General Data Protection Regulation

1) What is personal data and what category of data do we handle?

2) Who is responsible for the treatment of your personal data?

3) On what basis can we handle your personal data?

4) For what purposes and for how long do we treat your personal data?

5) How do we collect your personal data?

6) Data Analysis

1 - What is personal data and what category of data do we handle?

What is personal data? Personal Data is any information of any nature whatsoever on any medium (eg sound or image) relating to an identified or identifiable natural person. Identifiable is any person who can be identified directly or indirectly by, for example, the name, identification number, location data, electronic identifier or other elements that allow the identification of that individual.

Who are the holders of personal data? The Customer or User, an individual, to whom the data pertains and who has taken advantage of Zen Travel Spot's services or products. The Customer will be the person who concludes the contract with Zen Travel Spot or one of the Baguá Therapies Group companies and the User is the person who uses the services or products of Zen Travel Spot or the Baguá Therapies Group companies, but may not correspond to the Customer. For example:

  • In the corporate segment, the contract with Zen Travel Spot is in the company's name but the Users are the customers or employees of this company;
  • In the particular segment, a Customer may purchase various products and services.

In this respect Zen Travel Spot informs that it also protects personal data and respects the rights of customers and users.

What categories of personal data do we handle? The data categories we deal with are as follows:

  • Base data
  • Examples
  • Identification and contacts and
  • Other identifying data
  • Tax or civil identification numbers, payment details, billing address, telephone contact and email address; date of birth, gender, occupation and IP (if you registered on the internet)
  • Service
  • Products and services purchased or subscribed

2 - Who is responsible for the treatment of your personal data?

The person responsible for collecting and processing your personal data will be the Zen Travel Spot company that provides the service or product to you and decides which data is collected, the means of processing and the purposes for which the data is used.

3 - On what basis can we treat your personal data?

These are the circumstances in which we handle your personal data:

Consent When you have your express consent - in writing, orally or through the validation of an option - and prior and if that consent is free, informed, specific and unambiguous. Examples are your consent for Zen Travel Spot to analyze the use of services and products and make recommendations or send marketing messages to use your Baguá Therapies marketing message identification or usage data, the your consent so that we may use service information to improve our quality of service;

or

Contract performance and pre-contractual steps When the processing of personal data is necessary for the conclusion, execution and management of the contract concluded with Zen Travel Spot, such as the preparation of a proposal for products and / or services for the management of contacts, information and requests, to billing, collection and payment management;

or

Compliance with legal obligation When the processing of personal data is necessary to fulfill a legal obligation to which Zen Travel Spot is subject, such as the communication of identifying data to law enforcement, judicial, tax or regulatory entities;

or

Legitimate interest When the processing of personal data is in the legitimate interest of Zen Travel Spot or third parties, such as data processing for, quality of service improvement, fraud detection and revenue protection, and when our reasons for your use should prevail over your data protection rights.

4 - For what purposes and for how long do we treat your personal data?

Your personal data will be processed by Zen Travel Spot only for the period of time necessary to achieve the stated purpose or, as applicable, until you exercise your right of objection, right to be forgotten or withdraw consent. Once the retention period has elapsed, Zen Travel Spot will delete or anonymize data where it should not be retained for any other purpose than may remain.

For what purposes we treat your Personal Data?

Purposes

Purpose Examples (not exhaustive)

Marketing and Sales

  • Marketing or selling new products or services.
  • Analysis of consumption profiles
  • Adaptation and development of new products or services.

Customer Management and Service Delivery

  • Contact, information or order management
  • Complaint management;
  • Billing, collection and payment management

Accounting, Fiscal and Administrative Management

  • Accounting, Invoicing
  • Tax information, including sending information to the tax authority

Litigation Management

  • Judicial and extrajudicial collection
  • Management of other conflicts

Fraud Detection, Revenue Protection, and Auditing

  • Fraud detection and illicit practices
  • Protection and Revenue Control
  • Credit Risk Management
  • Internal Audit and Investigation

Network and Systems Management

Support and improvement of networks and applications that support the service

Service monitoring, improvement and support

Fulfillment of legal obligations

  • Call location for emergency services
  • Court claims
  • Investigation, detection and prosecution of serious crimes
  • Response to judicial, regulatory and supervisory entities

Information Security Control

  • Access management, logs
  • Backup Management
  • Security Incident Management

What are the deadlines for processing and retaining personal data?

Zen Travel Spot treats and retains your personal data according to the purposes for which it is processed.

There are cases where the law requires the processing and retention of data for a minimum period of time, eg 10 years the data required for reporting to the Tax Authority for accounting or tax purposes.

But where there is no specific legal obligation then the data will be processed only for the period necessary to fulfill the purposes that motivated its collection and preservation and always in accordance with the law, guidelines and decisions of the CNPD.

Thus Zen Travel Spot will treat and maintain your personal data for as long as you have a contractual relationship with you.

Zen Travel Spot may maintain other personal data for periods longer than the duration of the contractual relationship, either based on your consent, to secure rights or obligations related to the contract, or because you have legitimate interests that underlie it, but always for the duration of your contract. strictly necessary to achieve their purposes and in accordance with the guidelines and decisions of the CNPD.

Examples are contact for marketing and sales purposes, preservation of data in the context of invoice claim processes, exercise of warranty rights or offers that are of interest to the customer or prospectus.

5 - How do we collect your personal data?

We collect personal data upon your consent when you purchase Zen Travel Spot products or services, when you download or use Zen Travel Spot ebooks, quizzes, session offerings, products, services and applications or when you participate in market research. Collection can be done orally, in writing or through the Zen Travel Spot website. But your personal information may also be collected from publicly accessible sources or other sources.

How is your personal data collected indirectly? To better understand this indirect collection, we recommend the following cases:

Other relevant credit risk or identification and contact information for charge management, fraud detection and revenue protection. Zen Travel Spot may collect personal data from private entities that maintain relevant credit information from the holders of personal data, provided that such databases comply with applicable data protection rules. Zen Travel Spot may also access, collect or confirm personal data on Public Administration and private entity websites, in particular to confirm the accuracy of your identification and contact details.

6 - Data Analysis

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This privacy statement has been transcribed and prepared based on provisions of multiple laws, including art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

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