IDM Spain & Portugal Privacy Policy

Latest modification: April 2019

This privacy policy is applicable to the website www.idmspain.com (hereinafter referred to as the Website) and completes the privacy policies of the Thomas Cook Group.

Please read this policy carefully. You will find important information in it about the processing of your personal data and the rights granted to you by the regulations applicable in this respect.

We reserve the right to update our privacy policy at any time due to business decisions and to comply with any legislative or jurisprudential changes. If you have any queries or need any clarification regarding our Privacy Policy or your rights, you can contact us through the channels specified below.

You state that the data you provide us with, either now or in the future, are correct and truthful and you agree to notify us of any changes thereto. If you provide the personal data of third parties, you undertake to obtain the prior consent of those concerned and to inform them about the contents of this policy.

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

  1. Who is responsible for processing your data?

The data controller for the data of the Website’s users and customers is IN DESTINATION INCOMING, S.L.U., with registered office at C/ Calçat 2 | 07011 – Palma de Mallorca, Spain.

You can contact our Data Protection Officer by email at dpo.spain@thomascook.es or at C/ Calçat 2 | 07011 – Palma de Mallorca, Spain.

Alternatively, you can contact the Group’s Data Protection Officer by email at GroupDPO@thomascook.com, by calling +44 (0)207 557 6400 or at Thomas Cook Group plc | 3rd Floor, South Building | 200 Aldersgate | London EC1A 4HD | United Kingdom.

  1. What personal information do we obtain?

The data we process are those we obtain as follows:

  • From the forms that you complete and from the requests made through the Website. We will also process the data included in the requests and petitions that we receive by email or through telephone.
  • From the analyses obtained from users browsing the Website, whether registered or not.

The data that we obtain are provided either directly by you or by third parties that process requests on your behalf.

The categories of data we process normally consist of the following:

  • Identification and contact details;
  • Personal details, such as language;
  • Data provided in the queries you send;
  • Data related to your browsing, for example the IP address from which you connect to the Website, weblogs, visited pages or actions carried out on the Website. For such purpose, we use cookies and similar technologies that could involve tracking your browsing activities. Further information about our cookies policy is available at [inserter link]
  1. Why will we process your data?

We will process the data of the Website’s users to manage the relationship with them, the commercial processing and monitoring of your requests, to respond to your queries, and for administration and management of the Website’s security.

These data will also be processed for statistical purposes and to improve quality. We will also process your data in order to send commercial messages.

  1. To whom can we disclose your data?

We will only disclose your data when this is necessary to render the requested services, to fulfil legal obligations and with your prior consent.

For the booking to be processed correctly, the booking data will be disclosed to the companies that are involved in rendering the request. This could imply the international transfer of your data when these companies are based outside the European Economic Area.

  1. Legal basis for data processing

The legal basis for processing your data is to manage the legal relationship we hold with you, to execute a contract or to adopt pre-contractual actions.

Managing the security of the Website is based on the existence of a legitimate interest.

Collecting statistics and conducting quality control are based on our legitimate interest in evaluating our services.

The commercial monitoring of your requests and sending commercial messages are based on our legitimate interest in promoting our services and obtaining your consent to receive commercial messages by electronic means.

  1. How long will we keep your data?

In general terms, we will keep your data for the term the legal relationship lasts with us and, in all cases, for the terms stipulated in the applicable legal provisions, for example those regarding accounting and tax matters, and for the time required to settle any possible liabilities arising from the data processing. We will cancel your data when they are no longer necessary or relevant for the purposes for which they were collected.

The access logs to restricted areas of the website will be cancelled one month after they have been created. The browsing information will be cancelled once the user has disconnected from the Website and the statistics have been collected.

The data processed for commercial purposes will be kept until you request the cancellation thereof.

  1. What are your rights?

You are entitled to obtain confirmation on whether or not we are processing your personal data and, in such case, to access such data. You can also request the rectification of your data when they are inaccurate or to fill in the data that are incomplete, as well as to request the cancellation thereof when, among other reasons, the data are no longer necessary for the purposes for which they were collected.

Under certain circumstances, you may request to restrict the processing of your data. In such case, we will only process the data to draw up, file and defend claims or for the purpose of protecting the rights of third parties. Under certain conditions and for reasons related to your particular situation, you may also oppose the processing of your data. In this case, we will no longer process the data unless there are legitimate imperative reasons to do so, which prevail over your interests or rights and freedoms, or to draw up, file or defend claims. Moreover, under certain conditions, you may request the portability of your data so that they are transferred to another data controller.

You may revoke your consent granted for certain purposes, however this will not affect the legality of the processing based on the consent granted prior to such revocation, and you may file a claim in the Spanish Data Protection Agency.

In order to request to unsubscribe from the processing for commercial purposes, you can send an email to this email address: dpo.spain@thomascook.es

In order to exercise your rights, you must send a request to the relevant data controller along with a copy of your national identity document or another valid document that proves your identity by email or post to the address specified in the section “Who is responsible for processing your data?”.

You can obtain further information on your rights and how to exercise them on the Spanish Data Protection Agency’s website: http://www.agpd.es.

We use our own cookies and those of third parties in order to render our services and analyse the website’s activity for the purpose of improving its content. If you continue browsing without changing your browser’s settings, we will consider that you accept the use of cookies. Further information is available in our Cookies Policy.

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