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Privacy Policy 

Partners and Potential Partners 

lastminute.com group 




Your privacy is important to us. We have developed this Privacy Policy so that
our Partners and Potential Partners (i.e.: suppliers and clients)  and their
employees (“you”) understand how the companies forming part of lastminute.com
group - see Annex A - which might act as data controllers, collect, use,
disclose and store your personal information and the information of the company
you work for. 




1. Who is the controller of your personal data?

When this Privacy Policy mentions “lastminute.com group Company” , “we,” “us,”
“our” or “Data Controller”, it refers to Bravonext S.A. or to any other
lastminute.com group company - Annex A.

Furthermore, we inform you that, for compliance with the General Data Protection
Regulation (EU) 2016/679 (“GDPR”) purposes only (Art. 27 GDPR),  Bravonext S.A.
has designated as its EU representative Viaggiare SRL., an Italian company
belonging to the lm group, listed in the Italian Chamber of Commerce - Milano
under VAT identification no. IT04403760962 and registered office at Via
Francesco Ferrucci, 10 - 20145 Milan, Italy.

In addition to the above, we inform you that, in accordance with Article 27 of
the UK General Data Protection Regulation (UK GDPR), Bravonext S.A. has
designated as its UK representative LMnext services (UK) Ltd, an English company
belonging to the lm group, VAT identification no. UK 205 7906 10 and with its
registered office at Clerks Court, Ground Floor, 18-20 Farringdon Lane, London,
EC1R 3AH, United Kingdom.

Bravonext S.A., being an entity located in Switzerland, is subject also to Swiss
law regarding the protection of personal data. For that reason, we undertake to
comply with the obligations imposed by the General Data Protection Regulation
(EU) 2016/679 (“GDPR”) and the Swiss Federal Act on Data Protection of 25
September 2020 (FADP). 

If you establish contact or enter into a contract with another company within
the lastminute.com group, the entity with which you are finalising the contract
(or having contacts) will be the data controller for your personal information -
please see Annex A. 




2. What categories of your data do we collect and use?

The type of personal information we might collect include your name, telephone
number, e-mail address and other contact details, your business address, company
name and other details of the company you work for. 

We collect personal information about you and your company when you contact us
in relation to the services we could provide to each other. 




3. Why do you collect your data?

We use your personal information and your company information: 

a) To create and maintain the contractual relation established for the provision
of the product and/or service requested by you in all its phases and by way of
any possible integration and modification or to take steps at your request in
relation to pre-contractual measures. 

Legal basis: Article 6.1.b) GDPR - To fulfil a contract, or take steps linked to
a contract. 

b) To meet the legal, regulatory and compliance requirements and to respond to
requests by government or law enforcement authorities conducting an
investigation.

Legal basis: Article 6.1.c) GDPR - To comply with the law (i.e. to share
personal data with regulatory authorities).

c) To verify compliance with our contract and for the establishment, exercise or
defence of legal claims.

Legal basis: Article 6.1.f) GDPR-  To pursue our legitimate interest (i.e.
compliance with our terms and conditions, protection of our rights in the event
of any dispute or claim). 

d) To gather information about suppliers and select the best one to contract
with.

Legal basis: Article 6.1.b) and f) GDPR To perform pre-contractual activities
and to pursue our legitimate interest




4. Who sees, receives and uses your data?

We may share your personal and your company information with any company within
the lastminute.com group or to: 

 * Persons to whom the data must be communicated for managing the contractual
   relationship between us
 * Accountancy and insurance firms
 * Banks
 * Company employees responsible for performing the service
 * Territorial agencies and Supervisory Bodies

We may communicate your personal information to other parties If we have
appointed them to perform certain functions on our behalf, acting as data
processors pursuant to article 28 GDPR. 




5. How long do we retain your data? 

For purposes letter a), b) and c) above, we will only keep your information for
the length of time we require it for the purposes we have set out in this
Privacy Policy and no more than 10 years after the termination of our
contractual relationship. 

For the purpose letter d) above, your data will be cancelled after 2 years since
our last contact/communication with us. 




6. Transfers outside the EEA 

Your personal data is processed at the Data Controller’s registered office (see
point 1 and Annex A), on the lastminute.com group servers, and at the servers of
other entities to which data may be provided in order to process your data. 

Given the fact that we are an international travel company, we also transfer
your personal data to:

 * European Economic Area (EEA) countries and non-EEA countries offering an
   adequate level of data protection in accordance with the “Adequacy decisions”
   of the EU Commission that recognises some countries as providing adequate
   protection and/or the equivalent Swiss adequacy finding; 
 * non-European Economic Area countries where data protection laws may be less
   protective than the legislation in the EEA or in Switzerland. 

Countries where your data could be transferred to are United States, India and
United Kingdom.




7. What are your data protection rights and how can you exercise them?

You, as a data subject, can exercise, in relation to the data processing
described therein, the rights provided by the applicable data protection
legislation, including the right to: 

 * receive confirmation of the existence of his or her personal data, access its
   content and obtain a copy (rights of access); 
 * update, rectify and/or correct your personal data (right to rectification); 
 * request erasure of your data or restriction of processing of data processed
   in violation of the law, including that whose storage is not necessary in
   relation to the purposes for which the data was collected or otherwise
   processed (right to erasure and right to restriction); 
 * receive a copy of personal data provided during the employment relationship
   in a structured, commonly used and machine-readable format (e.g. data
   relating to salaries, internal mobility services) and request that that
   personal data is sent to another data controller (right to data
   portability); 
 * refuse consent or withdraw consent, where provided, without detriment nor
   prejudice to the lawfulness of the processing based upon the consent provided
   before the revocation. 

You also have the right to object to the processing of your data by us in some
circumstances when we rely on legitimate interest as legal basis (right to
object). 

To exercise the above rights, you may contact the Group Data Protection Officer
at dpo@lastminute.com 

You also have the right to make a complaint to the data protection supervisory
authority or to seek a remedy through the courts if you believe that your rights
have been breached. 




8. Identity and contact details of data controller Group DPO

Our Data Protection Officer (or "DPO") is available at: dpo@lastminute.com. 







ANNEX A - List of lastminute.com group Companies (and data controllers of your
personal data)Legal Entity

Registered Address

Blue S.A.S.

75, boulevard Haussmann

75008 Paris

France

Bravometa CH S.A.

Vicolo dei Calvi 2

6830 Chiasso

Switzerland

BravoNext S.A.

Vicolo dei Calvi 2

6830 Chiasso

Switzerland

BRAVOLIVIA S.L.

Paseo de la Florida 2 Oficina exterior 2

28008 Madrid

Spain

Bravoventure India Private Ltd

3 rd Floor, Wing B, Etamin Block, Exora Business Park

Kadubeesanahalli Village, Varthur Hobli, Outer Ring Road

Bengaluru - 560103

India

Bravoventure Poland Sp.z.o.o.

ul. 1 Maja 39

71-627 Szczecin

Poland

BRAVOVENTURE SPAIN S.L.U.

Paseo de la Florida 2 Oficina exterior 2

28008 Madrid

Spain

Comvel GmbH

Elsenheimerstrasse 49

80687 München

Deutschland

Cruiseland S.r.l.

Via Francesco Ferrucci, 10

20145 Milan

Italy

HolidayIQ Pte Ltd

105 Cecil Street

#13-02 The Octagon

Singapore 069534

lastminute.com N.V.

Rokin 92

1012 KZ Amsterdam

Netherlands

Leisure and Lifestyle Information Services Private Limited

1st Floor, B4 Wing, C/o Innovant Spaces Pvt ltd, Khata no 207/132, (Sy no
19/4&27), Kadubisanahalli Village,Varthur Hobli, Outer Ring Road

Bangalore 560103

India

LM Forward Ltd

Clerks Court, Ground Floor, 18-20 Farringdon Lane

London, EC1R 3AH

United Kingdom

LMnext CH S.A.

Corso San Gottardo 30

6830 Chiasso

Switzerland

LMnext DE GmbH

Elsenheimerstrasse 49

80687 München

Deutschland

LMnext FR S.A.S.U.

75, boulevard Haussmann

75008 Paris

France

LMnext Services (UK) Ltd

Clerks Court, Ground Floor, 18-20 Farringdon Lane

London, EC1R 3AH

United Kingdom

LMnext UK Ltd

Clerks Court, Ground Floor, 18-20 Farringdon Lane

London, EC1R 3AH

United Kingdom

LMnext US Inc.

Corporation service company

2711 Centerville Rd Suite 400

Wilmington, DE, 19808

USA

Madfish S.r.l.

Via Francesco Ferrucci, 10

20145 Milan

Italy

Pigi Shipping & Consulting S.r.l.

Via Francesco Ferrucci, 10

20145 Milan

Italy

QT Mobilitätsservice GmbH

Elsenheimerstrasse 49

80687 München

Deutschland

Red Universal de Marketing y Bookings Online S.A.U.

Paseo de la Florida 2 Oficina exterior 2 28008 Madrid Spain

Sealine Investments LP

5 South Charlotte Street

Edinburgh, EH2 4AN

Scotland

Sealine Investments 2 LP

5 South Charlotte Street

Edinburgh, EH2 4AN

Scotland

SMALLFISH SPAIN S.L.

Paseo de la Florida 2 Oficina exterior 2

28008 Madrid

Spain

StarTech S.r.l.

Via Francesco Ferrucci, 10

20145 Milan

Italy

Viaggiare S.r.l.

Via Francesco Ferrucci, 10

20145 Milan

Italy







Last updated December 2023




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