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Privacy Policy

At TOR GLOBAL TRAVEL (CICMA nº 3750), S.L.U (hereinafter referred to as "TGT"), recorded in the Commercial Registry of Madrid in Vol. 34.375, Folio 161, Sec. 8, Sheet M-618325, CICMA 3750, with registered offices located at Glorieta de Quevedo, 9, 28015 Madrid, we understand that the maximum standards of quality we demand of ourselves in every aspect of our products and services must unquestionably be applied to the protection of our client's privacy, as well.

Therefore, TOR GLOBAL TRAVEL (CICMA nº 3750) warrants that its intention is not only to comply strictly with the requirements of all applicable legislation regarding the processing of your personal information, including Regulation (EU) 2016/679 of April 27, 2016 by the European Parliament and the European Commission, concerning the protection of individuals with regard to the processing of personal data and the free circulation of such data, which replaced Directive 95/46/EC (the General Data Protection Regulation or GDPR), but to go a step further by ensuring and protecting your privacy to the greatest extent possible.

In this document, you will find all the information you need in order to understand how we manage and ensure your privacy.

Scope

As you know, TOR GLOBAL TRAVEL (CICMA nº 3750) offers all types of tourism services through its website. However, our website is not the only tool we use to interact with you. In addition to the information and resources available on the website, TOR GLOBAL TRAVEL (CICMA nº 3750) uses other media as a convenient means of keeping in touch with you and offering you all of the information you request. As such, you should be aware that this Privacy Policy extends to other means of communication besides our website, including social media, newsletters, emails, SMS, mobile apps and other existing methods. As we live in a constantly changing world, we recommend that you review this Privacy Policy periodically?at a minimum, each time you make reservations with us?to see if we have made any modifications.

Purposes

Depending on the type of relationship you choose to have with us, your information will be used for the following purposes:

1. Reservations: we use your personal information to process your online reservations. This includes sending the information to the appropriate service providers and to our own customer service department.

2. Improvements to our services: with the goal of receiving your feedback, TOR GLOBAL TRAVEL (CICMA nº 3750) may use your information to request your comments on your experience with any one of the services you contracted with us. To protect your privacy, the specific details you share with us will not be forwarded to the providers unless you specify otherwise.

Likewise, we may use your data for analytical purposes in order to improve our services and online platforms.

3. Account administration: we offer the possibility of creating a user account on our website. We use the information you provide to manage this account in order to perform maintenance and optimisation procedures. Thus, you can manage the status of your reservations yourself or through the TOR GLOBAL TRAVEL (CICMA nº 3750) agent assigned to your booking, complete your payments more quickly, take advantage of special promotions, make reservations more easily and manage your personal settings, which enable you to create and share lists, review previously viewed accommodations and your reservation history, and view other types of information that you have provided on lodging and destinations. They also enable you to view the comments you have posted on the lodging establishments in which you have stayed.

4. Marketing: in addition to the marketing activities that are carried out through the use of cookies (you can access our Cookie Policy here), we use your information to send you newsletters that are customised to your tastes, to display content that is adapted to your interests, including segmented advertising (advertisements based on your preferences and interests, displayed in third-party websites), and to conduct aggregate market research in order to consistently offer you the latest in trends and travel.

5. Market research: at times, we may invite you to participate in some type of market research. Of course, we will not use any information that cannot be aggregated and depersonalised, unless you consent to such use.

6. Fraud detection and prevention: to the extent required by law and good faith, we may use personal information to detect and prevent fraudulent, illegal or undesirable activities.

7. Advertising content: when you access a website or application that contains advertising space that displays one or more of our advertisements, it is probable that the advertisement contains one of our cookies. With your prior permission, it is probable that this cookie will be saved in your device, allowing us to recognise your browser during the period in which the cookie in question remains valid. We integrate cookies into the advertisements we distribute through third parties. These cookies are related to the software parameters of the browser you have previously used to enter or visit the official TOR GLOBAL TRAVEL (CICMA nº 3750) website. If your browser permissions and settings have authorised cookies to be stored, depending on the selected settings, these cookies will allow us to do the following:

a. Track the number of views and clicks on the advertising we distribute through third-party websites and applications.

b. Identify this content on websites or applications.

c. Determine the number of users who have clicked on each piece of content.

d. Calculate the amounts due to each of the parties involved in the advertising distribution chain (e.g. advertising agency, marketing department or website) and establish the corresponding statistics.

e. Adapt the presentation of the website linked to one of our advertisements in accordance with the preferences you set in your device (language, screen resolution, operating system, etc.) when you visited our website, in accordance with the hardware and the viewing or reading applications used by your device, and in accordance with the location data (longitude and latitude) transmitted by your device with your prior consent.

f. Track subsequent browsing performed through your device, including other websites, applications and advertising content.

The foregoing is without prejudice to our right to conserve your personal data, duly protected, for a period of five (5) years in order to facilitate legal actions stemming from liability of any kind, whenever the corresponding statutes of limitations have not expired.

Legitimation

The most common legal grounds for processing your data are that you have given your consent (for example, when you subscribe to our newsletter) or that such processing is necessary in order to provide a product or service you have contracted with us.

By law, the various countries involved in your relationship with TOR GLOBAL TRAVEL (CICMA nº 3750) may require your data to be processed in a given way (for example, in relation to tax matters or border issues).

Notwithstanding the foregoing, exceptional circumstances could arise in which the legal grounds for processing your data are of legitimate concern. Although we may not be able to waive such processing, we assure you that the use of your data will be restricted and carried out in accordance with best practices.

You should be aware that your opposition to certain types of processing could result in your inability to use some of the products or services you have contracted. Therefore, we waive any liability whatsoever that may arise from such situations.

Recipients

If you have contracted services from providers located outside of the European Economic Area, your information may be transferred to service providers based on your consent or as necessary for fulfilling the contract. When necessary, your information may also be transferred to the public administration of different countries in order to fulfil legal obligations.

Furthermore, as an international company, we must inform you that your information may be sent to TOR GLOBAL TRAVEL's (CICMA nº 3750) external collaborators that have been entrusted with managing certain processes (for example, reservations and payments, shipments, various types of administrative activities, etc.). In this regard, we assure you that these partners are subject to contracts and confidentiality clauses, in accordance with all applicable legal requirements.

You should also be aware that these service providers may be located outside of the European Economic Area. If you would like to learn more about the guarantees that have been established in relation to international processing of your information, you may contact us at [email protected].

If TOR GLOBAL TRAVEL (CICMA nº 3750) carries out or participates in a merger, acquisition, restructuring, sale of shares, bankruptcy proceeding or creditor meeting, we may sell, transfer or share all or part of our assets, including your personal information. In this case, we will inform you in advance of any such actions and will make you aware of any new privacy policies that may apply.

How does TOR GLOBAL TRAVEL (CICMA nº 3750) use social media?

We only use the Facebook plugin to encourage you to follow our website. All other options for sharing information with social media are offered through simple direct links without the use of plugins.

Except for specific cases in which your informed consent is requested in order to process your data, no other use is made of your information through social media.

How does TOR GLOBAL TRAVEL (CICMA nº 3750) use the comments and information you share with us regarding destinations?

After using the services, you may wish to share your impressions with TOR GLOBAL TRAVEL (CICMA nº 3750) or with other travellers. TOR GLOBAL TRAVEL (CICMA nº 3750)encourages you to do so, as this is our most effective means of ensuring the continuous improvement of our services.

Even if we do not send you a questionnaire, you may post your opinions in our forums, where they can be accessed by TOR GLOBAL TRAVEL (CICMA nº 3750) and other travellers.

As a logical consequence of sending comments to a publically accessible forum, you agree that any content (including your user ID if it was used to post the comment) may be posted in the various forums making up the TOR GLOBAL TRAVEL (CICMA nº 3750) community, whether on our website, social media or mobile apps. You further agree that TOR GLOBAL TRAVEL (CICMA nº 3750) may use this content (in full or in part) in any of its channels, as well as in its social platforms, newsletters and announcements, as the company sees fit, whether for marketing campaigns, for communications or for improving its services.

Security

When processing various types of information, in addition to complying fully with the requirements of data protection legislation, we consistently employ the latest security, encryption and access control systems in order to prevent unauthorised access and unwarranted use of personal information. In this way, we ensure that only authorised personnel will have access to your data and only for purposes of fulfilling their assigned duties.

Rights

In addition to periodically reviewing this Privacy Policy, as recommended previously, you may exercise your right to obtain and reuse, access, modify, limit, delete or opt out of the processing of your information, or exercise your right to withdraw your consent, by sending a written communication expressing your wishes?and including a copy of your ID?via post to TOR GLOBAL TRAVEL (CICMA nº 3750) at Glorieta de Quevedo, 9, 28015 Madrid or via email to [email protected].

You may opt out of the TOR GLOBAL TRAVEL (CICMA nº 3750) newsletters at any time by clicking on the Unsubscribe link you will find at the bottom of each newsletter, by unsubscribing directly here, indicating the unsubscribe email address, or by sending your request via email to [email protected]

You should be aware that any exercise of the aforementioned rights related to your personal information shall be performed within the limits imposed by law with regard to legal rights and requirements (fiscal, administrative, etc.). Deleting your information or opting out of having it processed does not imply its immediate removal, but instead, in accordance with the law, signifies that it will be archived for a limited time with access restricted to administrative and judicial authorities.

In any event, we will remind you of the laws regarding this Privacy Policy that will assist you in submitting a claim to the appropriate Data Protection Agency.

Origin and types of data

There are two ways to use our services: by previously registering with TOR GLOBAL TRAVEL (CICMA nº 3750) or without previously registering with TOR GLOBAL TRAVEL (CICMA nº 3750).

When making a reservation without having previously registered with TOR GLOBAL TRAVEL (CICMA nº 3750), you will provide us with the basic information required for the contracted service, such as your first name, last name(s), email address, nationality, passport or ID information, telephone number, credit card information for making the payment, the names of the other travellers and any other information requested by the provider that may be necessary in order to provide the service. This data will be stored or saved in accordance with the stipulations of the currently effective Privacy Policy.

It is important for you to know that we request only the information that is absolutely necessary in order to provide you with the requested service. With regard to your credit card information, the card number?excluding the last four digits of the primary account number (PAN)?is stored in a duly encrypted format. The authentication codes (CAV2, CVC2, CVV2, CID) are never stored in the system.

If your relationship with Tor Global Travel is to be long-term, as we hope it will be, the best way to connect with us is, without a doubt, to create a user account. Through your personal settings, in addition to any essential or mandatory information (such as your name and email address), you may choose which optional information you wish to share in your profile, as well as any optional data that may facilitate the reservation process and enable us send you information that best corresponds to your interests. TOR GLOBAL TRAVEL (CICMA nº 3750) reserves the right to access user accounts in order to perform optimisation and maintenance procedures.

Regardless of which method you choose, you always have the option of subscribing to our newsletter without the necessity of opening an account or booking a trip. In this case, you will be asked only for the information that is indispensable for providing you with the service.

When you use our website?particularly when you use our mobile applications?we may receive, store and process various types of data related to your location, including general information (for example, your IP address and postcode), as well as more specific information (such as the GPS feature used to access the website). Whenever the device permits it, you may disable the GPS and other geolocation features to prevent them from providing us with this type of information.

Certain information (such as your IP address, the date and time of access, the hardware and software you use, reference and exit pages, website browsing habits, number of clicks, page visits, visit order and time spent) may be automatically recorded by our servers each time you access or browse our website.

Additionally, you should be aware that, at TOR GLOBAL TRAVEL (CICMA nº 3750), we use cookies to improve your browsing experience and offer you the products and services that correspond most closely to your wishes. In this sense, you should be aware that we may receive information about you when you use certain social media services.

However, it is possible for us to process your information, whenever it pertains to your relationship with us, through third parties (for example, service providers).

Minors

Our services are intended for adults age 18 or older or for minors with the legal capacity to contract them. Non-emancipated minors are only permitted to use our services when they can demonstrate the express, specific consent of a parent or guardian. Otherwise, we reserve the right to remove all corresponding information and to cancel any reservations that have been made.

Links to other websites

TOR GLOBAL TRAVEL (CICMA nº 3750) offers links to other websites for your information and benefit. We shall not be held liable for the content provided on these third-party websites and cannot control or assume any responsibility whatsoever for the privacy policies of these websites. The third-party websites that are accessed through links from our website have their own privacy policies; therefore, we recommend that you read and evaluate them prior to using these websites.

Updated Aug 08, 2019