PRIVACY POLICY

The current privacy policy is an integrated part of the Portal´s Legal Notice.

1. DATA COLLECTION

In compliance with the provisions in the current regulations regarding data protection, NUBA EXPEDICIONES S.L (from now on, NUBA), informs that the user’s personal data, obtained or gathered through the sites www.nuba.es and www.nuba.net (from now on, the Portal), will be treated by NUBA as complements  of the following, among other, purposes:

• enable the provision of services offered on the Portal.
• manage User registration.
• attend to the solicitation of consultations, information, and/or complaints.
• inform users of news and other matters of interest.

Everytime we request, and the User provides, an email address, phone number, or other method of electronic communication, the User specifically accepts and authorizes that such methods are used preferably as a communication channel, as a channel to fulfill all or some of the purposes previously mentioned, and as a channel through which we can give information about any other relevant changes the Portal goes through.

The Users guarantee that the given personal data is real, precise, complete, and up to date, since the Users are the only ones responsible for any damage or prejudice, direct or indirect, that could happen as a consequence of the incompletion of such obligation.

2. COOKIES

NUBA uses its own as well as third-party cookies (both technical and of personalization) that (i) univocally identify the Users  during a session to show them private and personalized information and (ii) allow them to browse all areas and section of the Portal and make use of all its functions. These cookies are necessary for the functioning of the Portal.

NUBA also uses analytical third-party cookies that allow it to measure its audience and traffic parameters, control the progress and number of visits, as well as the Portal User´s most relevant operations.

Cookies are files sent to the browser, via a web server, with the purpose of registering User activity during their browsing time. The User can deny the installation of cookies by activating on their computer timely checks with the option that rejects the acceptance of cookies. The User needs to keep in mind that, by selecting this option, they may not be able to access certain areas or section of the Portal.

Please, consult the instructions and manual of your browser to extend this information.

3. CONTACT

The User acknowledges the rights of access, rectification, cancellation, and opposition (A.R.C.O) which can be exercised by addressing a letter and a ID photocopy with the subject ¨Ref. Privacidad¨ to the following address: Nuba Expediciones S.L., C/ María de Molina, 46, C.P.: 28006, Madrid.

 

DATA PROTECTION POLICY

Data Protection Policy from GRUPO NUBA (NUBA EXPEDICIONES, S.L.; NUBA CORPORATE, S.L.; PERFECT DAY TRAVEL BUSINESS, S.A.; KOROWAI, S.L.; INCOMING DESTINATION SERVICES SPAIN, S.L.; REINVENTUR HISPANIA XXI, S.L; VIAJES TIERRA VIVA S.A.; NEW BASQUE S.L.)  (From now on, GRUPO NUBA)

1. Who´s responsible for treating your data?

The one responsible for treating the data with respect to the distinct processes regarding the management of new Users, clients, and providers is GRUPO NUBA, with a registered office at C/Serrano 165. 28002 Madrid and CIF B83850859.

In regards to our Data Protection Policy the contact number is +34917454745 and the email address is protecciondatos@gruponuba.net.

What kind of data do we have about you and how did we access it?

The personal data categories NUBA deals with over their clients and providers are:

• identification data
• postal and electronic addresses
• commercial information

Under no circumstance do we deal with specially protected data.

All data mentioned above has been gathered by us either directly from you through sending a contact form, commercial offer presentation, contractual proposition, etc. or through your business as it provided us your identification data and further information necessary to carry out the contractual relationship between the two parties. It will be your obligation, or your business´, to provide us updated date in case of any modifications.

2. With what purpose do we use your data?

In GRUPO NUBA we process the data provided to us by those who are interested with the goal of managing distinct activities that come from specific procedures carried out in sales, post-sale services, supplier management, service quality, etc.

In this way, we will use your data to carry out some of the following actions:

1. sending the information that are requested through the contact form on our webpage or any other form of contact with our company,
2. provide both potential clients and our current clients with product offers and services of interest,
3. carry out the administrative, fiscal, and accounting management of our clients and7or providers,
4. carry out satisfaction polls, market studies, etc with the goal of offering the most adequate offers and an optimized quality of service.

We will not elaborate commercial profiles with the information provided and in consequence we neither will make automated decisions about you based on a commercial profile.

3. For how long will we keep your data?

The personal data relative to the physical persons tied to potential clients, clients, and providers that GRUPO NUBA collects through different contact forms and/or by gathering information will be kept as long as there´s no request for its deletion by those interested. The data provided by our clients and providers will be kept as long as there is still a commercial relationship between the two parties, respecting in any case the minimum legal conservation periods according to the subject.

In any case, GRUPO NUBA will keep your personal data during the period of time that is reasonably necessary keeping in mind our needs to answer potential questions, solve problems, make improvements, activate our services, and meet the requirements required by applicable law. This means that we can keep your personal data during a reasonable time, including after you´ve stopped using our products or this webpage. After this period, your personal data will be eliminated from all systems of GRUPO NUBA.

4. What is the basis of legitimation for the processing of your data?

According to the type of data processing we present ahead the basis of legitimation of such processing:

PROCESS	LEGITIMATION BASIS
Accounting management: billing management with clients and providers	Maintenance, development, and control of contractual relation between both parties.
Fiscal management: applying withholdings, bonuses, etc	Maintenance, development, and control of contractual relation between both parties; Fulfillment of legal obligations.
Administrative management: managing logistics, warehouse, delivery to clients, reception of goods, etc.	Maintenance, development, and control of contractual relation between both parties.
Marketing: commercial actions over our products and services addressed to our clients or those who have requested relative information in the past including conducting surveys of client satisfaction.	Free and unmistaken consent from the person interested (potential clients), we note that the withdrawing of this consentment in any case can condition the execution of the contract that existed between both parties;  Legitimate interest from the company over the promotion and commercialization of products and services similar to those obtained or requested by those interested in the past.

As for the basis of legitimation references, you find yourself obligated to provide personal data. If  you don´t  provide us personal character data, twe won’t execute the contract, meet the legal obligations, or the obligations derived from public power. 

5. To which recipients will your date be communicated?

GRUPO NUBA will never share your data with a third-party company that intends to use them in its direct marketing actions, except in case you´ve explicitly authorized us to.

We inform you that we can provide your personal data to organs of Public Administration and Authorities competent in cases where GRUPO NUBA receives a legal requirement from the part of such Authorities, or in the cases where, acting out on good faith, we consider that such action is reasonably necessary to fulfill a judicial process; to answer any complaint or juridic demand; or to protect the rights of GRUPO NUBA or its clients and general public. All of our companies are located in Spain.

6. What are your rights as someone affected or interested?

Everyone has the right to obtain confirmation of if GRUPO NUBA is processing personal data of their concern or not.

Specifically, those interested can request the right to access their personal data, as well as to receive them in a common format and mechanized reading if the processing happens over electronic methods (right to portability).

Likewise, those interested can request the right for correction of inexact data or, in that case, request its suspension when, among other reasons, the data is no longer necessary for the purposes for which they were collected.

Complementarily, in certain circumstances, those who are interested can request a limitation to the processing of their data, or in certain circumstances and for reasons related to their particular situation, those interested can exercise their right to oppose the processing of their data. GRUPO NUBA will stop processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims, or in those exceptions established in the applicable regulations.

Likewise, we inform you have the right to withdraw your consents granted at any moment without it affecting the legality of the processing based on the consent prior to its retreat.

Likewise, we inform the user that in any moment he/she can exercise the rights mentioned above, addressing us in writing by using the contact data that show in the Apparatus 1, ´Responsible for processing´ of the current policy for Protection of Data and Privacy from GRUPO NUBA, attaching a copy of your ID, You will also have the right to file a complaint before the Spanish Agency of data Protection, specially when you haven’t had satisfaction in exercising your rights.

Agencia Española de Protección de Datos: C/ Jorge Juan, 6. 28001 – Madrid. Telf. 901100099 / 912663517

7. Data protection for users of the website

In accordance with the current Regulation (UE) 2016/679, GRUPO NUBA informs that the website User´s personal character data will be processed for the processing activity of the indicated in each form of data collection in our webpage from the part of GRUPO NUBA. Such processing of your data will be covered by your own consent. By pressing the ´SEND´ button, the User consents to the processing of their data from the part of GRUPO NUBA.

Likewise, we inform you that, except for legal obligation or express consent on your part, GRUPO NUBA will not give your data to third-party individuals (in case of transfering, inform which data and to whom they shall be transfered).

Equally, we inform the User that, in any moment, he/she can exercise their rights of access, correction, or suspension of data, as well as having other rights acknowledge in the current document and regulated in the Regulation (UE) 2016/679, notifying GRUPO NUBA, C/Serrano 165. 28002 Madrid , e-mail: protecciondatos@gruponuba.net

On the other hand, in accordance with the provisions of the Law 34/2002, from July 11th, of Servicios de la Sociedad de Información y de Comercio Electrónico, GRUPO NUBA agrees to not send advertising through email without gathering beforehand the expressed authorization of the receiver.  The User can be opposed to the sending of advertizement by checking the corresponding box. 

8. Other information of interest about our privacy policy

8.1. Security Measurements

GRUPO NUBA adopts the security levels required by the current European and Spanish regulations on data protection taking in account the state of the art, the application costs, and the nature, the reach, the context, and the purpose of the processes described, as well as the risks and the variable probability and severity for  your rights and liberties as a person.

8.2. Processing of a minor´s data

For GRUPO NUBA it is of extreme importance to protect the privacy of minors, by virtue, only the data of your minor children in those cases where it is strictly necessary for complying with certain legal obligations (for example, application of withholdings on IRPF, etc).

In any case, such collection of data will happen always with your express consent as parents or tutors.

8.3. Changes in our Data and Privacy Protection Policy

Occasionally, GRUPO NUBA can make changes and corrections to its section of Data Protection Policy for Employees. Please, verify this section regularly to consult the changes that may have occurred and how they can affect you.

8.4. Why is it necessary to accept such Data and Privacy Protection Policy?

This section of the Data Protection Policy provides you, at an easily accessible manner, all the necessary information so that you can know the type of data that GRUPO NUBA keeps about its potential clients, clients, and suppliers, the purposes pursued, the rights that the data protection regulation grants you as an affected person and how to exercise such rights. Thus, with the deliberate sending of your personal data through our means of contact and/or with the start of a commercial relationship with our company we consider you recognize and accept the processing of your personal data as it is described in the current policy. This personal information will only be used for the purposes for which you have provide them or certain national or regional regulations that allow us to use them.

In any case, we should notify you that any denial from you part in providing us with certain requested data could block the development of the contractual relationship between the parties with possible serious consequences in the moment of providing various services contemplated within the commercial contract concluded with the contracting party.

If you have any questions regarding this section in the Data Protection Policy for Potential Clients, Clients, or Suppliers of GRUPO NUBA, please, contact the company using the address provided in the Apparatus 1 ´Responsible for Treatment´ and we will be delighted to assist you and give you an answer to the additional questions you’d like to ask.

9. Applicable Legislations

The current conditions will be held at all times by the provisions of the Spanish and European legislation in the matter of data protection of personal character and privacy.