PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE WORLD2MEET GROUP (W2M)
Data on persons, economic data, bookings and, in general, data on transactions of goods and services generated by the businesses developed by the companies of the WORLD2MEET group (hereinafter W2M group) are consolidated in centralised databases at group level. This policy applies to the consolidation and use of this data for intra-group administrative purposes.
The processing of consolidated customer or prospect data for commercial and profiling purposes is described in the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.
Please read this policy carefully, it contains important information about the processing of your personal data and your rights under applicable law.
- Who is responsible for the processing of your data?
Group companies are jointly responsible for the consolidation of data generated by their businesses, according to the division of responsibility set out below and in the sections of this policy:
- 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 administration and security of the consolidated databases;
- Each group company is responsible for its data communications to W2M for consolidation and for its use of the consolidated group data. Below is a list of the companies that are part of the W2M group:
Brand |
Description |
Operating company |
Address |
Web |
- |
Central services |
WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.w2m.travel/ |
NEW BLUE |
Agencia de viajes mayorista |
World 2 Meet Travel, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España
|
https://www.newblue.es/ |
ICARION |
Agencia de viajes mayorista
|
World 2 Meet Travel, S.L.U.
|
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.icarion.es/ |
KANNAK |
Agencia de viajes mayorista |
Circuitos Turísticos, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España
|
https://www.kannak.es/ |
W2M PRO |
Agencia de viajes mayorista
|
World 2 meet, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), Españ |
https://pro.w2m.travel/ |
VIAJES CIBELES |
Agencia de viajes mayorista
|
World 2 meet, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), Españ |
https://rutasculturales.viajescibeles.com/ |
W2M DMC |
Agencia de viajes receptivo – servicios turísticos en destino |
World 2 Meet S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://dmc.w2m.travel/ |
ESCAPE HOME |
Plataforma de alquileres vacacionales |
World 2 Meet S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.escapehome.com/ |
VIAJES AZUL MARINO |
Red de agencias de viajes |
W2M Corporate S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.viajesazulmarino.com/ |
AZULMARINO |
Red de agencias de viajes |
Viajes W2M S.A.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.azulmarino.com/ |
GRAND AZUL MARINO |
Red de agencias de viajes en España |
W2M Corporate S.L.U |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.grandazulmarino.com/ |
VIAJES CIBELES |
Red de agencias de viajes en España |
W2M Corporate S.L.U |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.viajescibeles.com/ |
THE SPHERE |
Agencia de viajes |
W2M Corporate S.L.U |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.thesphereprivate.com/ |
FLOWO |
Agencia de viajes en línea |
Flowo Travel, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.flowo.com/ |
WORLD 2 FLY |
Aerolínea |
World 2 Fly, S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
https://www.w2fly.es/ |
WORLD 2 FLY PORTUGAL |
Aerolínea |
World 2 Fly, Portugal S.A. |
General Firmino de Miguel, 3, 2ºB Torre 2, 1600-100 |
https://www.w2fly.pt/ |
HO7ELS |
Cadena hotelera |
Ganas De Viajar S.L.U. |
C/ General Riera 154, 07010 Palma (Illes Balears), España |
|
The companies of the W2M group have entered into a contract regulating the data processing they carry out to ensure an adequate level of protection of personal data. This privacy policy reflects the essential aspects of this contract. You can request more information by sending an email to dataprotection@w2m.com .
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 .
- For what purposes are data consolidated and on what legal basis?
The W2M group consolidates data for the following purposes:
- Elaboration of a master of persons at the group level
The identification and contact details you provide when interacting with group companies are consolidated in a unified database to form a master of persons. These interactions may occur in the context of a consumer relationship, e.g. when you make a reservation or travel with a group company (business-to-consumer or "b2c" relationships), or a professional relationship, e.g. if you are a contact person, a legal representative, an employee of a client company or a supplier (business-to-business or "b2b" relationships).
What categories of data are consolidated? See more
The categories of data that may be included in the person master consist of the following:
- Identification data, Identity document (type and number);
- Data on personal characteristics (gender and language);
- Personal contact details (in case the relationship with you is b2c);
- Professional and company contact details (in case the relationship is b2b).
The purpose of this consolidation is to have a unified register of persons in order to optimise operational processes common to the group companies where it is necessary to identify a person, 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. The processing of the master data of individuals by these companies will be carried out under the conditions and to the extent indicated in the privacy policy that governs your relationship with them and that was made clear to you at the time of obtaining your data. Each of the group companies is responsible for the specific use it makes of this data.
The elaboration of a master list of persons is based on the legitimate interest recognised by Recital 48 of the GDPR to transmit personal data within a corporate group for internal administrative purposes.
How has this interest been weighed against their rights and freedoms? See more
For the weighing of this interest against their rights and freedoms, the following has been determined:
- The processing is compatible with the reasonable expectations of the data subjects, as there is an existing relationship between the data subjects and the group companies.
- The synchronisation of data between corporate systems enables accurate and up-to-date data to be maintained, ensuring compliance with the principle of data quality, which is also in the interest of the data subjects themselves.
- The impact of the processing on the privacy of data subjects is limited, given the purpose of the processing and the fact that technical and organisational measures have been adopted to ensure that synchronisation only occurs when there is an existing relationship that requires the identification of the data subject and that there is a separation of functions between the persons responsible for the administration of the personal master and, in general, of the group's systems, and the persons who are users of these systems.
- Management control and business data analysis
Economic data, bookings and, more generally, transaction data on goods and services generated by the businesses developed by the W2M group are consolidated to enable W2M and its group companies 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 business strategies.
These processing operations are based on the legitimate interest of the W2M group in having a consolidated view of its business for business decision-making and the legitimate interest recognised by recital 48 of the GDPR to transmit personal data of customers within a corporate group for internal administrative purposes.
How has this interest been weighed against their rights and freedoms? Read more
For the weighing of this interest against their rights and freedoms, the following has been determined:
- The processing is compatible with the reasonable expectations of the data subjects, as they are customers of group companies or travellers included in the bookings processed by them and the processing takes place within the framework of existing relations with the group.
- The impact of the processing on the privacy of data subjects is limited, as technical and organisational measures have been taken to make it impossible for users generating reports and analyses to identify individuals. These measures include the separation of systems used for management control/business intelligence purposes from other systems, especially the system used for commercial campaigns, as well as the separation of functions between the persons who are users of the business intelligence tools and the persons in charge of the administration of the group's systems.
- To whom can your data be communicated?
It is not envisaged to communicate the data included in the master of persons or in the consolidation of economic, reservation and transaction data of goods and services to third parties outside the W2M group, except for legal obligations, with your prior consent or when it is necessary to provide you with the services you have contracted from the group.
- How long will we keep your data?
The data included in the master of persons in the group will be kept in an active state for as long as you maintain a relationship with the W2M group 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.
Economic data, booking data and, in general, data on transactions of goods and services processed for the purposes of management control and business data analysis are retained without time limit. This information is anonymised as the data in the person master is cancelled.
- 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. You can consult the mechanisms available to request your removal from the group's distribution lists or the deletion of your commercial profile in the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP .
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 ( https://www.aepd.es ) or by contacting the W2M Group's Data Protection Officer at dpo@w2m.com .
Latest revision