“Pax# Genuine Tourism Advisors” is deeply committed to compliance with Spanish and European regulations on the protection of personal data, and guarantees full compliance with the obligations established, as well as the implementation of the security measures provided in the General Data Protection Regulation (RGPD) (EU) 2016/679, of 27 April, and in the Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPD and GDD, hereinafter LOPD).
In accordance with these regulations, we inform that the use of our website may require certain personal data to be provided through contact forms, or by sending emails, and that these will be processed by “Pax# Genuine Tourism Advisors”, Data Controller, whose data are:
- Company Name: Pitarch Urani Associated Advisors SL
- CIF: B65484701
- Registered Office: Calle Pau Claris 170, 3ra Planta, 08037, Barcelona, Spain
- Telephone: 930 080 075
- eMail: firstname.lastname@example.org
Collection and Processing of Personal Data
Personal data is any information relating to a person: name, email, address, telephone, NIF/NIE… Additionally, when a User visits our website, certain information is automatically stored for technical reasons, such as the IP address assigned by your Internet access provider.
“Pax# Genuine Tourism Advisors”, as Data Controller, has the duty to inform the Users of its website about the collection of personal data that may be carried out, either by sending e-mail or by filling in the forms included in the website.
Only the data necessary to perform the contracted service, or to respond appropriately to the request for information made by the user will be obtained. The data collected are identifying and correspond to a reasonable minimum to be able to carry out the activity in question. In particular, no specially protected data is collected at any time. Under no circumstances will the data be used for purposes other than those for which they were collected.
Purpose: To respond to requests for information made through our contact form(s).
Legitimation: The legal basis that legitimizes this treatment is the consent of the User, which may be revoked at any time.
Transfer of data: Personal data will be processed through servers managed by Factoría Digital, which will be considered as Data Processor.
Mailing list registrations forms (newsletter)
Purpose: Sending communications, some of them commercial, of interest to users according to the theme of the web. As established by the LSSICE, “#NCOMM” undertakes not to send commercial communications without identifying them as such. For these purposes, the information sent to customers for the maintenance of the existing contractual relationship, if any, will not be considered as commercial communication.
Legitimation: The legal basis that legitimizes this treatment is the consent of the User, which may be revoked at any time.
Transfer of data: Personal data will be processed through servers managed by Mailchimp, which will be considered the Data Processor.
Only persons over 14 years of age may provide personal data on this website. As required by the LOPD and GDD, in the case of minors under 14 years of age, the consent of their parents or guardians will be a mandatory condition for us to process their personal data.
On the other hand, only persons over 18 years of age may contract our services. In the case of minors under 18 years of age, the consent of their parents or legal guardians will be a mandatory condition for us to provide the services offered, unless the minor is emancipated.
Users of the website of “Pax# Genuine Tourism Advisors” are informed that we have adopted the security, technical and organizational measures at our disposal to prevent the loss, misuse, alteration, unauthorized access and theft of data, and thus ensure the confidentiality, integrity and quality of the information contained therein, in accordance with the provisions of current legislation on data protection. The personal data collected in the forms are processed only by the staff of “Pax# Genuine Tourism Advisors” or by the designated Data Processors.
The User declares that all data provided by him/her are true and correct and undertakes to keep them updated. The User will be responsible for the veracity of his/her data and will be solely responsible for any disputes or litigation that may result from the falsity of such data. It is important that, so that we can keep the personal data updated, the User informs “Pax# Genuine Tourism Advisors” whenever there has been any change in them.
“Pax# Genuine Tourism Advisors” will not transfer or communicate to any third party your data, except in the cases provided by law or when it is strictly necessary for the provision of a service. Specifically, the data may be transferred to:
- Technology or computer service providers
- Payment service providers
- Courier and parcel delivery companies
- Third parties or intermediaries, as service providers, operating on our own behalf (agency, consultancy, etc.).
The transfer of data will take place in the strictest confidence, applying the necessary measures, such as the signing of confidentiality contracts, or adherence to their privacy policies set out on their respective websites. The User may refuse the transfer of his/her data to the Data Processors, by means of a written request, by any of the aforementioned means.
In addition, in those cases where necessary, Customer data may be transferred to certain agencies, in compliance with a legal obligation: Spanish Tax Agency, Labor Inspection, etc.
Ejercicio de Derechos del Usuario
The LOPD and the RGPD grant interested parties the possibility of exercising a series of rights related to the processing of their personal data. To do so, the User must contact us, providing documentation proving their identity (ID card or passport), by email to email@example.com, or by written communication to the address listed in our Legal Notice. Such communication must reflect the following information: name and surname of the User, the purpose of the request, address and supporting data.
The exercise of rights must be carried out by the User himself. However, they may be executed by a person authorized as legal representative of the User, providing the documentation proving such representation.
The User may request the exercise of the following rights:
- The right to request access to personal data, which is the right to obtain information on whether their own personal data is being processed, the purpose of the processing that, if any, is being carried out, as well as the information available on the origin of such data and the communications made or planned thereof.
- The right to request rectification, in the event that the personal data is incorrect or inaccurate, or deletion of data that proves to be inadequate or excessive.
- Right to request the limitation of its treatment, in which case only the data strictly necessary for the exercise or defense of claims will be kept by “Pax# Genuine Tourism Advisors”.
- Right to object to the processing: refers to the right of the data subject not to carry out the processing of their personal data or cease in cases where their consent is not necessary for the treatment, which are commercial prospecting files or that are intended to make decisions regarding the person concerned and based solely on the automated processing of their data, unless for legitimate reasons or the exercise or defense of possible claims have to continue to be treated.
- Right to data portability: in case you want your data to be processed by another company, “Pax# Genuine Tourism Advisors” will facilitate the portability of your data in an exportable format.
In the event that consent has been granted for any specific purpose, the User has the right to withdraw consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
We undertake to execute all these rights within the maximum legal deadline (1 month).
If a User considers that there is a problem with the way in which “Pax# Genuine Tourism Advisors” is handling his data, he can address his claims to the Security Officer or to the corresponding data protection authority, being the Spanish Data Protection Agency the one indicated in the case of Spain.
The personal data of Users who complete the contact form or send us an email requesting information will be processed for the time strictly necessary to respond to the request for information, or until the given consent is revoked.
Customers’ personal data will be processed until the end of the contractual relationship. The period of conservation of the personal data will be the minimum necessary, and may be kept until the end of the contractual relationship:
- 4 years: Law on Infractions and Penalties in the Social Order (obligations regarding affiliation, registrations, cancellations, contributions, payment of salaries…); Arts. 66 and following General Tax Law (accounting books…).
- 5 years: Art. 1964 Civil Code (personal actions without special time limit).
- 6 years: Art. 30 Code of Commerce (accounting books, invoices…)
- 10 years: Art. 25 Prevention of Money Laundering and Terrorism Financing Law.
- No time limit: disaggregated and anonymized data.
In the case of data processing of candidates (C.V.), “Pax# Genuine Tourism Advisors” may keep their curriculum for a maximum of two years in order to incorporate it to future vacancies, unless the candidate declares otherwise.
“Pax# Genuine Tourism Advisors” has a profile in some of the main social networks on the Internet (Twitter, LinkedIn, Vimeo, YouTube, SlideShare) recognizing itself in all cases responsible for the processing of the data of its followers, fans, subscribers, commentators and other user profiles (hereinafter, followers) published by “Pax# Genuine Tourism Advisors”.
The purpose of data processing by “Pax# Genuine Tourism Advisors”, when the law does not prohibit it, will be to inform its followers about its activities and offers, by any means that the social network allows, as well as to provide personalized customer service. The legal basis that legitimizes this treatment will be the consent of the person concerned, which may be revoked at any time.
In no case “Pax# Genuine Tourism Advisors” will extract data from social networks, unless the consent of the User is obtained specifically and expressly for this purpose (for example, for the realization of a contest).
International Data Transfers
“Pax# Genuine Tourism Advisors” uses the electronic communication sending services of the company Mailchimp, which is located in the United States. Standard contractual clauses approved by the European Commission have been signed with this entity, in order to ensure the appropriate level of protection in the processing of your personal data, in accordance with the criteria established by RGPD.
The applicant who sends electronic communications to “Pax# Genuine Tourism Advisors”, with the purpose of accessing to the personnel selection processes of the responsible, authorizes us to analyze the documents sent (e.g. the C.V. ), all content that is directly accessible through Internet search engines (e.g. Google), the profiles you maintain on professional social networks (e.g. LinkedIn), the data obtained in the entrance tests and the information you disclose in the job interview, with the aim of assessing your candidacy and being able, if necessary, to offer you a job. In case the candidate is not selected, “Pax# Genuine Tourism Advisors” will be able to keep stored his C.V. for a maximum of two years, in order to incorporate it to future vacancies, unless the candidate declares otherwise. The legal basis that legitimizes this treatment will be the consent of the person concerned, which may be revoked at any time.
The information provided by the User will, in any case, be considered confidential, and may not be used for purposes other than those described herein. “Pax# Genuine Tourism Advisors” will not disclose or reveal information about the claims of the User, the reasons for the advice requested or the duration of its relationship with the User.
This privacy and data protection policy has been drafted by ExpertosLOPD®, data protection company as of December 22, 2021, and may vary depending on the changes in regulations and jurisprudence that may occur, being the responsibility of the owner of the data to read the updated document, in order to know their rights and obligations in this regard at all times.