PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND PROSPECT DATA BY THE WORLD2MEET GROUP (W2M)
This policy applies to the commercial exploitation of the consolidated data of customers and potential customers of the World2Meet Tourism Group (hereinafter referred to as the W2M Group) for private individuals. Please read it carefully, you will find important information about the processing of your personal data and your rights under the relevant legislation.
- Who is responsible for the processing of your data?
WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., with registered office at Calle General Riera 154, 07010 Palma (Illes Balears), Spain (hereinafter W2M) is responsible for the commercial exploitation of the consolidated data of clients and potential clients of the W2M Group's businesses.
For more information about the W2M Group click here .
If you have any questions about this privacy policy, the processing of your data or the exercise of your rights under current legislation, please send an email to dataprotection@w2m.com . You can also contact the W2M Group's Data Protection Officer at dpo@w2m.com .
- What data is consolidated in the group's commercial database?
The customer and potential customer data to be consolidated are obtained from the following sources:
- Of the requests made and the forms filled in by the interested parties when interacting with the W2M Group's businesses, whether online, in person or by calling a call centre.
- Of the bookings and transactions made with such businesses.
- Profiles and analytics obtained from the browsing of users of the group's websites, whether registered or not.
- Participation in the group's loyalty programmes and commercial campaigns, e.g. competitions, promotions or prize draws.
What are the businesses from which these data are consolidated?
The businesses from which customer and potential customer data are consolidated are as follows:
Brand* |
Descriptión |
Operating company |
Adress |
Web |
NEW BLUE |
Wholesale travel agency |
World 2 Meet Travel, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.newblue.es/ |
ICARION |
Wholesale travel agency
|
World 2 Meet Travel, S.L.U.
|
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.icarion.es/ |
KANNAK |
Wholesale travel agency |
Circuitos Turísticos, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.kannak.es/ |
W2M PRO |
Wholesale travel agency |
World 2 meet, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://pro.w2m.travel/ |
W2M DMC |
Incoming travel agency - tourist services at the destination |
World 2 Meet S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://dmc.w2m.travel/ |
ESCAPE HOME |
Vacation rental platform |
World 2 Meet S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.escapehome.com/ |
VIAJES AZUL MARINO |
Travel agency network |
W2M Corporate S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.viajesazulmarino.com/ |
AZULMARINO |
Travel agency network |
Viajes W2M S.A.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.azulmarino.com/ |
GRAND AZUL MARINO |
Travel agency network |
W2M Corporate S.L.U |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.grandazulmarino.com/ |
VIAJES CIBELES |
Travel agency network |
W2M Corporate S.L.U |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.viajescibeles.com/ |
THE SPHERE |
Travel agency network |
W2M Corporate S.L.U |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.thesphereprivate.com/ |
FLOWO |
Online travel agency |
Flowo Travel, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.flowo.com/ |
WORLD 2 FLY |
Airline |
World 2 Fly, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.w2fly.es/ |
WORLD 2 FLY PORTUGAL |
Airline |
World 2 Fly, Portugal S.A. |
General Firmino de Miguel, 3, 2ºB Torre 2, 1600-100 |
https://www.w2fly.pt/ |
HO7ELS |
Hotel chain |
Ganas De Viajar S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
|
What categories of data are consolidated?
Website registration forms or newsletter sign-up forms:
- Identification and contact details, language, market/origin of the data.
Contact forms, calls to call centres, requests for information or quotes:
- Identification and contact details: Name, surname, contact details; email, fax, mobile number.
- Purpose of the request information relating to the service or product for which information is requested, e.g. dates of travel, number and age of passengers, itineraries and services included in the booking...
Data obtained from requests for services, bookings and quotations:
- Identification and contact details of the reservation holder, including name, surname, identification document (type, number, date of issue), country of residence, postal, shipping or billing address, email, fax, mobile phone number;
- Data on personal characteristics of the reservation holder, including gender, date and country of birth, nationality, family data (family situation: children, date of birth of children, adults or minors, partner), language;
- Data from the booking/request for services itself: e.g. dates of travel, number and age of passengers, itineraries and services included in the booking, loyalty cards of carriers or other tourism providers held by them.
- Transaction data on goods and services.
Health data or other special categories of data, such as religion or beliefs, or data on means of payment, e.g. bank cards, provided in the booking will never be incorporated into commercial profiles.
Navigation data:
- Information obtained by observing your browsing on the group's websites: record of pages visited (browsing history, record of time spent on each page, record of the time of the visit to the page, record of mouse activity through the different parts of the website, browser used). + More information in the cookie policies of the group's websites.
Participation in loyalty programmes and commercial campaigns (competitions, promotions or prize draws):
- Identification and contact details, language, market.
- Identification of the loyalty programme or the commercial campaign in which it participates
Participation in the group's loyalty programmes or commercial campaigns is subject to the terms and conditions and the privacy policy applicable to the same.
The extent to which data relating to you will be consolidated in the W2M Group's commercial database will depend on the consent you have given at the time of collection of your data by the Group company or companies with which you have interacted.
- If you have not consented to receive marketing communications or to have your data included in a group marketing profile: your data will not be consolidated for these purposes, but will continue to be consolidated for internal group administrative purposes. + More information about this consolidation here.
- If you have consented to receive non-personalised commercial communications, but not to the creation of a commercial profile: only the following categories of data will be consolidated: - Identification and contact details, language, market/origin of the data.
- If you consented to the inclusion of your data in a commercial profile of the group: All available data categories listed above under the point "Which data categories are consolidated?
- For what purposes are the data contained in the W2M Group's commercial database processed and on what legal basis?
The data are processed for the following purposes:
- Sending of non-personalised commercial communications and management of distribution lists (segmentation).
W2M processes the identification and contact data provided by the interested parties, together with data relating to their 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. + info on 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.
These processing operations are based on the consent requested by the business of the group with which you interacted at the time your data was collected. Failure to give your consent or withdrawal of your consent does not condition the execution of the reservations or the provision of the services you have contracted with that company.
You may at any time withdraw your consent or change your preferences regarding the processing of your data for marketing purposes according to the mechanisms described below in the "What are your rights" section of this policy.
- Development of commercial profiles for the personalisation of the group's services and commercial communications.
The data consolidated in our 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. The business profiles we produce are based on available information on the following issues:
- What are customers or potential customers of the group's businesses looking for?
- What do they buy?
- How do they buy it?
- Where do they buy it?
- How much do they buy?
- When and how often do they buy it
Thanks to these profiles we can determine when to send you a commercial communication according to the frequency of your bookings or the periods of the year in which you have or usually travel and personalise our offers according to the type of product that may be of interest to you, taking into account your past bookings, the amounts spent or the products about which you have made an enquiry without contracting them, for example, to promote products aimed at family holidays if you have travelled as a family, have consulted this type of product on the group's websites or have requested a quotation for this type of trip.
We also use this profile to personalise the treatment and services provided by the companies of the group, 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 contracted tourism products.
What does this personalisation involve?
The companies of the W2M group with which you contact or contract a service will consult your profile data in order to personalise the attention to your request and the provision of such service. This customisation is done according to the standards defined by W2M. The consultation of your profile only takes place when you contact and interact with group companies and is carried out via connection to the group's data consolidation tool (CDP). Your profile data is not incorporated into the systems of the group companies making the enquiry. However, please note that where such companies are located outside the European Economic Area (EEA), the consultation of your profile may involve the transfer of such data to countries that do not offer a level of protection of personal data comparable to the European level. The W2M group has taken organisational and technical measures to ensure an adequate level of protection of the personal data processed, regardless of the location of the group companies, including the formalisation of standard clauses approved by the European Commission between W2M and group companies located outside the EEA, the use of secure connections, strict control of access to profile data and the establishment of rules for persons authorised to access such information. For more information on these safeguards, please email dataprotection@w2m.com or contact the W2M Group Data Protection Officer at dpo@w2m.com.
While no automated individualised decisions that produce legal effects on our customers or significantly affect them in a similar way are made on the basis of this profile, we inform you of your right to object to the adoption of such decisions in accordance with the provisions of Article 22 of Regulation (EU) 2016/679. You may at any time withdraw your consent or change your preferences regarding the processing of your data for marketing purposes according to the mechanisms described in the "What are your rights" section of this policy.
- Where is your data stored?
The W2M group's commercial database is hosted in the EU.
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 processor. You can consult these conditions at the following link: https://useinsider.com/legal/scc/
- To whom can your data be communicated?
Your data will only be communicated between W2M group companies in the situations described in the previous sections or to third parties due to legal obligations or with your prior consent.
- How long will we keep your data?
Profiles and data processed for marketing purposes are retained in an active state as long as you do not revoke your consent or request their deletion and, in any case, for the periods provided for in the applicable legal provisions and for as long as necessary to meet any liabilities arising from the processing. The media on which the existence of your consent to the processing of your data for these purposes is recorded, such as signed forms, electronic form submission logs, etc., will be kept for the duration of the processing and the applicable limitation periods.
After 5 years from your last contact with the W2M Group, your personal data will be deleted, without prejudice to their retention for the applicable legal periods and for the time necessary to meet liabilities arising from the processing. Any interaction with group companies, e.g. logging on to a website, requesting product information, booking a trip or opening a newsletter or commercial communication, is considered as contact.
- What are your rights?
You have the right to obtain confirmation as to whether or not we are processing your personal data and, if so, to access it. You can also ask for your data to be corrected if they are inaccurate or for incomplete data to be completed, as well as request their deletion if, among other reasons, the data are no longer necessary for the purposes for which they were collected.
In certain circumstances, you may request that we restrict the processing of your data. In this case, we will only process the data concerned for the formulation, exercise or defence of claims or for the protection of the rights of other persons. You may also, under certain conditions, request the portability of your data to be transferred to another data controller.
Under certain conditions and for reasons relating to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that override your interests or rights and freedoms, or for the formulation, exercise or defence of claims.
You may withdraw your consent to the processing of your data for marketing purposes, including profiling, at any time. We will then stop processing your personal information for these purposes. The withdrawal of your consent shall not affect the lawfulness of the processing based on the consent prior to it.
To withdraw your consent or update your preferences regarding the processing of your data for marketing purposes, you can:
- Use the link provided for this purpose in our commercial communications;
- Request it by email to the following email address: dataprotection@w2m.com ;
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 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 post or e-mail indicating the right(s) 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 or by contacting the W2M Group's Data Protection Officer at dpo@w2m.com .
Latest revision: 17/02/2023