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Privacy Policy

I. PRIVACY POLICY AND DATA PROTECTION

Respecting what is established in current legislation, They Travelling (https://theytravelling.com/) commits to adopting the necessary technical and organizational measures, according to the appropriate security level corresponding to the risk of the collected data.

Laws incorporated in this privacy policy

This privacy policy is adapted to the current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following rules:

  • The Regulation (EU) 2016/679 of the European Parliament and of the Council, dated April 27, 2016, regarding the protection of individuals with regards to the processing of personal data and the free movement of such data (GDPR).
  • Organic Law 3/2018, dated December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
  • Royal Decree 1720/2007, dated December 21, 2007, which approves the Regulation for the development of Organic Law 15/1999, dated December 13, on the Protection of Personal Data (RDLOPD).
  • Law 34/2002, dated July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the person in charge of processing personal data

Contact email: contact@theytravelling.com

Personal Data Registry

In accordance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by They Travelling through the forms on its pages will be incorporated and processed in our file in order to facilitate, expedite, and fulfill the commitments established between They Travelling and the User, or to maintain the relationship established in the forms that the User fills out, or to address a request or inquiry from the User. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided in Article 30.5 of the GDPR applies, a record of processing activities is maintained that specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data will be subject to the following principles as outlined in Article 5 of the GDPR and in Article 4 and subsequent articles of Organic Law 3/2018, dated December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

  • Principle of lawfulness, fairness, and transparency: The User’s consent will be required at all times, preceded by completely transparent information regarding the purposes for which personal data is being collected.
  • Principle of purpose limitation: Personal data will be collected for specific, explicit, and legitimate purposes.
  • Principle of data minimization: The collected personal data will be only those strictly necessary in relation to the purposes for which they are processed.
  • Principle of accuracy: Personal data must be accurate and kept up to date at all times.
  • Principle of storage limitation: Personal data will only be kept in a form that allows the identification of the User for the time necessary for the purposes of their processing.
  • Principle of integrity and confidentiality: Personal data will be processed in a manner that ensures their security and confidentiality.
  • Principle of proactive accountability: The Data Controller will be responsible for ensuring that the aforementioned principles are upheld.

Categories of personal data

The categories of data processed by They Travelling are solely identifiable data. Under no circumstances are special categories of personal data processed in the sense of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. They Travelling commits to obtaining the explicit and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User will have the right to withdraw their consent at any time. Withdrawing consent will be as easy as giving it. As a general rule, the withdrawal of consent will not affect the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the proper development of the operation carried out.

Purposes of the processing to which personal data are intended

Personal data is collected and managed by They Travelling with the purpose of facilitating, expediting, and fulfilling the commitments established between the Website and the User, or for maintaining the relationship established in the forms filled out by the latter, or for addressing a request or inquiry.

Similarly, the data may be used for commercial purposes of personalization, operations, statistics, and activities related to the corporate purpose of They Travelling, as well as for data extraction, storage, and marketing studies to tailor the Content offered to the User, as well as to improve the quality, functioning, and navigation of the Website.

At the moment personal data is obtained, the User will be informed about the specific purpose or purposes of the processing to which the personal data will be intended; in other words, the use or uses that will be given to the collected information.

Retention periods of personal data

Personal data will only be retained for the minimum time necessary for the purposes of its processing and, in any case, only for the following period: 20 years, or until the User requests its deletion.

At the time when personal data is obtained, the User will be informed about the period during which the personal data will be retained or, when that is not possible, the criteria used to determine this period.

Recipients of personal data


The User’s personal data will be shared with the following recipients or categories of recipients:

If the Data Controller intends to transfer personal data to a third country or international organization, at the time when personal data is obtained, the User will be informed about the third country or international organization to which the data is intended to be transferred, as well as the existence or absence of an adequacy decision by the Commission.

Personal data of minors

Respecting what is established in Article 8 of the GDPR and Article 7 of Organic Law 3/2018, dated December 5, on the Protection of Personal Data and Guarantee of Digital Rights, only individuals over 14 years of age can lawfully provide consent for the processing of their personal data by They Travelling. If the individual is under 14 years of age, the consent of their parents or guardians will be required for the processing, and it will only be considered lawful to the extent that they have authorized it.

Secrecy and security of personal data

They Travelling commits to adopting the necessary technical and organizational measures, according to the appropriate security level corresponding to the risk of the collected data, in order to ensure the security of personal data and prevent the accidental or unlawful destruction, loss, alteration, unauthorized access, or disclosure of transmitted, stored, or otherwise processed personal data.

The Website has an SSL certificate (Secure Socket Layer), which ensures that personal data is transmitted securely and confidentially. The data transmission between the server and the User, and vice versa, is fully encrypted.

However, as They Travelling cannot guarantee the invulnerability of the internet or the complete absence of hackers or others who may fraudulently access personal data, the Data Controller commits to promptly informing the User when a security breach involving personal data occurs and is likely to result in a high risk to the rights and freedoms of individuals. According to Article 4 of the GDPR, a personal data breach is understood as a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to transmitted, stored, or otherwise processed personal data.

Personal data will be treated as confidential by the Data Controller, who commits to informing and ensuring through a legal or contractual obligation that this confidentiality is respected by its employees, associates, and all those who may have access to the information.

Rights arising from the processing of personal data

The User has over They Travelling and may therefore exercise against the Data Controller the following rights recognized in the GDPR and Organic Law 3/2018, dated December 5, on the Protection of Personal Data and Guarantee of Digital Rights:

  • Right of access: This is the User’s right to obtain confirmation from They Travelling regarding whether their personal data is being processed or not. If so, the User has the right to obtain information about their specific personal data and the processing activities conducted or being conducted by They Travelling. This includes, among other things, information about the origin of such data and the recipients of any communications made or planned with these data.
  • Right of rectification: This is the User’s right to have their personal data corrected if it is found to be inaccurate or incomplete, considering the purposes of the processing.
  • Right to erasure (“right to be forgotten”): This is the User’s right, as long as current legislation does not dictate otherwise, to obtain the deletion of their personal data when the data is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there are no overriding legitimate grounds for the processing; the personal data has been processed unlawfully; the personal data must be erased to comply with a legal obligation; or the personal data has been obtained from offering information society services directly to a child under 14 years of age. In addition to erasing the data, the Data Controller, considering available technology and the cost of implementation, must take reasonable measures to inform other controllers processing the personal data of the User’s request to delete any links to or copies or replications of that data.
  • Right to restriction of processing: This is the User’s right to restrict the processing of their personal data. The User has the right to obtain the restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to establish, exercise, or defend legal claims; and when the User has objected to the processing.
  • Right to data portability: If the processing is carried out by automated means, the User has the right to receive their personal data from the Data Controller in a structured, commonly used, and machine-readable format, and to transmit those data to another Data Controller. Where technically feasible, the Data Controller will transmit the data directly to the other Data Controller.
  • Right to object: This is the User’s right to prevent the processing of their personal data or to stop the processing by They Travelling.
  • Right not to be subject to a decision based solely on automated processing, including profiling: This is the User’s right not to be subject to an individualized decision based solely on automated processing of their personal data, including profiling, except where current legislation dictates otherwise.

Therefore, the User may exercise their rights by submitting a written communication to the Data Controller with the reference “GDPR-https://theytravelling.com/“, specifying:

  • First and last name of the User, and a copy of their ID card (DNI). In cases where representation is allowed, the identification of the person representing the User will also be required through the same means, along with the relevant document proving the representation. The photocopy of the ID card may be substituted by any other legally valid means of identity verification.
  • A request stating the specific reasons for the request or the information the User wishes to access.
  • Mailing address for notifications.
  • Date and signature of the requester.
  • Any document that substantiates the request being made.

This request and any other attached document can be sent to the following email address:

Email address: contact@theytravelling.com

Links to third-party websites

The Website may include hyperlinks or links that provide access to third-party websites different from They Travelling, and therefore not operated by They Travelling. The owners of these websites will have their own data protection policies, and they will be responsible for their own files and privacy practices in each case.

Complaints to the supervisory authority

If the User believes that there is a problem or violation of the current regulations in the way their personal data is being processed, they have the right to an effective judicial remedy and to lodge a complaint with a supervisory authority, particularly in the State where they have their habitual residence, place of work, or the place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (http://www.agpd.es).

II. Acceptance and Changes in this Privacy Policy


It is necessary for the User to have read and agree with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller can proceed with it in the manner, within the timeframes, and for the purposes indicated. The use of the Website implies the acceptance of its Privacy Policy.

They Travelling reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by legislative, jurisprudential, or doctrinal changes by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. It is recommended that the User periodically check this page to stay informed about the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council, dated April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data (GDPR), and Organic Law 3/2018, dated December 5, on the Protection of Personal Data and Guarantee of Digital Rights.