Last amended: May 2018

This Privacy Policy applies to the B2B COMING2 platform (hereinafter, the website). Please read it carefully. In it you will find important information about the processing of your personal data and the rights and obligations recognized by the current legislation on the subject. We reserve the right to update our Privacy Policy at any time in connection with business decisions and to comply with any changes in legislation or case law. Should you have any questions or need any clarification regarding our Privacy Policy or your rights, you may contact us through the channels listed below.

You state that the information that you provide to us, now or in the future, is correct and truthful, and you agree to notify us of any changes to it. In the event of providing third-party personal data, you undertake to obtain the prior consent of those affected and to inform them of the contents of this policy.

In general, the fields in our forms that are marked as mandatory must be completed in order to process your requests.

1. Who is responsible for processing your data?

Responsible party: COMING2 DESTINATION MANAGEMENT, S.A (COMING2)
Tax ID code: A76599471
Postal address: Plaza Mediterráneo nº5, Ed. Neptuno, 07014 - Palma (Balearic Islands), Spain
Telephone: 971 787 700
Email: coming2@coming2.com
Data Protection Officer contact: dpd.privacy@grupo-pinero.com

2. What personal information do we collect?

The data of our users are collected:

• From requests for the creation of user accounts.
• From the forms you have been asked to fill out and the requests you make.
• From information generated by the contractual relationship itself.

The categories of data we process typically consist of:

• Identification and professional contact information.
• Data on personal characteristics, such as language. 
• Data on transactions for goods and services. 

User data has been provided either directly by the user or by the person who has submitted the request for registration of the corresponding accounts on behalf of the user.

3. Why do we process your data?

The data of our website's users will be processed for the purposes of managing our relationship with them, attending to their requests and queries, processing bookings, administration and management of the security of the website, and compliance with our legal obligations, statistical and quality assurance purposes.

The professional contact details of the users of the website will be processed to send them professional information regarding news, products and tourist services marketed by COMING2.

4. Who can we share your data with?

Your data will only be disclosed to third parties under legal obligation, with your consent or when necessary for management and control of the contractual relationship.

5. Legal basis for processing

The basis for the processing of your data is the management of the legal relationship that is established with you, the provision of the services requested or contracted and compliance with legal obligations, especially the applicable regulations in accounting, tax and tourism matters.

The management of the website security is based on the existence of a legitimate interest. The compilation of statistics and the performance of quality control checks are based on our legitimate interest for internal administrative purposes, as well as on the evaluation of our services.

The sending of professional information about news, products and tourist services marketed by COMING2 is based on our legitimate interest in keeping the collaborating entities informed about our products and services.

6. How long do we keep your data? 

In general, we keep your data for the duration of your relationship with us and in any case for the periods specified in the applicable legal provisions, for example in accounting and tax matters, and for the time necessary to meet any liability arising from the processing. We will cancel your data when they are no longer necessary or relevant for the purposes for which they were collected.
Information relating to browsing will be deleted once the web connection is finalized and the statistics are completed.

7. What are your rights?

You have the right to obtain confirmation of whether or not we are processing your personal data and, if so, to access them.  You may also request that your data be corrected if they are inaccurate or that incomplete data be completed, and you may also request that they be deleted if, among other reasons, the data are no longer necessary for the purposes for which they were collected

In certain circumstances, you may request a restriction on the processing of your data. In such cases, we will only process the data concerned for the purpose of formulating, exercising or defending claims or for the protection of the rights of others. 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 prevail over your interests or rights and freedoms, or for the formulation, exercise or defense of claims. Likewise, and under certain conditions, you may request the portability of your data so that they may be transmitted to another data controller.

You may revoke the consent you have given for certain purposes, without affecting the lawfulness of the processing based on your consent prior to its withdrawal, and file a complaint with the Spanish Data Protection Agency.

To be withdrawn from the mailing list of professional information about our products and tourist services you must send an email to the address below: baja@coming2.com 

To exercise your rights, you must send to the party responsible for processing a request accompanied by a copy of your national identity card or other valid document identifying you by regular mail or email to the addresses indicated in the section "Who is responsible for processing your data?".

For more information about your rights and how to exercise them, please visit the Spanish Data Protection Agency's website at http://www.agpd.es.

8. What are your obligations?

The use of the website implies the unconditional acceptance by users of the site's terms of use and privacy policy, as well as their commitment to fully comply with the obligations imposed by the General Data Protection Regulation ((EU) REGULATION 2016/679) and/or the personal data protection regulations applicable to the agency (hereinafter and jointly the Data Protection Regulations).

With regard to the processing of data of the persons for whom enquiries and bookings are processed, users undertake in particular to comply with the duty of information provided for by the Data Protection Regulations, to the obligation to request consent for the processing of data for advertising purposes, to grant full effect to the rights of the data subject and to maintain full confidentiality with regard to the personal data being processed.

The personal information available through the website can only be accessed or used for booking management and to provide the contracted services.

PRIVACY POLICY FOR COMMERCIAL CORRESPONDENCE

This privacy policy applies to our commercial communications.

Please read it carefully. In it you will find important information about how your personal information is processed and about your rights under current regulations on the matter. 

We reserve the right to update our privacy policy at any time in connection with business decisions, and to comply with any changes in legislation or case law. If you have any questions or need any clarification regarding our Privacy Policy or your rights, you can contact us through the channels listed below.

1. Who is responsible for handling/processing your data?

The party responsible for handling/processing your data is VIAJES GTI GRUPO TURÍSTICO INTERNACIONAL, S.A., with Tax ID code A30350714 and registered address at Plaza Mediterráneo nº5 Ed. Neptuno 07014 - Palma de Mallorca (hereinafter, GRUPO PIÑERO).

You can contact GRUPO PIÑERO's Data Protection Officer at dpd.privacy@grupo-pinero.com

2. What personal information do we collect?

The data used to create commercial profiles are obtained:

• From the forms you've been asked to fill out and the requests/queries you make to hotels and companies of GRUPO PIÑERO, for example, reservations or requests for services.
• From the information provided to these hotels and companies in order to contract our services.
• From the information generated by your stays in our hotels and by the provision of contracted services.
• From complaints by guests and customers of the group and from satisfaction surveys.
• From profiles and analytics obtained from the browsing habits of users of the group's websites, whether registered or not. This may involve the use of browser tracking technologies (more information in our cookie policies).
• From your participation in marketing campaigns, e.g. contests or promotions.

The categories of data we process typically consist of:

Identification and contact information.

• Data on personal characteristics, such as gender, date and country of birth, nationality, marital status and language.
• Economic and transaction data: data related to the history of reservations and stays in our hotels.
• Data relating to the history of contact with the group.
• Data relating to claims and complaints lodged: Name, origin of the complaint, type and reason for the complaint, contact identification data, contact location data (phone/cell no., email, etc.).
• Data relating to customer preferences and profile, and commercial tracking data.
• Consolidated data generated by website user browsing habits.

We NEVER process or include health data or other special categories of data, such as religion or beliefs, or payment method data, such as bank card data, in the profiles of our customers and users.

3. Why do we create profiles and for what purposes do we process this data? 

The data we collect from the commercial profiles helps us to know and better understand our customers and users in order to improve their experience, through the analysis and improvement of the quality of our services and their customization, as well as that of our offers and commercial communications.

We make automated decisions based on the commercial profiles of our customers and users.

4. Who can we disclose your information to?

We will only disclose your information if required by law or with your prior consent.

5. Legal basis for processing

The creation of commercial profiles, the customization of our services and the sending of offers and personalized commercial communications are based on the consent requested, without the withdrawal of such consent conditioning the provision of the services contracted.

The sending of non-customized commercial communications, such as newsletters, and the use of quality statistics and surveys are based on our legitimate interest in the evaluation and promotion of our services.

6. How long will we keep your information? 

Profiles and data processed for commercial purposes are kept active as long as the data subject does not withdraw his or her consent or request their deletion and, in any event, for the periods specified in the applicable legal provisions and for the time necessary to address any liability issues arising from such 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, check-in sheets, etc. will be kept for the entire duration of the processing and the applicable time limits.
 

7. What are your rights?

You have the right to obtain confirmation of whether or not we are processing your personal data and, if this is the case, to access such data.  You may also request that your data be corrected if they are inaccurate or that incomplete data be completed, and you may also request that they be deleted if, among other reasons, the data are no longer necessary for the purposes for which they were collected.

Under certain circumstances, you may request restrictions on the processing of your data. In such cases, we will only process the data concerned for the purpose of lodging, exercising or defending claims or for the protection of the rights of others.

Under certain conditions and for reasons relating to your particular situation, you may also object to the processing of your data. In such cases, we will stop processing the data, except for compelling legitimate reasons that prevail over your interests, rights and freedoms, or for the formulation, exercise or defense of claims.

However, you may at any time withdraw your consent and object to the processing of your data for direct marketing purposes, including for the purpose of commercial profiling. In such case we will stop processing your personal information for such purposes. Withdrawal of your consent shall not affect the lawfulness of processing based on your prior consent.

Likewise, and under certain conditions, you may request the portability of your data so that they may be transmitted to another data controller.

You also have the right to file a complaint with the Spanish Data Protection Agency or any other competent supervisory authority.

To exercise your rights, you must send us a request accompanied by a copy of your national identity card or other valid document identifying you by regular mail or email to the addresses indicated in the section "Who is responsible for processing your data?".

To revoke your consent to receive our commercial communications, simply send an email to: baja@coming2.com

For more information on your rights and how to exercise them, please visit the Spanish Data Protection Agency's website at http://www.agpd.es.