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Introduction

SIS Spa in Spain naturally takes your privacy very seriously and will safely process and use all information we have about you. Because most companies' privacy statements are drafted in incomprehensible legal language, we have listed the most important points for you in (more or less) ordinary English (at least we´ve tried to, but in places this has not been so easy ;-). It's useful that we understand what we promise you, right? If anything is unclear, send us a mail to sis@remove-this.spa-in-spain.com or call +34 628 149 640.

The purpose of our privacy policy is to inform you as to how we use the information you share with us in order to provide you with a great service, experience and so we can continue to make improvements. We want to ensure that you understand what information we collect with your consent, what we do and don´t do with it, and what your rights are.

This policy applies to all data collected by SIS Spa in Spain via the website, telephone, the newsletter, in competitions and in other ways.

This privacy statement is quite long and to make it easier to find what you are looking for you can scroll down to the specific topics described below:


1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW YOUR PERSONAL DATA IS COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. HOW WE DISCLOSE YOUR PERSONAL DATA AND THE DATA WE COLLECT ABOUT YOU

6. HOW WE SECURE YOUR DATA

7. HOW LONG WE RETAIN YOUR DATA FOR AND THE DATA WE COLLECT ABOUT YOU

8. YOUR LEGAL RIGHTS

9. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how SIS Spa in Spain collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc.

This website is not intended for children and the only circumstances in which we collect data relating to children, is when you make a booking of travel services and you have children in your party.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

SIS Spa in Spain C.B. is the controller and responsible for your personal data (collectively referred to as "SIS", "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are :

Full name of legal entity: SIS Spa in Spain CB
FAO Data Privacy Manager
Email address: sis@spa-in-spain.com
Postal address:Plaza del Mercat 3, 1D, 07340, Alaró, Islas Baleares, Spain

Telephone number: 0034 628 149 640

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 25th May 2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
 

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(A) Identity Data

This includes data relating specifically to your identity, such as your first name, maiden name, last name or similar identifier, title, date of birth, gender, nationality and passport details.

(B) Contact Data

This includes data relating to how you may be contacted, such as your (postal) address, email address and telephone numbers.

(C) Financial Data

This includes data relating to your means and methods of payment, such as your bank account and payment card details.

(D) Transaction Data

This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

(E) Technical Data

This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

(F) Profile Data

This includes the data that we receive when you make an enquiry or booking such as, your interests, preferences, feedback and survey responses.

(G) Usage Data

This includes information about how you use our website, products and services.

(H) Marketing and Communications Data

This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data & Sensitive data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Sensitive data

You can choose to share certain sensitive information with us (for example your medical history or current health situation), for example because you have requested specific medical assistance or to prepare a particular health program. By sharing sensitive personal information with us, you agree that we may collect, use and share this information with third parties to provide/prepare the services you request. If you withdraw your consent, we may not be able to provide all or part of the services that you have requested from us.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are attempting to book.

In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.
 

3. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you including through:

(A) Direct interactions

You may provide us with your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• make an enquiry or booking of travel services;

• subscribe to our newsletter or other publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us some feedback; or

(B) Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

(C) Third parties

We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:

(i) analytics providers such as Google based inside and outside the EU;

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity;
(b) Contact.

(a) Performance of a contract with you (where you make a booking with us).
(b) Necessary for our legitimate interests (so we can process your enquiries and bookings)

To send help requests to our team so they can reply back to you

(a) Identity;
(b) Contact.

(a) Performance of a contract with you (where you make a booking with us).
(b) Necessary for our legitimate interests – so we can assist you with your travel plans.

To confirm, amend or deliver your booking through SIS Spa in Spain to process and deliver your booking including:

(a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and Communications.

(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to secure deposit payments and debts due as per the properties’ payment or cancellation policy), to keep our records updated, to enable us to contact you to amend bookings and facilitate additional payments or refunds should this be required

To receive newsletters, rewards, and notifications of special offers

(a) Identity;
(b) Contact;

(a) Consent; SIS can send you newsletters when (i) you have made an enquiry/booking through one of the SIS websites and did not indicate at the moment of booking that you do not want to receive a newsletter, or (ii) if you registered yourself for the personalized SIS newsletter.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity;
(b) Contact;
(c) Technical.

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we send to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)


Guest reviews

If you have booked a travel service through SIS, we may ask you to write a guest review. When you send us a review, we can inform other travelers about the quality and the overall experience of the trip and / or other services that you have used. If you object to online publication of your review, please let us know at the time you send us the review. We can also display the review anonymously on your request.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

If you wish to view and/or amend your personal data or unsubscribe from our marketing material, please contact us

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you (we call this marketing).

If you have signed up for our newsletter and other promotional material, these e-mails can be personalized based on your personal details, past purchases and / or surfing habits.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time (by following the opt-out links on any marketing message sent to you or contacting us at any time).

Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.

Cookies

Like many websites, we use cookies (small text files saved to your computer) for certain features. By using this site you agree to the placement of cookies on your computer in accordance with the terms of this policy. Cookies allow us to personalise the content of the site for you, and to monitor website traffic. Cookies are also set when you use any of the social media sharing buttons on our site (to post on Facebook, for example); SIS does not have control over the cookie policies of third-party social media sites. You may set up your computer to reject cookies, or control which cookies your computer will and won’t accept by following the relevant instructions which can be found at www.aboutcookies.org or via the help menu in your browser; in that case, you may not be able to use certain features on our site.

For more information about the cookies we use, please see Cookie Policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

5. DISCLOSURES OF YOUR PERSONAL DATA

SIS will not sell or rent your information to or share with third parties for marketing purposes.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Your personal data is only shared with external third parties and our leisure partners (hotels, spas, car rental and other (transport) partners), but only when strictly necessary for the performance of our agreement with you. Some of our partners are located outside the European Economic Area.

These external third parties and leisure partners are also regarded as individual controllers of your personal data and they bear individual responsibility for this. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  

We may pass on your personal data to a third party if we have to provide or share it in order to comply with a legal obligation.


6. DATA SECURITY

SIS will take all appropriate technical and organizational measures to protect your personal data against loss or unlawful use. We cannot guarantee the security of information that is sent to us via the internet/email.

In case of any suspected personal data breach we will immediately notify you and any applicable regulator of a breach where we are legally required to do so.
 

7. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes. 

The information collected by Google analytics can be stored indefinitely and used for the purposes it was obtained for.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 

8. YOUR LEGAL RIGHTS

In the event that we actually process your personal data, you remain the owner of your data. That is why you have the right to:

(A) Request access to your personal data - (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(B) Request correction of your personal data - This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(C) Request erasure of your personal data - This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(D) Object to processing of your personal data ­- where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(E) Request restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(F) Request transfer of your personal data - to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(G) Right to withdraw consent - where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to use the aforementioned rights and / or have other questions, comments and / or complaints, please contact us with your motivated request.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
 

9. GLOSSARY

LAWFUL BASIS

• Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

• External Third Parties

i. Suppliers of travel services [acting as processors] or leisure partners (hotels, spas, car rental and other (transport) partners), (we will only disclose your personal data to those suppliers who provide the travel services that make up any booking of travel services that you make with us.)

ii. Service providers [acting as processors] based in the EU who provide IT and system administration services.

iii. Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in the EU who provide [consultancy, banking, legal, insurance and accounting services].

iv. Regulators and authorities acting as processors or joint controllers based in the EU who require reporting of processing activities in certain circumstances].


This version was last updated on 25th May 2018 and historic versions can be obtained by contacting us.

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