Spirit of England & Scotland

WEB PRIVACY POLICY

RESPONSIBLE FOR THE

TREATMENT

VIAJAYA, SL,CICMA No. 4755, Calle Mistral 2, 2F 28223

Pozuelo de Alarcón, Madrid and CIF B75526731

PURPOSES OF

TREATMENT FROM THE DATA

PERSONNEL OF THE

INTERESTED PARTIES

1. Management of contact information for website users.

2. Compliance with legal obligations imposed on the

controller.

RIGHTS

OF THE

INTERESTED PARTIES

You may exercise your rights of access, rectification, objection,

erasure, portability, restriction of processing, and objection to

automated individual decisions. You may also revoke your consent if

you have given it for a specific purpose.

By automated email with the word "unsubscribe" and "preference

center", as well as by request submitted via email:info@viajaya.travel

or at VIAJAYA’s registered office.

You can file a complaint with the Spanish Data Protection

Agency:www.aepd.es

INFORMATION

ADDITIONAL

You can access more information in general conditions

FOR THE PROTECTION OF

DATA

WEB PRIVACY POLICY

1. Who is responsible for the processing of your personal data?In compliance with current legislation on personal data protection, the interested party is

informed that personal data will be processed by the data controller:

VIAJAYA, SL

CICMA No. 4755, Calle Mistral 2, 2F 28223 Pozuelo de Alarcón, Madrid and CIF B75526731

(hereinafter, “VIAJAYA”)

We inform you that for any questions regarding the processing of your personal data, you

can contact our data protection officer at the following email address: info@viajaya.travel

2. What data is processed, for what purpose, and on what legal

grounds?

Your personal data may be processed for any of the following purposes:

PURPOSE 1 – Management of contact information for website users

● Description of purpose: To manage the personal data of users who contact

VIAJAYA through the contact form provided. Your data will be processed to

manage said contact and address any queries, questions, or comments you may

send us through the channels provided for this purpose on our website.

● Legal basis: Art. 6.1.b) GDPR - Processing necessary for the performance of a contract to

which the data subject is party or in order to take pre-contractual measures at the

request of the data subject.

● Data processed for this purpose: identifying data (name, surname, email).

PURPOSE 2 – Compliance with legal obligations

● Description of the purpose: Your personal data may be processed in compliance

with any legal obligations imposed on VIAJAYA in any manner.

● Basis for legitimacy: art. 6.1.c) GDPR – Processing necessary for compliance with a

legal obligation applicable to the data controller.

Data processed for this purpose: any category of personal data that is already being

processed by the controller for any other processing purpose previously informed.

3. Where do the personal data we process come from?The data that VIAJAYA processes as a result of the interactions made by the user

through our website comes from the following sources:

● Data obtained as a result of the user’s browsing and use of the website.

● Data provided by the interested party/user in the contact form available on the

website, by sending emails, or by any other means through which the interested

party communicates with VIAJAYA.

● Third-party data provided by the user. If the personal data provided is from a third party,

the user guarantees that they have informed them of the Privacy Policy and have

obtained their authorization to provide their data to VIAJAYA for the purposes indicated

above.

In any case where the user or interested party is directly responsible, the user or

interested party guarantees that the data provided is accurate and up-to-date, and is

responsible for any direct or indirect damage or loss that may arise as a result of failure to

comply with this obligation.

4. To whom are personal data communicated?

In order to fulfill the purposes previously reported, your personal data may be

communicated to the following recipients:

RECIPIENT 1:In your case, Judges, Courts and Public Administration.

RECIPIENT 2:suppliers and collaborating entities of VIAJAYA, for the provision

of the services and purposes informed to the user of the website.

RECIPIENT 3:VIAJAYA suppliers that, where applicable, are contracted to measure web

traffic and user behavior through cookies and similar systems, in accordance with the

Cookie Policy.

No international transfer of participants’ personal data is anticipated. However, if any

international transfer is made, it will always be carried out in compliance with the

requirements established by current regulations, through the adoption of the appropriate

legal safeguards. These may consist of the formalization with the data recipient of (i)

Standard Contractual Clauses approved by the European Commission to legitimize the

international transfer of data to third countries, or (ii) another valid legal instrument that

guarantees an adequate level of protection equivalent to that of the European Economic

Area.

5. How long do we process and retain your personal data?

The personal data provided by the interested party will be processed and retained for as

long as necessary to fulfill the stated purposes. They may also be retained when necessary

to comply with a legal obligation or for the formulation, exercise, or defense of legal claims.If the interested party exercises their right to cancellation or deletion, their data will be

kept blocked and available to the Administration of Justice for the legally established

periods to address potential liabilities arising from the processing of personal data.

Likewise, the data subject is informed that their data will be retained in accordance with

the legal deadlines applicable in each case, taking into account the type of personal data

processed and the purpose of the processing. When processing is no longer necessary,

the affected data will be blocked so that they are only available upon request from public

authorities and courts that may require them, as well as in anticipation of their need for

the exercise, formulation, or defense of any action or claim that may arise from the activity

carried out.

Once any applicable legal retention period and any actions that may arise from the

relationship have expired, your data will be completely deleted. For more information, see

the data processing section of the general terms and conditions. Data relating to medical

intolerances, allergies, or special mobility needs are deleted upon termination of the

service.

6. What are your rights regarding personal data?

We remind you that, as an interested party, you may exercise your rights to access,

rectification, or erasure, restriction of processing, objection, portability, and object to

automated individual decisions with VIAJAYA. You may revoke your consent if you have

given it for a specific purpose and may change your preferences at any time.

The interested party may exercise their rights by emailing info@viajaya.travel

or at VIAJAYA’s registered office, as indicated above.

The interested party is informed that they may address any type of complaint regarding

personal data protection to the Spanish Data Protection Agency www.aepd.es, the Spanish

Supervisory Authority.