Privacy Policy

I. PRIVACY POLICY AND DATA PROTECTION

Respecting the provisions of the current legislation, SkySeaHolidays (hereinafter, also Website) commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to the current Spanish and European regulations on the protection of personal data on the internet. Specifically, it respects the following regulations:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR).
• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE).

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected on SkySeaHolidays is: SKYSEA Holidays, S.L., with NIF/CIF: B93637312. Their contact details are as follows:

Address: AVENIDA CARLOS DE HAYA, 5

Contact email: [email protected]

Registration of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by SkySeaHolidays, through the forms extended on its pages, will be incorporated and processed in our file in order to facilitate, expedite and fulfill the commitments established between SkySeaHolidays and the User or the maintenance of the relationship established in the forms that the User fills out, or to attend to a request or inquiry from the same. Additionally, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to its purposes, the processing activities carried out and other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles set out in Article 5 of the GDPR and Articles 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness, and transparency: The User’s consent will be required at all times with fully transparent information about the purposes for which personal data are collected.
• Principle of purpose limitation: Personal data will be collected for specified, explicit, and legitimate purposes.
• Principle of data minimization: Personal data collected will only be those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: Personal data must be accurate and kept up to date.
• Principle of storage limitation: Personal data will only be kept in a form that allows the identification of the User for as long as necessary for the purposes of their processing.
• Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of proactive responsibility: The Data Controller will be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on SkySeaHolidays are solely identification data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. SkySeaHolidays commits to obtaining the User’s explicit and verifiable consent for the processing of their personal data for one or more specific purposes.

The User has the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or can provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing for which the personal data are intended

Personal data are collected and managed by SkySeaHolidays to facilitate, expedite and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms filled out by the latter or to respond to a request or inquiry.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical, and activities related to the corporate purpose of SkySeaHolidays, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as improve the quality, operation, and navigation of the Website.

At the time personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be given to the collected information.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 18 months, or until the User requests their deletion.

At the time personal data are obtained, the User will be informed about the period for which the personal data will be retained or, when that is not possible, the criteria used to determine this period.

Personal data of minors

Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may lawfully consent to the processing of their personal data by SkySeaHolidays. If it involves a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

SkySeaHolidays commits to adopting the necessary technical and organizational measures, according to the appropriate level of security for the risk of the data collected, in a way that guarantees the security of personal data and prevents their accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to transmitted, stored, or otherwise processed data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted or encrypted.

However, because SkySeaHolidays cannot guarantee the impregnability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller commits to notifying the User without undue delay when a personal data security breach occurs that is likely to result in a high risk to the rights and freedoms of individuals. According to Article 4 of the GDPR, a personal data security breach means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring through a legal or contractual obligation that such confidentiality is respected by their employees, associates, and any person to whom they make the information accessible.

Rights derived from the processing of personal data

The User has over SkySeaHolidays and can, therefore, exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Right of access: It is the User’s right to obtain confirmation of whether SkySeaHolidays is processing their personal data or not and, if so, obtain information about their specific personal data and the processing that SkySeaHolidays has carried out or is carrying out, as well as, among other things, the available information about the origin of those data and the recipients of the communications made or planned for them.
• Right of rectification: It is the User’s right to have their personal data modified that turn out to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right of erasure (“the right to be forgotten”): It is the User’s right, provided that the current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for the processing; the User objects to the processing and there is no other legitimate reason to continue with it; the personal data have been unlawfully processed; the personal data must be erased to comply with a legal obligation; or the personal data have been obtained as a result of a direct offer of services of the information society to a minor under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform controllers who are processing the personal data of the data subject’s request to delete any links to those personal data.
• Right to restriction of processing: It is the User’s right to limit the processing of their personal data. The User has the right to obtain the restriction of the processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs them to make claims; and when the User has objected to the processing.
• Right to data portability: In case the processing is carried out by automated means, the User will have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit them to another data controller. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.
• Right to object: It is the User’s right not to carry out the processing of their personal data or to cease the processing of them by SkySeaHolidays.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, unless otherwise provided by current legislation.

Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “GDPR-www.skyseaholidays.com“, specifying:

• Name, surname of the User, and a copy of the DNI. In cases where representation is admitted, it will also be necessary to identify by the same means the person representing the User, as well as the document accrediting the representation. The photocopy of the DNI may be replaced, by any other valid means in law that proves identity.
• Request with the specific reasons for the request or information to which you want access.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that accredits the request made.

This request and any other attached documents may be sent to the following address and/or email:

Postal address: AVENIDA CARLOS DE HAYA, 5 – 6 I

Email: [email protected]

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than SkySeaHolidays, and therefore are not operated by SkySeaHolidays. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or violation of the current regulations in the way their personal data are being processed, they will have the right to effective judicial protection and to file a complaint with a supervisory authority, in particular, in the State where they have their habitual residence, place of work, or place of the alleged violation. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy, as well as that they accept the processing of their personal data so that the Data Controller can proceed with it in the form, during the periods, and for the purposes indicated. The use of the Website will imply acceptance of its Privacy Policy.

SkySeaHolidays reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative, jurisprudential, or doctrinal change by the Spanish Data Protection Agency. The changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.