This privacy policy applies to the www.traveltozero.com website (hereinafter the Website).
Please read it carefully. It contains important information about the processing of your personal data and your rights under applicable law.
We reserve the right to update our privacy policy at any time due to business decisions, as well as to comply with possible legislative or jurisprudential changes. If you have any questions or need any clarification regarding our Privacy Policy or your rights, you can contact us through the channels indicated below.
You represent that the information you provide us, now or in the future, is correct and truthful and you agree to inform us of any changes to them. In case of providing personal data of third parties, you undertake to obtain the prior consent of those concerned and to inform them about the content of this policy.
In general, the fields on our forms that are marked as mandatory must be completed in order to process your requests.
Unless specifically indicated otherwise, the data controller is PROA GROUP JPG S.L., (hereinafter JPG) with registered office at Es Ferrers, n.º 1, 07500 Manacor, Balearic Islands, Spain with email: info@proagrup.com.
The data controller is part of the PROA GROUP. You can check below the details of the entities that make up the group:
For any questions regarding the protection of your personal data, please contact the Data Protection Officer of PROA GROUP at rgpd@proagrup.com.
Your data will be processed for the following purposes:
Below, you will find detailed information on each of these purposes.
What data are processed for this purpose and how are they obtained?
The categories of data that JPG will process for these purposes concern the following categories:
These data are obtained either directly from you through the contact form, from the requests you make on our web forms or through our call center, or from third parties who have requested a service on your behalf, e.g. the person who has booked a garage appointment on your behalf.
The processing of this data is necessary for the processing of your request and the execution of the service contract, the provision of the requested services or for the application of pre-contractual measures to your own request.
The data provided in the forms for requesting information or a quote for the purchase of a vehicle are consolidated in PROA GROUP databases for the purposes of management control and analysis of business data and sending commercial communications (+ info in the sections “Consolidation of group customer data”, “Management control and analysis of business data” and “Sending of informative and commercial communications”).
We process navigation data (IP addresses or logs) to administer and manage the security of the website. This processing is based on our legitimate interest in ensuring the security of the website. This interest is expressly recognized by article 49 of the GDPR. In weighing this interest against your rights and freedoms, it has been taken into account that this processing corresponds to general security practices and does not pose significant threats to data subjects.
Calls made to our Call Center and by our agents will be recorded for security and quality management purposes. If you do not want the call to be recorded, you may indicate this to the agent who answers the call.
The recordings will be cancelled within 60 days, except when they have to be kept for a longer period of time in order to manage possible incidents or complaints. The above is without prejudice to their retention for the time necessary to meet possible liabilities arising from the processing or the periods provided for by the applicable legal provisions.
Access to the content of the recordings is restricted to the Call Center managers and to the persons who require such access for the proper handling of your complaint, for example, our legal department or our Data Protection Officer.
The recording of calls is based on our legitimate interest, on the one hand, in being able to prove the content of the conversation held between our customers and agents, especially in relation to the contracting of products or services and the management of their claims or complaints and, on the other hand, to evaluate and manage the quality of our customer service.
In weighing this interest against their rights and freedoms, it was determined that the processing corresponded to the reasonable expectations of our customers as it is a generalized practice, that these recordings could also benefit the data subjects themselves, for example, in the event of a discrepancy regarding their requests or complaints, and that they did not pose a significant threat to their privacy given the possibility of opposing the processing, the limited number of people who can access the recordings and the limited storage time.
In order to evaluate and manage the quality of our services and products, we perform statistics based on aggregated data obtained from the navigation data of our web visitors, e.g. IP address, weblogs, pages visited or actions performed on the Web (+ info in our cookies policy).
These treatments are based on our legitimate interest to evaluate and manage the quality and content of our services.
For the weighing of this interest with respect to their rights and freedoms, it has been determined that the processing had a limited impact on the privacy of data subjects, as it corresponds to reasonable expectations of them and did not pose significant threats to occur on aggregate data and with the consent of the data subjects with respect to the metrics made through the use of cookies.
The identification and contact data provided by the people who have used any form on the web, will be processed for sending non-personalized commercial communications related to products and services offered by JPG and management of your mailing list.
For the management of the distribution list, the recipients of the communications are segmented according to their customer status and language and the type of relationship they have with JPG. This processing consists of a simple classification according to objective criteria and is not intended for commercial profiling, forecasting or behavioral analysis.
This processing is based on the consent you are asked to give. Failure to give your consent or withdrawal of consent does not condition the provision of the services requested.
You may at any time request to unsubscribe from the processing for commercial purposes by activating the link provided for this purpose in our communications or by sending an email to: rgpd@proagrup.com.
The consultation data together with the data generated by the services or products contracted in the companies of PROA GROUP are consolidated in databases owned by PROA GROUP JPG S.L.
What data are consolidated?
The categories of customer data that are consolidated are as follows:
These data are consolidated in PROA GROUP systems located in the European Union.
The purpose of this consolidation is to have a customer register at group level, to standardize the formats and codification of information and to allow centralized management of operational processes common to all companies.
This consolidation is based on the legitimate interest recognized by Article 48 of the GDPR to transfer personal data of customers within a group of companies for internal administrative purposes.
How has this interest been weighed against your rights and freedoms?
For the weighing of this interest against your rights and freedoms, the following has been determined:
The consolidated data are also used for the purpose indicated below:
PROA GROUP processes the information obtained from the group's consolidated customer data to generate reports and analyze business data for business intelligence and management control purposes. These analyses and reports provide results in the form of aggregated data and are used to produce statistics and forecasts to facilitate business decision-making, optimize processes, measure the performance of the products offered by the group and establish business strategies.
These processing operations are based on PROA GROUP's legitimate interest in having a consolidated view of its business for business decision-making and internal group administrative purposes.
How has this interest been weighed against your rights and freedoms?
For the weighing of this interest with respect to your rights and freedoms, the following has been determined:
In general, the data will be kept for the duration of the relationship with JPG and PROA GROUP and in any case for the periods provided for in the applicable legal provisions and for the time necessary to meet any liabilities arising from the processing. Your data will be deleted when they are no longer necessary or relevant for the purposes for which they were collected.
Data processed for commercial purposes will be kept for as long as their deletion is not requested. The media on which the existence of your consent to the processing of your data is recorded, such as electronic form submission logs, will be kept for the duration of the processing and the applicable statute of limitations.
The data processed by PROA GROUP for the purposes of management control and business data analysis are kept without time limit as they are aggregated data.
Your data will only be communicated between PROA GROUP companies in the situations described in the previous sections or to third parties due to legal obligations, with your prior consent or when it is necessary to provide you with the requested services.
You have the right to obtain confirmation of whether or not we are processing your personal data and, if so, to access them. You may also request that your data be corrected if it is inaccurate or that incomplete data be completed, as well as to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may request that we restrict the processing of your data. In such a case, we will only process the data concerned for the formulation, exercise or defense of claims or for the protection of the rights of other persons. Under certain conditions and for reasons relating to your particular situation, you may also object to the processing of your data. In this case, we will stop processing the data except for compelling legitimate reasons that override your interests or rights and freedoms, or for the formulation, exercise or defense of claims.
You may also, under certain conditions, request the portability of your data to be transferred to another data controller.
You may revoke the consent you have given for certain purposes, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.
You may revoke your consent or object to the processing of your data for direct marketing purposes at any time. We will then stop processing your personal information for such purposes. You also have the right to object to automated individual decisions that produce legal effects on you or significantly affect you in a similar way, where this right is conferred in accordance with the provisions of Article 22 of Regulation (EU) 2016/679.
To stop receiving commercial communications from the group, you can use the link provided for this purpose in our communications or send an email to the following email address: rgpd@proagrup.com.
You also have the right to lodge a complaint with a data protection authority. You can consult the list and contact details of the European data protection agencies on the European Commission's website at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
To exercise your rights, you must send us a request by post or e-mail to the addresses indicated in the section Who is the data controller of your data?
You can obtain more information about your rights and how to exercise them on the website of the Spanish Data Protection Agency (https://www.aepd.es).