Privacy policy - Movviendo EN

Privacy Policy

At MOVVIENDO TOURISM GROUP SL we care about privacy and transparency. In addition, we are committed to treat your data in compliance with the Data Protection regulations in force:
– EU Regulation 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
– Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).
Below, we provide you with details of the personal data processing that we carry out, as well as all the information relating to the same.
1. Who is responsible for the processing of your data?

MOVVIENDO TOURISM GROUP SL B18579458
C/ LA NIÑA S/N – 18194 – CHURRIANA DE LA VEGA – GRANADA 647925800
direccion@granavision.com

1.1. Contact details of the Data Protection Delegate (DPD):

GRUPO ALTABIR (FORMACONT SL), CIF B18955195

C/ Luis Amador 26, Centro de Negocios Cámara de Comercio de Granada, P.0 – Of.B dpo@altabir.es
2. For what purpose do we process your personal data?
MOVVIENDO TOURISM GROUP SL processes the information provided to us by interested parties for different purposes. Below is a description of each of the purposes according to the data processing carried out:

⦁ Processing of images for promotional purposes: we process the information provided by interested parties in order to capture, disseminate and transfer images and/or videos for promotional purposes for publication on the Internet (social networks, video platforms and websites), in the entity’s publications and other media.
⦁ Processing of job candidates’ data: we process the information provided by interested parties in order to manage the CVs received and carry out personnel selection processes, interviews and other procedures necessary for the search for the best possible candidate for a specific job.
⦁ Processing of customer data: we process the information provided by interested parties in order to carry out the administrative, accounting and tax management of the services requested, as well as to send promotional communications about our products and services.
⦁ Processing of potential customers and contacts: we process the information provided to us by interested parties in order to manage potential customers who have expressed interest in our products and/or services, as well as other commercial contacts and, where appropriate, to send promotional communications, including by electronic means.
⦁ Processing of supplier data: we process the information provided to us by interested parties in order to carry out the fiscal, accounting and administrative management of suppliers, as well as professional contact details.
⦁ Processing of newsletter subscriber data: we process the information provided by interested parties for the purpose of sending our newsletter and other promotional communications of interest to newsletter subscribers.
⦁ Processing of personnel data: we process the information provided to us by interested parties for the purpose of personnel management; training; occupational risk prevention and health surveillance; preparation of payroll, social security and contributions; registration of working hours; accidents at work, where appropriate.
⦁ Processing of data for the exercise of data subjects’ rights: we process the information provided to us by data subjects in order to manage and attend to the requests of data subjects in the exercise of the rights established in the data protection regulations.
⦁ Processing of data collected in the contact form on the website: we process the information provided by interested parties in order to deal with their requests.
⦁ Processing of video surveillance data: we process the data in order to guarantee the security of people, goods and facilities.
⦁ Processing of video surveillance data (work monitoring): we process the data for the purpose of monitoring and managing work activity using the video surveillance systems of the data controller.
⦁ Processing of the data of the parties involved in the protocol for the prevention of sexual or gender-based harassment: we process the information provided by individuals in order to manage the protocol for the prevention of sexual or gender-based harassment; regulation of the procedure, management of the complaint, collection of personal data and interviews with the parties concerned.
⦁ Processing of customer health data: we process the data provided to us by the persons concerned on basic health data such as allergies, intolerances or disabilities in order to adapt the experience to their needs.
No automated decisions will be made on the basis of the data provided.

If you do not provide your personal data, we will not be able to fulfil the purposes described above.
3. How long will we keep your data?

Each data processing will have a retention period. Therefore, we indicate the retention period according to the different types of data processing that we carry out at MOVVIENDO TOURISM GROUP SL:

⦁ Processing of images for promotional purposes: The data will be kept as long as the interested party does not request their deletion.
⦁ Processing of job applicants’ data: Two years from the last interaction.
⦁ Processing of customer data: Data will be retained for as long as the data subject does not request deletion and, where applicable, for the years necessary to comply with legal obligations.
⦁ Processing of potential customers and contacts: The data will be kept for as long as the data subject does not request their deletion.
⦁ Processing of suppliers’ data: The data will be kept for as long as the data subject does not request its deletion, and, where appropriate, for the years necessary to comply with legal obligations.
⦁ Processing of newsletter subscriber data: The data will be kept for as long as the data subject does not request its deletion.

⦁ Processing of personnel data: For as long as the employment relationship with the entity is maintained and for the years necessary to comply with legal obligations.
⦁ Processing of data for the exercise of data subjects’ rights: Data will be kept for the time necessary to resolve requests and for at least three years to deal with possible claims.
⦁ Processing of data collected in the contact form on the website: The data will be kept for as long as the interested party does not request their deletion.
⦁ Processing of video surveillance data: The data will be kept for a maximum of 30 days, except for communication to Security Forces and Bodies and/or Courts and Tribunals.
⦁ Processing of video-surveillance data (labour control): The data will be kept for a maximum of 30 days, except in the case of communication to the Courts and Tribunals.
⦁ Processing of the data of the parties involved in the protocol for the prevention of sexual harassment or harassment for reasons of sex: The data will be deleted after two years, unless it is necessary to delete them.
⦁ The data will be deleted after two years, unless it is necessary to keep them in order to determine the possible responsibilities that may arise in the event of possible claims made by the affected parties.
⦁ Processing of customer health data: They will be kept for as long as the customer maintains a contracted activity that requires the use of this information to adapt their experience to their needs.
⦁ What is the legitimation for the processing of your data?
Each data processing will have a different legitimacy. Therefore, we indicate the legal basis for each of the data processing operations that we carry out at MOVVIENDO TOURISM GROUP SL:
⦁ Processing of images for promotional purposes:
o Consent of the data subject: capture, dissemination and transfer of image and/or video for promotional purposes for publication on social networks, video platforms and websites, as well as in the entity’s publications and other media (RGPD art. 6.1.a).
⦁ Processing of the data of job applicants:
o Execution of a contract or pre-contractual measures: Management of CVs submitted by the candidate in order to carry out personnel selection processes for the search for the best possible candidate for a given job. (RGPD art. 6.1.b).
⦁ Processing of customer data:
⦁ o Execution of a contract or pre-contractual measures: Fiscal, accounting and administrative management of customers (RGPD art. 6.1.b).
⦁ o Legitimate interest of the Controller: Sending of promotional communications, including by electronic means (RGPD Recital 47, LSSICE art. 21.2).
⦁ Processing of potential customers and contacts:
⦁ o Execution of a contract or pre-contractual measures: Management of potential customers who have expressed an interest in our products and/or services. (RGPD, art. 6.1.b).
⦁ o Consent of the data subject: To send promotional communications, including by electronic means (RGPD, art. 6.1.a, LSSICE art.21).
⦁ o Legitimate interest of the Data Controller: Management of professional contact data (LOPDGDD art.19, RGPD art. 6.1.f).
⦁ Processing of supplier data:
⦁ o Execution of a contract or pre-contractual measures: To carry out the administrative, accounting and fiscal management of the contracted services (RGPD art. 6.1.b).
⦁ o Legitimate interest of the Controller: Management of professional contact data (LOPDGDD art.19, RGPD art. 6.1.f).
⦁ Processing of newsletter subscriber data:
⦁ o Consent of the data subject: to send our newsletter and other promotional communications of interest to newsletter subscribers (RGPD, art. 6.1.a, and LSSICE art.21).
⦁ Processing of personal data:
⦁ o Execution of a contract or pre-contractual measures: Personnel management, training and training (RGPD art.6.1.b).
⦁ o Compliance with a legal obligation: Occupational risk prevention and health surveillance; preparation of payroll, social security and contributions; recording of working hours; management of occupational accidents, if applicable. (Law 31/1995, of 8 November, on the Prevention of Occupational Risks; Royal Legislative Decree 2/2015, of 23 October, approving the revised text of the Workers’ Statute Law; Royal Legislative Decree 8/2015, of 30 October, approving the revised text of the General Law on Social Security; Royal Decree-Law 8/2019, of 8 March, on urgent measures for social protection and to combat precariousness in the working day; RGPD arts.
6.1.c and 9.2.b). Royal Decree 902/2020, of 13 October, on equal pay for men and women.
⦁ Processing of data for the exercise of data subjects’ rights:
⦁ o Fulfilment of a legal obligation: to manage and deal with requests from data subjects in the exercise of the rights established in the data protection regulations (RGPD, art.6.1.c).

⦁ Processing of data collected in the contact form on the website: o Execution of a contract or pre-contractual measures: To deal with your request (RGPD, art. 6.1.b).
⦁ Processing of video surveillance data:
o Public interest mission: Processing necessary for the performance of a mission carried out in the public interest or in the exercise of public powers vested in the controller (GDPR art. 6.1.e), as stated in the “Guide on the use of video cameras for security and other purposes”, published by the Spanish Data Protection Agency.
⦁ Processing of video surveillance data (labour monitoring):
o Execution of a contract or contractual measures: Royal Decree Law 2/2015, approving the revised text of the Workers’ Statute Law (art. 20.3); Organic Law 3/2018 on the protection of personal data and guarantee of digital rights (art. 89).
⦁ Processing of the data of the parties involved in the protocol for the prevention of sexual or gender-based harassment: o Compliance with a legal obligation: Organic Law 3/2007, of 22 March, for the effective equality of women and men (art. 48); Royal Decree 901/2020, of 13 October; Law 31/1995, of 8 November, on the prevention of occupational hazards (art. 14).
⦁ Processing of customer health data: o Consent of the interested party: Regarding the content, use and conservation of the health data provided (RGPD, art. 9.2.a).
5. To which recipients will your data be disclosed?

Depending on the data processing, data may be transferred to other recipients. To this end, we detail the data transfers in each of the data processing operations that we carry out at MOVVIENDO TOURISM GROUP SL:
⦁ Processing of images for promotional purposes:
o Internet (social networks, video platforms and websites), the entity’s website and other media, for the purpose of transfer and publication of images and/or video for promotional purposes.
⦁ Processing of job applicants’ data: No data will be transferred to third parties, unless legally obliged to do so.
⦁ Processing of customer data:

o Tax Administration, for the purpose of complying with legal obligations (legal requirement).
o Public Administrations, only if there is a legal obligation (legal requirement).
o Financial institutions, for the purpose of issuing the corresponding receipts (contractual requirement).
o Hotels or accommodation, for the purpose of managing bookings if the service includes accommodation (contractual requirement).
o Monuments, museums and tourist attractions, when required for the purchase of nominative tickets or access to certain enclosures (contractual requirement).

• Processing of potential clients and contacts: Data will not be transferred to third parties, except under legal obligation.
• Processing of supplier data:

o Tax Administration, for the purpose of complying with legal obligations (legal requirement).
o Financial institutions, for the purpose of making the corresponding payments (contractual requirement).
• Processing of newsletter subscriber data: Data will not be transferred to third parties, except under legal obligation.
• Processing of staff data:

o Tax Administration, Social Security, and Mutual Insurance Companies, for the purpose of filing taxes and social security obligations (legal requirement).
o Banks and financial institutions, for the purpose of making payroll payments (contractual requirement).
o State Foundation for Employment Training (Fundae), for the purpose of managing employee training bonuses (contractual requirement).
• Data processing for the exercise of data subject rights:

o Supervisory authorities, public administration bodies, and the Ombudsman, where applicable, for the purpose of managing and responding to requests and potential complaints (legal requirement).
• Processing of data collected in the website’s contact form: Data will not be transferred to third parties except under legal obligation.
• Processing of video surveillance data:

o Where applicable, state security forces and bodies, as well as courts and tribunals, for the purpose of providing images if a crime has been committed (legal requirement).

• Processing of video surveillance data (workplace monitoring):

o Courts and Tribunals for the purpose of providing images if a workplace offense has been committed (legal requirement).
• Processing of data of the parties involved in the protocol for the prevention of sexual or gender-based harassment:
o State security forces; judicial bodies; and the Public Prosecutor’s Office for the purpose of reporting the commission of a possible crime (legal requirement).

• Processing of customer health data:
o Restaurants or catering companies, if the participant has provided information about food allergies or special dietary needs, this will be shared exclusively with the staff responsible for food preparation and distribution. Only relevant information will be provided, without including personal data (such as first and last names), to ensure the food safety of the attendee (consent of the data subject).
⦁ Data transfers to third countries
Depending on the data processing, data transfers to third countries may occur. To this end, we break down each of the data processing procedures we carry out at MOVVIENDO TOURISM GROUP SL, indicating whether any data transfers to third countries occur:
• Processing of images for promotional purposes: Social media and promotional dissemination systems, for the purpose of advertising the entity’s services. The guarantee for this transfer has been established through: Explicit consent of the data subject. You can find additional information in: the entity’s Privacy Policy.
• Processing of data of job candidates: No data transfers to third countries are planned. • Processing of customer data: No data transfers to third countries are planned.
• Processing of potential customers and contacts: No data transfers to third countries are planned.
• Processing of supplier data: No data transfers to third countries are planned.
• Processing of newsletter subscriber data: No data transfers to third countries are planned.
• Processing of staff data: No data transfers to third countries are planned.
• Processing of data for the exercise of data subjects’ rights: No data transfers to third countries are planned.
• Processing of data collected in the website contact form: No data transfers to third countries are planned.

• Processing of video surveillance data: No data transfers to third countries are planned.
• Processing of video surveillance data (workplace monitoring): No data transfers to third countries are planned.
• Processing of data of the parties involved in the protocol for the prevention of sexual or gender-based harassment: No data transfers to third countries are planned.
• Processing of customer health data: No data transfers to third countries are planned.
7. What are your rights when you provide us with your data?

Anyone has the right to obtain confirmation as to whether MOVVIENDO TOURISM GROUP SL is processing personal data concerning them.
Data subjects have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected. They also have the right to data portability.
Under certain circumstances, data subjects may request that the processing of their data be restricted, in which case we will only retain it for the exercise or defense of legal claims.
In certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. In this case, MOVVIENDO TOURISM GROUP SL will stop processing the data, except for compelling legitimate reasons, or to exercise or defend against potential legal claims.
You may exercise your rights by contacting dpo@altabir.es or C/ Luis Amador 26, Granada Chamber of Commerce Business Center, P.0 – Office B.
When commercial communications are sent using the legitimate interest of the controller as the legal basis, the data subject may object to the processing of their data for this purpose.
If you have given your consent for a specific purpose, you have the right to withdraw it at any time, without affecting the lawfulness of the processing based on the consent given prior to its withdrawal.
If you feel that your rights regarding the protection of your personal data have been violated, especially when you have not been satisfied in the exercise of your rights, you may file a complaint with the competent Data Protection Supervisory Authority through its website: www.aepd.es.

8. How did we obtain your data?

The personal data we process at MOVVIENDO TOURISM GROUP SL comes from: The data subject.