1.0 Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2.0 Relevant legislation
Along with our business and internal computer systems, our websites are designed to comply with the following national and international legislation with regards to data protection and user privacy:
- Ley Orgánica 15/1999 de Protección de Datos de Carácter Personal
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
Our sites’ compliance with the above legislation, all of which are stringent in nature, means that our site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether our site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.
3.0 Personal information that www.easycyclingsitges.com collects and why we collect it
Our website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, our site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser, and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within our websites.
3.2 Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by our websites or passed to / be processed by any of the third party data processors defined in section 6.0. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
3.3 Booking Systems
Should you choose to book with us directly using our booking tool Rezgo or an email link like this one, none of the data that you supply will be stored by our websites. If you book via Rezgo the data will be processed by them. Furthermore, doesn’t matter if you book via Rezgo or email the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS(sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
Furthermore, Easy Cycling Sitges will only ask for the name and contact details of the main traveler – the person who made the booking – as it is needed for our payment systems – see section 6 – and for our booking records which we need to present to authorities in case of legal checks. Our bookings are collated in a normal hardcopy diary that is normally stored in our office or with one of our guides during the excursion.
3.4 Facebook Pages & Instagram
Should you choose to add a comment to any posts that we have published on our Facebook pages or on Instagram, the name you enter with your comment will be saved bis those third party data processors, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective page/profile’s post. Only your name will be shown on the public-facing website.
Your comment and it’s associated personal data will remain on those sites until we see fit to either 1.) remove the comment or 2.) remove the post. Should you wish to have the comment and it’s associated personal data deleted, please email us here using the email address that you commented with.
If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any post comments that you submit on Facebook or Instagram.
3.5 Marketing – Photos & Videos
If you don’t want your photo or video to be used or if you don’t want that we take photos or videos of you, please, let us know during the booking process that you don’t want any photos/videos taken of you. However, we will as well ask you before the excursion for your consent. This consent can be withdrawn at any time.
If you are under 16 years of age you MUST obtain parental consent before appearing in one of our photos/videos.
6.0 Our third-party data processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
7.0 Data Breaches
We will report any unlawful data breach of our websites’ database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 Data Controller
The data controller of our websites is: Easy Cycling Sitges
Carrer Doctor Molins 6
9.0 Data Protection Officer
Mr Alejandro Hernandez Sanchez
General Manager, Easy Cycling Sitges
Telephone: +34 658 025 242