PRIVACY AND DATA PROTECTION POLICY (GDPR)

At MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.), we believe in the importance of guaranteeing the security and identity of our customers and users, as well as the correct processing of the data they provide us with for the performance of our functions as managers and organisers of tourist and leisure tours. As a result of the application of European personal data protection regulations – Regulation (EU) 2016/679 – and Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights, we provide you with everything you need to understand it. In addition, we have put in place security measures to ensure compliance based on the type of data we use and its correct processing through risk analysis techniques.

Among others, the legislative framework to which we refer is as follows:
• Organic Law on Personal Data Protection and Guarantee of Digital Rights 3/2018 – LOPDGDD
• European Regulation (EU) 679/2016 – GDPR
• Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce

In accordance with the principle of layered information set out in the regulation, we provide you with the most relevant information that may be of interest to you:

Who is responsible for your data?
• Company name: MNPQ GESTORES TURÍSTICOS, S.L.
• Tax ID number: B/19.650.613
• Address: Paseo de la Sabica, 32 – C.P. 18.009 Granada, Province of Granada, Spain.
• Trademark: MY TOP TOUR
• Contact email: soporte@mytoptour.es
• Contact telephone number: +34 858 809 002

What will we use your data for?
At MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.), we use your data for the proper execution of the tourist services offered by our website. The processing of your data as a customer for the purposes described above is carried out in accordance with the applicable legal bases and, in particular, where applicable, on the basis of the consent of the data subject, which is given by providing the requested data, filling in and accepting this legal notice during the registration process in any of our areas, through the contact form on this website or during the online purchase and booking process.

Under no circumstances will individualised automated actions and/or profiling be carried out that produce legal effects or significantly affect you in a similar way, except for those specific to the selection processes for the job offers in which you register. The personal data provided will be kept for the duration of the binding contractual relationship or until you request its deletion, provided that it is adequate, relevant and limited to what is necessary for the purposes for which it is processed. The customer/user is solely responsible for filling in the forms with false, inaccurate, incomplete or outdated information.

LEGAL BASIS FOR PROCESSING

The processing of personal data is carried out in accordance with the provisions of Article 6 of Regulation (EU) 2016/679 (GDPR), depending on the specific purpose of the processing:

Execution of a contract (Art. 6.1.b GDPR) Processing necessary to manage reservations made by the user, process payments, issue tickets or access vouchers, provide the contracted tourist services, and provide customer support.

Compliance with legal obligations (Art. 6.1.c GDPR) Processing necessary to comply with legal obligations applicable to the company, including tax, accounting, and administrative obligations.

Consent of the data subject (Art. 6.1.a GDPR) Processing based on the user’s consent for managing contact forms, sending commercial communications, the use of non-essential cookies, and the personalization of content or advertising when authorized by the user.

Legitimate interest (Art. 6.1.f GDPR) Processing necessary to ensure website security, prevent fraud, analyze service usage in an aggregated manner, and improve the quality and functioning of the platform, provided that such interests do not override the rights and freedoms of the data subject.

The user may withdraw their consent at any time without affecting the lawfulness of the processing based on consent prior to its withdrawal.

Where do we obtain your data?
The data we use and process has been provided by customers knowingly and with their express consent when completing the initial data collection forms. We have Processing Activity Records in accordance with the obligations described in the European Regulation, which define the types of data we hold and how we process it.

The categories of personal data that may be processed include:
• Identifying data: name, surname, nationality, identity card or passport.
• Contact details: email address, telephone number.
• Booking and transaction data: services contracted, dates, times, amount, payment method (without access to full card details).
• Browsing data: IP address, cookie identifiers, information about website use.
• Marketing data: preferences, interaction with advertising campaigns.
• Images and audiovisual recordings, where applicable, for promotional purposes and always in accordance with current regulations.
No special categories of personal data are processed (Art. 9 GDPR).Who will we share your data with?

Personal data may be disclosed to third parties when necessary for the provision of the service or the operation of the website. Typical recipients include:

• Stripe Payments Europe Ltd.:secure payment management and processing.
• Google LLC (Google Analytics y Google Ads):web analytics, traffic measurement, and digital advertising.

• Microsoft Corporation (Microsoft/Bing Ads):online advertising and campaign measurement.

• Meta Platforms Inc. (Facebook/Instagram):personalized advertising and remarketing.
• TikTok Technology Ltd.:advertising and campaign measurement.
• Regiondo GmbH: Reservation management platforms and tourism providers necessary to execute the contracted service.

These third parties act as data processors or independent controllers, as appropriate, and are subject to contracts and data protection obligations.

INTERNATIONAL DATA TRANSFERS

Some of the technology and advertising providers mentioned in this privacy policy, such as Google, Meta, Microsoft, or TikTok, may be located outside the European Economic Area, mainly in the United States.

In these cases, personal data may be transferred internationally to allow the operation of analytics services, digital advertising, payment management, or technological tools used by MY TOP TOUR.

These transfers are carried out with appropriate safeguards, such as the use of standard contractual clauses approved by the European Commission or adherence to the EU-U.S. Data Privacy Framework, where applicable.

To ensure an adequate level of protection of personal data, MY TOP TOUR applies the following safeguards:

•  Signing of Standard Contractual Clauses (SCC) approved by the European Commission.

•  International transfer impact assessments (ITA).

•  Technical security measures such as encryption, pseudonymization and access control.

•  Adherence of certain providers to the EU-U.S. Data Privacy Framework where applicable.

What are your rights and how can you exercise them?

Any customer/user has the right to obtain confirmation as to whether or not MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.) is processing personal data concerning them. Furthermore, as provided for in the General Data Protection Regulation (GDPR), we inform you that you have the following rights:

●       Access your data

As a customer/user, you have the right to access your data to find out what personal data we are processing that concerns you.

●       Request the rectification or deletion of your data

In certain circumstances, as a customer/user you have the right to rectify any inaccurate personal data concerning you that is processed by us or even to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

●       Request the limitation of the processing of your data

In certain circumstances, as a customer/user you will have the right to request us to limit the processing of your data, in which case we inform you that we will only keep them for the exercise or defense of claims as provided for in the General Data Protection Regulation.

●       To the portability of your data

In certain circumstances, as a customer/user, you will have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit it to another data controller.

●       Object to the processing of your data

In certain circumstances and for reasons related to your particular situation, as a client/user you have the right to object to the processing of your data. In such cases, we would cease processing your data unless there are compelling legitimate grounds for doing so, or for the establishment, exercise, or defense of legal claims. You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. However, if you withdraw your consent, certain services or functionalities that depend on it may not be available.

Where should you go to exercise your rights?

To exercise the recognized rights, the interested party may contact us through 2 main channels:

●       Through the email address of My Top Tour (MNPQ Gestores Turisticos, S.L.), which is legal@mytoptour.es

●       Addressing a letter to My Top Tour (MNPQ Gestores Turisticos, S.L.) located at Paseo de la Sabica, 32 18009 Granada

We will respond to your requests as soon as possible and, in any case, within the time limits required by current legislation.

Privacy rights for residents of the United States (CCPA/CPRA)

If you reside in California or other U.S. states with applicable privacy laws, you may have additional rights regarding your personal data, including:

•  Right to knowwhat personal data we collect, use, share or disclose.

•  Right of accessto the stored information.

•  Right of rectificationof inaccurate data.

•  Right to erasure or deletionof your personal data.

•  Right to limit useof sensitive information, where applicable.

• Right not to sellnor share your personal data for advertising purposes (“Do Not Sell or Share My Personal Information”).

•  Right not to suffer discrimination for exercising their rights.

You can exercise these rights by sending a request to: support@mytoptour.es

You can also manage your cookie preferences and object to the sale or sharing of data via the specific link available on our website.

How long do we keep your data?

Personal data will be kept for the time necessary to provide the tourist services and manage the reservations made by the user. Once the contractual relationship has ended, the data may be kept for the periods required by applicable legislation to comply with tax, accounting, and administrative obligations.

As a guideline, the applicable conservation periods are as follows:

• Data related to reservations and tourist services: for the duration of the service and subsequently for the time necessary to manage incidents or claims.

• Client and billing data: 6 years in accordance with the Commercial Code.

• Tax data: 4 years in accordance with the General Tax Law.

• Data used for commercial communications or marketing: until the user withdraws their consent.

• Cookies and browsing data: for the time indicated in the corresponding cookie policy.

The reproduction, transformation, distribution, public communication, making available to the public, and, in general, any other form of exploitation, whether partial or total, of the elements referred to in the preceding section are prohibited. These acts of exploitation may only be carried out by virtue of express authorization, which, in any case, must explicitly reference the ownership of the aforementioned intellectual property rights of My Top Tour (MNPQ Gestores Turisticos, S.L.).

Regarding references to third-party products and services, the company acknowledges the corresponding industrial and intellectual property rights of their owners, and their mere mention or appearance on the website does not imply the existence of any rights or responsibilities on the part of the company. My Top Tour (MNPQ Gestores Turisticos, S.L.) about them, nor endorsement, sponsorship or recommendation unless expressly stated.

This website contains materials prepared by My Top Tour (MNPQ Gestores Turisticos, S.L.) for informational or guidance purposes, and may be modified, developed or updated without prior notice.

My Top Tour (MNPQ Gestores Turisticos, S.L.) We are not responsible for any errors, variations, or omissions that may be found, nor for the use made of these documents. We recommend consulting official bulletins or gazettes, as well as the original sources of information.

The links contained on this website may lead the user to other third-party websites and pages about which My Top Tour (MNPQ Gestores Turisticos, S.L.). It does not exercise any type of control nor is it responsible for the content and condition of the linked websites.

My Top Tour (MNPQ Gestores Turisticos, S.L.) It does not guarantee the absence of viruses or other harmful elements that could cause damage or alterations to the computer system, and therefore is not liable for any damages that these elements may cause to the user or third parties. All third-party links to the Website must be to its homepage; deep linking, framing, and any other use of the Website’s content for the benefit of unauthorized third parties are expressly prohibited.

The interested party also has the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you believe that the processing of your data does not comply with current regulations.

Data Sharing with Partner Companies

In order to guarantee the proper provision of the contracted services, we inform you that your personal data may be shared with collaborating companies and/or business partners of My Top Tour (MNPQ Gestores Turisticos, S.L.), when necessary to carry out the execution of the requested service.

These companies will only use your data for purposes related to the provision of the service and will be subject to the same confidentiality and data protection obligations set out in this privacy policy, in accordance with applicable data protection regulations.

Under no circumstances will your personal data be shared for purposes other than those mentioned, unless your explicit consent is obtained or there is a legal obligation.

You can exercise your rights of access, rectification, erasure, restriction, objection and portability of your data at any time by writing to soporte@mytoptour.es

DATA PROCESSING ON SOCIAL MEDIA AND AUTHORISATION FOR THE USE OF IMAGES AND CONTENT

MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.) has corporate profiles on social media (Instagram, TikTok, etc.) and is responsible for processing the personal data of those who interact with these profiles, always for informational and promotional purposes. The customer expressly authorises MY TOP TOUR, as well as authorised third-party collaborators, to capture and use images and audiovisual recordings in which they may appear during the course of the contracted activities (tours, excursions, guided visits, etc.). Such content may be used without financial compensation, without time or territorial limits, and disseminated through social media, websites, newsletters and other proprietary channels for promotional purposes only.

In addition, MY TOP TOUR may share content (photos, videos, reviews, social media posts) generated and published by customers themselves on public channels, always in compliance with current legislation, image rights and copyright. Such content will not be used for paid advertising or commercial campaigns outside its own channels without the additional consent of the author. Customers may request not to appear in images or videos captured directly during the activities by notifying the guide in advance or by emailing soporte@mytoptour.es. The processing of personal data, images and content by will be carried out in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), respecting privacy and the right to one’s own image at all times. The interested party may revoke their consent for the use of their image for promotional purposes at any time, without retroactive effect, by writing to soporte@mytoptour.es.

Interest-based advertising and opt-out
We use third-party advertising services, such as Microsoft Advertising, to display ads based on your previous visits to our website. Microsoft uses cookies and similar technologies to collect information about your activity on this site and other sites in order to offer you interest-based advertising. You can object to the collection and use of your information for interest-based advertising through the following official mechanisms:

• Microsoft ad settings: You can turn off personalised ads by visiting the Microsoft Privacy Settings page.

• Industry opt-out platforms: You can use the opt-out tools of the Digital Advertising Alliance or Your Online Choices.

• Browser control: You can also set your browser to refuse all cookies or to indicate when a cookie is being sent.

Intellectual Property and Content
The intellectual property rights of the website, its source code, design, navigation structure, databases and the various elements contained therein (images, files, logos and any other element subject to protection) are owned by MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.), which has the exclusive right to exploit them in any form and, in particular, the rights of reproduction, distribution, public communication and transformation.

The reproduction, transformation, distribution, public communication, making available to the public and, in general, any other form of exploitation, partial or total, of the elements referred to in the previous section is prohibited. These acts of exploitation may only be carried out with express authorisation and, in any case, must make explicit reference to the ownership of the aforementioned intellectual property rights of MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.).

With regard to references to third-party products and services, the company acknowledges the corresponding industrial and intellectual property rights of their owners, their mere mention or appearance on the website does not imply the existence of any rights or responsibility of MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.) over them, nor does it imply any endorsement, sponsorship or recommendation unless expressly stated.

This website contains materials prepared by MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.) for informational or guidance purposes, which may be modified, developed or updated without prior notice. MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.) is not responsible for any errors, variations or omissions that may be found, nor for the use made of these documents. We recommend consulting the official gazettes or journals, as well as the information sources from which the news has been obtained.

The links contained on this website may lead the user to other third-party websites and pages over which MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.) has no control and is not responsible for the content and status of the linked websites. MY TOP TOUR (MNPQ GESTORES TURÍSTICOS, S.L.) does not guarantee the absence of viruses or other harmful elements that could cause damage or alterations to the computer system, and therefore is not liable for any damages that these elements may cause to the user or third parties. All third-party links to the Website must be to its home page, with “deep links”, “framing” and any other use of the Website’s content in favour of unauthorised third parties being expressly prohibited.

Right to lodge a complaint with the Supervisory Authority
Likewise, the interested party has the right to file a complaint with the Spanish Data Protection Agency (www.aepd.es) if they consider that the processing of their data does not comply with current regulations.

COOKIE POLICY
• Data controller: MNPQ GESTORES TURÍSTICOS, S.L.
• Tax ID number: B19650613
• Address: Paseo de la Sabica, 32, 18009 Granada, Spain
• Email: soporte@mytoptour.es
• Trademark: My Top Tour

We care about your privacy.
• We use cookies to improve your experience, personalise content and advertisements.
• We also use them to offer you the best social media features and analyse traffic.
• We respect your privacy: we only share this data with trusted partners to improve your experience.

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Legal basis for the use of cookies
Technical or necessary cookies are installed on the basis of legitimate interest and technical necessity for the functioning of the website. Preference, analytics and marketing cookies are only used when the user has given their explicit consent, in accordance with Article 6.1.a of the GDPR and the ePrivacy Regulation. This website uses different types of cookies. Some cookies are placed by third-party services that appear on our pages. You can change or withdraw your consent at any time from the Cookie Statement on our website. Find out more about who we are, how you can contact us and how we process personal data in our Privacy Policy. When contacting us regarding your consent, please indicate the ID and date of your consent. Your consent applies to the following domains: mytoptour.es
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