Dear user, Be MyJourney Limited, with legal offices in Fact 2 Richmond Mansions, Old Brompton Road-LONDON-SW5 9HL, as Data Controller, would like to inform you about your personal data processing within our website www.bemyjourney.com (hereinafter “Website”).
In this section you can find the following information:
- Who is the Data Controller?
- What personal data is the Data Controller processing?
- What are the modalities and purposes of personal data processing?
- On which legal basis are data processing activities carried out?
- Who can access your personal data?
- Does BeMyJourney transfer your data?
- For how long are your personal data stored?
- Is your personal data processing statutory?
- What are your rights as a data subject?
- How can you lodge a complaint to the UK Commissioner?
- Minors
- External links
- Update to this Privacy Policy
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Who is the Data Controller?
Be MyJourney Limited, with legal offices in Fact 2, Richmond Mansions, Old Brompton Road-LONDON-SW5 9HL, is the Data Controller (hereinafter “Data Controller” or “Be MyJourney”) of your personal data collected within the Website. For any request relating to your personal data processing, please contact this e-mail address: andrea@bemyjourney.com.
2. What personal data is the Data Controller processing?
BeMyJourney processes personal data you directly provided us. These are identifying data, such as:
- Name
- Surname
- E-mail address
- Phone number
- IP address
BeMyJourney may also process other personal data you have provided BeMyJourney with by sending specific requests or submitting further personal data within forms on the Websites.
3. What are the modalities and purposes of personal data processing?
The above-mentioned personal data are processed by electronic means, by means of the operations of collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, erasure and destruction of data.
Your personal data are processed for the following purposes:
- Service purposes: BeMyJourney processes your personal data in order to fulfil your requests and your downloads within the Website;
- Browsing: BeMyJourney processes your personal data for the purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning and for ascertaining liability in case of hypothetical computer crimes against the Website;
- Survey: BeMyJourney may process anonymised data in order to perform surveys and improve its services by prior request to the user;
- Administrative purposes in any case connected with the fulfilment of the relevant contractual obligations, for the fulfilment of legal obligations such as, for example, those of an accounting or fiscal nature, or to comply with requests from Judicial Authorities;
- Newsletter purposes, in case you subscribed to BeMyJourney’s newsletter services and to update you on the latest news, offers and initiatives of BeMyJourney;
- Marketing purposes, in order to send you commercial and advertising information about our services, as well as catalogues and brochures or invitations to events, and in general commercial communications on BeMyJourney and its initiatives
4. On which legal basis are data processing activities carried out?
BeMyJourney processes your personal data on the following legal basis:
- Contract: for the purposes of litt. a. of para. 3 BeMyJourney processes your personal data in order to fulfil a contractual obligation related to services offered within the Website;
- Legal obligation: for the purposes of litt. d. of para. 3 BeMyJourney processes your personal data in order to fulfil legal obligations related to the service and/or to comply with requests from Judicial Authorities.
- Legitimate interest: for the purposes of litt. b. and c. of para. 3 BeMyJourney processes your personal data in order to guarantee the technical performances of the Website and to exercise its right to defend from any claim, complaint, dispute, litigation, both in court or extrajudicial, and to improve the quality of its services;
- Consent: for the purposes of litt. e. and f of para. 3 BeMyJourney processes your personal data only if you have prior given your consent to the newsletter services and to receive commercial and advertising material.
5. Who can access your personal data?
The data collected for the performance of the aforementioned purposes will also be processed by third parties appointed for this purpose as Data Processors or, as the case may be, communicated to them as independent Data Controllers, namely:
- persons, companies, associations or professional firms providing assistance and consultancy to BeMyJourney, as well as in accounting, administrative, legal, tax and financial matters;
- companies, bodies, associations that perform services connected and instrumental to the execution of the purposes of para. 3 (e.g. service providers, such as hotels, guides, etc.);
- Public administrations for the performance of institutional functions within the limits established by law and regulations;
- In addition, personal data may be made accessible, communicated and transferred to Public Bodies, Judicial Authorities, Police Forces in order to follow up on requests for investigation or where expressly required by law.
The complete and up-to-date list of the subjects who process personal data in their capacity as Data Processors and independent Data Controllers is available upon request to BeMyJourney.
6. Does Be MyJourney transfer your data?
In its capacity as a travel intermediary/advertiser, Be MyJourney might transfer personal data in the EEA, in providing booking requests to its service providers, or may use services from providers located within the United States. In any case BeMyJourney is committed to ensuring adequate levels of protection and safeguards in accordance with applicable regulations, including the provision of technical and organisational security measures.
7. For how long are your personal data stored?
BeMyJourney retains your personal data:
- For the purposes of litt a. para 3. for the time necessary to provide you the services you have requested and, in any case, for no more than 5 years;
- For the purposes of litt. b para 3. browsing data (IP address) are deleted immediately; in case of need of exercising BeMyJourney’s rights from claims, complaints, disputes, litigation, for the time of duration of the proceeding or settlement;
- For the purposes of litt. c para. 3 for the time necessary to fulfil to contractual obligations, legal obligations or to comply with requests from Judicial Authorities, in any case no more than 10 years from the termination of contracts, from the closure of relevant fiscal year, or from the Judicial Authority request;
- For the purposes of litt. d. and e. para 3. for a maximum of 2 years.
At the expiration of the retention period, data are definitely deleted or anonymised.
8. Is your personal data processing statutory?
Your personal data conferral:
- Is statutory for the purposes of service: in case of denial, BeMyJourney will not be able to fulfil your requests;
- Is mandatory for the purposes of browsing: in case of denial, you will not be able to browse the Website. In case of claims, complaints, disputes, litigation, BeMyJourney will not be able to defend in court or to settle.
- Is mandatory for the purposes of administrative purposes and legal obligations: in case of denial, BeMyJourney will not be able to fulfil obligations under regulations and national (laws, regulations, including sectoral ones) and supranational legislation applicable;
- Is optional for the purposes of newsletter and marketing: failure to provide this information will have no consequences except for the impossibility of receiving news, updates, promotions, commercial communications and advertising.
9. What are your rights as a data subject?
As a data subject, you have the right to:
- ask BeMyJourney for copies of your personal information. This right always applies (right of access);
- ask BeMyJourney to rectify information you think is inaccurate. You also have the right to ask Be MyJourney to complete information you think is incomplete. This right always applies (right to rectification);
- ask BeMyJourney to erase your personal information in certain circumstances (right to erasure or to be forgotten). There are some exemptions, such as:
- When BeMyJourney is legally obliged to keep hold of your data such as to comply with financial or other regulations.
- When keeping your data is necessary for establishing, exercising or defending legal claims.
Be MyJourney will inform you in case the exemption may apply;
- ask BeMyJourney to restrict the processing of your information in certain circumstances (right to restriction of processing). There are some exemptions, such as:
- you have provided your consent to continue the data processing
- the data is needed for legal claims
- data are used to protect another person’s rights
Be MyJourney will inform you in case the exemption may apply;
- object to processing if BeMyJourney is able to process your information because the process is in its legitimate interests or based on your consent (right to object to processing);
- to ask that BeMyJourney transfers the information you provided from one organisation to another, or give it to you. The right only applies if the processing is based on your consent or under, or in talks about entering into a contract and the processing is automated (right to data portability).
You are not required to pay any charge for exercising your rights. BeMyJourney has one month to respond to your request.
10. How can you lodge a complaint to the UK Commissioner?
You have always the right to lodge a complaint to the UK data protection Commissioner- ICO.
11. Minors
BeMyJourney does not provide services directly to children or proactively collect their personal information. However, the information in the relevant parts of this notice applies to children as well as adults.
12. External links
Where BeMyJourney provides links to websites of other organisations, this privacy policy does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.
13. Update to this Privacy Policy
Be MyJourney reserves the right to periodically amend this Privacy Policy and will publish each new release on the Website.
