In compliance with the new Regulation 679/2016 of Data Protection, the Organic Law 3/2018, of Personal Data and Guarantee of Digital Rights, the responsible for the application informs all USERS that, MUST, is property of MUST TRAVEL & TECH S.L., with Spanish nationality and C.I.F (tax ID number) B67225169, as well as owner and responsible for the treatment of personal data given the USER, informs that, the data with personal character provided voluntarily by USER, is carried out, having adopted every security measure legally required for the data protection and the protection of the intimacy of USERS.
The USERS, by ticking on the corresponding box in the registry form, accept expressly, freely and unmistakably that their personal data are treated by the provider for the purposes and rights that are set hereunder and can withdraw the consent whenever he/she desires.
Confidentiality and security are priority values for MUST TRAVEL & TECH S.L. and, as consequence, we assume the compromise of guaranteeing the privacy of the user at every moment and of not gathering unnecessary information. Hereunder, we provide all the necessary information on our Privacy Politics in relation with the personal data we gather, explaining:
1. RESPONSIBLE FOR THE TREATMENT.
Must Travel & Tech, S.L.
Plaza. Pau Vila, 1 Palau de Mar Pier 01. 08003 Barcelona
[incluir dirección de email]
Hereafter ‘MUST’, ‘us’, ‘we’, or the ‘Responsible for the Treatment’.
This Privacy Politics covers all the gathered and used data by us in the mobile phone application MUST (hereafter, the ‘Platform’).
2. GATHERED PERSONA DATA
Personal Data refers to any information or data that may identify you.
In this sense, all personal data gathered by MUST include/all personal data that MUST TRAVEL & TECH S.L. will request to USERS for the registry and use of the Application are the following:
- Your full name, e-mail address, phone number, date of birth, gender, image used for your profile and the country in which the account was created, among others.
- Other data such as pictures and/or videos which you decide to publish on your account, your tastes and/or preferences, to who you follow, comments or recommendations that you make, shared content and/or messages and communications exchanged with other USERS, creation and edition of places, as well as other data provided by you voluntarily.
At the time of register in the Application, besides the indicated data, you must introduce a password which you can modify after in your profile on the Application, together with the rest of the profile data. The password will be strictly confidential, personal and untransferable. You commit yourself not to divulge the data related to your account nor make them accessible for third persons. You are the only responsible in case of use of said data by third persons, including the publications made on the Platform, or any other act which is made through the use of the USER name and/or the password.
You guarantee that all data on your identity and legitimacy facilitated to MUST in the registry forms of the Platform are truthful, accurate and complete. Furthermore, you commit yourself to keep your data updated. In the case that you facilitate any false, inaccurate or incomplete data or if MUST considers that there are reasonable grounds to doubt on the truthfulness, accuracy and integrity of the data, MUST can deny you present or future access and use of the Platform or of any of you contents and/or services.
Obligation of facilitate your personal data to us and the consequences of not doing so.
The requested personal data are necessary to manage your requests and/or providing the services to contract, therefore, if you so not facilitate them, we could not attend you properly nor providing you the requested services.
In any case, we reserve the right to decide over the incorporation or not of your personal data and other information into our data bases.
Likewise, information indirectly provided by the USER at the time of creating the account and using our Services is also gathered:
MUST Platform also allows the registry through the synchronization of the services of third persons (Log-in on your Facebook account). If you follow a link in this website, consider that you share information of the social profile with us. The shared personal data depend on the configuration of your Platform in social media. Visit the social networks Platform in question and revise its Privacy Politics to understand how your personal data are shared and used in this context. The data we gather in you social profile are the e-mail address, the phone number (if you have it configured), name and surname, gender, date of birth and city of residence.
The provision of Personal Data requires a minimum age of 16 or, in the case, hold enough legal capacity to contract.
3. PURPOSES OF YOUR PERSONAL DATA TREATMENT
Your facilitated personal data through the use of MUST Platform are necessary for:
- Identifying you as USER and being able to give provide you with access to the different functionalities, products and services which are at your disposal as a registered USER.
- Carrying a proper management of the services and providing you the requested service.
- Managing and monitoring the contractual and precontractual relation with you.
- Making possible the contact with other USERS of the Platform.
- Answering to your questions and/or requests.
- Communicating with you, even via e-mail and/or SMS (only if you accept), in relation with the new services, updates or any other matter which we consider can be of your interest.
- Improving, developing and trying our Platform.
- Protecting the rights, the property and/or the security of MUST.
- Sending commercial Communications to inform you of our products and services, even via electronic media, sending information and personalized advertising, even via electronic media, as well as sending notices that inform of the publication of new announcements which coincide with your preferences, considering you have expressly accepted it. At any moment, you can withdraw your consent from your profile.
- Likewise, we use the information related with your location to provide, personalize and improve our products, with the purpose of being of your and other USERS’ interest.
On the other hand, for the proper functioning of the Platform, we use technical and functional cookies for:
If you want to obtain detailed information on the cookies we use, you can check our policy on cookies here.
4. LEGITIMACY FOR THE TREATMENT OF PERSONAL DATA
4.1 Managing your registry as USER of the Platform:
The treatment of your data is necessary for the exercise of the terms which regulate the use of the Platform. In case you choose to use the access or user login through a social network, the reason why we are legitimize for treating your data is the consent you provide at the moment of authorizing the transfer of your data from the social network.
Likewise, we consider that we have a legitimate interest to carry out necessary verifications to detect and prevent possible frauds when your register in the Platform.
4.2. USER SERVICES:
We have a legitimate interest to attend the requirements or inquiries that you present us through the diverse existent contact method. We understand that the treatment of these data is advantageous for you as it allows us to attend you properly and solve your presented queries.
When you contact us for the management of incidences related to the use of the Platform, the treatment is necessary for the execution of the contractual relation with you.
When your query is related with the exercise of the rights, of which we inform hereunder, or with your claims related with our services, what legitimates us to treat your data is the compliance with the legal obligations by us.
4.3. Sending of commercial communications:
The legitimate ground to treat your data with marketing purposes is the consent you provide us (for example: when you accept to receive personalized information through diverse methods, when authorizes the sending of notifications ‘push’ in your mobile device, or when you accept the legal bases to publish you pictures on the Platform).
To show the personalized information, we consider that we have a legitimate interest to carry a profiling with the information that we have on you and the personal data that you have facilitated us, as we understand that the treatment of these data is also advantageous for you as it allows the improvement of your experience as USER and the access to information according to your preferences.
Considering that we have a legitimate interest to analyze the usability of the Platform and the level of satisfaction of the USER, as the purpose is to improve the experience of the USER and to offer a better-quality service.
5. ADDRESSEES OF THE GATHERED PERSONAL DATA
Your Personal Data could be communicated to third persons, this is:
- Persons and USERS with who you communicate and share information. When you communicate and shar information using our Platform, You use the USERS who can see what you share. In these data is included the USER name, as well as the information shared publicly.
-Persons who see your activity in MUST can decide whether to share it with others. Likewise, when you comment a publication of another USER or ‘react’ to its content, anyone can see your comment or reaction, as well as have access to the data of your profile and any other public publication which you have previously made.
- When you decide to use applications, websites and other third-persons services which use MUST or are integrated in them, these platforms can receive information about your publications or content that you share.
- Your personal data may be communicated to advertisers to indicate which sort of persons see their adverts and what results they generate. Nevertheless, we will not provide information which directly identify You, such as your name or e-mail address.
- Third-persons which help us to provide IT services, as providers of the Platform, hosting services, maintenance and support of our data bases, as well as our software and applications which can contain Your data.
- Third-persons which help us provide digital services and reviews, CRM, web analysis and search engines.
- Advertising agencies, marketing, digital media and social networks to help us offer adverts, marketing and campaigns, to analyze its their effectiveness and administrate your contact and queries.
- For the efficiency of the service, in some occasions, Your data may be communicated to services providers who may be located in U.S.A. or other countries or territories located outside the Economic European Area. Nevertheless, we assure that all communication of your personal information that we carry or those third-persons we share your personal information with, comply with the applicable legislation to us.
6. RETENTION OF YOUR PERSONAL DATA
We will retain only your Personal Data during the period of time needed for the purpose of the treatment, until Your delete your account or during the established legal time-limit for it.
When You delete your account, we delete the content You have published, as well as the pictures, therefore You could not retrieve this information. In any case, your data may be retain by virtue of legal obligation, for the established time-limit, however, such data will be blocked. Nonetheless, the information shared about You by other persons will not be deleted, thus it is not a part of your account.
The Personal Data obtained through the registry in the Platform, the ones obtained through a query via the query forms or via e-mail address, will be retained until the service is carried or during the period of time of attention for the solution of Your query. In case of receiving Your CV, your data may be retained during a maximum of one year for future selection processes.
The Personal Data obtained with your express consent for the sending of communications with commercial character and/or information bulletins, will be retained until you withdraw consent and request the deletion of the service.
It is possible that we retain some personal data to comply with our legal or regulatory obligations, as well as to administer our rights (e.g., to exercise our claims before Court) or with statistical or historical purposes.
When we do not need your personal data, these will be deleted from our systems and registries or will be anonymized to unable their identification.
RIGHTS OF ACCESS, RECTIFICATION, OBJECTION AND ERASURE
MUST TRAVEL & TECH S.L., as responsible for the treatment of the personal data granted by the USERS, guarantees the USER, in any case, the exercise of the rights of access, rectification, erasure, information and objection, in the terms set forth in the current legislation.
Right of Access
At any moment, the USER has the right to access his/her information, to rectify it if his/her data are wrong, to object to any sort of treatment associated to the contractual relation and to unsubscribe from the Application.
Right of rectification
Whenever you desire, the USER could access his/her data to modify any of them which is wrong.
Right of objection
When the USER understands that the treatment of his/her data is not adequate, he/she can object said treatment.
Right of erasure
The USER holds the right to erase the service when he/she considers so, without need of justification.
Right to be forgotten
When the USER decides to cancel the relation established with MUST, or unsubscribe from the Application, You hold the right and MUST is obliged to delete the data provided by the USER, without being able to use them in benefit of the Application.
Right of limiting the treatment
The USER holds the right to obtain, from the responsible of the treatment, the limitation of the treatment of the data when the former challenges the accuracy of said data, during a period of time enough to carry the appropriate verifications.
Right of data portability
These rights can be effectively exercised previous certification of personality in the procedures and deadlines established on the Royal Decree 1720/2007, of 21st of December, addressing a writing to the address set in the Legal Notice.
The treatment of the persona data and the sending of communications via electronic media, in the case, are adjusted to the regulations established on the RGDP, the Organic Law 3/2018, of 5th of December, on Personal Data Protection and Guarantee of Digital Rights and on the Law 34/2002, of 11th of July, on Information Society and Electronic Commerce Services.
Likewise, the USER can unsubscribe from any of the services at his/her disposal.
INFORMATION AND PROTECTION OF MINORS
MUST does not support that under 16 minors register on the Application or introduce their e-mail address. Nevertheless, with the new General Regulation on Data Protection (RGPD), the age which requires the consent of the parents or legal representative has been reduced, being of 13 years-old. If you are concerned about you children using the services of this Application, we advise you to supervise the access of your child to Internet or use filters for Internet surfing.
SECURING YOUR PERSONAL DATA
With the purpose of maintaining security of your personal data, we inform you that we have adopted all the measures of technical and organizational nature necessary for guaranteeing the security of the provided personal data from their modification, loss and unauthorized treatments or accesses.
UPDATING YOUR PERSONAL DATA
It is important for us to be able to keep your personal data updated that you inform us whenever that there has been a modification of your personal data, in other case, we are not liable for their accuracy.
MUST is not liable for the privacy politics of the personal data that you may facilitate to third-persons through the available links in our Application.
If you have any doubt or concern about the procedure through which we treat and use your personal data or you desire to exercise any of the above described rights, please contact with firstname.lastname@example.org