Party responsible for processing

Basquetour Turismoaren Euskal Agentzia –Agencia Vasca de Turismo, S.L, Rioja 360 Grados Avanza, Sociedad de Promoción de La Rioja, el Departamento de Desarrollo Económico y Empresarial de Gobierno de Navarra, Turismo de Aragón and la Dirección General de Turismo de la Generalitat de Catalunya. 

Email: info@camino-ignaciano.com     Tel. 945 218178

How have we obtained your data

Obtained from the interested party themselves:  If you are a user of our website, you have provided it yourself, either offline or online by requesting our services to be able to maintain the contractual relationship with you, or by contacting us to request information.

When you provide your personal data, you are guaranteeing that you are entitled to provide this information and that it is true, accurate, precise and up to date, that it is not confidential, that it does not breach any contractual restriction or third-party rights and that you agree not to impersonate other Users.

Obtained automatically due to visiting our website: If you have submitted the data through this website, we compile information, for example, when you access the page, when you sign up, fill in forms with personal data, or when you communicate with us directly by email.

When you visit our website data is sent from your browser to our server, to optimise our services and improve your experience as a user, for example when you access the page or when you log into our Services through third-party services such as social media or Google.  This data may be gathered and stored automatically by us or by third parties on our behalf. This data can include:

-                the user's IP address

-                the date and the time of the visit

-                the URL of site the user comes from

-                the pages of our website visited

-                information on the browser used (browser type and version, operating system, etc.).

We can process and log these uses, sessions and related information, whether independently or with help from third-party services, even using cookies and other tracking technology such as flash cookies and web analytics.

Our website has connections to social media. When you choose to interact with us using social media, we cannot accept responsibility for the privacy settings the user has chosen. The social network can inform of your IP address or which page you are visiting on our website and can establish a cookie to enable it to function correctly, or for example your name will be listed in the “likes” you give or the comments you make on our social media page. If you do not wish for your personal data to be associated with these “likes” or comments, configure your privacy to avoid this, for example using a pseudonym or alias that does not reveal your full name.

If you start a session on one of these social networks during your visit to our website, the social network may add that information to your profile and that information will be transferred to the social network. If you do not want this data transfer to take place, log out of your social media before accessing our website or mobile apps, as influencing this data transfer through social media is beyond our control.

If the user, through our official page on a social network, decides to post and/or share text, photos, videos and other information and/or content, they shall be solely responsible for the compliance of this content with the corresponding legal regulations. Remember that regarding the other people's data, you must respect their privacy and take special care when communicating or posting their personal data. Only the holder can authorise the processing of their personal data. On this page, or on our official page on social media, the user may only post personal data, photographs and information and other content for which they are the holder and owner, or for which they have third-party authorisation. If you provide or post third-party data, it is your responsibility to gain their prior express consent to use, communicate and post it and is your responsibility to inform them that their data we will process it and that you have posted it. In addition to the data protection regulations, the publication of third-party data without their consent may infringe those related to the right to honour, privacy or the personal image of these third parties.

In any event, we may remove any content published by the user from this website and from our social media pages if we detect that it breaches the current legislation, and the content of this privacy policy.

Our social media is not stored directly on our Services. Your interactions with them are governed by their policies and not by ours. Read the privacy policies of those social networks for detailed information on the collection and transfer of personal data, your rights and your privacy settings.

Third-party data

Regarding other people's data, you must respect their privacy and take special care when posting their personal data. Remember that, as a user, you may only provide and consent to the processing of your own personal data, but not that of third parties, and that if you provide us with third-party data you are conceding personal data, and therefore it is your responsibility to obtain express prior consent from those third parties to use and provide it, and you will be responsible for informing them that their data will be included in our files.

The publication of third-party data without their consent may infringe, in addition to the data protection regulations, the right to honour, privacy or the personal image of these third parties, rights which are protected by Organic Law 1/1982, of 5 May, on the civil protection of the right to honour, privacy and personal image.

Purpose

We may process your data for different purposes, for example:

a)              If you are a current or potential customer, to maintain contact and communication with you, to manage the contractual and/or commercial relationship, including post-sales services and guarantees.

b)              If you are a user of our website, or the sender or recipient of an email, to maintain contact and communication with you and manage the orders you make online.

c)              If you provide us with your CV information or send us your CV, to contact you and manage the selection process being conducted.

e)              To carry out opinion and/or satisfaction surveys and send you, by electronic communication, information on our activities, products and/or services. If we already have a prior contractual relationship, these communications will be sent based on our legitimate interest. If we do not have a prior contractual relationship, we will only send you this type of communications if you have authorised them by marking the option that is expressly included for this purpose in the corresponding forms. The electronic communications we will send you will include, in the communication itself, the option to stop receiving them. If you opt for this, we will stop sending any further communications of this type from then on.
Storage period
Your personal data you provide us will be held unless you request its deletion. Even if you request this, we will be able to hold it for the time needed, limiting its processing, to fulfil the legal/contractual obligations to which we are subject and/or for the legally established period for the expiry of any responsibilities on our part and/or the exercise or defence of complaints stemming from the relationship maintained with the interested party.
Lawful basis
The legal basis that justifies the processing of your data may be as follows:

On one hand this may be the legal relationship that binds us if you are current customer/supplier, or the precontractual relationship of any type existing between the parties if you are a potential customer/supplier (for example if you have requested information, an offer or a quote, etc.). The provision of the data requested is compulsory as it is required to enter into and/or maintain the contractual or precontractual relationship and comply with the legal obligations deriving therefrom; if you do not provide it, we will not be able to provide the service resulting from this relationship.

It may also be your consent if you have made a request through our website if you are a user thereof or if you have sent us your CV. This consent is granted to us unequivocally when you provide your data on- or offline, as this provision is deemed a clear affirmative act declaring this consent. You may withdraw this consent at any time by sending us an email informing us to info@camino-ignaciano.com but this withdrawal may make us unable to respond to your request.

It may also be compliance with regulations on prevention of money laundering, taxes, etc.

Our legitimate interest as an organisation also constitutes a legal basis to process your data in order to:

-Conduct opinion and/or satisfaction surveys.

-Inform you of our activities, products and/or services (even by electronic communication). If we already have a prior contractual relationship, these communications will be sent based on our legitimate interest. Otherwise, we will only send you this type of communications if you give consent by marking the option that is expressly included for this purpose in the corresponding forms. In any event the electronic communications we will send you will include, in the communication itself, the option to stop receiving them.
Recipients
We inform you that the data you provide may be communicated to third-party entities for purposes directly related to legitimate functions of assignor and assignee, such as:

1.               Transport companies commissioned with the shipping and delivery logistics of our goods.

2.              Banking entities for management of collections and payments.

4.              Entities or organisations to which there is a legal obligation to communicate data (Inland Revenue, etc.).

INTERNATIONAL TRANSFERS

If we use suppliers from the USA, which may have access to personal data, for the purpose of providing auxiliary services for our activity  (accommodation, housing, software as a service, remote backups, IT maintenance or support services, email managers, email senders and email marketing, file transfers, etc.). these companies may be different and vary over time but, in any event, we will select companies adhered to the Privacy Shield agreement between the USA and the EU, or belonging to countries that have been declared to have a satisfactory level of protection, which means they are obliged to comply with requirements equivalent to those in Europe on data protection. In any event, by accepting this data protection policy you expressly and unequivocally authorise the communication of the data to these companies, knowing that this entails an international transfer of data to a country outside of the European Economic Area and provide your unequivocal consent for this transfer.

Rights

You may, when relevant, exercise your rights to access, rectify, delete, limit and oppose its processing, as well as to not be subject to decisions based solely on the automated processing of your data, at the postal or email addresses indicated at the top of this privacy policy. In both cases send a signed, written request, attaching a copy of your national identity document, passport or other valid document that identifies you. In the event your data changes, you must report this to the same address; the company accepts no responsibility if you fail to do so.

Right to access: You can ask us what personal data we are processing and request a copy thereof.

Right to rectify: You can request the rectification of incorrect personal data or to complete it if it is incomplete, by means of an additional declaration.

Right to deletion (the right to be forgotten): You can request we delete your personal data when: it is not necessary for the purposes for which it was collected, you withdraw your consent, it has been processed unlawfully or due to compliance with a legal obligation.

Right to the limitation of processing: You may request the limitation of processing of your data, in which case we will only store it for the exercise or defence of complaints.

Right to oppose: You can oppose the processing of your data if this processing is based on the legitimate interest of the person responsible for the file or for advertising purposes.

Once we receive any of the above requests, we will respond within the legally established timelines. You may make a complaint before the Spanish Data Protection Agency. If you would like further information about the rights you can exercise and to request the forms for exercising your rights, you can to visit the website of the Spanish Data Protection Agency, www.aepd.es  
Data category
The data categories we process are: identification data; professional information.