HCC St. Moritz

PRIVACY POLICY

Last update: 11th April 2016

1. DESCRIPTION:

The acceptance of the privacy policy of Travel Compositor (later called “Privacy policy”) is a necessary condition for using this service.

This “Privacy policy” regulates the recompilation, treatment, and usage of the personal and no personal information of the users of the service, since the date of entry into that appears in the header.

Travel Compositor is going to ask always to the users before the using their data for any purpose other than those described in this Privacy Policy.

In the treatment of personal data of its users, Travel Composer complies at all times with current legislation, specifically Organic Law 15/1999, of 13 December, Data Protection (hereinafter "LOPD") and its implementing regulations. To do this,they adopt the technical and organizational measures to prevent loss, misuse, alteration, unauthorized access and theft of personal data, given the state of technology access, the nature of the data and risks to which they are exposed.

1. Collected information.

The service can be used for users by different ways, for example searching information of destinations or be a registered user, collecting different information in every case.

1. Non registered user

In this case the service collects the IP address, and the following information of the user (later a “Non Personal Information”)

• Redirected by doing click in another website
• Storing cookies on the user’s computer hard drive. See our Cookie Policy for more information.
• Specific data of the device used by the user (for example, the model, version of the operative system, errors that are generated using the Service, which navigator is used, language, date an hour of the request, URL of reference, others…)
• Data of the user location using different technologies, for example GPS signals sends by a mobile phone, information through WiFi Acces, information on access points Wi-Fi antennas or nearest mobile telephony, among others. Always according to the privacy settings on your device.
• Moreover, Travel Compositor uses Google Analytics, which is an analytic service owned by Google, Inc. residing in the United States with headquarters at 1600 Amphitheatre Parkway, Mountain View, California 94043 To provide these services, they use cookies that collect information, including the IP address of the user, which will be transmitted, processed and stored by Google on the terms set out in the web www.google.com. Including the possible transmission of such information to third parties for legal requirement reasons or where such third parties process the information on behalf of Google.

Anyway, you are able to disable these cookies of Google Analytics here (crear el hiperenlace)

1. Registered user

Travel Compositor

Every user has to indicate in the registration process: Name and last name, country, telephone number and e-maill. Then every user has to choose a password which confidentially has to keep. 

The user who wants to book a trip using the Service has to indicate in addition: DNI or ID Card, date of birth, flight dates, transports, hotels or services hired and payment method.

Moreover, when you make a reservation for another person using Travel Compositor, the software is going to ask about the personal information and preferences of the other person.

You must have permission from those other persons before providing their personal data and trip preferences

1. Rights and purposes

Under the provisions of the Data Protection Act, we inform you that the completion of forms by the user is voluntary, although the failure to complete the required fields limits the access or use of the Service.

Personal information that users gives us are automatically incorporated and in the files owned by Travel Compositor for future user request in order to meet all their needs, also to keep in touch with them via e-mail, to ask about the activity of the service and their services.

The User is allowed in every moment to perform its access rights, rectify or cancel their Personal Information sending an e-mail to info@travelcompositor.com

Here (poner hiperelenace) you will find different types to exercise such rights.

Travel Composer respects the confidentiality of the data collected in the file, and makes use of it in accordance with the purpose, to fulfill its obligation of custody and to take all necessary measures to prevent alteration, loss, or unauthorized access data, in accordance with the provisions of Royal Decree 1720/2007, of December 21, approving the Regulations implementing the data Protection Act is approved

To delete a User in Travel Compositor, you have to contact with info@travelcompositor.com

1. Minors

The service is focused on adults with full legal power to make use of the system. Minors are not authorized to use the Service.

If Travel Compositor requires a User accreditation of age, and it is not satisfactory, Travel Compositor reserves the right to terminate and cancel this user data

If the Service discovers any user who is a minor, this account is going to be closed immediately as its Personal and No Personal information deleted

1. Use of data

Travel Compositor is going to use data of its users for commercial, personalization, operational and statistical reasons

In this sense, we use the collected information to offer requested products and services; send confirmation and updates on your trip; manage your account; communicate with you in general; answer your questions and comments; prevent potentially prohibited or illegal activities and enforce our terms and conditions.

Travel Compositor is going to use the user’s e-mail for the followings reasons, that the users accepts:

Sending newsletters, the User can cancel this service at any time.

Notifies service questions or user (for example, reset password)

 Notify misconduct and, if necessary, report the suspension or withdrawal of the User account.

By accessing or using the service, user explicitly agrees to receive these emails, but may unsubscribe: a) specified in any communication link is sent via email or; b) sending an email to info@travelcompositor.com.

 However, the user may not unsubscribe from our correspondence determined as messages concerning your account, the same security issues or the terms and conditions of service

Travel Compositor may also use the Personal user Information as anonymous data to show to third parties. You can also share statistics and demographic information about users and their use of the Service with third parties, but none of this will enable those third parties to identify a user.

1. Services suppliers and others.

There are others who manage part of the Service.

These others are obligated by Travel Compositor to comply this Policy Privacy as applicable to them and also they must have their own. However, Travel Compositor will not be responsible for compliance with this policy.

In some cases, Travel Compositor could share, use, preserve or disclose the Personal Information to other, of non-aggregated form.

• To provide the Service

1. Suppliers, as hotels providers, airlines or activities providers are used to compose the trip. In Travel Compositor, all the services are provided by a third party provider and they are described as them. We recommend that to examine the privacy policy of every other who provides the service. Please note that these suppliers also may contact you as necessary to obtain additional information.
2. Third party suppliers which provide services, including the processing of credits cars, commercial analytics, customer service or marketing. are able to collect and have access to the necessary information to act their functions, but they have no power to share or use this information for others ends.

• To cooperate with competent authorities

1. We though that is currently necessary to satisfy every law or legal process from all around the world and we believe that if we do it our responsibility will be diminished. In any case, we only provide the information required.
2. We believe that this kind of actions are appropriated to comply with the terms and conditions of Travel Compositor, including any investigation of possible violations of them
3. If its necessary to detect, prevent or otherwise address and prosecute fraud, security or technical issues related to Travel Compositor
4. If this action is according to protect the rights, property or security of Travel Compositor, employers and users.
5. We believe it is reasonably necessary to satisfy any law or on its own initiative or at the request of third parties who prove a legitimate interest.

In every way, if Travel Compositor is part of a fusion, acquisition or another transaction which is related with the sale of all or some of its assets or securities with voting rights, User information, including Personal Information obtained through the Service, may be included in the transferred assets or securities. If this happens, your personal information will remain subject to this Privacy Policy.

7- Security measures

Travel Compositor takes all necessary technical and organizational measures to protect the security and integrity of personal information against unauthorized access and against alteration, loss or accidental destruction

Thus, sending a data submission made by the user through the Service, for example when the payment is protected by techniques of electronic security in the network. Also, the information provided and stored in the databases of Travel Compositor is also protected by security systems that prevent access to them by unauthorized third parties

Travel Compositor makes its best efforts to provide the most updated for the effectiveness of these safety systems. In addition, Travel Compositor stores Personal Information for as long as the rules allow, and periodically destroys it if no longer needed

Travel Composer cannot guarantee the absolute security of personal information, so the user must collaborate and use at all times and common sense on the Personal Information Publishing

The user must be aware that publishing the data will be its own responsibility. Travel Compositor cannot guarantee that the published information will not be seen by unauthorized persons. You understand and acknowledge that, even after disposal, Personal Information may remain visible in cache or if other users have copied or stored Information

8- Changes of the Privacy Policy

We may update this Privacy Policy in the future.

We will inform you about material changes to this Privacy Policy by sending a notice to the email address you gave us and by placing a notice in a prominent location on our website

9- Contact

If you have questions about this Privacy Policy contact us at:

E-mail: info@travelcompositor.com

Phone: 971 55 72 43

Address: Parc Bit - Building Naorte 1-1, Palma de Mallorca - Spain

In addition, you can communicate directly with the travel provider phone number or address provided on your travel itinerary