Last modification: April 2018
You declare that the data you provide, now or in the future, is correct and truthful and you agree to notify us of any changes to this data. If you provide personal data from third parties, you agree to obtain the prior consent of the parties in question and inform them about the content of this policy.
In general, the mandatory fields in our forms must be completed in order to process your requests.
1. Who is responsible for processing your data (the data controller)?
The data controller which shall process the data collected on the www.roomdi.es website is TRAVELTINO 2009 S.L., with address at transversal 2ª Muelle De Los Llanos, Edificio lanzateide Of. 20-21 38001 Sta. Cruz De Tenerife, Spain.
We belong to the Logitravel Group. You may contact the Data Protection Officer of the Logitravel Group at firstname.lastname@example.org.
2. What personal information do we collect?
The data we process is collected:
- From the forms that you fill out and from the requests that you make on the Website; for example, when you register, sign up to our newsletters, save a quote or purchase a trip. We also process the data included in requests that we receive by email or via our call centre.
- From profiles and analytics collected from users (registered or otherwise) browsing the Website.
- From your interest in our sales campaigns; for example, in contests or promotions.
- From the social media profile which you decide to use to log into our Website.
The data we collect is provided either directly by you or by third parties who process requests on your behalf; for example, the person making the booking, the company for which you work, or other travel agencies.
The data categories which we process typically consist of:
- Identification and contact details, ID number or passport.
- Personal details, such as language, gender, date of birth and nationality.
- Financial and transaction-related details.
- Location: Only if you have given your consent may we determine your approximate location to tailor the content of the Website according to your location. This location is deduced by analysing your IP address and/or the location of your Internet provider, and, therefore, does not enable us to know your exact location. We do not associate location data with identified users.
- Data regarding your booking history.
- Sales tracking data and, where appropriate, data related to your preferences and sales profile.
- Identification and contact details collected from the social media profile which you used to log into our Website. These details are only processed for this purpose.
- Data generated by your use of social media networks which you have decided to share with us (for example, likes and comments).
3. Why do we process your data?
We process your data for the following purposes:
- To manage our relationship with you.
- To process your requests and provide contracted services.
- To assess the quality of our services. In order to assess quality, we may send you satisfaction surveys, although there is no requirement to complete them.
- To comply with our legal obligations; for example, in accounting and tax affairs.
The data of Website users is also processed for the administration, management and control of the Website itself and its restricted access areas, as well as for statistical purposes and the enhancement of the Website and our services.
For reasons of security and quality control, calls made to our call centre and our agents may be recorded. If you do not wish the call to be recorded, please inform the agent attending to you.
We process your data for the following commercial purposes:
- To send commercial messages to our customers and users. These messages refer to products or services marketed by Logitravel Group related to the following industries: tourism, automotive, leisure, art, culture, training, telecommunications, financial and insurance.
- With your consent, we shall create a commercial profile based on your bookings and the data provided on the Website so that our deals and commercial messages are tailored to that profile. Automated decisions are not made based on the profiles of our customers.
- If you have requested a quote or have started but not completed a booking process on the Website or via our Call Centre, the data provided may be used to commercially follow-up your request. To this end, our agents may contact you by email or by phone, for example to resolve possible incidents in the booking process.
- If you show interest in our promotional campaigns, your data shall be processed in order to manage and control them. Interest in our promotions implies your consent to the processing and transfer of your data to the extent and under the terms and conditions indicated in that campaign, with said consent being an essential requirement for your interest in the promotions. Depending on the type of promotion, the data of interested parties or winners may be published on our websites, social media profiles or in the press. In the case of competitions and prize draws, the personal data of winners required to benefit from the prizes shall be communicated to their suppliers, with the parties in question thereby consenting to the international transfer of their personal details when said suppliers are located outside the European Economic Area.
4. Who may we disclose your data to?
In general, we shall only disclose your information with your prior consent, when it is necessary for the processing of your requests, the provision of contracted services, or to comply with our legal obligations. In particular:
- For the correct processing of the bookings requested, the data included in such bookings shall be disclosed to the suppliers of the tourist services included in the contracted packages and/or to companies which manage global booking systems. This may imply the international transfer of your data, if these companies are located outside the European Economic Area.
- We may also disclose data to fraud detection platforms in order to detect and prevent fraudulent payments or bookings.
- We disclose data of our customers and users to other Logitravel Group companies for the following internal administrative purposes:
- Analysis of business data and corporate information collected from consolidated customer data and bookings from group travel agencies, corporate management control, statistics and group-wide quality assessment. The group-wide data controller is Toolfactory, S.L., with registered address at Edificio Logitravel, Parcela 3B (Parc Bit) - Ctra. Palma - Valldemossa km 7.4, 07121 Palma de Mallorca, Spain.
- The commercial use of all the commercial databases of Logitravel travel agencies. The data controller for this processing is Travel Concept, S.L., with registered address at Edificio Logitravel, Parcela 3B (Parc Bit) - Ctra. Palma - Valldemossa km 7.4, 07121 Palma de Mallorca, Spain.
We may resort to technological solutions or services provided by companies which are outside the European Economic Area for certain functionalities of the Website. In this case, we shall adopt the appropriate measures to guarantee an appropriate level of personal data protection. In particular:
- We use various services provided by Google and its affiliates. These companies adhere to the Privacy Shield agreement between the EU and the USA. Under this agreement, personal data transferred from an EU company to a company from the United States shall be processed according to a series of well-defined protection standards and safeguards, thereby ensuring an appropriate level of protection. You may check the validity of Google's accession to the Privacy Shield at the following link: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- The chat feature incorporated into our Website is provided by the American company LiveChat, Inc. This company adheres to the Privacy Shield agreement (https://www.privacyshield.gov/participant?id=a2zt0000000L16xAAC&status=Active).
Please note that all information found in the blog, forums or other engagement tools available on the Website shall become public information, so users should take special care when deciding to post comments or share their personal details.
The use of these engagement tools is subject to the conditions listed below.
You undertake to make appropriate use of the comment posting feature of the Website, agreeing to refrain from posting details and/or comments which:
- Engage in unlawful or illegal activities or those that are contrary to good faith and public order.
- Disseminate content or propaganda of a racist, xenophobic or pornographic nature, or any defending terrorism, or that violates human rights.
- Contain content entailing an infringement of intellectual and industrial property rights.
- Harm the image of third parties.
- Introduce or transmit computer viruses or any other physical or logical systems which may cause damage to the company's computer systems.
- Use the email accounts or personal data of other users and modify or tamper with their messages.
We reserve the right to remove, or not publish, any comments or posts which fail to meet the abovementioned standards, particularly those which violate the respect for human dignity, which are discriminatory, xenophobic, racist, pornographic, which constitute an attack against youth or childhood, public order or safety or which, in our opinion, are not suitable for publication. We shall not be held responsible for the information stored at the request of users and, in particular, regarding the opinions expressed. Neither are we responsible for the accuracy, quality, reliability and correctness of the information which users may include. Notwithstanding the foregoing, anyone whose personal data is included in comments or posts published on the Website may request, at any time, the removal of such data, as indicated in the section "What are your rights?".
5. Legal basis for processing
The legal basis for the processing of your data is the management of the legal relationship established with you, the provision of requested or contracted services, and compliance with legal obligations, especially those applicable to accounting, taxation, tourism or traveller security and control.
The following data processing is based on a legitimate interest:
- Management of the security of the Website and our call centre, as well as the adoption of fraud detection and prevention measures based on our legitimate interest in guaranteeing the security of our systems and transactions.
- The monitoring of statistics and quality control, including recordings of calls to our call centre, based on our legitimate interest to assess our services.
- The commercial tracking of your requests, the sending of commercial messages and the consolidation of the commercial databases of Logitravel travel agencies form our legitimate interest and that of the group to promote the products or services sold by the Logitravel Group, as well as your consent for receiving such messages by electronic means.
- The analysis of customer data is based on the group's interest in processing this information for internal administrative purposes.
The following processing items are based on your consent, without the withdrawal of such consent conditioning the provision of contracted services:
- The commercial profiling of data for the sending of personalised offers and commercial messages is based on the requested consent;
- Browsing profiles based on information collected from cookies or similar technologies.
6. For how long will we retain your data?
In general, we shall keep your data for the duration of the relationship you have with us and, in any case, throughout the periods provided in the applicable legal provisions, for example, in relation to accounting and tax matters, and for the time necessary to meet possible processing-related liabilities. We shall remove your data when it is no longer necessary or relevant for the purposes for which it was collected. Specifically:
Access to restricted areas of the Website shall be withdrawn one month after its creation. Browsing-related information shall be removed once the website connection has been completed and the statistics compiled.
Recordings of calls to the call centre shall be discarded within a maximum period of 2 months, unless required otherwise for the time required to manage possible incidents or deadlines stipulated by legal provisions.
The data processed for commercial purposes, including commercial profiles, shall remain valid until its deletion is requested. Consent is recorded, for example, in electronic form submission logs, and shall be kept for the entire duration of the processing and the applicable limitation periods.
7. What are your rights?
You have the right to obtain confirmation about whether or not we are processing your personal data and, in that case, access such data.
Once you are registered on the Website, you may check your booking history, as well as access your profile and update the information you provided at the time of registration.
You may also ask for your data to be rectified if it is inaccurate or incomplete. In addition, you may request the deletion of your data if, among other reasons, it is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request limitations upon the processing of your data. In this case, we shall only process the data in question for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions, and for reasons related to your particular situation, you may also object to the processing of your data. In this case, we shall cease to process your data other than for compelling legitimate reasons which prevail over your interests or rights and freedoms, or for the formulation, exercise or defence of claims.
Similarly, and under certain conditions, you may request the portability of your data for it to be transferred to another data controller.
You may revoke the consent that you had given for certain purposes, without affecting the legality of the processing based on the consent prior to its withdrawal.
To request your withdrawal from processing for commercial purposes you may:
- Update your preferences in your profile, accessible from your Website account.
- Send an email to the following email address: email@example.com.
- Use the link provided in our newsletters for this purpose.
At any time you may revoke your consent for geolocation or the installation of tracking or profiling cookies by modifying the privacy options of your web browser or your device. You may learn more about online behavioural advertising and how to manage the privacy of your browser to refuse such processes at www.youronlinechoices.eu. Further information about our cookies policy is available at link.
You also have the right to file a claim with a data protection authority. You may check the list and contact details of the European data protection agencies on the European Commission website: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
To exercise your rights, you must send us a request accompanied by a copy of your national identity document, or another valid identity document, by postal or electronic mail, to our Data Protection Officer at the addresses indicated in the 'Who is responsible for processing your data (the data controller)?' section.
You may obtain more information about your rights and how to exercise them on the website of the Spanish Data Protection Agency ('Agencia Española de Protección de Datos') at http://www.agpd.es or on the website of the data protection authority of your country.