Privacy Policy

I. PRIVACY AND DATA PROTECTION POLICY

In compliance with current legislation, NeoGeoDmc.com (hereinafter, also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it respects the following standards:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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 (LOPD-GDD).
• Royal Decree 1720/2007 of 21 December, approving the Regulations for the development of Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
• Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data processing

The controller responsible for the processing of personal data collected at NeoGeoDmc.com is: neogeo soluciones tecnológicas y vacacionales sl

Address: C/ komentu kalea 26, 48200, Durango
Contact Telephone: +34 604 84 26 41
Contact Email: admin@neogeoviajes.es

Personal Data Registry

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by NeoGeoDmc.com through the forms provided on its pages will be incorporated and processed in our files in order to facilitate, expedite, and fulfill the commitments established between NeoGeoDmc.com and the User, or to maintain the relationship established in the forms filled out by the latter, or to address a request or inquiry. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject to the following principles set out in Article 5 of the GDPR and in Article 4 and following of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness, and transparency: the consent of the User will be required at all times after providing completely transparent information on the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit, and legitimate purposes.
• Principle of data minimization: the personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and always kept up to date.
• Principle of storage limitation: personal data shall only be maintained in a way that allows the identification of the User for the time necessary for the purposes of its processing.
• Principle of integrity and confidentiality: personal data will be processed in a way that guarantees its security and confidentiality.
• Principle of proactive responsibility: the data controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed at NeoGeoDmc.com are solely identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. NeoGeoDmc.com undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the operation carried out.

Purposes of the processing for which the personal data are intended

Personal data are collected and managed by NeoGeoDmc.com for the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User or the maintenance of the relationship established in the forms filled out by the latter or to attend to a request or inquiry.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical purposes, and activities typical of the corporate object of Tours Compositor, as well as for the extraction, storage of data, and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation, and navigation of the Website.

At the time the personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be given to the information collected.

Personal data retention periods

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 18 months, or until the User requests its deletion.

At the time the personal data are obtained, the User will be informed about the period during which the personal data will be stored or, when that is not possible, the criteria used to determine this period.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time the personal data are obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of Articles 8 of the GDPR and 7 of Organic Law 3/2018 of December 5 on the Protection of Personal Data and guarantee of digital rights, only those over 14 years of age may grant their consent for the lawful processing of their personal data by Tours Compositor. If the user is a minor under 14 years of age, the consent of the parents or guardians will be required for the processing, and this will only be considered lawful to the extent that they have authorized it.

Security and secrecy of personal data

NeoGeoDmc.com undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of personal data and avoid the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, because NeoGeoDmc.com cannot guarantee the invulnerability of the internet or the total absence of hackers or others who fraudulently access personal data, the data controller undertakes to communicate to the User without undue delay when a breach of personal data security occurs that is likely to entail a high risk to the rights and freedoms of natural persons. Following the provisions of Article 4 of the GDPR, a breach of personal data security is understood as any breach of security resulting in the accidental or unlawful destruction, loss, or alteration of personal data transmitted, stored, or otherwise processed, or unauthorized communication or access to such data.

Personal data will be treated as confidential by the Data Controller, who undertakes to inform of and guarantee by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights derived from the processing of personal data

The User has rights over NeoGeoDmc.com and may, therefore, exercise against the data controller the following rights recognized in the GDPR and in Organic Law 3/2018 of December 5 on the Protection of Personal Data and guarantee of digital rights:

• Right of access: It is the User's right to obtain confirmation as to whether or not NeoGeoDmc.com is processing their personal data and, if so, to obtain information about their specific personal data and the processing that NeoGeoDmc.com has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications made or planned for them.
• Right to rectification: It is the User's right to have their personal data modified if it proves to be inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure ("the right to be forgotten"): It is the User's right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and this does not have another legal basis; the User opposes the processing and there is no other legitimate reason to continue with it; the personal data have been processed unlawfully; the personal data must be deleted in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must adopt reasonable measures to inform the controllers who are processing the personal data of the request of the interested party to delete any link to those personal data.
• Right to restriction of processing: It is the User's right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the processing.
• Right to data portability: In the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller. Whenever technically possible, the Data Controller will directly transmit the data to that other controller.
• Right to object: It is the User's right not to have the processing of their personal data carried out or to cease the processing thereof by Tours Compositor.
• Right not to be subject to a decision based solely on automated processing, including profiling: It is the User's right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation establishes otherwise.

Thus, the User may exercise their rights by means of a written communication addressed to the data controller with the reference "GDPR-www.NeoGeoDmc.com", specifying:

• Name, surname of the User and copy of the ID (DNI/NIE/Passport). In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document proving the representation. The photocopy of the ID may be replaced by any other valid legal means that proves identity.
• Request with the specific reasons for the application or information to which access is sought.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document that proves the request being made.

This request and any other attached document may be sent to the following address and/or email:

Address: Goinekalea 12 bajo, 48200 – Durango- Bizkaia
Contact Email: admin@neogeodm.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to web pages of third parties other than Tours Compositor, and which are therefore not operated by Tours Compositor. The owners of such websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

In the event that the User considers that there is a problem or infringement of current regulations in the way their personal data is being processed, they will have the right to effective judicial protection and to file a claim before a supervisory authority, in particular, in the State in which they have their habitual residence, place of work, or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and agrees with the conditions on the protection of personal data contained in this Privacy Policy and Cookies Policy, as well as accepting the processing of their personal data so that the Data Controller can proceed with it in the manner, during the periods, and for the purposes indicated. Use of the Website will imply acceptance of the Privacy and Cookies Policy of the same.

NeoGeoDmc.com reserves the right to modify its Privacy and Cookies Policy, according to its own criteria, or motivated by a legislative, jurisprudencial, or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy and Cookies Policy will be explicitly notified to the User.

This Privacy and Cookies Policy was updated on January 1, 2021, to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and to Organic Law 3/2018 of December 5 on the Protection of Personal Data and guarantee of digital rights.