Privacy Policy

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This website privacy policy is divided into the following sections:

• Who we are
• Our website
• Our collection and use of your personal information
• Transfer of your information out of the EEA
• Cookies and similar technologies
• Marketing
• Your rights
• Keeping your personal information secure
• How to complain
• Changes to this website privacy policy
• How to contact us

Who we are

This website is operated by Travel with Arantxa (operated by Pulse Ltd). We are a Travel Management Company providing travel and consultancy services. For more information please see https://www.pulse.gi/aboutus.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in Gibraltar) and we are responsible as 'controller' of that personal information for the purposes of those laws.

Our website

This privacy policy only relates to your use of our website, the Travel with Arantxa website.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you when you access our website, register with us, contact us, send us feedback, purchase products or services via our website, post material to our website and complete customer surveys or participate in competitions via our website.

We collect this personal information from you either directly, such as when you register with us, contact us via our website, or indirectly, such as your browsing activity while on our website (see 'Cookies' below).

The personal information we collect about you depends on the particular activities carried out through our website. Such information includes:

• Your name, address and contact details
• IP address
• Details of any feedback you give us by phone, email, post or via social media
• Information about the services we provide to you

We use this personal information to:

• Create and manage your communications with us
• Verify your identity
• Customise our website and its content to your particular preferences
• Notify you of any changes to our website or to our services that may affect you
• Improve our services
• For data security purposes
• Job applications

This website is not intended for use by children under the age of 13 and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, and these will depend on the personal information in question and the specific context in which we collect it.

The legal bases we may rely on include:

• Consent: where you have given us clear consent for us to process your personal information for a specific purpose
• Contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
• Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

Further information — the personal information we collect, when and how we use it

What information we ask for: contact details — your name and email address.

When you register with us, how do we use your information:

• To create and manage your details with us
• To communicate with you
• To assist us with data security
• To manage any job applications you may be interested in

Who we share your personal information with

We routinely share your name and email address with our group companies. This data sharing enables us to get back to you with the expertise you require and to assist in the prevention of data security.

We will share personal information with law enforcement or other authorities if required by applicable law.

We will not share your personal information with any other third party.

Whether information has to be provided by you, and if so why

The provision of your name and email address is required from you to enable us to communicate with you.

We may transfer your personal information obtained from this website outside the European Economic Area (EEA) for security purposes. These transfers are subject to special rules under European and Gibraltar data protection law.

The following countries to which we may transfer personal data have been assessed by the European Commission as providing an adequate level of protection for personal data: Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (limited to the Privacy Shield framework).

Except for the countries listed above, non-EEA countries do not have the same data protection laws as Gibraltar and the EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission. To obtain a copy of those clauses please visit this European Commission page.

If you would like further information please contact our Data Protection Officer (see 'How to contact us' below).

Cookies and similar technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on our use of cookies, please see our Cookie Policy.

For further information on cookies generally, visit www.aboutcookies.org or www.allaboutcookies.org.

Marketing

We would like to send you information about our products and services, events and news, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

You can unsubscribe at any time by:

• Contacting us at arantxa.martin@pulse.gi
• Using the 'unsubscribe' link in emails or 'STOP' number in texts

For more information on your rights in relation to marketing, see 'Your rights' below.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• Fair processing of information and transparency over how we use your personal information
• Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
• Require us to correct any mistakes in your information which we hold
• Require the erasure of personal information concerning you in certain situations
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit those data to a third party in certain situations
• Object at any time to processing of personal information concerning you for direct marketing
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• Object in certain other situations to our continued processing of your personal information
• Otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the guidance from the Gibraltar Regulatory Authority: gra.gi.

If you would like to exercise any of those rights, please:

• Email or write to our Data Protection Officer
• Let us have enough information to identify you, e.g. name and email address
• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill)
• Let us know the information to which your request relates

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Gibraltar is the Gibraltar Regulatory Authority, who may be contacted at info@gra.gi or telephone: (+350) 20074636.

Changes to this website privacy policy

This website privacy policy was published on 1st June 2020.

We may change this website privacy policy from time to time; when we do, we will inform you when you visit our website.

How to contact us

Please contact our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you:

• Email: arantxa.martin@pulse.gi
• Phone: +350 2250 0597
• WhatsApp / Mobile: +34 676 593 972