PRIVACY POLICY

PRIVACY POLICY

Introduction
Please take the time to read this document carefully as it contains details of the basis on which we will process (collect, use, share, transfer) and store your information. You must show this notice to all parties related to your agreement with Wilderness Patagonia. If you have provided us with information about another person, it is considered that you have their permission to do so.

If you have any questions or need more information, you can send an email to our Compliance Officer at [email protected] or write to our Compliance Officer, Wilderness Patagonia, Dr. Arturo Jauretche 5030, San Carlos de Bariloche, Zip Code 8400 – Argentina.

Use of information
Wilderness Patagonia, can design and execute customized products, programs and services, either on your behalf or together with you, at all times, we treat all personally identifiable information strictly in accordance with the European General Data Protection Regulations ( GDPR) with effect from May 25, 2018.

Data controller and data processor
We will ensure that data is processed lawfully, fairly and openly and transparently, and we will ensure that appropriate security measures are taken against unauthorized or illegal processing or accidental loss, destruction or damage using appropriate technical or organizational measures. (such as restricting access to key people within our organization for certain aspects of your information; and periodically verify the level of security we apply to prevent unauthorized use, accidental loss or misuse of your information).

Providers (providers of accommodation, transportation or ancillary travel services, our Customer Database software provider and similar service providers to us, including third party companies using our services), are governed by and will be deemed to they operate strictly in accordance with the terms of such contracts and nondisclosure agreements.
Importantly, from their perspective, these contracts were established to define how data will be processed between us, including the circumstances in which we act as processors (such as visa applications) or as required by the GDPR. When we act as a controller of your data, in certain circumstances we will determine the purposes and the means to process your data; in particular, this will include data processed by providers to tailor travel services to your specific needs.

Legal bases
When we collect information about you, we may collect personal data that may include a variety of information about a person (for example, their name, residence address, communication and contact details, and other personal information, such as date of birth). When relevant to do so, we may also collect information related to an individual, indirectly by reference to an identifier (for example, an IP address, which is a unique number that identifies your computer, laptop, or similar portable device).
When necessary and appropriate for that, we will also collect more confidential personal information (such as health details, creditworthiness, and other similarly sensitive information). More details on this are provided below.

In certain circumstances (for example, in the course of designing an itinerary as it best suits your needs) we will collect information from a variety of different sources (for example, publicly available sources such as social media and networking sites; databases of third-party data generally available to the wealth advisory sector and industry and commerce in general, including other designated providers in the process of handling aspects of a travel product, such as ship crews, aircraft pilots, or other personnel , may include information about you about past experience within the travel industry.

Data storage
Our goal is to keep all our data in electronic format. Our data is stored on secure devices that, in turn, are stored in a closed and alarmed office. These devices have password protection. The data stored on these devices is done on secure cloud-based platforms where it is reasonable to do so. These platforms are all ISO / IEC 27001 certified. This is recognized as one of the most widely recognized independent international safety standards.

The data within our electronic storage platforms is stored in a partitioned format, ensuring that only employees or other authorized agents who have the right needs can see the required data.
In the event that, for any reason, we store your data in physical format (for example, printed), it will be kept in a secure file within the Wilderness Patagonia office.

The data management policies of the responsible employees govern the strict transportation, use and subsequent destruction of the hard-format document. Details can be found in Annex E – Data Transport Policy of the Wilderness Patagonia Master Security document. This may be available upon request from our Compliance Officer.

Using information about you
We will use information, including confidential information, about individuals and other parties related to our business activities, because it is primarily:
1 – Necessary for a person to use a custom travel product without the provision of personal data (eg preferences);
2 – it is necessary to fulfill a legal obligation (for example, passport details);
it is necessary to protect the vital interests of a data subject or another person; and
3 – necessary for our own legitimate interests or those of other controllers or third parties (for example, to search for credit or anti-money laundering agencies, to control emails, calls and other communications or to carry out market research, analysis and development statistics) , except when such interests are overridden by the interests, rights or freedoms of the data subject.

These bases include, for the design of customized travel opportunities, the provision of budgets, the implementation and management of the execution of any given trip, the hosting of clients, the follow-up and the exchange of future opportunities that are within the scope of a customer’s appetite for traveling.

When processing personal data for profiling purposes, we will ensure that adequate safeguards exist, ensuring:
1 –the processing is fair and transparent and provides meaningful information about the logic involved; as well as the meaning and intended consequences;
2 – use only appropriate procedures for profiling;
3 – Appropriate technical and organizational measures have been implemented to correct inaccuracies and minimize the risk of errors in the recording of profiled data; and,
4 – protect your personal data in proportion to the risk to your interests and rights and avoid discriminatory effects.

We will also use your information when there is a justifiable reason to do so, such as complying with a legal obligation (for example, for the prevention and detection of fraud and financial crime, which may include processes that identify you); and for the recording of all communications by any or all means for audit purposes.

We will share information, including confidential information, about you and other parties related to our products and services because it is:
1 – Necessary for the creation or to take measures to carry out a travel itinerary or other Wilderness Patagonia service; or,
2 – necessary for the fulfillment of a legal obligation; or,
3 – necessary to protect your vital interests; or,
4 – necessary for our own legitimate interests or those of other controllers or third parties; and,
5 – necessary for a task performed in the public interest or for the exercise of official authority (for example, a regulatory body).

This includes sharing your information within Wilderness Patagonia as necessary and carefully selected third parties who provide a service to us or on our behalf, this includes our insurance providers and our banks or other financial services that we use that may require details for fraud Obligations Against money laundering. (You may write to our Compliance Officer at the above details if you would like to see a list of all insurance companies and financial institutions with which we have agreements).

What we will not do with your information.
Unless required by law, or for similar reasons, other than those described (see above: How to share your information), we will never share personal information without good reason and without ensuring that appropriate care and necessary guarantees; in any other case, we will ask for your consent to share that information and explain the reasons.

How long will we keep the information?
We will only maintain and / or maintain information about an individual for as long as is necessary to provide our products and services or to comply with a legal or regulatory obligation.
This means, we will only maintain, the information that is necessary to be able to effectively handle administrative problems, inquiries about past trips, repeated business inquiries, insurance claims and / or compliance with legal or financial audit reasons; In general, we will keep the information for a minimum retention period of 7 years and / or a maximum period of 40 years, after the cessation of a product or service that we have provided.

However, we will keep the information for much shorter periods if such information is simply related to a quote that did not result in a trip; In these circumstances, we will maintain the information for a minimum retention period of 12 months and a maximum period of 7 years, unless such information is manifestly outdated, in which case we may maintain the listing information for shorter periods.

In any case, all the information will be stored in strict compliance with the GDPR legislation at all times; and using the appropriate technical or organizational measures, regularly:
1 – Review the amount of time we keep and / or maintain information about you;
2 – consider the purpose or purposes for which we maintain information about you when deciding whether (and for how long) to retain it;
3 – securely delete information about you that is no longer necessary for this purpose or for these purposes; and,
4 – Update, archive or securely delete your information if it is out of date.

Delicate information
By performing our functions as a data controller and data processor, we may collect confidential information about you and other parties related to our products and services:
1 – Necessary for the creation or to take measures to carry out a travel itinerary or other Wilderness Patagonia service; or necessary for the fulfillment of a legal obligation; necessary to protect your vital interests;
2 – necessary for our own legitimate interests or those of other controllers or third parties;
3 – and, necessary for a task performed in the public interest or for the exercise of official authority (for example, a regulatory body).

What we understand by confidential data includes information such as:
1 – About an individual’s health, including medical conditions;
2 – any criminal conviction; and, racial or ethnic origin or religious beliefs.

We will always apply additional organizational and technical measures for this category of data, including restrictions on accessing this data (this is where data can be protected with additional levels of security to prevent misuse and protect personally identifiable information against use or improper or unjustified dissemination).

Use and storage of your travel information
Due to the regional nature of the trips and our operations, it is probable that the trips made with Wilderness Patagonia are made outside the Argentine Republic (RA). In this circumstance, the transfer, storage or processing of information about you or a person will occur beyond the RA for the reasons indicated above in “Sharing your information”. In any case, if we are forced to transfer your information outside the RA, you must comply with the transfer conditions established in the European GDPR guidelines and restricted to countries that are considered to have adequate data protection laws.

We will always apply additional organizational and technical measures for this category of data, including restrictions on accessing this data (this is where data can be protected with additional levels of security to prevent misuse and protect personally identifiable information against use or improper or unjustified dissemination).

Using our website and cookies
You will be asked to accept a cookie, which is a small file of letters and numbers that is downloaded to your computer when you visit any of the websites of our group of companies. This will be clearly explained to you when you visit the website and you will normally have to accept the cookie to take advantage of the services that the website can offer.

Cookies are operated in strict accordance with the European Regulation on Privacy and Electronic Communications 2011 (PECR) and are widely used by many websites and mainly allow the site to remember a person’s preferences, recording the information that the person may have entered on our web pages.

These same rules also apply if anyone accesses or uses any other type of technology to gain access to information stored electronically by us, including application technology that Wilderness Patagonia can use to facilitate or improve customer experiences.

Individual rights
People have a number of rights related to the information we have. These rights include but are not limited to:
1 – A copy of the personal information we have (upon request, Wilderness Patagonia has up to one calendar month to provide such information to a person);
2 – rectify the information, if it is inaccurate or incomplete;
3 – request the removal or deletion of an individual’s personal data, in part or in whole, when there is no compelling reason for its continued processing;
4 – suppress the processing of an individual’s personal data, when processing is restricted, we are allowed to store personal data, but not carry out additional processes. We will retain enough information about the person to ensure that the restriction is respected in the future (see Marketing);
5 – object to certain uses of an individual’s personal information (see Marketing);
6 – in certain circumstances, not be subject to a decision when based on automated processing; and o produces a legal effect or an equally significant effect on an individual;
7 – withdraw any permission you or a person has previously provided; and,
file a complaint with the corresponding entity at any time if you or a person are not satisfied with our use of such information.

People can request a copy of the personally identifiable information we have when contacting us, including the right to have such information in a portable “right to data portability” format, so normally we will not only provide the information for free (However, we may apply a charge when requests for information are excessive), but we will provide that information in an easily accessible format, including electronic formats, if an individual requires it in that format to ensure that the information can be easily exchanged with other organizations.

If you want more information or want to make a Subject Access Request (SAS), you can send an email to [email protected] or write to our Compliance Officer.

Marketing
1 – When we contact you to promote products, programs and services, as an individual (including, individual merchants and individual companies), we will rely on the permission we have (if we can) or request your permission (consent) to communicate with you, including means to contact you (for example, by phone or email, push notifications, SMS text messages or publications) to inform you about;
2 – New products, programs or services that we have or are developing;
testing products and services that we believe can improve our service for you or our business processes;
3 – offer you rewards;

Generally, we will ask for your permission when you contact us the first time (generally, but not limited to, our websites), however, you will have the right to easily withdraw such consent at any time (unsubscribe). We will regularly review any such consent to verify that your relationship with us and any processing that includes the purposes have not changed.

In all situations in which we market a business, we will observe both market standards and the rules and guidelines of privacy and electronic communication regulations (PECR).

We have implemented such a process to ensure that we renew your consent at appropriate intervals, including parental or third-party (when trusted) consent, and act on withdrawals of consent (unsubscribe) as soon as is possible and we will not penalize you if you do not choose to give and / or then decide to withdraw your consent.

Research and analysis
The personal information we hold may be converted into statistical or aggregated data (for example, this data cannot be traced to an individual) to produce or conduct statistical or analytical research and development work, which should not be shared beyond Wilderness Patagonia. This is done to enable us to optimize our marketing approach and customer experience.

We may continue to use personally identifiable information that we may have, specifically related to a person’s past experiences traveling with Wilderness Patagonia, after travel has been completed, to process the research and analysis as outlined above.