Last modification: 22th February 2023 

I- PRIVACY POLICY FOR TRAVELLERS 

II-PRIVACY POLICY FOR WEBSITE USER 

 

I- I.    PRIVACY POLICY FOR TRAVELLERS 

 

WORLD 2 MEET is an independent tourist intermediary specialised in the distribution of accommodation and other tourist services at the destination, such as transfers or excursions.

This privacy policy applies to bookings processed by WORLD 2 MEET and serves to inform travellers whose personal data are included in these bookings about the processing of their personal data and the rights they are entitled to under current legislation on the subject. 

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

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

Unless otherwise specified, WORLD 2 MEET, S.L.U (hereinafter WORLD 2 MEET), with registered office at Calle General Riera 154, 07010 Palma (Illes Balears), Spain, is responsible for processing the personal data of travellers included in tourist services bookings requested by travel agencies or tour operators. WORLD 2 MEET is part of the World2Meet (W2M) tourism group.  + More info about the group here. For further information on the processing of your data or to exercise your rights under current legislation, please send an email to dataprotection@w2m.com or contact the W2M Group's Data Protection Officer at dpo@w2m.com. 

2. What personal information do we collect?  

The data we process are those obtained from bookings communicated by tour operators and/or travel agencies that market tourist services or products to end customers.

The categories of data that we process for the purpose of handling bookings consist of the following: 

• Identification and contact details: Name, address, e-mail address, telephone number if available; ID card/passport details (document number, expiry date and country of issue).  
• Data on personal characteristics: if applicable, nationality, gender and language.  
• Booking data (dates, itinerary, services included, etc.) 
• Transaction data on goods and services.

3. What will we process your data for and on what legal basis? 

We process the personal data of travellers included in bookings for the purposes described below: 

3.1.    Processing of bookings

3.2.    Consolidation of data for internal W2M group administrative purposes. 

• Constitution of a master of persons 
• Management control and business data analysis

3.1. Processing of reservations and management of the reservation system 

Traveller data provided by travel agencies or tour operators will be processed for the purpose of processing the booking and the services included in the booking. These processing operations are necessary for the execution of the reservation, the provision of the requested services or for the implementation of pre-contractual measures at the request of the data subjects. 

3.2. Consolidation of data for internal W2M group administrative purposes.  

Data on persons, economic data, reservations and, in general, data on transactions of goods and services generated by the businesses developed by the group companies are consolidated in centralised databases for group-internal administrative purposes. Below you will find an overview of these treatments. For further information, in particular to find out about the companies that make up the group, please consult the PRIVACY POLICY APPLICABLE TO THE COLLECTION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP. WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., with registered office at C/ General Riera 154, 07010 Palma (Illes Balears), Spain (hereinafter W2M) is responsible for the administration and security of the consolidated databases; each of the group companies is responsible for the data communications it makes to W2M for consolidation and for the use it makes of the consolidated group data. These processing operations are based on the legitimate interest of the W2M Group to transfer personal data within the corporate group for internal administrative purposes and to have a consolidated view of its business for business decision-making.  

Elaboration of a master of persons at the group level The identification and contact details you have provided together with information concerning your identity document (type and number); your gender and language, will be consolidated in a unified database at group level. The aim is to have a single register of persons to optimise operational processes common to the group companies where a person needs to be identified, e.g. for payments or invoicing of services or for integration with reservation systems. This unified database will be synchronised with the systems of the group companies with which you have an existing relationship. 

Management control and business data analysis We also process the information obtained from the consolidation of economic data, reserves and, in general, the data of transactions of goods and services generated by the businesses developed by the companies of the group to generate reports and analyse business data for business intelligence and management control purposes. These analyses and reports provide results in the form of aggregated data and are used to produce statistics and forecasts to facilitate business decision-making, optimise processes, measure the performance of the tourism products offered by the group and establish business strategies.  

4. To whom may we disclose your data?  

Your data will only be communicated between W2M group companies in the situations described in this policy. We will disclose travellers' data when legally obliged to do so, with their consent or when it is necessary for the correct processing of the booking or the provision of the requested services. Specifically:  

The data included in the service bookings will be communicated to the providers of the tourist services concerned, for the provision of the contracted services.  

Please note that where the services requested are to be provided outside the European Economic Area, these communications may involve the transfer of your data to countries that do not offer the same level of protection for personal data as the EU. 

These international communications and transfers of data are necessary for the performance of the package travel contract or for the implementation of pre-contractual measures at the request of the data subjects.

5. How long will we keep your data?  

In general, we will retain data for the time periods provided for in the applicable legal provisions, e.g. in accounting and tax matters, and for as long as necessary to meet any liabilities arising from the processing.

Data relating to travellers included in bookings shall be kept for five years. After that time, if there is no need for retention to justify settlements with agencies and tour operators, the data shall be deleted. 

Data consolidated for intra-group administrative purposes shall be retained in accordance with the criteria set out in the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP.

6. What are your rights?  

You have the right to obtain confirmation as to whether or not we are processing your personal data and, if so, to access it. You can also ask for your data to be corrected if they are inaccurate or for incomplete data to be completed, as well as request their deletion if, among other reasons, the data are no longer necessary for the purposes for which they were collected. 

In certain circumstances, you may request that we restrict the processing of your data. In this case, we will only process the data concerned for the formulation, exercise or defence of claims or for the protection of the rights of other persons. Under certain conditions and for reasons relating to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that override your interests or rights and freedoms, or for the formulation, exercise or defence of claims. You may also, under certain conditions, request the portability of your data to be transferred to another data controller.

You may revoke any consent you have given for certain purposes, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

You also have the right to lodge a complaint with a data protection authority. A list and contact details of the European data protection agencies can be found on the European Commission's website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. 

To exercise your data protection rights, you can send a request by post or e-mail indicating the right(s) you wish to exercise to: W2M Group - Attn. Responsible for the attention of RGPD rights, C/General Riera 154, 07010 Palma (Illes Balears), Spain. Email: dataprotection@w2m.com 

You can also obtain more information about your rights and how to exercise them on the W2M Group's privacy portal, on the website of the Spanish Data Protection Agency at www.aepd.es , on the website of the data protection authority in your country or by contacting the W2M Group's Data Protection Officer at dpo@w2m.com. 

 

II- PRIVACY POLICY FOR WEBSITE USERS 

 

This privacy policy applies to the b2b platforms W2M PRO (https://pro.w2m.travel) and W2M DMC (https://dmc.w2m.travel) (hereinafter collectively the Website). Please read this policy carefully. Here you will find important information about the processing of your personal data and your rights under the relevant regulations.

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

In the event of providing personal data of third parties, it undertakes to obtain the prior consent of those concerned and to inform them of the content of this policy. 

 

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

Unless otherwise specified, the party responsible for the processing of your personal data is WORLD 2 MEET TRAVEL, S.L.U., (hereinafter WORLD 2 MEET), with registered office at Calle General Riera 154, 07010 Palma (Illes Balears), Spain. WORLD 2 MEET is part of the World2Meet (W2M) tourism group.  + More info about the group here. For further information on the processing of your data or to exercise your rights under current legislation, please send an email to dataprotection@w2m.com or contact the W2M Group's Data Protection Officer at dpo@w2m.com. 

2. What will we process web user data for and on what legal basis? 

We process personal data in the circumstances and for the purposes described below:

2.1.    Administrative and commercial management of the relationship with your agency

2.2.    Metrics

2.3.    Data consolidation for advertising purposes and commercial profiling

2.4.    Consolidation of data for internal W2M group administrative purposes.
-    Constitution of a master of persons
-    Management control and business data analysis

2.1. Administrative and commercial management of the relationship with your agency 

We will process the identification, position and professional contact data provided by the person in charge of the agency or, if applicable, directly by the agency's agents, in order to process your registration, provide a user name and password to access the website and for the administrative and commercial management of the relationship with the agency. All these processing operations are necessary for the execution of the contractual relationship with the agencies that have subscribed to. The processing of data of legal representatives and contact persons of the agencies is based on the existence of the legitimate interest recognised by art. 19 Organic Law 3/2018, of 5 December, on the Protection of Personal Data and the guarantee of digital rights.

Financial data and data on transactions of goods and services will be processed for accounting and administrative management purposes in compliance with our legal obligations in accounting and tax matters.

All these data are consolidated in databases at group level. + info in section "2.4. Consolidation of data for internal W2M group administrative purposes" of this policy

2.2. Metrics 

In order to evaluate and manage the quality of our services and products, we perform statistics based on aggregated data obtained from transaction data and web browsing data, e.g. IP address, weblogs, pages visited or actions performed on the website (+ info in our cookie policy W2M PRO and in our cookie policy W2M DMC). This treatment is based on your consent to the installation of cookies, which you may revoke at any time through the configuration panel of the Web or by modifying the privacy options of your web browser or your terminal.

We also produce anonymous statistics from aggregated booking data to measure the performance of our routes and services. These processing operations are based on our legitimate interest in evaluating and managing the quality of our services and products. In order to weigh this interest against their rights and freedoms, it has been determined that the processing had a limited impact on the privacy of the data subjects, corresponded to reasonable expectations of the data subjects and did not pose significant threats. 

2.3. Data consolidation for advertising purposes and commercial profiling 

Data on customers and potential customers of the W2M Group are consolidated in a commercial database for direct marketing and profiling purposes. An overview of these treatments can be found below. For further information please refer to the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLANATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.

The entity responsible for processing the data included in the commercial database of the W2M group is WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., with registered office at C/ General Riera 154, 07010 Palma (Illes Balears), Spain (hereinafter W2M). 

Your inclusion in this database is based on the consent you have been asked to give. Failure to give your consent or withdrawal of consent does not condition the execution of bookings or the provision of the services you have contracted. The extent to which data relating to you will be consolidated in W2M's database and what specific use will be made of it will depend on the consent you have given at the time of providing your data.  You may revoke this consent or change your preferences at any time in accordance with the mechanisms described in the "What are your rights?" section of the privacy policy applicable to the commercial exploitation of customer and prospect data. 

Sending of non-personalised commercial communications and management of distribution lists (segmentation): W2M processes the identification and contact data that you have provided together with the data relating to your customer status, language and market/origin of the data, for the purpose of sending, by any means, non-personalised commercial communications relating to the tourism products and services offered under the brands operated by the group.  + More information on the W2M Group brands here.  

To manage our distribution lists, we segment the recipients of our communications according to data source, market and language. This processing consists of a simple classification according to objective criteria and is not intended for commercial profiling, prediction or behavioural analysis. 

The service we use to send our marketing communications is located outside the European Economic Area.   The service has been configured for data to be stored in a data centre located in the EU.  As a supplementary measure, the contractual conditions applicable to this service include the standard clauses approved by the European Commission to ensure an adequate level of protection of personal data transferred to this processor.  

Development of a commercial profile for the personalisation of the group's commercial communications and services: The data consolidated in the group's commercial database is used to perform behavioural analysis and predictive modelling in order to understand and predict our customers' wants and needs, the actions related to the purchase of our products and services and the factors that condition them. If you have authorised the personalisation of the group's services and communications, W2M will access the data generated by your bookings in order to include them in your commercial profile. This profile will be enriched with the information generated from your interactions with the companies and digital media of the group, e.g. your requests for information or quotes or the data generated by your browsing on our websites.  + More information about the data we include in our commercial profiles and their sources in section 2 of the privacy policy applicable to the commercial exploitation of customer and potential customer data. 

Your profile will allow us to determine when to send you a commercial communication and to personalise our offers according to the type of product you are likely to be interested in, based on the results of behavioural analysis and the application of predictive models. 

We will also use the data included in your profile to personalise the treatment and services provided by the companies of the group with which you interact, for example, to wish you a happy birthday or to take into account the preferences you have expressed at the time of making your reservations or during your use or enjoyment of the tourism products contracted. For this purpose, the companies of the group with which you interact in the future will have access to your profile. 

 + info on the logic of our commercial profiles and what is involved in the personalisation of our services in section 3. b) of the privacy policy applicable to the commercial exploitation of customer and potential customer data.

 

2.4. Consolidation of data for internal W2M group administrative purposes  

Data on persons, economic data, reservations and, in general, data on transactions of goods and services generated by the businesses developed by the group companies are consolidated in centralised databases for group-internal administrative purposes. Below you will find an overview of these treatments. For further information, in particular to know the companies that make up the group, please consult the PRIVACY POLICY APPLICABLE TO THE COLLECTION OF PERSONAL DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP.  

WORLD 2 MEET SERVICIOS CORPORATIVOS, S.L.U., with registered office at C/ General Riera 154, 07010 Palma (Illes Balears), Spain (hereinafter W2M) is responsible for the administration and security of the consolidated databases; each of the group companies is responsible for the data communications it makes to W2M for consolidation and for the use it makes of the consolidated group data. These processing operations are based on the legitimate interest of the W2M Group to transfer personal data within the corporate group for internal administrative purposes and to have a consolidated view of its business for business decision-making. 

Elaboration of a master of persons at the group level The identification and contact details you have provided together with information concerning your identity document (type and number); your gender and language, will be consolidated in a unified database at group level. The aim is to have a single register of persons to optimise operational processes common to the group companies where a person needs to be identified, e.g. for payments or invoicing of services or for integration with reservation systems. This unified database will be synchronised with the systems of the group companies with which you have an existing relationship.

Management control and business data analysis We also process the information obtained from the consolidation of economic data, reserves and, in general, the data of transactions of goods and services generated by the businesses developed by the companies of the group to generate reports and analyse business data for business intelligence and management control purposes. These analyses and reports provide results in the form of aggregated data and are used to produce statistics and forecasts to facilitate business decision-making, optimise processes, measure the performance of the tourism products offered by the group and establish business strategies.  

3. To whom may we disclose your data?  

Your data will only be communicated between W2M group companies in the situations described in this policy, or to third parties due to legal obligations, with your prior consent or when it is necessary for the management and control of the contractual relationship, e.g. to your agency. 

4. How long will we keep your data?  

We will retain your data for as long as you remain a user of the Website, the data generated by transactions carried out on the Website will be retained in accordance with the periods provided for by current legislation on accounting and tax matters and in any case we will retain the data for the time necessary to meet possible liabilities arising from the processing. We will delete your data when they are no longer necessary or relevant for the purposes for which they were collected. 

The data processed by W2M for commercial purposes, including commercial profiles, will be kept for as long as you do not object to the processing or request its deletion, applying the retention criteria indicated in the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL EXPLOITATION OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP.

Data consolidated for intra-group administrative purposes shall be retained in accordance with the criteria set out in the PRIVACY POLICY APPLICABLE TO THE CONSOLIDATION OF DATA FOR INTERNAL ADMINISTRATIVE PURPOSES OF THE W2M GROUP. 

5. What are your rights?  

You have the right to obtain confirmation as to whether or not we are processing your personal data and, if so, to access it. You can also ask for your data to be corrected if they are inaccurate or for incomplete data to be completed, as well as request their deletion if, among other reasons, the data are no longer necessary for the purposes for which they were collected. 

In certain circumstances, you may request that we restrict the processing of your data. In this case, we will only process the data concerned for the formulation, exercise or defence of claims or for the protection of the rights of other persons. Under certain conditions and for reasons relating to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that override your interests or rights and freedoms, or for the formulation, exercise or defence of claims. You have the right to obtain confirmation as to whether or not we are processing your personal data and, if so, to access it. You can also ask for your data to be corrected if they are inaccurate or for incomplete data to be completed, as well as request their deletion if, among other reasons, the data are no longer necessary for the purposes for which they were collected. 

In certain circumstances, you may request that we restrict the processing of your data. In this case, we will only process the data concerned for the formulation, exercise or defence of claims or for the protection of the rights of other persons. Under certain conditions and for reasons relating to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that override your interests or rights and freedoms, or for the formulation, exercise or defence of claims. You also have the right to object to automated individual decisions that produce legal effects on you or significantly affect you in a similar way, where this right exists in accordance with Article 22 of Regulation (EU) 2016/679.  

You may also, under certain conditions, request the portability of your data to be transferred to another data controller.

You may revoke any consent you have given for certain purposes, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
You may at any time withdraw your consent to the processing of your data for commercial purposes, including commercial profiling, or change your preferences in this regard according to the mechanisms described in the section "What are your rights?" of the PRIVACY POLICY APPLICABLE TO THE COMMERCIAL PROCESSING OF CUSTOMER AND POTENTIAL CUSTOMER DATA BY THE W2M GROUP .

You also have the right to lodge a complaint with a data protection authority. A list and contact details of the European data protection agencies can be found on the European Commission's website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.  

To exercise your data protection rights, you can send a request by post or e-mail indicating the right(s) you wish to exercise to: W2M Group - Attn. Responsible for the attention of RGPD rights, C/General Riera 154, 07010 Palma (Illes Balears), Spain. Email: dataprotection@w2m.com 

You can also obtain more information about your rights and how to exercise them on the W2M Group's privacy portal, on the website of the Spanish Data Protection Agency at www.aepd.es , on the website of the data protection authority in your country or by contacting the W2M Group's Data Protection Officer at dpo@w2m.com. 

6. What are your obligations?  

Use of the Website implies unconditional acceptance by users of the terms of use and privacy policy of the same, as well as their commitment to comply fully with the obligations imposed on them by the General Data Protection Regulation (REGULATION (EU) 2016/679) and/or the personal data protection regulations applicable to the agency (hereinafter and jointly the Data Protection Regulations).

With regard to the processing of data of persons for whom bookings are processed, users undertake in particular to comply with the duty to provide information provided for in the Data Protection Regulations, to give effect to the rights of the data subject and to maintain full confidentiality with regard to the personal data being processed. 

Personal information available through the Website may only be accessed or used for the purposes of managing bookings and providing the services contracted by end customers.