Update May 2019
Responsable: MARIA CARMEN ANDRES URTASUN
Aim: To handle information requests through the website, aiming to maintaining business relationship and performance in tasks of information, services and other activities.
Legitimacy: The legitimacy is based on the consent you gave us when clicking the button “I accept the data protection policy”.
Recipients: Data only will be transferred to those entities that are necessary for the sole purpose of complying with the purpose stated above, if not for legal obligation.
Rights: You may use your right to access, modify, suppress, oppose, transfer or withdraw your consent on your personal data through the email [email protected], or in the postal address following:
Company Name: MARIA CARMEN ANDRES URTASUN (also Traveller in Style)
Postal Address: APARTADO 181, POLIGONO 26 Nº 121, 07814 SANTA GERTRUDIS (ILLES BALEARS, SPAIN)
Tax Identification Number: 47023022M
Telephone: + 34 608 436 806
E-mail: [email protected]
Registration Data: Registro de Marcas de Madrid. Documento No.3.719.029
Maria Carmen Andres Urtasun, as the Data Processor for the Website, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and the free movement of this data and other current regulations on the protection of personal data, and by Law 34/2002, of July 11, Services of the Information Society and Electronic Commerce (LSSICE), informs you the User that personal data collected through the forms available on the website: https://www.travellerinstyle.com, are included in computerized files for User specific services of María Carmen Andrés Urtasun, who will adopt the necessary measures to ensure the security, integrity and confidentiality for data in accordance with the provisions in the EU General Data Protection Regulation (GDPR).
PURPOSE OF PERSONAL DATA PROCESSING
In this policy, we use a few terms which are defined as follows: A “Member” is anyone who has registered an TiS account, including Homeowners and Guests. A “Homeowner” is someone who offers Properties (“Supplier Properties”) via published listings on the TiS Site (“Listings”). A “Guest” is someone who books, or seeks to book, Supplier Properties. “Accommodation” means a vacation or other property. “Payment Services” means any payment processing services provided through or in connection with a Member’s use of the TiS Site.
1. INFORMATION WE COLLECT
There are three general categories of information that Maria Carmen Andres Urtasun collects.
1.1. Information You Give Us.
We collect information you share with us when you use the TiS Site in order to ensure the adequate performance of contracts between you and Maria Carmen Andres Urtasun, or between you and a Homeowner. The provision of this information is necessary to use the TiS Site and, without it, we will not be able to provide you with services that you request.
Account Information. When you sign up for an TiS account or submit a request for Accommodation booking information, we require certain information such as your name and email address.
Profile Information. To use certain features within the TiS Site, we may need to ask you to complete a profile, which may include your address and phone number.
Other Authentication-Related Information. To help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identification that you provide (like a photo of your government-issued ID) or other authentication information.
Payment Information. When you use the Payment Services (such as when booking Accommodation or a travel-related experience through us or establishing a Supplier relationship via us), we require certain financial information (like your bank account or credit card information) to process payments and comply with applicable law. If you are a Homeowner, we may require additional information such as your ID or tax ID (where permitted by applicable law), and other proof of identification or verification in order to verify your identity, provide the Payment Services to you, and comply with applicable law. If you are a Guest, we may retain your financial information to assist you with booking travel-related experiences with third parties.
Communications with TiS. When you communicate with Maria Carmen Andres Urtasun or through the TiS Site, we collect information about your communication and any information you choose to provide.
Other Information. You may otherwise choose to provide us information (such as your itinerary, food allergies, emergency contact information, travel preferences, and information about other guests accompanying you on your stay) when you fill in a form, speak to, or otherwise communicate with Maria Carmen Andres Urtasun, conduct a search, update or add information to your TiS account, respond to surveys, participate in promotions, or use other features of the TiS Site.
1.2. Information We Automatically Collect from Your Use of the TiS Site.
When you use the TiS Site, we collect information about the services you use and how you use them, even if you don’t sign up for an TiS account. We process this information for the activities and legal bases described in Section 2 below.
Usage Information. We collect information about your interactions with the TiS Site, such as the pages or other content you view, your searches for villas, bookings you have made, the experiences and activities you book with others through us, and other actions on the TiS Site.
Location Information. When you use certain features of the TiS Site, we may collect different types of information about your general location (e.g. IP address, zip code).
Log Data. We automatically collect log information when you use the TiS Site, even if you have not created an TiS account or logged in. That information includes, among other things: details about how you’ve used the TiS Site (including if you clicked on links to third party applications), IP address, access times, hardware and software information, device information, device event information (e.g., crashes, browser type), unique identifiers, and the page you’ve viewed or engaged with before or after using the TiS Site.
Spam. In accordance with LSSICE, Maria Carmen Andres Urtasun and her Tis Site does not partake in SPAM practices, therefore, it does not send commercial emails that have not been previously requested or authorized by the User. Consequently, in all the communications that you will receive from Maria Carmen Andres Urtasun or any TiS Site representative, the User has the possibility of canceling his or her express consent to receive our communications.You can revoke your consent at any time by sending a letter with the subject “UNSUBSCRIBE” to [email protected]
We will not use your personal data for any other purpose than those described except by legal obligation or judicial requirements.
1.3. Information We Collect from Third Parties.
Maria Carmen Andres Urtasun may collect information that others provide about you when they use the TiS Site, or obtain information from other sources and combine that with information Maria Carmen Andres Urtasun collects through the TiS Site. Maria Carmen Andres Urtasun does not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to Maria Carmen Andres Urtasun should be directed to such third parties.
Third Party Services. If you link, connect, or login to your TiS account with a third party service (e.g., Facebook, Twitter, Google, Instagram), we may collect information from the third party service, such as your registration and profile information. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
2. HOW WE USE THE INFORMATION WE COLLECT
We use, store, and process information about you to provide, understand, improve, and develop the TiS Site, and to create and maintain a trusted and safer environment.
2.1. Provide, Improve, and Develop the TiS Site.
• Enable you to access and use the TiS Site.
• Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings.
• Operate, provide, improve and optimize the TiS Site and experience, such as by performing analytics and conducting research.
• Personalize or otherwise customize your experience by, among other things making Accommodation suggestions, ranking search results or showing ads based on your search or booking history, and any preferences you provide to us, or that are signified by your search and booking history.
• Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier.
• Provide customer service.
• Send you service or support messages, such as updates, security alerts, and account notifications.
• If you provide us with your contacts’ information, we may use and store this information for any purpose you authorize at the time of collection.
• We process this information given our legitimate interest in improving the TiS Site and our users’ experience with it, and to ensure the adequate performance of our contract with you.
2.2. Create and Maintain a Trusted and Safer Environment.
• Comply with our legal obligations.
• Resolve any disputes with any of our users and enforce our agreements with third parties.
• Enforce our Terms of Service, Member agreements, and policies.
• We process this information given our legitimate interest in protecting the TiS Site, to verify and ensure the adequate performance of our contract with you, and to comply with applicable laws.
2.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing.
• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about our products and services or partner campaigns and services.
• Personalize, measure, and improve advertising.
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Maria Carmen Andres Urtasun or its third party business partners.
• Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with our services, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
• We process this information given our legitimate interest in protecting the TiS Site, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3. SHARING AND DISCLOSURE
3.1. With Your Consent or Where Authorized by Law.
We may share your information at your direction or as described by us to you at the time of sharing, such as if you, as a Guest, have requested us to connect you with a third party vendor or to purchase services from a third party vendor on your behalf, in connection with your booking (e.g., an activities provider), or if you, as a Supplier, have agreed to let us market your Accommodation through, or refer you to, a third party’s Site. In these situations, you are authorizing TiS to disclose to these third party vendors information required to book them and to receive the relevant services from them. This could include special preferences or requests, and any additional guest information. These third party vendors are not controlled by TiS and personal information shared with them is subject to their privacy policies and practices.
3.2. Sharing between Suppliers and Guests.
When you as a Guest submit a booking request, certain information about you may be shared with the Supplier to coordinate the booking, such as your name, contact details, and arrival date.
When you as a Supplier have a confirmed booking, certain of information about you may be shared with the Guest to coordinate the booking, such as your full name, phone number, and Accommodation address.
Sharing this information is necessary to provide Guests with our services, and we don’t share your billing and payout information with other Members.
3.3. Reviews, Listings, and other Public Information.
The TiS Site publishes information that is visible to the general public. For example:
Public Listing pages are publicly visible and include information such as the Accommodation’s approximate or exact location, Listing description, calendar availability, and any additional information the Supplier chooses to share.
After completing a booking, Guests may write reviews which may appear publicly on Listing pages (and other pages on which we may market Accommodations) under their first name, last initial, and general location.
If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the TiS Site, that content is publicly visible.
Information you share publicly on the TiS Site may be indexed through third party search engines. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.4. Additional Services by Suppliers.
Suppliers may use third party services available through the TiS Site to assist with managing their Accommodation or providing additional services, such as cleaning services, insurance or activities providers. Suppliers may use features on the TiS Site to share information about the Guest (like the Guest’s check-in and check-out dates, name, phone number, and anonymized email address) with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services.
3.5. Safety and Compliance with Law.
We will attempt to notify Members about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon TiS’s property, its Members and the TiS Site (collectively, “Risk Scenarios”). In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
We may display parts of the TiS Site (e.g., your Listing page) on sites operated by TiS’s business partners, using technologies such as widgets or APIs.
3.7. Security Forces and Tax Authorities.
In jurisdictions where we facilitate the collection and remittance of occupancy taxes, Suppliers and Guests expressly grant us permission, without further notice, to disclose Suppliers’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.
3.8. Business Transfers.
4. OTHER IMPORTANT INFORMATION
4.1 Linking Third Party Accounts.
You may link your TiS account with your account at a third party social networking service. When you create this link: the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
the publication and display of information that you provide to TiS through this linkage is subject to any of your settings and authorizations on the TiS Site and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
4.2 Google Maps/Earth.
4.3 Third party partners & integrations
The TiS Site may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). TiS doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Airbnb, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
4.4 Storage of your personal data
Your data will be kept for the duration of the commercial relationship with Maria Carmen Andres Urtasun or until you exercise your right to cancellation or opposition, or limitation to processing.
4.5 Lawfulness of personal data processing
Treatment for your data will be done with following legal bases that legitimize it:
A. Request for information and/or the contracting of the services of María Carmen Andrés Urtasun, whose terms and conditions will be made available to you in any case, prior to a possible contracting.
The legal basis for data processing is your consent granted to carry out the purposes described above, which will be requested at the time by marking the corresponding box when collecting your data.
Failure to provide the personal data requested or failure to accept this data protection policy means that it is impossible to subscribe, register, or receive information about Maria Carmen Andres’ products and services.
In cases where there is a prior contractual relationship between the parties, the legitimacy for the development of administrative, tax, accounting, and labor obligations that are necessary under current legislation will be the prior existence of the commercial relationship established between the parties.
Any communication sent will be incorporated into the Information Systems of Maria Carmen Andres Urtasun. By accepting these conditions, terms, and policies, the User expressly consents to Maria Carmen Andres Urtasun carrying out the following activities and/or actions, unless the User indicates otherwise:
• The sending of commercial and/or promotional communications by any means enabled informing the Users of the activities, services, promotions, advertising, news, offers, and other information about the services and products related to the activity.
• In the event that the User has expressly consented to the sending of commercial communications electronically by subscribing the NEWSLETTER, the sending of such communications by electronic means informing the Users of the activities, services, promotions, advertising, news, offers, and other information about the services and products of Maria Carmen Andres Urtasun equal or similar to those that were originally the aim of the contract or interest by the User.
• The storage of personal data during the periods provided in the applicable provisions.
5.1. Official means of communication
The User is informed that the means enabled by the company to communicate with customers and others affected are the corporate phone, corporate mobile phones, and corporate email.
If you send personal information through a means of communication other than those indicated in this section, Maria Carmen Andres Urtasun will be exempt from liability in relation to the security measures available regarding the medium in question.
If you include files that contain personal data on shared hosting servers, María Carmen Andrés Urtasun is not responsible for the breach by the user of Data Protection Regulation.
6. ASSIGNMENTS OR TRANSFERS RECIPIENTS
Maria Carmen Andres Urtasun does not carry out any data transfer or communication unless there is a reasonable need to comply with a legal procedure, legal obligation, or prior to obtaining the User’s consent.
International transfers of your personal data will not be made without your prior consent, without prejudice to blocking or canceling your account if there may be indications of the commission of a crime by the User. The information provided will only be available to Maria Carmen Andres Urtasun at this time.
The information that you provide us both through this website and through the application will be hosted on the servers of Maria Carmen Andres Urtasun www.travellerinstyle.com. The data processing of said entity is regulated by a contract regarding the processing between Maria Carmen Andres Urtasun and said company. In no case will this data processor subcontract services that involve any data processing by third parties without our prior consent.
As treatment managers, Maria Carmen Andres has hired following service providers, having committed to compliance with regulatory provisions, applicable in terms for data protection, at time for hiring:
6.1. Data collected by service users:
If User includes files that contain personal data on shared hosting servers, María Carmen Andrés Urtasun is not responsible for the breach by the user of Data Protection Regulation.
6.2. Data retention in accordance with LSSI:
Maria Carmen Andres Urtasun as a hosting service provider and under the provisions contained on Law 34/2002, of July 11th, on the Information Society Services and Electronic Commerce (LSSI), will keep certain personal identification and traffic data for a maximum period of 12 months, essential information to identify the source of data stored and the time when service started.
Retention of such data does not affect secret in communications and may only be used within the framework for a criminal investigation or to safeguard public safety, making them available to the judges and/or courts or the Ministry which thus requires.
Data communication to State Forces will be under legal provisions on personal data protection.
7. YOUR CHOICES
7.1. Managing Your Information.
You may access, update, and correct most of your basic personal information by logging into your TiS account and reviewing your settings and profile. Where permitted by applicable law, you may request written copies of your personal information held by us. In some cases and where permitted by law, we may charge a fee which will be disclosed to you before we comply with your request. You are responsible for keeping your personal information up-to-date.
7.2 Data Retention & Account Cancellation.
We generally retain your information for as long as is needed to provide the TiS Platform to you, or for as long as your account is active. If you no longer want us to use your information to provide the TiS Platform to you, you may cancel your account or request us to erase your personal information. To cancel your TiS account, contact us. If you cancel your account or request erasure of your personal information, note that:
– Information you have shared with others (such as Listing reviews) may continue to be publicly visible on the TiS Platform in association with your first name, even after your TiS account is cancelled.
– Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
– Because we maintain the TiS Platform to protect from accidental or malicious loss and destruction, residual copies of your information may not be removed from our backup systems for a limited period of time.
– TiS may retain certain information to the extent necessary to comply with its legal obligations.
– TiS may retain certain information as necessary for its legitimate business interests, such as fraud detection and prevention, enhancing user safety, and defending itself against legal claims. For example, if TiS removes a user account for fraud or user safety reasons, TiS may retain certain information from that account to prevent that user from opening a new TiS account in the future.
7.3 Withdrawing Consent.
According to the Spanish Law, you are entitled to withdraw consent you previously gave to Maria Carmen Andres Urtasun to process your information and to end your use of the TiS Platform by cancelling your account as described in this section. Additionally, you may have the right to limit the ways in which we use your personal information.
Maria Carmen Andres Urtasun is continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.
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