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info@travel-operator-groupement.com
Travel Operator Groupement with registered office in Madagascar – Morafeno, 201, Antsiranana (hereinafter “TOG”) is constantly committed to protecting the online privacy of its users.
This page describes the general methods of processing the personal data of site users and cookies, referring to any specific sections where the site user can find specific information and any requests for consent (for individual treatments).
The information is provided only for this site and not for other websites that may be consulted by the user via links.
Travel Operator Groupement, Data Controller based in Morafeno, 201 Antsiranana, Madagascar, is committed to protecting the user’s personal information and this document aims to help you understand what information we may collect and how we use it.
This document was drawn up pursuant to art. 13 of EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to know our privacy policy.
The general methods of processing the personal data of users of the site and cookies are described and how your personal information is managed when you use our site (hereinafter “Site”).
The information and data you provide or otherwise acquired in the scope of use of the Travel Operator Groupement services, – such as: access to the reserved area of the Site, newsletters, etc. hereinafter “Services” -, will be processed in compliance with the provisions of the Regulations and the confidentiality obligations that inspire the activity of the Travel Operator Groupement.
According to the rules of the Regulation, the treatments carried out by Travel Operator Groupement will be based on the principles of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality.
The owner of the treatments carried out through the Site is Travel Operator Groupement as defined above to which you can write for any information concerning the processing of personal data.
The person in charge for the protection of personal data (hereinafter, “DPO”) can be reached at the following address: DPO@travel-operator-groupement.com.
This information is provided only for this Site and not for other websites that may be consulted by the user via links.
Please refer to any specific sections of the Site where you can find specific information and any requests for consent for individual treatments.
After browsing the Site, we inform you that Travel Operator Groupement will process personal data (Article 4 (1) of the Regulation) hereinafter only “Personal Data”.
In particular, the Personal Data processed through the Site are as follows:
The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning (see the paragraph on cookies below), to identify anomalies and / or abuses, and are deleted immediately after processing.
The data could be used by the competent authorities to ascertain responsibility in the event of hypothetical computer crimes against the site.
Apart from what is specified for navigation data, the user is free to provide personal data contained in any request forms present on the website (eg. To activate newsletters, free registration, purchase, etc.).
Failure to provide them could make it impossible to provide the service.
In these cases, only the information necessary for the requested service will be requested (see the specific information in detail).
In the use of some Services of the Site, the processing of Personal Data of third parties sent by you to the Travel Operator Groupement may occur.
With respect to these hypotheses, you act as an independent data controller, assuming all the obligations and responsibilities of the law.
In this sense, it confers on this point the widest indemnity with respect to any dispute, claim, request for compensation for damage from treatment, etc. that it should reach Travel Operator Groupement from third parties whose Personal Data have been processed through its use of the Site functions in violation of the applicable personal data protection rules.
In any case, should it provide or otherwise process Personal Data of third parties in the use of the Site, it guarantees from now – assuming all related responsibility – that this particular hypothesis of treatment is based on an appropriate legal basis pursuant to art . 6 of the Regulation which legitimizes the processing of the information in question.
The processing of personal data that we intend to carry out, with your specific consent where necessary, has the following purposes:
• Allow the provision of the Site Services; The legal basis of the processing is the execution of pre-contractual measures adopted at the request of the same (Article 6 (1) (b) of the Regulation) as the processing is necessary for the provision of the Service.
The provision of Personal Data for these purposes is optional but failure to provide it would make it impossible to activate the Services provided by the Site.
Furthermore, your personal data may possibly be processed for the following purpose:
• integration of the “user profile” present in the Customer Relationship Management (“CRM”) of Travel Operator Groupement through the interactions made on the social pages (for example, messages and / or comments on the Travel Operator Groupement Facebook page, or in any other environment or social page of the Data Controller), to respond to requests for assistance from the user concerned.
The legal basis of the processing for the purposes described is identified in the execution of a contract or pre-contractual measures or in the response to requests from the interested party (Article 6 par. 1, letter b) of the Regulation).
The provision of your personal data for the aforementioned purposes is optional, but failing that, it may not be possible to respond to your requests.
The details of the interactions made by the user concerned on our social pages (for example, messages and / or comments on the Facebook page of Travel Operator Groupement SpA, or on any other environment or social page of the Owner) may also involve further processing of his personal data for the purpose of defense against abuse and / or unlawfulness and purposes of improving the support offered to its users who interact through our social channels, as in the case of statistical and / or aggregate processing that allow us to better orient our communication strategies with online users.
The legal basis of the processing for the specific additional purpose described is identified in the legitimate interest of the Data Controller (Article 6 par. 1, letter f) of the Regulation) in the management of the data of its users.
The interested user has the right to object at any time for reasons connected to his particular situation to the processing of data for such additional purposes, unless the Data Controller demonstrates the existence of binding legitimate reasons to proceed with the processing that prevail over interests, rights and freedoms of the interested party or for the assessment, exercise or defense of a right in court.
Your Personal Data may be shared, for the aforementioned purposes, with:
• persons authorized by Travel Operator Groupement to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (eg employees and system administrators).
• third parties possibly involved in the management of the site who typically act as data processors (the complete and updated list of data processing managers is present and available at www.travel-operator-groupement.com).
• subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data by virtue of the provisions of the law or orders of the authorities.
Some of your Personal Data are shared with Recipients who could be found outside the European Economic Area.
Travel Operator Groupement ensures that the processing of your Personal Data by these Recipients takes place in compliance with the Regulations. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis.
Pursuant to articles 15 and following of the Regulations, you have the right to ask Travel Operator Groupement, at any time, to access your Personal Data, to rectify or delete them or to oppose their processing, you have the right to request the limitation of processing in the cases provided for by art. 18 of the Regulation, as well as to obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation.
Requests must be sent in writing to the Data Controller at the following address: privacy@travel-operator-groupement.com or to the DPO (Data Protection Officer) at the following address: DPO@travel-operator-groupement.com.
In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.
This privacy policy is effective from 23/2/2022. Travel Operator Groupement reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. Travel Operator Groupement will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Site.
Travel Operator Groupement therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to always be updated on the data collected and on the use made of it by Travel Operator Groupement.