1. Controller’s Identity and Contact Details

Professinal Land Services on Destination SL.
(Registered address:  Calle San Juan 15 9 La Laguna, San Cristobal De La Laguna, Santa Cruz De Tenerife, Espana, 38660; Company registration number: CIF B21888029;
License number: I-AV-0004948.1
Data protection contact person: Kovács Péter;
Contact email and phone: info@plsdincoming.com, +36 1 445 29 54;
hereinafter referred to as: “Professinal Land Services on Destination”) acts as the controller in relation to
the personal data of current, former, and prospective customers.

2. Applicable Laws Governing Data Processing

– Act CXII of 2011 on the Right to Informational Self-Determination and Freedom of Information;
– Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection
of natural persons with regard to the processing of personal data and on the free movement
of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – GDPR).

3. Definitions

Controller: A natural or legal person, public authority, agency or other body which, alone or
jointly with others, determines the purposes and means of the processing of personal data;
where the purposes and means of such processing are determined by Union or Member State law,
the controller or the specific criteria for its nomination may be provided for by Union or
Member State law.

Processing: Any operation or set of operations which is performed on personal data or on sets
of personal data, whether or not by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or combination, restriction,
erasure or destruction.

Processor: A natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller.

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016
on the protection of natural persons with regard to the processing of personal data and on the
free movement of such data, and repealing Directive 95/46/EC.

Supervisory Authority or NAIH: National Authority for Data Protection and Freedom of Information
(Hungary).

Personal Data: Any information relating to an identified or identifiable natural person (‘data
subject’); an identifiable natural person is one who can be identified, directly or indirectly,
in particular by reference to an identifier such as a name, an identification number, location
data, an online identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person.

Special Categories of Personal Data: Personal data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, or trade union membership, and the processing of
genetic data, biometric data for the purpose of uniquely identifying a natural person, data
concerning health or data concerning a natural person’s sex life or sexual orientation.

Customer: Individuals who are personally, via the website, by phone, or in any other way interested
in the products and services of ViaSale Travel, or those who enter into a travel contract with
ViaSale Travel.

Cookie: For the purpose of providing personalised services, ViaSale Travel places a small data
package (a so-called “cookie”) on the User’s computer. The purpose of the cookie is to ensure the
highest possible standard of operation of the viasaletravel.hu website, to provide personalised
services, and to enhance user experience. The User can delete the cookie from their computer, or
set their browser to prohibit the use of cookies. By prohibiting the use of cookies, the User
acknowledges that the operation of the site without cookies may not be fully functional.

IP Address: An Internet Protocol (IP) address is a unique network identifier used by computers
communicating via the Internet Protocol to identify each other. Every computer, mobile phone,
tablet, etc. connected to the internet has an IP address, as do servers or providers providing
hosting and domain services. A specific address is not necessarily tied to a single device: some
devices may have multiple addresses.

4. Principles of Data Processing

ViaSale Travel shall take appropriate measures to ensure that personal data relating to
customers are always:

– processed lawfully, fairly, and on a proper legal basis (lawfulness, fairness, and transparency);
– collected only for specified, explicit, and legitimate purposes and not further processed in
a manner that is incompatible with those purposes;
– adequate, relevant, and limited to what is necessary in relation to the purposes for which
they are processed (data minimisation);
– accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure
that personal data that are inaccurate, having regard to the purposes for which they are processed,
are erased or rectified without delay (accuracy);
– kept in a form which permits identification of data subjects for no longer than is necessary
for the purposes for which the personal data are processed; personal data may be stored for
longer periods insofar as they will be processed solely for archiving purposes in the public
interest, scientific or historical research purposes or statistical purposes, subject to
implementation of the appropriate technical and organisational measures required by the GDPR
(storage limitation);
– processed in a manner that ensures appropriate security of the personal data, including
protection against unauthorised or unlawful processing and against accidental loss, destruction
or damage, using appropriate technical or organisational measures (integrity and confidentiality).

5. Data Processed by ViaSale Travel – Purpose, Legal Basis, and Retention Period

ViaSale Travel processes the following categories of personal data for the purposes set out below:

I. Enquiry for a service via website, in person, by phone, or by other means
– Name: essential for identifying the customer
– Email address, phone number: essential for contacting the customer later
– Subject of the enquiry: period, destination, accommodation category, catering, budget, number
of passengers, number and ages of children/infants – necessary to specify the enquiry and to
provide a personalised response based on the customer’s disclosure
Legal basis: consent of the enquirer. Data is processed for the duration indicated by the enquirer
or until consent is withdrawn.

II. Travel agency (partner agency) enquiry via in person, phone, or other means
– Name: essential for identifying the client
– Email address, phone number: essential for contacting the client later
– Subject of the enquiry: as above
– Partner agency staff email and phone number: necessary to respond to the partner’s enquiry
Legal basis: consent of the enquirer. Retention as above.

III. Website enquiries
– Name: essential for identifying the customer
– Email address, phone number: essential for contacting the customer later
– Subject of the enquiry: as above
– Car rental: requested car category
– Transfer service: arrival time, flight number, number of passengers
– Local programme choice: date and number/age of participants
– User’s IP address: automatically recorded by the ViaSale Travel website
– Additional demographic, interest, habit, and preference data (based on browsing history)
via cookies, with the user’s consent
Legal basis: consent. Retention as above.

IV. Newsletter, eDM subscription
– Name (surname and given name): essential for identifying the customer
– Email address: essential for contacting the customer later
– Subject of interest (newsletter / Canary Islands Magazine, travel guide) – as specified by the customer
Legal basis: consent. Retention as above.

ViaSale Travel uses the MailerLite marketing automation and newsletter platform. By accepting
marketing and newsletter data processing, the user acknowledges that their data will be
transferred to the MailerLite system exclusively for the above purpose, in accordance with its
Data Processing and Terms of Use, available here.

V. Use of chat
– Name (surname and given name): essential for identifying the customer
– Email address: essential for contacting the customer later
– Subject of the enquiry (period, destination, accommodation category, catering, budget,
number of passengers, number and ages of children/infants, programmes, transfer or car rental)
Legal basis: consent. Retention as above.

6. Recipients of Personal Data and Categories of Recipients

ViaSale Travel generally shares customers’ personal data on a controller-to-controller basis
with the following third parties:

– Within the ViaSale Travel group of companies, including the ViaSale Travel Hungarian
Commercial Representation;
– With organisations providing services to ViaSale Travel or to its customers
(e.g., insurance providers, IT service providers, newsletter service providers);
– With third parties involved in the performance of the travel contract
(e.g., hotels, airlines, etc.);
– With service providers and businesses involved in the performance of local representation
(e.g., car rental companies, shipping companies, programme organisers);
– With businesses engaged in recording website usage and user habits required for IT development;
– With supervisory authorities and other regulatory bodies and organisations.

Customers may request personalised information about the processing of their personal data
by ViaSale Travel (purpose of processing, legal basis, scope of data, data transfers,
retention period, logic of profiling) at the following contact point:
info@plsdincoming.com, +36 1 445 29 54;
Hermina Business Tower, 1146 Budapest, Hermina út 17., B. Tower, 2nd Floor, Office 4.

7. International Data Transfers to Third Countries

Customers’ personal data may be transferred to controllers and processors located in countries
outside the European Economic Area (EEA) where necessary for the performance of the travel
contract, or if the traveller has given their explicit and informed consent (Article 49 GDPR).

Prior to the conclusion of the travel contract, ViaSale Travel shall inform the traveller
whether adequate protection of the transferred data is ensured in relation to the non-EU recipient
of the traveller’s data. Adequate protection may be provided by:

– Standard data protection clauses adopted by the European Commission in accordance with the
examination procedure referred to in Article 93(2) GDPR;
– Standard data protection clauses adopted by the supervisory authority and approved by the
Commission in accordance with the examination procedure referred to in Article 93(2) GDPR;
– An approved code of conduct pursuant to Article 40 GDPR together with a binding and enforceable
commitment of the controller or processor in the third country to apply the appropriate safeguards
including those relating to data subjects’ rights; or
– An approved certification mechanism pursuant to Article 42 GDPR together with a binding and
enforceable commitment of the controller or processor in the third country to apply the
appropriate safeguards, including with regard to data subjects’ rights.

In this regard, ViaSale Travel strives to ensure that contractual data protection clauses
approved by the European Commission / NAIH are accepted by its third-country partners.

8. Customer’s Right of Access

The customer has the right to access their personal data.

If the customer requests confirmation from ViaSale Travel as to whether or not their personal
data are being processed, ViaSale Travel is obliged to provide such information.

The right of the customer to receive confirmation as to whether or not ViaSale Travel processes
their personal data:

– applies to personal data relating to the customer;
– does not apply to anonymous data;
– does not apply to personal data not relating to the customer; and
– includes pseudonymised data that can clearly be linked to the customer.

ViaSale Travel shall, at the request of the customer, provide access to and a copy of their personal
data. If the customer requests additional/repeated copies of their personal data, ViaSale Travel may
charge a reasonable fee to cover administrative costs incurred in fulfilling the request, which fee
shall be borne by the customer.

9. Customer’s Right to Rectification

The customer has the right to have their personal data rectified. This right:

– does not apply to anonymous data;
– applies to personal data relating to the customer;
– does not apply to personal data not relating to the customer; and
– includes pseudonymised data that can clearly be linked to the customer.

ViaSale Travel shall, at the request of the customer, correct or supplement their personal data
as appropriate. ViaSale Travel shall inform the recipients (if any) of such personal data of the
rectification. However, ViaSale Travel shall not inform the recipients if doing so proves impossible
or would involve a disproportionate effort.

10. Customer’s Right to Erasure

In certain circumstances, the customer has the right to have their personal data erased.

ViaSale Travel shall erase the customer’s personal data without undue delay if:

– ViaSale Travel processes the personal data, and
– the customer requests the erasure of their personal data, and
– the personal data are no longer necessary for the purposes for which they were processed.

ViaSale Travel shall also erase the customer’s personal data without undue delay if:

– ViaSale Travel processes the customer’s personal data, and
– the customer requests erasure, and
– the customer withdraws their consent on which the processing is based, and
– there is no other legal ground for further processing.

Furthermore, erasure shall be carried out without undue delay if:

– the processing is necessary for the legitimate interests pursued by ViaSale Travel or a third
party, and
– the customer objects to such processing, and
– there are no overriding legitimate grounds for the processing.

Erasure shall also occur without undue delay if:

– the customer requests it, and
– the processing of such data by the Company is unlawful, or
– erasure is required by applicable law, or
– the customer’s data have been collected in relation to the offer of information society services.

ViaSale Travel shall inform the recipients (if any) of the erasure. However, recipients shall not
be informed if it proves impossible or would involve disproportionate effort.

11. Customer’s Right to Restrict Processing

The customer may request the restriction of the processing of their personal data.

This right:

– does not apply to anonymous data;
– applies to personal data relating to the customer;
– does not apply to personal data not relating to the customer; and
– includes pseudonymised data that can clearly be linked to the customer.

ViaSale Travel shall restrict processing for the period necessary to verify the accuracy of the
personal data, if the customer contests its accuracy.

Restriction shall also apply if the processing is unlawful and the customer opposes erasure.

Restriction shall apply where:

– the customer requests it, and
– ViaSale Travel no longer needs the data for the purposes of processing, and
– the customer requires the data for the establishment, exercise, or defence of legal claims.

Restriction shall apply where:

– the customer objects to processing necessary for the legitimate interests of ViaSale Travel, and
– is awaiting verification as to whether there are overriding legitimate grounds for the processing.

ViaSale Travel shall inform the recipients (if any) of the restriction, unless impossible or
disproportionately difficult.

Where processing is restricted, ViaSale Travel may:

– store the personal data;
– process the personal data with the customer’s consent;
– process the personal data for the establishment, exercise, or defence of legal claims, or to
protect the rights of another person.

ViaSale Travel shall not use the customer’s data for direct marketing purposes, including profiling
or automated decision-making in individual cases.

12. Customer’s Right to Data Portability

The customer has the right to receive the personal data concerning them, which they have provided
to a controller, in a structured, commonly used, and machine-readable format, and has the right
to transmit those data to another controller without hindrance from the controller to which the
personal data have been provided, where:

– the processing is based on consent or on a contract; and
– the processing is carried out by automated means.

This right:

– does not apply to anonymous data;
– applies to personal data relating to the customer;
– does not apply to personal data not relating to the customer; and
– does not apply to pseudonymised data that cannot be clearly linked to the customer.

13. Time Limits for Handling Requests from Data Subjects

ViaSale Travel shall respond to customer requests concerning their rights described above within
the following time limits:

– Right to be informed: at the time of data collection (if provided by the data subject) or within
one month (if not provided by the data subject);
– Right of access: within one month;
– Right to rectification: within one month;
– Right to erasure: without undue delay;
– Right to restriction of processing: without undue delay;
– Right to data portability: within one month;
– Right to object: upon receipt of the objection.

14. Right to Lodge a Complaint

If the customer believes that their rights have been infringed, ViaSale Travel recommends that the
customer first initiate consultation with the controller by directly contacting the designated
contact person indicated above. If such consultation does not lead to a result, or if the data
subject does not wish to participate in such consultation, they may turn to the courts or to the
supervisory authority (NAIH). In the case of court proceedings, the data subject may choose to
initiate proceedings before the court having jurisdiction over their domicile or residence.

Contact details of NAIH:
1125 Budapest, Szilágyi Erzsébet fasor 22/C.
Telephone: +36 1 391 1400
Fax: +36 1 391 1410
E-mail: ugyfelszolgalat@naih.hu
Website: www.naih.hu

15. Amendments to This Notice

ViaSale Travel reserves the right to amend this notice at any time. Where applicable, ViaSale Travel
shall inform customers of such amendments by letter or e-mail, and in all cases in accordance with
applicable law.