GEMA TRAVEL  PERSONAL DATA PROTECTION POLICY
PREAMBLE


This document represents GEMA TRAVEL's commitment to comply with the strictest and rigorous rules and legislation applicable to the Privacy and Personal Data Protection Policy and to which each employee, and well understood, each manager, is obligatorily bound, either through the Clauses of this document, or subserviently through the Corporate Code of Ethics in force in the company.


We are a multicultural company, working and uniting people and organizations from several continents, countries and territories where technology is the main link, chiseling barriers, breaking down distances and creating ties that with each passing day turn into real strengths of fraternity.


Also, as a commercial entity, GEMA TRAVEL is therefore subject to internationally applicable rules. On the other hand, although access to the web pages of GEMA TRAVEL does not imply that the user is obliged to make any personal data available, for GEMA TRAVEL to follow the purpose of satisfying users and commercial partners favourably with tourist services and products in accordance with the principles set out in this Privacy and Data Protection Policy, it is imperative for GEMA TRAVEL to have certain personal data and, sometimes, the user’s debit or credit card or bank account details, hereafter referred only to as "Data".


As a prerequisite for obtaining any "Data", GEMA TRAVEL provides users, in general, with its Privacy and Data Protection Policy. Users have the option to accept and consent to the processing of their "Data" by GEMA TRAVEL in accordance with this Privacy and Data Protection Policy. However, if they do not accept the terms of the proposed Privacy and Data Protection Policy, users will not benefit from the services provided by GEMA TRAVEL.


GEMA TRAVEL reserves the right to modify or periodically update this Privacy and Data Protection Policy in order to adapt it to the applicable legislative changes. In case of such modification, GEMA TRAVEL will announce on this web page the modifications or updates introduced and, in case of affecting existing treatments of personal data, GEMA TRAVEL will request from the affected users their consent to those modifications or updates. In any case, GEMA TRAVEL suggests users to periodically consult their Privacy and Data Protection Policy on a regular basis.


By accessing and using the website, the user expressly agree to the terms of this Privacy and Data Protection Policy; if the user does not agree to any of the terms hereof, he should not use the website or provide his personal information. Therefore, if the does not accept the terms of the proposed Privacy and Data Protection Policy, he will not be able to benefit from the services provided by GEMA TRAVEL.


CLAUSE 1
Use and Collection of Personal Data

1.1 As a general principle of the Privacy and Data Protection Policy of GEMA TRAVEL, no personal data that identifies a user by simply visiting the website shall be registered automatically. Nevertheless, certain non-personal information exists and does not identify a specific user that is collected and recorded on GEMA TRAVEL's Internet servers, namely the type of Internet browser of the user and the operating system used, in order to improve the navigation of users on the website, without prejudice to the provisions for IP addresses as indicated in Clause 6 of this Privacy and Data Protection Policy.

1.2 However, some pages of the website will require the user to provide certain personal data, the "Data", which means any information through which the user can be personally identified to access some of its services, such as flights, travel insurance, cruises, accommodations or any other tourist product or service made available on the website.

1.3 The "Data" collected will be subject to specific treatment and incorporated in the GEMA TRAVEL Database. To this end, GEMA TRAVEL will provide all users with the appropriate technical resources so that they can previously access this Privacy and Data Protection Policy or any other relevant information, such as statistical data, and give their consent for GEMA TRAVEL to process their "Data" or any other information made available on the website.

1.4 Responses to the "Data" questions are voluntary, without the lack of response implying a loss of quality or quantity of the corresponding services and contents, unless something different is specifically indicated for these services and contents. The collection and treatment of "Data" is for the purpose of administering, expanding, adapting and improving the services and content to which users have access through the websites of GEMA TRAVEL and/or through any other one that may be made available in the future.

1.5 The collection and processing of "Data" may also serve to send by traditional and/or electronic means updates and/or commercial information on the services or content offered by GEMA TRAVEL through its website or other present or futures means. With the necessary prior consent, information will be made available to users about GEMA TRAVEL, its brand names, the group companies, the set of products that it commercializes and its business activities. For this purpose, it is included in the procedures that may be adopted for the collection of "Data" an option that allows the user to choose to receive future mailings with commercial information of GEMA TRAVEL or the companies of its group, all in accordance with the Applicable law.

1.6 GEMA TRAVEL may occasionally organize promotions, contests, or sweepstakes through its website. The management of user participation in this type of activity, which in any case will be voluntary, will require the processing of certain user "Data" such as e-mail address, mobile phone number or name and postal address.

1.7 GEMA TRAVEL enables users to purchase their products and services through the website, in which case their "Data", including their credit or debit card number, or bank account number, will be processed in order to effectively maintain the commercial relationship and correct management of the commercial transaction.

1.8 GEMA TRAVEL warrants to users that information on the use made of their "Data" may be provided at any time. To this end, users must send a request in writing to info@boxtravel.eu.

1.9 Users are guaranteed the right to exercise their right to oppose, access, rectify or delete their "Data" contained in the "Database" of GEMA TRAVEL by sending their request to info@boxtravel.eu.

1.10 GEMA TRAVEL will make available and make use of the "Data" it has obtained when it is legally necessary to identify, contact or exercise any legal action that may be appropriate against those who may be in any way causing damage or violating, voluntarily or involuntarily, to the intellectual property rights or rights of any other nature of GEMA TRAVEL or any third party, regardless of whether it is a user of the website or not.

1.11 GEMA TRAVEL makes available and undertakes to keep information, statistical data and business opportunities up to date on its website, in order to provide tourists, business and commercial travellers with the maximum knowledge of the economic and social reality of each potential destination of its customer portfolio. Certain of these data and information may only be accessed by users upon prior payment of an amount that will be fixed on a case-by-case basis, either to cover the costs of accessing the data and information made available, or by imposition of the sources that feed the Database containing this information amd data.

1.12 The definitions and concepts adopted by the United Nations shall prevail in all the Site, in relation to the references to continents, countries and territories, as well as their names and symbols. GEMA TRAVEL encourages and gratifies all users of its website that detect or suggest the due and necessary corrections that allow to improve the quality of the information made available on this website. Any request for correction should be sent to info@boxtravel.eu, and the author should identify himself. The conditions of these gratuities are included in the chapter "Price and Payment" found on the link on the first page of the www.boxtravel.eu website.

1.13 GEMA TRAVEL provides on its website information and data exclusively related to activities connected to the tourism sector, economic and financial data, and data on economic and commercial activities, in general, on continents, countries and territories. Any other type of data, information and comments that users may make available as a result of access this website, namely religious, racial, gender, political and belief, will not be the subject of any formal position on the part of GEMA TRAVEL and neither does it feel bound.

1.14 Users of the website who do not accept the terms of the proposed Privacy and Data Protection Policy will not be able to benefit from the products and services provided by GEMA TRAVEL.

CLAUSE 2
Cession of Personal Data

2.1 The "Data" made available by users is for the exclusive use of GEMA TRAVEL and entities of its group. Partner entities may only access and use the "Data" with the prior written consent of the users, and those entities are bound by the strict conditions of the Privacy and Data Protection Policy of GEMA TRAVEL.

2.2 Any cession of "Data" is strictly subject to applicable law.


CLAUSE 3
Security of Personal Data

GEMA TRAVEL adopts the "Data" protection security levels required by law, and installs the appropriate technical means and measures to prevent loss, misuse, alteration, unauthorized access, and theft of the "Data" made available by users, all in compliance with applicable safety laws. Nevertheless, users should be aware of the technological constraints that may exist.

CLAUSE 4
Minors of Age

4.1 The contents of the GEMA TRAVEL website are informative and of general interest and, therefore, it is not liable to cause any moral or other damages, and may even be accessed by any minor of age. However, GEMA TRAVEL, within the scope of its activity, will seek to develop and promote specific content targeted at minors.

4.2 At the GEMA TRAVEL website, products and services are presented, as well as registrations are permitted upon availability of "Data". GEMA TRAVEL suggests that parents and guardians in general make use of the technological means widely available to limit access to the website to minors under their responsibility.

CLAUSE 5
Use of Cookies

5.1: GEMA TRAVEL prizes for the privacy of each user of its website. It does not collect, misuse or process any information relating to personal data, other than information collected through cookies, as described in this Clause.

5.2 The GEMA TRAVEL website may contain links to other websites of the company, websites of its partners, or websites of other companies in the group. Each user, when accessing a third party website, must be aware that these websites have their own privacy policies, of which GEMA TRAVEL is not responsible.

5.3 To optimize the GEMA TRAVEL website in terms of system performance, usability and availability of useful information about its products and services, the information is gathered and stored automatically in log files on the user's computer, namely the IP address, browser type, language settings, operating system, Internet Service Provider (ISP), date and time.

5.4 GEMA TRAVEL uses the information collected to manage the efficiency of the website, to learn more about the behaviours of the users of the website, to analyse the trends and gather demographic data about the users as a whole. The information collected can be used by the Marketing services to optimize and improve the users' experience in order to provide products and services that best serve the wishes and desires of consumers.

5.5 GEMA TRAVEL uses cookies when a user accesses its website. Cookies are mechanisms for collecting information that the pages of the website transfer automatically to the hard disk of the user's computer, in order to copy data about the visit and navigation carried out by the user on the website. Thanks to cookies, it becomes possible for GEMA TRAVEL to recognize registered users after they have registered for the first time, without having to register at each visit to access the different areas and services that they have previously accessed. Cookies are solely associated with a user by keeping him completely anonymous along with his computer, and do not provide by themselves the name, nickname or any other user information.

5.6 The cookies used do not allow readings of data on the user's hard drive or read cookies encrypted by other vendors, nor do they offer any information to anyone other than GEMA TRAVEL. GEMA TRAVEL encrypts user identification data for enhanced security. The user also has the possibility to configure its browser to be warned on the screen of the reception of cookies and to prevent the installation of cookies on their hard disk.

5.7 In order to access the website, it is not necessary for the user to allow the installation of cookies sent by GEMA TRAVEL, without prejudice to the fact that in such case the accessibility to certain pages of the website may be considerably affected and, in particular, without cookies it is not possible to set custom preferences in certain parts of the website, such as the competitions organized by GEMA TRAVEL through its website.

5.8 This website, e-mail messages, the different on-line services and interactive applications may make use of cookies to optimize the services of GEMA TRAVEL.

5.9 A cookie is a small information file, usually composed of letters and numbers that the Internet server of GEMA TRAVEL sends to the browser cookie file, located on the hard disk of the user's computer. This action allows the GEMA TRAVEL website to automatically recognize the user's device when a connection is established between the Internet server and the user’s browser, allowing the presentation of information tailored to his requirements and interests, improving the browsing experience in the website.

5.10 GEMA TRAVEL may use the following types of cookies on its websSite:

5.10.1 Session Cookies: these cookies are temporary and remain stored in the user's bowser cookie file for the duration of the session. These cookies may be required for certain applications and functionality of the Site to function properly.

5.10.2 Persistent cookies or location cookies: these cookies remain in the user's browser cookie file for a considerable period of time, which will depend on the settings that are selected by the user in the configuration of his browser. These cookies allow the information to be transmitted to the server whenever the user visits the GEMA TRAVEL website.

5.11 GEMA TRAVEL may request the services of third parties to carry out monitoring activities of its Marketing communications. These entities use cookies to measure the efficiency of the campaigns and to customize the content. The information collected by these mandated entities may include geographical location data, such as the IP address data but without ever questioning the anonymity of users.

5.12 GEMA TRAVEL uses appropriate technologies for the continuous optimization of Marketing communication, which allows checking the on-line behaviour in terms of time, geographical location and use of this website. This information is collected through the location of pixels and/or cookies and is not related to personal data. All information required for analysis is stored on strategically located servers. GEMA TRAVEL does not share the use of this information with third parties.

5.13 Any user is free to accept or reject cookies, and to do so, configure the settings of its browser.

CLAUSE 6
Use of IP Addresses

6.1 On the Internet, computers communicate with each other thanks to the IP protocol, which uses numeric addresses, called IP addresses. Each computer on a given network has a unique IP address on that network that is automatically assigned to the user's personal computer by the Internet Service Provider (ISP), allowing the user to surf through the Internet.

6.2 When a user accesses the GEMA TRAVEL website, it receives and knows the IP address of the user. GEMA TRAVEL captures IP address numbers for reasons of system administration, obtaining statistical information to better tailor products and services intended for consumers, in general, and in particular, to monitor the use of the Site and to perform the statistics of the visits that occur on the website. GEMA TRAVEL does not relate the identifiers of the IP addresses with any data or information that allows to identify a specific person, which is why a user's access to the website is registered but does not allow GEMA TRAVEL to identify the user, being completely anonymous.

6.3 GEMA TRAVEL reserves the right to make use of the IP address numbers so that, in collaboration or not with the user's Internet service provider, it can ensure compliance with the General Conditions of Use of the Site, protect the services and/or contents of the Site, and protect the interests of GEMA TRAVEL customers and third parties.

CLAUSE 7
Options for receiving information

The user is guaranteed the option to choose whether or not to receive information or communications from GEMA TRAVEL when the "Data" is being requested. The user is always guaranteed the option to remove his name from any mailing list of GEMA TRAVEL in order not to receive further communications in the future. To ensure the immediate deletion of its "Data" from any list, the user should simply send an email to info@boxtravel.eu and follow specific instructions contained in the communications received from GEMA TRAVEL. If the user can not complete the procedure indicated in the communications, he should send an e-mail to info@boxtravel.eu, adding a copy of the e-mail from the website which he does not want to receive more information from, expressly mentioning that he wants to be removed from the mailing list.

CLAUSE 8
Secure Payment by Credit Card

To prevent any eventuality, GEMA TRAVEL uses SSL technology to protect payments from customers who use their credit card for this purpose. All personal data necessary to process a reservation (names, addresses, e-mails, bank details) are encrypted by SSL technology at the moment of processing, ensuring the protection of the payment made. In this way, it will not be possible to uncover any information that transits through the Internet. When the abbreviation https:// (meaning secure http protocol) appears in the address bar and a closed padlock becomes visible on the left side of the address bar, this indicates that the communication is secure.


CLAUSE 9
Links to other web pages or websites

This website contains links to other web pages. GEMA TRAVEL is solely responsible for the practices of privacy and "Data" protection of its own websites or websites whose content it manages. Notwithstanding the foregoing, GEMA TRAVEL analyses the contents of the web pages of third parties before making them available to their customers and only makes them available if it is considered that they comply with the applicable Law and will be monitored by a Ombudsman for the defence of the interests of GEMA TRAVEL customers.


CLAUSE 10
Chats and Forums

10.1 Users are solely responsible for the content of electronic messages they send from public places through the website, such as Forums and Chats.

10.2 Users are cautioned that if they decide to disclose their "Data", such as their user-name, email address or telephone number in Forums or Chats, such "Data" may be collected and used by third parties and may result in the reception of unwanted messages from third parties.

10.3 GEMA TRAVEL does not guarantee the confidentiality with respect to third parties nor will it be responsible for the use given by third parties to the information or "Data" made available by users in public places through the website.

10.4 GEMA TRAVEL reserves the right to withdraw through voluntary agreements or other effective means that may be established, the contents sent by the users to the public places of the Site if it considers, in good faith, that from those contents may result illicit or damage to property or rights, which may give rise to compensations.

10.5 In the event that a competent body declares the unlawfulness of a content sent by users to the public places of the website of GEMA TRAVEL and orders its withdrawal or determines to prevent access to such content, GEMA TRAVEL will act diligently and comply with such declaration, excluding expressly in this case the responsibility of GEMA TRAVEL for hosting the said content.

CLAUSE 11
Contact Addresses

Any request for information regarding this Privacy and Data Protection Policy, any comments on this website or to access, rectify, delete the personal data or oppose to the treatment thereof, should be sent to info@boxtravel.eu.

CLAUSE 12
Legal Reasons

GEMA TRAVEL shares information with companies, organizations or individuals outside the company if the use and preservation or disclosure of such information is strictly necessary to comply with any law, regulation, legal process or enforceable request of a state agency or entity; implement the Privacy and Data Protection Policy, including investigation of potential data breaches; detect, prevent or otherwise solve technical, fraud or security problems; protect from damages the rights, property or safety of GEMA TRAVEL, its users or the general public, under the terms required or permitted by law.

CLAUSE 13
Alterations

This Privacy and Data Protection Policy may be changed from time to time. The rights acquired by users under this Privacy and Data Protection Policy will not be reduced without their express consent. Any changes to the Privacy and Data Protection Policy will be posted on this website and, if the changes are significant, it will be provided a more prominent notice (including, for certain services, email notification of changes to the privacy policy). Prior versions of this Privacy and Data Protection Policy will also be available and accessible for consultation.

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