on the legitimate interest of the W2M Group to transfer personal data within the corporate Group for internal administrative purposes and to have a consolidated view of its business for business decision-making.

Creation of a group-level master record of individuals: The identifying and contact information you have provided, along with the information regarding your identification document (type and number), gender, and language, will be consolidated into a unified database at the Group level. The aim is to have a single register of individuals to optimise operational processes common to the Group companies where a person needs to be identified, e.g., for payments or invoicing of services or for integration with reservation systems. This unified database will be synchronised with the systems of the Group companies with which you have an existing relationship.

Management control and business data analysis: We also process the information obtained from the consolidation of economic data, reserves and, in general, the data of transactions of goods and services generated by the businesses developed by the companies of the Group to generate reports and analyse business data for business intelligence and management control purposes. These analyses and reports provide results in the form of aggregated data and are used to produce statistics and forecasts to facilitate business decision-making, optimise processes, measure the performance of the tourism products offered by the Group and establish commercial strategies.

Who can we disclose your data to?

Your data will only be communicated between W2M group companies in the situations described in this policy. We will disclose travellers' data when legally obliged to do so, with their consent or when it is necessary for the correct processing of the booking or the provision of the requested services. Specifically:

The data included in the service bookings will be communicated to the providers of the tourist services concerned, for the provision of the contracted services.

Please note that where the services requested are 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 for personal data as the EU.

These international communications and transfers of data are necessary for the performance of the package travel contract or for the implementation of pre-contractual measures at the request of the data subjects.

How long will we retain your data?

In general, we will retain data for the time periods provided for in the applicable legal provisions, e.g. in accounting and tax matters, and for as long as necessary to meet any liabilities arising from the processing.

Data relating to travellers included in bookings shall be kept for five years. After that time, if there is no need for retention to justify settlements with agencies and tour operators, the data shall be deleted.

Data consolidated for intra-group administrative purposes shall be retained in accordance with the criteria set out in the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF DATA FOR W2M GROUP INTERNAL ADMINISTRATIVE PURPOSES.

What are your rights?

You have the right to obtain confirmation of whether or not we are processing your personal data, and if so, to access that data. You may also request the rectification of inaccurate data or the completion of incomplete data, as well as the deletion of data when, among other reasons, it is no longer necessary for the purposes for which it was collected.

In certain circumstances, you may request the restriction of the processing of your data. In such cases, we will only process the affected data for the establishment, exercise, or defence of legal claims or for the protection of the rights of other individuals. Under certain conditions and on grounds relating to your particular situation, you may also object to the processing of your data. In such cases, we will stop processing the data unless we have compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims. You may also, under certain conditions, request the portability of your data to be transferred to another data controller. You may also, under certain conditions, request the portability of your data to be transferred to another data controller.

You may withdraw your consent for certain purposes without affecting the lawfulness of the processing based on your consent prior to its withdrawal.

You also have the right to lodge a complaint with a data protection authority. A list and contact details of the European data protection agencies can be found on the European Commission's 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 postal mail or email, indicating the specific rights you wish to exercise, to: W2M Group - Attn. Responsible for the attention of RGPD rights, c/ General Riera 154, 07010 Palma (Illes Balears), Spain. Email: dataprotection@w2m.com.

More information about your rights and how to exercise them can be found on the W2M Group's privacy portal, on the website of the Spanish Data Protection Agency at www.aepd.es, on the website of the data protection authority in your country or by contacting the W2M Group's Data Protection Officer at dpo@w2m.com.

This privacy policy applies to the B2B website https://www.w2mpro.com/ (hereinafter referred to as the website). Please read this policy carefully. Here you will find important information about the processing of your personal data and the rights granted to you by the current legislation in this matter.

In the event of providing personal data of third parties, it undertakes to obtain the prior consent of those concerned and to inform them of the content of this policy. 

Who is responsible for the processing of your data?

Unless otherwise specified, the party responsible for the processing of your personal data is WORLD 2 MEET, S.L.U., (hereinafter W2MPRO), with registered office at Calle General Riera 154, 07010 Palma (Illes Balears), Spain. W2M PRO is part of the World2Meet tourism group. + info about the Group here. For further information on the processing of your data or to exercise your rights under current legislation on the subject, please send an email to dataprotection@w2m.com or contact the Data Protection Officer of the W2M Group at dpo@w2m.com.

What will we process web user data for and on what legal basis?

We process personal data in the circumstances and for the purposes described below:

Administrative and commercial management of the relationship with your agency
Metrics
Data consolidation for advertising purposes and commercial profiling
Consolidation of data for internal administrative purposes of the W2M Group
Establishment of a master database of individuals
Management control and business data analysis

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 person in charge of the agency or, if applicable, directly by the agents of your agency, in order to process your registration, provide a user and password to access the W2M PRO website and for the administrative and commercial management of the relationship with the agency. All such processing is necessary for the performance of the contractual relationship with the agencies that have subscribed to W2MPRO. 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 the guarantee of digital rights.

Financial data and data on transactions of goods and services will be processed for accounting and administrative management purposes in compliance with our legal obligations in accounting and tax matters.

All these data are consolidated in databases at group level. More information in section "2.4. Consolidation of data for internal W2M group administrative purposes" of this policy.

Metrics

In order to evaluate and manage the quality of our services and products, we perform statistics based on aggregated data obtained from transaction data and web browsing data, e.g., IP address, weblogs, pages visited or actions performed on the website (more info in our cookie policy). This processing is based on your consent for the installation of cookies, which you can revoke at any time through the website's configuration panel or by modifying the privacy settings in your web browser or device.

We also produce anonymous statistics from aggregated booking data to measure the performance of our routes and services. These processing operations are based on our legitimate interest in evaluating and managing the quality of our services and products. In weighing this interest against their rights and freedoms, it has been determined that the processing had a limited impact on the privacy of data subjects, corresponded to reasonable expectations of data subjects and did not pose significant threats.

Data consolidation for advertising purposes and commercial profiling

Data on customers and prospects of the W2M Group are consolidated into a commercial database for direct marketing purposes and for the creation of commercial profiles. An overview of these data processing activities can be found below. For further information, please refer to the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP.

The entity responsible for processing the data included in the commercial database of the W2M Group is WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., with registered offices at c/ General Riera, 154, 07010 Palma (Illes Balears), Spain (hereinafter W2M).

Your inclusion in this database is based on the consent you have been asked to give. Failure to give your consent or withdrawal of consent does not condition the execution of bookings or the provision of the services you have contracted. The extent to which data relating to you will be consolidated in W2M's database and what specific use will be made of it will depend on the consent you have given at the time of providing your data. You may revoke this consent or change your preferences at any time in accordance with 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 of non-personalised commercial communications and management of distribution lists (segmentation): W2M processes the identification and contact data that you have provided together with the data relating to your customer status, language and market/origin of the data, for the purpose of sending, by any means, non-personalised commercial communications relating to the tourism products and services offered under the brands operated by the Group. More info about the W2M Group brands here.

To manage our distribution lists, we segment the recipients of our communications according to data source, market and language. This processing consists of a simple classification according to objective criteria and is not intended for commercial profiling, prediction or behavioural analysis.

The service we use to send our marketing communications is located outside the European Economic Area. The service has been configured for data to be 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 personal data transferred to this data processor.

Development of a commercial profile for the personalisation of the Group's commercial communications and services: The data consolidated in the Group's commercial database is used to perform behavioural analysis and predictive modelling to understand and predict our customers' wants and needs, the actions related to the purchase of our products and services and the factors that condition them. If you have authorised the personalisation of the Group's services and communications, W2M will access the data generated by your bookings in order to include them in your commercial profile. This profile will be enriched with information generated from your interactions with the Group's companies and digital media, e.g., your requests for information or quotes or data generated by your browsing on our websites. More information about the data we include in our commercial profiles and their sources can be found 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 to personalise our offers according to the type of product you are likely to be interested in, based on the results 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 companies of the Group with which you interact, for example, to wish you a happy birthday or to take into account the preferences you have expressed at the time of making your reservations or during your use or enjoyment of the tourism products contracted. For this purpose, the companies of the Group with which you interact in the future will have access to your profile.

More information on the logic of our commercial profiles and what is involved in the personalisation of our services in section 3. b) of the Privacy Policy applicable to the commercial exploitation of customer and prospect data.

Consolidation of data for internal administrative purposes of the W2M Group

WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., with registered office at C/ General Riera 154, 07010 Palma (Illes Balears), 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 it makes to W2M for consolidation and for the use it makes of the consolidated group data. These processing operations are based on the legitimate interest of the W2M Group to transfer personal data within the corporate Group for internal administrative purposes and to have a consolidated view of its business for business decision-making.

Who can we disclose 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 it is necessary for the management and control of the contractual relationship, e.g. to your agency.

How long will we retain your data?

We will retain your data for as long as you remain a user of the Website, the data generated by transactions carried out on the Website will be retained in accordance with the periods provided for by current legislation on accounting and tax matters and in any case, we will retain the data for the time necessary to meet possible liabilities arising from the processing. We will delete your data when it is no longer necessary or relevant for the purposes for which it was collected.

The data processed by W2M for commercial purposes, including commercial profiles, will be retained for 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 PROSPECT DATA BY THE W2M GROUP.

Consolidated data for intra-group administrative purposes will be retained according to the criteria set out in the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP.

What are your rights?

In certain circumstances, you may request the restriction of the processing of your data. In such cases, we will only process the affected data for the establishment, exercise, or defence of legal claims or for the protection of the rights of other individuals. Under certain conditions and on grounds relating to your particular situation, you may also object to the processing of your data. In such cases, we will stop processing the data unless we have compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims. You have the right to obtain confirmation of whether or not we are processing your personal data, and if so, to access that data. You may also request the rectification of inaccurate data or the completion of incomplete data, as well as the deletion of data when, among other reasons, it is no longer necessary for the purposes for which it was collected.

In certain circumstances, you may request the restriction of the processing of your data. In such cases, we will only process the affected data for the establishment, exercise, or defence of legal claims or for the protection of the rights of other individuals. Under certain conditions and on grounds relating to your particular situation, you may also object to the processing of your data. In such cases, we will stop processing the data unless we have compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims. You also have the right to object to automated individual decisions that produce legal effects on you or significantly affect you in a similar way, where this right exists in accordance with Article 22 of Regulation (EU) 2016/679.  

You may also, under certain conditions, request the portability of your data to be transferred to another data controller.

You may withdraw your consent for certain purposes without affecting the lawfulness of the processing based on your consent prior to its withdrawal.

You may at any time revoke your consent to the processing of your data for commercial purposes, including commercial profiling, or change your preferences in this respect according to the mechanisms described in the section "What are your rights?" of the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND PROSPECT DATA BY THE W2M GROUP.

What are your obligations?

Use of the Website implies unconditional acceptance by users of the terms of use and privacy policy of the same, as well as their commitment to comply fully 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 Regulations).

With regard to the processing of data of persons for whom bookings are processed, users undertake in particular to comply with the duty to provide information provided for in the Data Protection Regulations, to give effect to the rights of the data subject and to maintain full confidentiality with regard to the personal data being processed.

Personal information available through the Website may only be accessed or used for the purposes of managing bookings and providing the services contracted by end customers.