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PRIVACY POLICY

The Privacy Policy is part of the General Conditions that govern the https://robertarrigo-karolina.tourtivity.travel/ Booking website URL along with the Cookie Policy and the Legal Notice.

TRIGGLE SPAIN SLU, reserves the right to modify or adapt this Privacy Policy at any time. Therefore, we recommend that you review it each time you access the Website. In the event that a user has registered on the Website and accesses his or her account or profile, when accessing the Website, he or she will be informed of any substantial changes in relation to the processing of his or her personal data.


1. Who is responsible for the processing of your data?

The data collected or voluntarily provided by you through the Website, either by browsing it, as well as all those you may provide us with in the contact forms, via email or telephone, will be collected and processed by the Data Controller, whose details are indicated below:

TRIGGLE SPAIN SLU CIF: B57776552 (being part of the TRIGGLE AG group, with registered office in Zug, Switzerland)

Address: C/ Gremi Cirurgians i Barbers, 25, B, 1, 3, 07009, Palma de Mallorca.

Registered in the Mercantile Registry of Palma de Mallorca, Volume 2509, Sheet 10, Page PM-70247, insc. 2.

Contact at TRIGGLE SPAIN SLU for the protection of your personal data.

C/ Gremi Cirurgians i Barbers, 25, B, 1, 3, 07009, Palma de Mallorca.

Phone: 871520950

Mail: rgpd@triggle.app

If, for any reason, you wish to contact us in any matter related to the processing of your personal data or privacy (with our Data Protection Officer), you can do so through any of the means indicated above.


2. What data do we collect through the website?

By the simple act of browsing the Website, TRIGGLE SPAIN SLU will collect information regarding:

  • IP address.
  • Browser version.
  • Operating System.
  • Duration of the visit or navigation through the Website.

This information is stored by means of Google Analytics, so we refer to Google's Privacy Policy, as Google collects and processes this information. http://www.google.com/intl/en/policies/privacy/

Similarly, the Web Page provides the utility of Google Maps, which can access your location, if you allow it, in order to provide greater specificity on the distance and / or paths our headquarters. In this regard, we refer to the Privacy Policy used by Google Maps, in order to know the use and treatment of such data http://www.google.com/intl/en/policies/privacy/

The information that we handle will not be related to a specific user and will be stored in our databases, with the purpose of making statistical analyses, improvements in the Website, about our products and/or services and will help us to improve our commercial strategy. The data will not be communicated to third parties.


3. User registration on the website/ Sending of forms

In order to access certain products and/or services it is necessary for the user to fill out a form. To do so, the registration form asks for a series of personal data. The data are necessary and mandatory to carry out such registration. In the case of not providing such fields, the registration will not be carried out.

In this case, the navigation data will be associated to the user's registration data, identifying the same specific user who navigates the Web Page. In this way, it will be possible to personalize the offer of products and/or services that, to our criterion, more adjusts to the user.

The registration data of each user will be incorporated into the databases of TRIGGLE SPAIN SLU, along with the history of operations carried out by the same, and will be stored in the same until the account of the registered user is deleted. Once such an account has been deleted, said information will be removed from our databases, keeping those data related to the transactions made in a separate section for 10 years, without access to or alteration of the same, in order to comply with the terms of the law. The data that are not linked to the transactions carried out will be kept unless you withdraw your consent, in which case they will be deleted immediately (always taking into account the legal deadlines).

The legal basis for the processing of your personal data is the execution of a contract between the parties.

In relation to the sending of communications and promotions by electronic means and the response to requests for information, the legitimacy of the treatment is the consent of the user.

The purposes of the treatment will be the following:

  • To manage your access to the Website.
  • Manage the reservation or purchase of the products and/or services and the utilities made available to you through the Website.
  • Keep you informed of the processing and status of your requests.
  • Respond to your request for information.

Thus, we inform you that you can receive communications via email and/or telephone, in order to inform you of possible incidents, errors, problems and / or status of your requests.

For the sending of commercial communications, the express consent of the user will be requested at the time of registration. In this regard, the user may revoke the consent given, addressing TRIGGLE SPAIN SLU, using the means indicated above. In any case, in each commercial communication, the possibility will be given to unsubscribe at the time of receipt, either by means of a link and/or email address.


4. Sending of Newsletter

If the option to subscribe to the Newsletter of TRIGGLE SPAIN SLU is enabled, it will be necessary to provide us with an email address to which it will be sent.

Such information will be stored in a database of TRIGGLE SPAIN SLU, which will be registered until the interested party requests the cancellation of the same or, where appropriate, TRIGGLE SPAIN SLU stops sending it.

The legal basis for the processing of these personal data is the express consent given by all those interested who subscribe to this service by checking the box provided for that purpose.

The data of the e-mails will be only treated and stored with the purpose of managing the sending of the Newsletter by the users who request it.

To send the Newsletter, the express consent of the user will be requested at the time of registration by checking the box for this purpose. In this regard, the user may revoke the consent given by contacting TRIGGLE SPAIN SLU, using the means indicated above. In any case, in each communication, you will be given the opportunity to unsubscribe at the time of receipt, either through a link and/or email address.

If you are one of the following groups, please consult the drop-down information:

4.1. Web or E-mail contacts

For what purposes will we process your personal data?

  • To answer your queries, requests or requests.
  • To manage the requested service, to answer your request, or to process your request.
  • To provide you with information about your request by electronic means.
  • Commercial or event information by electronic means, provided that there is express authorization.

What is the legitimacy for the processing of your data?

The acceptance and consent of the interested party: In those cases where to make a request it is necessary to fill out a form and click on the send button, the completion of the same will necessarily imply that you have been informed and have expressly given your consent to the content of the clause attached to the form or acceptance of the privacy policy.

All our forms have a checkbox with the following formula, in order to send the information:   □ I have read and accept the Privacy Policy.

4.2. Buyers

To whom does this definition apply?

A buyer is a person who carries out the act of buying and that may or not be the consumer of the product or acquired service. Covers needs by buying goods or services in exchange of a given price.

For what purposes will we process your personal data?

•    Preparation of the budget and monitoring of it through communications between both parties.

•    Information by electronic means, regarding your request.

•    Commercial or event information by electronic means, as long as there is express authorization, within the context of the same channel where the purchase or enquiry has taken place.

•    To manage the administrative, communication and logistics services carried out by the person in charge.

•    Carry out the corresponding transactions.

•    Invoicing and declaration of the opportune taxes.

•    Control and recovery management.

What is the legitimacy for the treatment of your data?

The legal basis is your consent and the execution of a contract.

4.3. Marketplace participants

To whom does this definition apply?

A Marketplace participant is the person that has an agreement of use of the platform created and managed by Triggle and therefore, receives a user and password in order to configure the necessary objects to sell its products and services through Triggle or promote existing marketplace products.

For what purposes will we process your personal data?

•    Information by electronic means, regarding your request.

•    Commercial or event information by electronic means, as long as there is express authorization.

•    To manage the administrative, communication and logistics services carried out by the person in charge.

•    Carry out the corresponding transactions.

•    Invoicing and declaration of the opportune taxes.

•    Control and recovery management.

What is the legitimacy for the treatment of your data?

The legal basis is the acceptance of a contractual relationship, or in its absence your consent when contacting us or offering us your products by any means.

4.4. Suppliers

For what purposes will we treat your personal data?

•    Information by electronic means, concerning your request.

•    Commercial or event information by electronic means, provided that there is express authorization.

•    To manage the administrative, communications and logistics services carried out by the person in charge.

•    Invoicing.

•    Carry out the corresponding transactions.

•    Invoicing and declaration of the opportune taxes.

•    Control and recovery management.

What is the legitimacy for the treatment of your data?

    The legal basis is the acceptance of a contractual relationship, or in its absence your consent when contacting us or offering us your products by any means.

4.5. Shareholders

For what purposes will we process your personal data?

  • To organize the necessary actions to achieve the aims of the company.
  • Internal management and legal compliance.
  • Calling of meetings.
  • Carrying out the corresponding transactions.
  • Declaration of the opportune taxes.

What is the legitimacy for the treatment of your data?

The legal basis is contractual, the acceptance of a contract of sale of shares or similar, or the participation in the constitution of the company.

4.6. Social Network Contacts

For what purposes will we process your personal data?

  • To answer your queries, requests or requests.
  • To manage the requested service, to answer your request, or to process your request. 
  • To relate to you and create a community of followers.

What is the legitimacy for the processing of your data?

The acceptance of a contractual relationship in the environment of the social network that corresponds, and according to its privacy policies: 

Linkedin    http://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv

How long will we keep personal data?

We can only consult or cancel your data in a restricted way when you have a specific profile. We will treat them as long as you let us by following us, being friends or giving "like", "follow" or similar buttons.

Any correction of your data or restriction of information or publications must be done through the configuration of your profile or user in the social network itself. 

4.7. Video Surveillance

For what purposes will we process your personal data?

  • Video surveillance of our facilities.
  • Control of our employees.
  • Sometimes they can be given to the courts and tribunals for the exercise of legitimate actions.

What is the legitimacy for the treatment of your data?

The unequivocal consent of the interested party when accessing our facilities after visualizing the informative poster of the video-surveillance area, as well as the legitimate interest of the person in charge.

4.8. Job Seekers

For what purposes will we process your personal data?

  • Organization of selection processes for the hiring of employees.
  • Appointing you for job interviews and evaluating your application.
  • If you have given us your consent, we may pass it on to collaborating or related entities, with the sole aim of helping you find employment.

What is the legitimacy for the processing of your data?

The legal basis is your unequivocal consent, by giving us your CV and receiving and signing information regarding the treatment we will carry out.

How long will we keep the personal data?

The CV will be stored for a period of one year, after which, if we have not contacted you, it will be deleted.


5. Human Resources

For what purposes will we process your personal data?

  • Management of the labor relationship and the worker's file.
  • To carry out all those administrative, fiscal and accounting procedures necessary to comply with our contractual commitments, obligations in the field of labour regulations, Social Security, prevention of occupational hazards, tax and accounting.
  • Management of payroll payments through financial institutions.
  • Hourly control through the access control system by means of fingerprint/card (if applicable).
  • Management of group insurance / pension plan of the entity.
  • Carrying out training activities, both subsidized and non subsidized.

What is the legitimacy for the processing of your data?

The legal basis for the processing of your data is the execution of your employment contract. The fulfillment of the relevant legal obligations. The consent of the interested party.


6. Do we include personal data of third parties?

    No, as a general rule we only process the data provided by the owners. If you provide us with third party data, you must previously inform and request consent from such persons, or else you exempt us from any responsibility for non-compliance with this requirement.


7. And data of minors?

We do not process data of minors under 14 years old, so please do not provide them if you are not that age.


8. Will we communicate by electronic means?

We will only communicate with you in order to manage your request, if it is one of the means of contact you have provided us with.

If we make commercial communications, they will have been previously and expressly authorized by you.


9. What security measures do we apply?

You can rest assured: We have adopted an optimum level of protection for the personal data we handle, and have installed all the technical means and measures at our disposal, according to the state of technology, to prevent the loss, misuse, alteration, unauthorized access and theft of personal data.


10. To what extent will decision making be automated?

TRIGGLE SPAIN SLU does not use fully automated decision-making processes to establish, develop or terminate a contractual relationship with the user. In the event that we use such processes in a particular case, we will keep you informed and communicate your rights in this regard if prescribed by law.


11. Will profiling take place?

In order to offer you products and/or services in accordance with your interests and to improve your user experience, we may create a "business profile" based on the information you provide. However, no automated decisions will be made based on that profile.


12. To which recipients will your data be communicated?

To the companies of the group to which TRIGGLE SPAIN SLU (TRIGGLE AG) belongs.

Your data will not be passed on to third parties, unless legally obliged to do so. Specifically, they will be communicated to the State Agency of the Tax Administration and to banks and financial entities for the collection of the service provided or product acquired, as well as to those in charge of the processing necessary for the execution of the agreement.

In case of purchase or payment, if you choose any application, web, platform, bank card, or any other online service, your data will be transferred to that platform or will be treated in its environment, always with the maximum security.

In the event that you have given us your consent for the processing of your name and images and other information, related to the activity of TRIGGLE SPAIN SLU, will be disclosed on various social networks and website of TRIGGLE SPAIN SLU.


13. International transfers

In the event that it is necessary for TRIGGLE SPAIN SLU to carry out international data transfers, the company will ensure that such transfers are possible in accordance with the General Data Protection Regulations or any other requirement established by applicable regulations. To this end, the company shall adopt the necessary agreements to guarantee a level of data protection equivalent to that provided for in European regulations. All this under the qualification of the article 49.c) of the General Regulation of Data Protection or any other mechanism that guarantees a level of data protection equivalent to the one foreseen in the European regulations.


14. What rights do you have?

  • To know if we are treating your data or not.
  • To access your personal data.
  • To request the rectification of your data if they are inaccurate.
  • To request the deletion of your data if they are no longer necessary for the purposes for which they were collected or if you withdraw your consent.
  • To request the limitation of the treatment of your data, in some cases, in which case we will only keep them in accordance with the regulations in force.
  • To carry your data, which will be provided to you in a structured, commonly used or machine-readable format. If you prefer, we can send them to the new person in charge you designate. This is only valid in certain cases.
  • To file a complaint with the Spanish Data Protection Agency, if you believe that we have not attended you correctly.
  • To revoke the consent for any treatment for which you have consented, at any time.

If you modify any data, we thank you for informing us so that we can keep them updated.


15. Would you like a form to exercise your rights?    

  • We have forms for the exercise of your rights, ask us for them by email or if you prefer, you can use the ones elaborated by the Spanish Agency of Protection of Data or third parties.
  • These forms must be electronically signed or accompanied by a photocopy of your ID.
  • If someone represents you, you must attach a copy of their ID card, or have them sign it with their electronic signature.
  • The forms can be submitted in person, sent by letter or by mail to the address of the person in charge at the beginning of this text.

You have the right to file a complaint with the Spanish Data Protection Agency, in the event that you consider that your request for rights has not been properly addressed.

The maximum period for resolution by TRIGGLE SPAIN SLU is one month, counting from the effective receipt of your request by us.

You have the right to revoke at any time the consent for any of the treatments for which you have granted it.


16. Do we use cookies?

If we use other types of cookies than those required, you can consult the cookie policy in the corresponding link from the beginning of our website.

 

17. How long will we keep your personal data?

  • Personal data will be kept for as long as you continue to be linked to us.
  • Once you have left our site, the personal data processed for each purpose will be kept for the legally established period of time, including the period in which a judge or court may require them in accordance with the statute of limitations for legal actions.
  • The data processed shall be maintained until the legal periods referred to above expire, if there is a legal obligation to maintain it, or if no such legal period exists, until the interested party requests its deletion or revokes the consent granted.
  • We will keep all the information and communications related to your purchase or to the provision of our service, as long as the guarantees of the products or services last, in order to attend to possible claims.
  • In each treatment or typology of data, we provide you with a specific period, which you can consult in the following table:


File
Document
Storage
Customers
Bills
10 years
Forms and Coupons
15 year
Contracts
5 years
Human Resources
Payroll, TC1, TC2, etc
10 years
Resumes
Until the end of the selection process, and 1 more year with your consent
Severance documents, Contracts and Data of temporary workers
4 years
Worker's file
5 years after leaving
Suppliers
Invoices
10 years
Contracs
5 years
Access Control and Video Surveillance
Visitor list
30 years
Videos
30 day blockade
3 years destruction
Accounting
Books and Accounting documents
6 years

Partners agreements and Board of Directors

Finantial status and Audit files

Records and Documents releated to Grants
Taxes
Administration of the Entity, Rigths and Obligations related to tax payment
10 years

Administration of Dividend payments and Tax retentions
Health & Safety
Medical records
5 years
Environment
Chemical information or Hazardus substances
10 years

Environmental permit documents
3 years after closing the activity

Records on recycling
3 years

Grants for Clean-up operations
4 years

Accident reports
5 years
Insurance
Insurance policies
6 years (general rule)


2 years (damages)


5 years (personal)


10 years (life)
Purchases
Register all deliveries of goods or services, intracommunity acquisitions, imports and exports for VAT Purposes
5 years
Legal documents
Intellectual and Industrial property
5 years

Contracts and agreements
5 years

Pemitrs, Licenses and Certificates
6 year from the date of expiration

Confidentiality and non-competition agreements
The duration of the obligation
Protection of Personal Data
Processing of personal data, if different from the porcessing notified to the AEPD.
3 years

Personal data of employees stored on networks, computers and communications equipments used by them, access control and internal management/administration systems
5 years


This Privacy Policy was last updated on 16/02/2022.