Privacy Policy

1. Who does this Privacy Policy apply to?
2. Who is the personal data controller?
3. What is the legal basis for processing the data?
4. What information do we process?
5. For what purposes do we process the data?
6. How long do we store the data?
7. To which recipients are the data communicated?
8. Can international data transfers be carried out?
9. What rights does the user have regarding the data provided?
10. How do we protect our users’ data?
11. Amendments
12. Applicable law

1. Who does this Privacy Policy apply to?

By visiting or consulting the website of www.tuna-tour.com (hereinafter, the “Website”) and using the services offered, you, the user (potential customers, customers, applicants, inter alia) accept the processing of your personal data, complying with the terms set out herein (hereinafter, the “Privacy Policy”).

This Privacy Policy and the form of processing your data will be regulated by the General Data Protection Regulation, or Regulation [EU] 2016/679 (“GDPR”).

2. Who is the personal data controller?

This is the relevant information of the Controller of the personal data processed and which are provided by the users:

3. What is the legal basis for processing the data?

The legal basis for processing the personal data is:

• The completion of the forms at the TUNA TOUR website. These forms (section 4.a) are completed by the data subject or he/she shares certain information and thereby provides his/her full consent to the processing of his/her personal data.
• The legitimate interest of TUNA TOUR.
• Performance of an agreement.
• Compliance with applicable regulations and public interest in reference to that which is determined by COVID-19.

4. What information do we process?

The information that we receive from users or that they share, and which will be dealt with in the strictest confidentiality, is processed and managed as set out below.

a) a) Information that users provide us with directly: TUNA TOUR collects and stores certain information which the user enters on the TUNA TOUR Website, through the following sections/forms.

b) Information that users provide us with indirectly:

4.1. Data quality: The user must guarantee, both vis-à-vis TUNA TOUR and vis-à-vis third parties, the quality of the information and personal data provided via the TUNA TOUR Website. This means that all the personal data and information provided must be real, truthful, up-to-date and belong to the user and not to third parties. If the data belong to third parties, we assume that it is with their consent and we would ask you to invite said third party to consult our legal texts as soon as possible.

4.2. Modification of data: The user must notify TUNA TOUR about any modification made to the personal data provided, being liable, in any case, for the truthfulness and accuracy of the data provided at all times..

5. For what purposes do we process the data?

6. How long do we store the data for?

TUNA TOUR will keep the user’s personal data for as long as is reasonably necessary to: comply with any of the objectives mentioned in this Privacy Policy and to comply with current legislation, regulatory requirements and relevant orders by competent courts or, in any case, for as long as we send you information or communications and the data subject does not request their deletion or object to them.

Your personal data will be anonymised or deleted once they are no longer relevant for the purposes for which they were collected.

Retention periods applied:

• Selection processes (CVs): one (1) year.

7. To which recipients are the data communicated?

The personal data that TUNA TOUR collects will be used exclusively for the achievement of the object defined at the TUNA TOUR Website. In order to achieve this objective and provide the service correctly, TUNA TOUR could share certain personal data of users:

• When legally required, TUNA TOUR may share information with enforcement authorities and/or third parties regarding requests for information relevant to investigations of a criminal nature and into alleged illegal activities.
• External service providers: some companies outsourced by TUNA TOUR may have access to your personal data and personal information, always under the exclusive control of TUNA TOUR, when necessary to provide our services.

i. If you, the user, specifically authorise the sending of commercial information, there may be collaboration with Selligent Marketing Cloud (Selligent Inc., and Selligent, S.A.) – Mailings sending platform may be collaborated, always under the exclusive control of TUNA TOUR. The user can consult the Privacy Policy of this provider here.

ii. Payment gateway: Banco Sabadell (Banco de Sabadell, S.A.), a company registered in Spain. It processes personal data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate any financial losses or other damages to Users, Customers and Stripe; and (iv) promote, analyse and improve our products, systems and tools. The user can consult the Privacy Policy of this provider here.

iii. Help Service Platform: Zendesk (Zendesk, Inc.), a company registered in the United States. It processes personal data to: (i) offer, operate, improve and promote its services, (ii) process and complete transactions and send related information, (iii) send transaction messages, such as answers to your comments, questions and requests; provide service and customer support, and send you technical notices, updates, security alerts and support and administrative messages; (iv) send promotional communications, offer information about products and services, functions, surveys, newsletters, offers, promotions, competitions and events, inter alia. The user can consult the Privacy Policy of this provider here.

• With the consent of the user: apart from that which is established above, you, the user will be informed in the event that any information about you is brought to the attention of the commercial partners of the Website, or of third parties, of a nature other than those purposes set out at the TUNA TOUR website (for example: for commercial purposes), so that you have the opportunity to decide not to share your information. None of the foregoing data communications will include selling, renting, sharing, or otherwise disclosing the personal information of customers for commercial purposes in a manner contrary to the commitments made in this Privacy Policy.

8. Can international data transfers be carried out?

In the event that we carry out transfers of your personal data to a third country, in other words, a country outside the European Economic Area (the countries of the European Union plus Liechtenstein, Iceland and Norway), we will comply with all laws applicable to said transfer, including ensuring that your personal data are kept secure and the presence of safeguards to ensure that there is suitable protection. To this end, TUNA TOUR will use standard data protection clauses adopted by the European Commission.

9. What rights do you, the user, have regarding the data provided?

The user may exercise the following rights vis-à-vis TUNA TOUR:

• Right to be informed: you, the user, have the right to receive clear, transparent and easily understandable information about the way in which we use your information and your rights. This is why we provide you with said information in this privacy policy.
• Right of access: you, the user, have the right to obtain access to your information (if we are processing it), as well as other types of information (similar to that provided in this Privacy Policy), so that you are informed and you can verify that we use your information in accordance with data protection legislation.
• Right to rectification: you, the user, have the right to have your information corrected (inaccurate data) in the event that it is incorrect or incomplete.
• Right of erasure: It is also known as the “right to be forgotten” and, in short, it allows you to request the deletion or erasure of your information when the data are no longer necessary for the purposes for which they were collected. This does not constitute a general right of erasure; there are exceptions.
• Right to restrict processing: you, the user, have rights that allow you to “block” or prevent the further use of your information. When the processing is restricted, we will only keep your information for the bringing or defence of claims. We also keep lists of users who have requested to “block” their information from further use in order to ensure that the restriction is respected in the future.
• Right to data portability: you, the user, have rights that allow you to obtain and reuse your personal data for your own purposes in different services.
• Right to object: you, the user, have the right to object to certain types of processing, including processing for direct marketing purposes. Except on legitimate, overriding grounds, or for the bringing or defence of any claims.

The exercising of the aforementioned rights is very personal, so it will be necessary for you, the user, to prove your identity.

PTo exercise the aforementioned rights provided for in the legislation, the user can contact TUNA TOUR by e-mail protectdades@grupbalfego.com or by writing to the address that appears in section 1 of this Policy. The communication must contain the following data and documents:

• Name and surname of the data subject, attaching a photocopy of the DNI (Spanish identity card) or another valid document that identifies him/her and, where appropriate, of the person representing him/her; if an electronic signature is used, these documents are not required).
• Indication of the address of the data subject and petition in which the request is specified (the right that is intended to exercise).

The user will also have the right to file a claim with the corresponding Control Authority/Spanish Data Protection Agency (www.aepd.es), when deemed appropriate.

10. How do we protect our users’ data?

TUNA TOUR informs the user that it has adopted the necessary technical and organisational measures required by current regulations on Data Protection to guarantee the security of your data, in order to avoid the unauthorised alteration, loss, access or processing thereof.

As mentioned, the personal data provided by users via the TUNA TOUR Website will not be transferred to other entities or companies to be used for their own purposes. However, some companies subcontracted by TUNA TOUR may have access to personal data and information, always under the exclusive control of TUNA TOUR, for the sole purpose of providing a service necessary for the proper functioning of the TUNA TOUR Website.

11. Amendments

TUNA TOUR reserves the right to amend this Privacy Policy at any time, in accordance with the applicable laws. We thus recommend you to periodically review this Privacy Policy in order to keep informed about how we process and protect your personal data, as well as your rights.

12. Applicable Law

This Policy will be governed and interpreted in accordance with Spanish legislation, as shall the settlement of any dispute or disagreement related with this Website. The use of the services of this Website implies the specific acceptance of Spanish jurisdiction.
 

Last updated: July 2021.