Club RCI Privacy Policy

1. Our Commitment to Your Privacy

Club RCI is committed to protecting the privacy of our potential and existing customers. The Club RCI privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other channels online and offline as further described.

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information, goods or services you have requested.

The Club RCI company that is the controller for the processing of your Personal Data as set out in this Privacy Policy can be found on Esti@clubrci.es and c/ Ferraz 82, 28008 Madrid, Spain, being the controller means that this company is responsible for ensuring that your personal data is processed in compliance with applicable privacy and data protection legislation.

2. Personal Data

“Personal Data” is information or pieces of information that could allow you to be identified, such as for example:

• Name and contact details (e.g. postal and email address, telephone number)
• Account information (e.g. user name, profile picture or social media account ID) )
• Country of residence)
• Birth date)
• Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data)
• Preferences (e.g. shopping habits, preferred educational courses) )
• Company or school name and address)
• Credit and debit card number)
• Medical condition (e.g. allergies or illness)

How do we collect Personal Data?

We collect Personal Data in a variety of ways:

• Directly from you: Information is collected directly from you, either by you providing the information directly to us or you acting in a manner that provides us with the information, for example:
  • Offline: We collect Personal Data from you offline, for example when you contact customer service, enrol in a programme or service or provide information to us in writing.
  • Online: We collect your Personal Data through the Club RCI Programmes, for example when you sign up for a newsletter or a brochure, enrol in a programme or service. We also collect Personal Data:
    • Through cookies. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. For detailed information about the cookies we use and the purposes for which we use them, please see our cookie policy.
    • Through your use of a mobile application. When you download and use one of our mobile applications, and to the extent allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the mobile application on your device accessing our servers and what information and files have been downloaded to the mobile application based on your device number.
    • Through your device. Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content. Read more about such services under “How do we use Personal Data?”
• From our corporate affiliates, business partners, assistance providers or claim handlers. We may receive Personal Data from other parties in conjunction with your course/program, including:
  • Our corporate affiliates, such as Club RCI that promotes the sales of our services and offers customer service in your country of residence and provides us with the Personal Data that is needed to come to an agreement with you on your order, or the school in your country of destination that provides some of the services that you have ordered, or the Swiss principal company that is located in Spain and is responsible for the performance of the contract with you for any of Club RCI’s offers.
  • Business partners, such as local sales agents that promote the sales of our services in your country of residence.
  • Claims handlers who receive information about your insurance claims in case of an insurance situation.
• From other sources. We may receive your Personal Data from other sources, such as public databases; joint marketing partners such as marketing agencies or providers of software and services for digital marketing automation and analytics; social media platforms, including but not limited to; Facebook, Instagram, Snapchat, Musically, LinkedIn, Twitter, YouTube and messenger services such as WhatsApp or Facebook Messenger; from people with whom you are friends or otherwise connected with on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your Club RCI programmes account, such Personal Data that you have registered in your profile, such as your email address, phone number, postal address, date of birth, name and user name will be shared with us. Furthermore, we use cookies to track members of social media networks as further explained in our cookie policy.

• If you browse our sites We may also collect information about your use of our services through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the Club RCI programme you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the Club RCI  programs, along with the time of the visit and the page(s) that were visited. These data are only stored and used together with other Personal Data that you have submitted if you have given your consent to do so. You can read more about collection of your IP address and other browsing data in our cookie policy.

How do we use Personal Data?

• • Your Personal Data will be processed by Club RCI for the purposes of completing your booking, providing you with the programmes and services that you have ordered (including travel insurance coverage), for customer service, administrative services or as otherwise necessary to perform the contract between you and us or as further described in this policy.
  • We may also use Personal Data:
    • For statistical purposes, calculating usage levels, and helping diagnose server problems with the Club RCI programmes as well as to ensure that the Club RCI programmes function properly.
    • To allow you to contact and be contacted by other users through the Club RCI programmes, as permitted by the applicable p programme.
    • To allow you to participate on message boards, chat, profile pages and blogs and use other services enabling you to post information and materials.
    • If you have given your consent:
      • To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the Club RCI programmes experience and content based on your past activities on the Club RCI programmes. For example, depending on what Club RCI programme you have searched for on our website, or in previous browsing, the offer presented to you on the Club RCI programmes may be limited to a specific language, course length or budget.
      • To provide you with personalized location-based services and content through the use of your device’s physical location. For example, you will be redirected to the local Club RCI website in your language if your device indicates that you are browsing from that country, or you may be suggested the nearest Club RCI office to your location for visits or information.
      • To market our programmes and services, including special promotions based on your interests, for example through email marketing solutions such as Salesforce Marketing Cloud’s management software which maintains mailing lists and schedules and modifies email messages based on what recipients read, click-on or forward. All such email communication will include a clear unsubscribe link.

How do we share Personal Data?

• • We share your Personal Data with our corporate affiliates, business partners and service providers both within and outside the EEA/Switzerland:
    • Our corporate affiliates are for example a local Club RCI company that promotes the sales of our services and offers customer service in your country of residence, or the school in your destination country that provides some of the services that you have ordered, or one of the principal companies that is offering another of Club RCI’s programme.
    • Business partners are for example local sales agents that promote the sales of our services in your country of residence; transportation or accommodation providers in your destination country; or course leaders, activity leaders or other contractors for management of any of our programs; or a travel insurance company that prepares the travel insurance for you.
    • Service providers, such as providers of IT systems, for example for managing customer relations or payments, scheduling classes or storing learning results; or providers of software and services for digital marketing automation and analytics.
  • We have put appropriate safeguards in place for transfers of your Personal Data outside the EEA/Switzerland, including the standard data protection clauses adopted by the European Commission, available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915 and http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087. For more information on standard data protection clauses in place, please see the contact section below.
  • We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

On what do we base our right to collect and use Personal Data?

We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services or programmes that you have ordered from us, or when there is a legitimate interest for us (i.e. the service provider) to use your Personal Data, such as for the marketing of programmes or services similar to the one(s) you have already purchased from that same legal entity.

To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can for example be information about health, ethnicity or religious beliefs, read more under “Sensitive data”.

To the extent that we use your Personal Data to send you offers beyond what is considered to be within our legitimate interest, such as marketing of programmes and services provided by an Club RCI affiliate, we base this on your specific consent.

3. Security

We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.

4. Unsubscribe

If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.

Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable.

5. Third Party Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the Club RCI programme contain a link. The inclusion of a link on Club RCI programmes does not imply endorsement of the linked site by us or by our affiliates.

Additionally, we may provide you with access to third-party functionality that permits you to share your activities on Club RCI programmes to your social media account(s), for example Facebook or LinkedIn. Please note that any information that you provide through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.

6. How long do we store personal data?

We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.

We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 10 years after your last completed service or delivery of programme.

7. If you are under the age of 16

If you are under the age of 16, you should review this text together with your parent or guardian to make sure you both understand them. We are not responsible for checking your age but sometimes we still do verification checks. If we learn that you are under the age of 16 and that we have collected information about you without consent from your parent or guardian, we will delete the information as soon as possible and you will not be able to use Club RCI programmes.

8. Sensitive Data

We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary (for example in order to provide you with the services and programmes you have ordered and in relation to your insurance). We will make sure that we receive your explicit consent to such processing and treat this information securely.

9. Updates To This Privacy Policy

Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.

10. Your Rights

You have a right to, once per calendar year, contact us and without cost find out which information about you that is being used. You have a right to receive your Personal Data in a machine readable format and you have a right to transfer your personal to another data controller.

You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes and you may at any time request that the use of your Personal Data is restricted or that we shall delete your Personal Data. Note however that a restriction or deletion could mean that we are not able to provide you with information, services or programmes as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.

11. Contact Us

If you would like to have a copy of the information Club RCI holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact one of our office (C/ Ferraz 82, 28008 Madrid, Spain) or email us to esti@clubrci.es.

If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.