Written on October 2nd, 2020
This Policy applies to all external parties, tour operators, travel agencies, partners, wholesalers, customers, tourists, visitors to GAPA Travel and its brands’ websites and social networks, subscribers of GAPA Travel newsletter, reports, marketing materials and any other channel whose personal information can be collected, stored and used by GAPA Travel or its partners. This Policy also applies to GAPA Travel’ management of personal information through its brands’ websites, such as Latinconnect (www.latinconnect.com) and Selected Moments (www.selectedmoments.com).
GAPA Travel and its brands understand that the right of people to their privacy is important and must comply with data protection regulations.
The user is informed and consents to the processing of data provided during navigation on the website and information generated as a result of its use, including, where appropriate, international communications or information transfers.
If data provided refers to third-party natural persons other than the user, the latter must guarantee having obtained data and prior consent from the third-parties to communicate their data. The user must inform to the third-party, in advance, the purposes of data processing, communications and other terms provided in this Policy.
User declares that they are 18 years or older. Data on minors provided during website navigation must be expressly authorized by a parent or guardian before its management and processing, according to this Policy; including, if applicable, data on health
The user guarantees the accuracy and truthfulness of personal information provided and commits to keep data updated.
The use of this website is subject to the Privacy and Personal Data Processing Policy, the Terms and Conditions of Use and the Cookies Policy detailed below.
By accessing this website and using its contents, you agree to having read and accepted its policies and conditions.
WHO IS IN CHARGE OF DATA PROCESSING?
Company name: GAPA Travel
Legal ID: RUC 302741-1-410368 DV. 03
Registered office address: Panama City, Panama
Contact information: email@example.com
WHERE DO GAPA TRAVEL AND ITS BRANDS COLLECT PERSONAL INFORMATION?
GAPA Travel and its brands collect your personal information when you (as a user or organization) purchase or use our services, request information, register for an event, enroll in a seminar, request customer services, or communicate with us through any legal channel, and when reasonably necessary for matters directly related to the functions of GAPA Travel under Data Protection regulations.
PERSONAL INFORMATION WE COLLECT AND PROCESS FROM YOU:
Identity information such as your name, surname, passport number, user ID or similar
Contact information such as billing address, delivery address, email address and phone numbers
Financial information, such as information related to payments.
Information about transactions, such as payments made by/to you and other details of purchased products and services.
Technology information, such as Internet Protocol (IP) address, your login data, browser type and version, location, operating system and platform, user ID, and cookies ID used to access our website and other web-based products.
Profile information such as your username and password, purchases or orders, working place, interests, preferences, and comments and responses to our surveys.
Marketing and communications information, such as newsletters, preferences to receive commercial information from us and, when appropriate, your communication preferences.
Other kinds of information you may provide; for example, sent to us via email, etc.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We use the following methods to collect your personal information:
a)Direct contact during our business. You may provide us with your contact information (name, phone, email, etc.) when you:
a.1) Participate in international tourism fairs, marketing exchanges, business tours or other interactions with our company during events and meetings.
a.2) Subscribe to our publications or newsletters.
a.3) Create an account on our websites.
a.4) Request information about your trip.
a.5) Respond to our surveys.
a.6) Provide feedback on our products or services.
a.7) Register in our webinars.
If you do not provide this information, you will not be able to interact or communicate with us, or purchase our services.
b) Automatic interactions with our websites, in which we can automatically collect technical data about your equipment, navigations and patterns. We collect this personal information through cookies, server logs and other similar technologies. Please check our Cookies Policy to know more about our use of these technologies.
c) When you use third-party or public sources, from which we can receive your personal information, such as:
c.1) The employer of an organization or company with which we work.
c.2) A customer, supplier, business partner or other company with which we have a commercial or contractual relationship. The terms of our contract with your employer or organization may require that we process your personal information to fulfill our obligations or exercise our rights under that agreement.
c.3) Analysis providers such as Google INC or Facebook, outside the EU.
c.4) Contact, financial and transactional data from technical, payment and delivery service providers hosting our data inside and outside the EU.
c.5) Contact data of social network resources.
HOW DO GAPA TRAVEL AND ITS BRANDS USE YOUR PERSONAL INFORMATION?
GAPA Travel processes your personal information for the purposes listed below, based on the need to process your information to pursue our legitimate interests as a tourism company and improve our services. We use your personal information for the following:
a) Configure and manage your account for all processes of reservations, operations and finances of the company.
b) Reserve tourism services with our suppliers.
c) Manage operations and logistics of contracted tourism services.
d) Chat rooms, messages and webinars – we can collect your personal information, records, IP addresses, etc. when you use our chat rooms, message boards, social network forums and others. Data is only used for internal analysis in order to improve the user’s experience and our service.
e) Direct marketing, such as CRM (Customer Relationship Management) and other email marketing processes (e.g. newsletters to circulate important information about our business, such as new products, availability, special deals, and any other basic information).
f) Personalization of your experience, according to your feedback and suggestions, through our tourism services and websites.
g) Marketing strategies and internal research to improve our services, including studies regarding market change, customer needs, statistical reports, problem solving, etc.
h) Make payments to tourism service providers such as hotels, car rentals, tour operators and other direct tourism services.
i) Prevent fraud and other criminal activities.
j) For reasons of network and information security so that we can take measures to protect your information against loss, damage, theft or unauthorized access.
k) General management, including mapping your queries, complaints or claims.
WITH WHOM DO WE SHARE YOUR INFORMATION?
GAPA Travel and its brands only share or disclose personal information when it is necessary to carry out our business operations and provide services in the best possible way. We may share your personal information with:
Tourism suppliers such as hotels, car rentals, local tour operators, private transport services, drivers and tour guides, and other suppliers involved in our regular commercial operations.
Our Latinconnect partners in our CAT channel.
Banks, payment processors and financial service providers.
Direct marketing service providers, such as email marketing or CRM platforms.
Government tax administration offices.
IT support and maintenance providers.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
GAPA Travel and its brands retain your personal information for as long as it is necessary to fulfill the purposes for which we collect it, including compliance with legal, accounting and/or reporting requirements.
YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION
GAPA Travel and its brands respect your right to access and control your information, and we will respond to information requests. If applicable, we will correct, amend or delete your personal information. If you have any questions or requests regarding your personal information, please contact our Data Protection team via email at: firstname.lastname@example.org.
WE WILL BE HAPPY TO RECEIVE YOUR REQUESTS FOR THE FOLLOWING:
Information on why, how and who processes your personal information.
Access to a copy of your personal information.
Correction or update of your personal information. You can update your information using the “Contact us” form available on our websites.
Elimination of your information due to legal or other requirements. For preferences such as “email marketing”, you can always click on the “Unsubscribe” link of our newsletters to stop receiving them. We will respect your decision according to our agreement and in compliance with our legal obligations.
Important: If you are dissatisfied with the way GAPA Travel and our brands manage your personal information, you have the right to file a complaint with a data protection regulatory body in Costa Rica or the European Union, depending on the country where you work or live, or where your rights have been infringed. Here is a list of national authorities for personal information protection: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
However, if you believe your personal information has been used or is being used in a way that does not comply with this agreement, please contact us before filing a complaint. We'll try to solve any problems or concerns you may have.
LINKS TO THIRD-PARTY WEBSITES
CONTACT AND LEGAL INFORMATION
If you have any questions or requests regarding your personal information, please write to the GAPA Travel Data Protection Team at email@example.com or contact us here