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Privacy Policy

Please read this policy carefully, you will find important information about the processing of your personal data and the rights recognized by current regulations on the matter.  
In case of providing personal data of third parties, you undertake to obtain the prior consent of those individuals and to inform them about the content of this policy.
The fields of our forms that are indicated as mandatory, must necessarily be completed in order to process your requests.

1. Who is responsible for the processing of your data? 

Unless otherwise specifically indicated, the controller of your personal data is W2M LAPLAND OY (hereinafter "E-NORTH"), with registered office at Rukajärventie 48G, 93830 Rukatunturi, Finlandia. 
E-NORTH is part of the World2Meet Group (W2M Group). For more information about the processing of your data or the exercise of the rights recognized by current regulations on the matter, you can send an email to dataprotection@w2m.com  

2. Processing of your data for and legal basis

We process personal data in the circumstances and for the purposes described below:

Contact persons and legal representatives B2B clients (Travel Agencies, Tour Operators, etc ...).

  • Registration of travelers or users interested in receiving information.
  • Management of reservations and provision of the requested services.
  • Attention to queries and complaints.
  • Group-level data consolidation:
    • Consolidation of personal data at the group level (master data).
    • Sending commercial communications and managing distribution lists.
    • Management control and analysis of business data.

2.1 Registration of travelers or users interested in receiving information

We record the data of users who complete the Contact Form included on the website in order to process their requests for information about the services offered. 
What data do we record and how has it been obtained? 
Personal Data we register consists of:

  • Identification data: name and surname
  • Contact details : email and telephone
  • Travel preference data, e.g.  preferred services or travel dates.

These data are provided directly by the interested parties through the forms indicated for this purpose on the web.
The processing of this data is necessary for the provision of the requested information and future contacts.
This data is consolidated into group-level databases.  + info in the section "Consolidated data at group level" of this policy.

2.2 Management of reservations and provision of the requested services

The data provided in the reservation or service requests will be processed for the management of said reservations and the provision of the requested services. 
What data are processed for this purpose and how have they been obtained? 
The categories of data we process for these purposes are as follows:

  • Identification and contact data of the holder of the reservation.
  • Data of the reservation / request for services (dates, itinerary, services included in the trip, identification data of travelers, as well as, when necessary for the trip, their contact details, personal characteristics data (gender and date of birth / age) and ID / passport (nationality, document number, expiration date and issuing country);
  • Economic and transaction data.

We obtain this data directly from the traveller or from third parties who have processed the request on their behalf, for example, the holder of the booking, the company for which you work in the case of business travel or other travel agencies.
This processing is necessary for the provision of the requested services, the execution of the travel contract or for the application of pre-contractual measures at the request of the interested parties.
The economic data and transactions of goods and services will be processed for the purposes of accounting and administrative management and compliance with our legal obligations in accounting and tax matters.
Bookings and economic and transaction data are consolidated into group-level databases.  + info in the section "Consolidated data at group level" of this policy.

2.3 Attention to queries and complaints

The data provided in the queries or claims you send us will be processed to meet your requests and manage any complaints. This processing is necessary for the execution of a contract or the application of pre-contractual measures at the request of the interested parties. The processing of any health data that you have provided in your claim is covered by art. 9.2. f) of the RGPD, as such processing is necessary for the formulation, exercise or defense of claims.

2.4 Group-level data consolidation

People data, economic data, reservations and, in general, transaction data  for goods and services generated by the businesses developed by the companies of the W2M group are consolidated into centralized databases at the group level. The companies of the group are jointly responsible for this consolidation, according to the distribution of responsibility indicated below and in the following sections:

  • The head of the Group is the company WORLD 2 MEET GLOBAL SERVICES, S.L.U., with address at Calle General Riera 154, 07010 Palma (Illes Balears), Spain (hereinafter W2M), is responsible for the administration and security of the consolidated databases.
  • Each of the companies in the group is responsible for the data communications it makes to W2M for consolidation.  The following is the list of companies that are part of the W2 M group:
    • WORLD 2 MEET, S.L.U.
    • WORLD 2 MEET TRAVEL, S.L.U.
    • FLOWO TRAVEL, S.L.U.
    • WORLD 2 FLY, S.L.U.
    • WORLD 2 MEET GLOBAL SERVICES, S.L.U.
    • W2M CORPORATE, S.L.U.

The group companies have concluded a contract regulating data processing to ensure an adequate level of protection of personal data.  This privacy policy reflects the essential aspects of this agreement with respect to the respective functions and relationships of the group companies in relation to You.  You can request more information about this contract by sending an email to dataprotection@w2m.com.

What data is consolidated and for what purposes?
CONSOLIDATION OF PEOPLE DATA AT THE GROUP LEVEL (MASTER DATA)The data of all persons who interact with the companiesof the group are consolidated, for example, contact persons or legal representatives, travel agents, workers, private customers or travelers, and this, both in the framework of professional relationsis (business to business relations or "b2b"), as consumer (business to consumer or "b2c" relationships).
The categories of data that are included in the master of people consist of: identification data, identity document (type and number), personal contact data (b2c relationships) and / or professional (b2b relationships), personal characteristics data (gender and language), company (b2b relationships).
The purpose of this consolidation is to uniquely identify people who maintain a relationship with the group, standardize the formats and coding of their information and keep this data updated.  W2M is responsible this processing.

  • This unified database is synchronized with the systems of the companies of the group in which it is necessary to identifythe ein order to carry out the processing of personal data raised by the relationships that you.  maintains with these companies. Only the companies of the group with which it maintains a relationship will access the data included in the master of persons and only when there is a valid legal basis according to the purpose or purposes indicated in the privacy policy applicable to this processing. Each of the group companies is responsible for its specific use of this information.  The following is the list of companies that are part of the W2 M group:
    • WORLD 2 MEET, S.L.U.
    • WORLD 2 MEET TRAVEL, S.L.U.
    • FLOWO TRAVEL, S.L.U.
    • WORLD 2 FLY, S.L.U.
    • WORLD 2 MEET GLOBAL SERVICES, S.L.U.
    • W2M CORPORATE, S.L.U.

This consolidation is based on the legitimate interest of the group in having a unified person registry to optimize the operational processes common to the group companies in which it is necessary to identify a person, for example, for payments or billing of services or for integration with reservation systems. 
How has this interest been evaluated against their rights and freedoms? 
For the evaluation of this interest with respect to their rights and freedoms, the following has been determined: The synchronization of the identification data between the corporate systems guarantees compliance with the principle of accuracy of the data, which also benefits the interested parties. The impact on the privacy of the interested parties is limited, as technical and organizational measures have been adopted so that synchronization only occurs when there is a current relationship that requires the identification of the interested party and since there is a separation of functions between the people in charge of the administration of the master of people and, in general, of the systems of the group, of persons who are users of such systems.


SENDING COMMERCIAL COMMUNICATIONS AND MANAGING DISTRIBUTION LISTSIf you have consented to the receipt of commercial communications, your identification and contact data will be received by W2M. W2M will process this data as responsible for the processing to send you communications related to activities, products and tourist services of the group. To manage the distribution lists of the group, W2M performs a segmentation of the recipients of its communications based on the origin of the data, market and language. This processing consists of a simple classification according to objective criteria and is not intended to carry out commercial profiles, predictions or behavioral analysis. 
This processing is based on the consent that is requested. Not giving your consent or withdrawing it does not condition the execution of the reservation or the provision of the contracted services. 
At any time you can request your withdrawal from the processing for commercial purposes by activating the link provided for this purpose in our communications or by sending an email indicating "unsubscribe" in the subject to: dataprotection@w2m.com.


MANAGEMENT CONTROL AND ANALYSIS OF BUSINESS DATAW2M and the group companies will process the economic and transaction data of goods and services obtained from the consolidated customer and reserve data to generate reports and analyze business data for business intelligence and management control purposes. These analyses and reports offer results in the form of aggregated data and serve to elaborate statistics and forecasts to facilitate business decision making and optimize processes, measure the performance of tourism products offered by the group and establish business strategies.
This processing is based on the legitimate interest of the group in having a consolidated vision of its business for business decision-making and internal administrative purposes. 
How has this interest been evaluated against their rights and freedoms? 
In order to evaluate this interest against their rights and freedoms, the following has been determined:

  • Recital 48 of the GDPR recognises the legitimate interest in transmitting personal data of customers within a business group for internal administrative purposes.
  • The processing is compatible with the reasonable expectations of the interested parties, as they are customers of group companies or travelers included in the reservations processed by them and the processing takes place within the framework of current relations maintained with said group.
  • Technical and organisational measures have been adopted to limit the impact of the processing on the privacy of data subjects, in particular to make it impossible for the users generating the reports and analyses to identify individuals. These measures include the separation of the systems used for management control/business intelligence purposes from the rest of the operating systems, especially the system used to enhance commercial campaigns, as well as the separation of functions between the people who are users of the Business Intelligence tools and the people in charge of the administration of the group's systems.

3.  To whom can we communicate your data?

Your data will only be communicated between the companies of the W2M group in the situations described in this policy, or to third parties due to legal obligations, with your prior consent or when it is necessary to provide you with the requested services. 
The company that employs you will have access to all corporate travel reservations that affect its workers, although you will never be informed of data regarding the reservations that these workers request in a private capacity. Reservations include the following information: dates, itinerary, services included in the trip, price and the identification data of the travelers included in them.

4. How long will we keep your data?

In general, we will keep your data for the duration of the relationship you have with us and in any case for the periods provided for in the applicable legal provisions, for example, in accounting and tax matters, and for the time necessary to meet possible responsibilities arising from the processing. We will cancel your data when they are no longer necessary or relevant for the purposes for which they were collected. 
The traveller profiles will be kept for the duration of the contractual relationship with the company that employs you.
The data processed by W2M to send commercial communications and manage its distribution lists will remain active as long as you do not request its deletion. 
The data included in the master of people of the W2M group will be kept as long as it maintains a relationship with the group and in any case during the periods provided for in the applicable legal provisions and the time necessary to attend to possible responsibilities arising from the processing.

5. What are your rights?

You have the right to obtain confirmation of whether or not we are processing your personal data and, if so, access it. You can also request that your data be rectified when they are inaccurate or that the data that is incomplete be completed, as well as request its deletion when, among other reasons, the data is no longer necessary for the purposes for which they were collected. 
In certain circumstances, you may request the limitation of the processing of your data. In such a case, we will only process the data concerned for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions and for reasons related 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 prevail over your interests or rights and freedoms, or for the formulation, exercise or defense of claims. Likewise, and under certain conditions, you can request the portability of your data so that they can be transmitted to another person responsible for the processing.
You can revoke the consent you have given for certain purposes, without affecting the legality of the processing based on the consent prior to its withdrawal.
At any time you can request your withdrawal from the processing for commercial purposes by activating the link provided for this purpose in our communications or by sending an email indicating "unsubscribe" in the subject to: dataprotection@w2m.com.

You also have the right to lodge a complaint with a data protection authority. You can consult the list and contact details of European data protection agencies on the European Commission's website in http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You can exercise your data protection rights by request by post or email sent to the headquarters ofthe group at Calle General Riera 154, 07010 Palma (Balearic Islands), Spain or dataprotection@w2m.com
You can obtain more information about your rights and how to exercise them on the page of the Spanish Agency for Data Protection in www.aepd.es or on the page of the data protection authority of your country.