is concerned about your privacy and
we are committed to its preservation.
clear and complete information in order to collect, use, store, process and
protect your Personal Data.
Therefore, we strongly recommend that you read
and the a3transfer platform.
The expressions contained in the DEFINITIONS
Whenever the expressions below are used in
current legislation, namely:
Registration Data: affiliation, address
(including email address), personal qualification, understood as name, surname,
marital status and occupation of the User.
Personal Data: data related to the natural
person. They are all data that can be used directly or indirectly to identify a
person, for example: name, photos, email, bank details, medical information,
geolocation, telephones, messages in social networks, IP address, etc.
Processing of Personal Data: any operation that
contains Personal Data, such as those related to the collection, production,
reception, classification, use, access, reproduction, transmission,
distribution, processing, filing, storage, disposal, evaluation or control of
the information, modification, communication, transfer, dissemination or
1) COLLECTION OF PERSONAL DATA AND INFORMATION
In the first place, it is important to
highlight that it is essential for the collection, storage and processing of
personal data obtained from users, in order to enable the provision of services
offered through its Platform.
In this way, it is important that you know and
accept expressly and unequivocally, that a3transfer collects, receives and
stores Personal Data and information automatically on its servers regarding the
activities resulting from the user's browser, which includes geolocation , IP
addresses, cookies or other sequences of identifying characters, as well as
information on transactions made through the platform.
It is important to note that some personal data
are necessarily collected by a3transfer in order to enable the execution of the
service contract signed with the Users, as well as in the legitimate interest of
allowing the operationalization of PLATAFORMA.
In addition, it should be remembered that in
order to use the tools offered by a3transfer, you must register and, therefore,
provide your full name, date of birth, identification document (DNI, NIF and /
or CIF), telephone, address and email address, as well as create an access
password that will be your exclusive knowledge.
You are aware that it is your sole
responsibility to provide true, accurate, current and complete information when
registering to access the Platform. We remind you that the provision of
incomplete or false information is a crime typified by law and can result in a
severe conviction to those who execute it.
2) CONTROL OF REGISTRATION DATA BY USERS
Each user has control of the Registration Data
contained in the profile created in a3transfer and can access and modify them
by using their username and password. We remind that the username and password
are individual and known only to the user, who must ensure the confidentiality
of such data. a3transfer is not responsible for the way in which this data is
used by the User. Users can update their registration information in a3transfer
through the a3transfer Platform
3) COLLECTION AND USE OF PERSONAL DATA AND
The Personal and Registration Data collected,
as well as any other information collected, may be used for our team to
communicate with you, to notify you about your activity related to a3transfer
tools, as well as alerts and system notifications .
In addition, the Personal and Registration Data
collected, as well as any other information and access records to the
a3transfer tools, may be stored, processed, processed and used by us for the
(i) Make possible the provision of the services
offered by a3transfer in an effective and efficient way, allowing its operation
in a fast and safe way;
(ii) Auxiliary, when necessary and appropriate,
for the different Users (Users, Affiliates, Travel Agencies, carriers and in
general Buyers) to communicate, especially in cases of eventual conflicts
arising from the quality of the service, to delays in the delivery of the
CONTENT of information about any reservation, to Copyright and Intellectual
(iii) Carry out analyzes and studies related to
the behavior, interests and demographic data of the Users, in order to
understand their demands and needs and to be able to provide more adequate,
effective and interesting services, improving the usability experience of the
tools of a3transfer;
(iv) Improve our commercial and marketing
strategies in order to improve the services offered;
(v) Send messages to Users with information on
products, services, advertising, promotions, banners and news from a3transfer,
with the sole purpose of keeping informed about our offers.
3.1) Personal data and user rights
We emphasize that it is the right of the Users
to receive clear and complete information, provided that it is formally
requested, about personal data eventually collected and / or processed by
a3transfer. For more detailed information on how data is collected, the use of
cookies and similar tools, visit our Cookies Policy (link).
In addition, Users may always contact
a3transfer to request the exercise of their rights of exclusion, rectification,
correction and restriction of use regarding their personal data, including
providing the requested personal data in an appropriate, structured and usual
format, always that the applicable legislation guarantees it.
Users may also exercise their rights and submit
claims to the competent data protection authorities to act in their
For the exercise of any of their rights linked
to the personal data eventually collected and processed by a3transfer, as well
as to send doubts and questions about the issue, Users should contact
a3transfer via email firstname.lastname@example.org
Users whose personal information has been collected
and processed on the basis of the consent granted, may withdraw it at any time,
without affecting the legality of the collection and processing carried out by
a3transfer during that period. The personal data obtained on the basis of
a3transfer's legitimate interest or the need to execute a contract may be
subject to questioning via email email@example.com
In the event that the user withdraws the
consent or requests the exclusion of data when it is collected and processed
based on the legitimate interest and / or need to execute the contract, the
latter acknowledges and accepts, from now on, that a3transfer will not be
liable for any loss / or damage caused to your personal data if the user
decides to withdraw consent.
We highlight that some personal data collected
must, for legal obligations imposed on a3transfer by the competent authorities,
be kept in our files for a legally determined minimum period, even if the User
requests their exclusion and / or alteration. By way of illustration, data
linked to fiscal documents, financial transactions, fiscal identity, full name
and others necessary to identify a particular financial, tax or fiscal
operation will be maintained by a3transfer even if its exclusion is requested.
It is important to reiterate that it is
essential for a3transfer the collection, storage and processing of personal
data obtained from Users, in order to enable the provision of services offered
through its online booking engine.
However, we guarantee our Users to apply the
best efforts to keep all personal data collected properly secure, protected and
confidential, although it is technically unfeasible to guarantee the
inviolability of the data in case of possible external attacks and system
In such cases, we undertake to inform Users of
what happened and what data were violated, within the principle of transparency
and trust that should govern the relationship between a3transfer and its Users.
You may request, at any time, to be excluded
from the lists intended for sending promotional or advertising messages.
For more detailed information on data
3.2) Responsibility of the Users regarding the
protection of collected data
If the user uses the a3transfer online booking
engine, this means that this is probably a user interested in receiving a road
passenger transport service and uses the a3transfer services to market their
products. Regarding the personal data of the clients, collected by the Users
and eventually delivered to a3transfer, we act as data processors and comply
with the legal obligations related to the protection of personal data.
However, in this context, users are understood
as data controllers, taking into account that they are responsible for the
collection of personal data with their customers. In this way, Users agree and
recognize that they are exclusively responsible for fully respecting the
applicable data protection legislation, especially the GDPR if the customer who
had the data collected is in a country belonging to the European Union.
Although a3transfer suggests certain
functionalities that may facilitate its Users to remain in compliance with the
legislation related to the protection of personal data, such as standardized
data collection notices, Users recognize that a3transfer does not act or offers
legal and legal consulting services of any nature, exempting it, from now, of
responsibility in that sense. a3transfer strongly recommends that Users obtain
the appropriate legal and technical advice to ensure that they comply with the
laws and regulations applicable to their business, in particular those relating
to the protection of personal data.
4) STORAGE AND PROTECTION OF PERSONAL DATA
All Personal Data of Users collected and
of navigation, registration in a3transfer, use of the Platform, or at any other
time of contact / communication between the User and the Platform, will be
stored in our database, and processed, until the moment the user withdraws
their consent so that we can do so. All other data, as specified above, will be
retained for the time necessary for the respective purposes for which they were
originally collected. We may also retain information as required by law. for a
minimum of 6 (six) months or longer, provided that it is defined by a judicial
or administrative order, according to current legislation, or for legitimate
purposes of development and provision of services to users.
The Data collected by Personnel informed to
a3transfer, or otherwise collected by a3transfer, will be stored in secure
databases, within the best practices, with restricted access only to employees
with the necessary credentials, which are obliged to maintain the Confidentiality
of information and do not use it improperly.
a3transfer may store and process Personal Data
and other information collected on a server located in Brazil or abroad.
5) DISCLOSURE TO THIRD PARTIES OF REGISTRATION
DATA AND COLLECTED PERSONS
You agree that a3transfer can deliver Personal
and Registration Data, such as the full name and email address, to the Buyer,
damage to other a3transfer users or third parties.
In the same way, you agree that, ―in an attempt
to prevent illegal activities, suspicion of fraud, disputes, complaints about
the CONTENT of the services we provide or any indication of illicit committed
by the Users, which includes the dissemination of SPAM and situations involving
potential threats to the physical security of someone - their Personal Data and
the Registry of Users involved are provided. In certain cases, if deemed
necessary, a3transfer may also provide the data collected to the bodies and
entities involved in the investigation or resolution of conflicts between Users
or between Users and third parties, such as insurance companies, arbitration
lawsuits and other bodies. competent administrative
You agree that a3transfer may share with the
Producers, Affiliates and other partners that receive commission, the Personal
and Registration Data of the Buyer, such as email, full name, identification
document (DNI, NIF and / or CIF), date of birth, telephone and address, when
the appointees have configured on the Platform the receipt of purchase data
(including subscriptions) and their splittings (possible purchase status).
You also agree that a3transfer may share the
Personal and Registration Data collected with a3transfer's outsourced service
providers, in order to allow the development of their respective activities and
make it possible to improve the services and operations of the Platform, but
without limiting to them, such as the following services: data backup, fraud
prevention services, email and database service providers, invoice issuance,
among others. In this case, a3transfer requires that all service providers with
whom it shares the Personal Data of users include in their contracts provisions
that guarantee due protection, secrecy and confidentiality in the processing of
You further agree that, in the event of a
possible corporate operation that involves the restructuring of the business
group that a3transfer integrates, as well as the purchase and / or sale of
shares and assets, the Personal Data collected may be considered as one of the
commercial assets to be transferred . In such cases, a3transfer may transfer
the Personal and User Registration Data if it is purchased by, or if it is
merged with another company (s).
Excluding the hypotheses mentioned in this
Platform, as well as the access records to the platform (IP address, date, time
and time zone) and the data related to the transactions carried out carried out
through the Platform, may only be disclosed to third parties in the following
Upon request or by specific authorization of
With a court order.
6) MAINTENANCE OF REGISTRATION AND PERSONAL
DATA AFTER EXCLUSION OF THE ACCOUNT
You can delete your a3transfer account at any
time by accessing the Platform Settings, any other means destined to achieving
that objective being ineffective. If the User makes the corresponding request,
in the terms of Item 3.1 above, a3transfer will make the final exclusion of the
Personal Registration Data provided by the User at the end of their
relationship with a3transfer, within a maximum period of 5 days. Access (IP)
records, if any, will be excluded as they meet 180 days of storage, under
current legislation in each country.
We are against any practice that promotes spam
of any kind and we guarantee that the messages sent by the Platform are always
of interest or importance to its recipients. In addition, at any time the user
can also choose to stop receiving a3transfer emails, adjust their preferences
to receive emails or cancel their account, as mentioned above.
In the same way, we ask our users not to
practice spam, to verify that the messages sent are always of interest to the
recipient, knowing previously that breach of good Internet practices may result
in the cancellation of the account of the infringing user in the a3transfer
a3transfer reserves the right, at any time, to
of technological improvement or its functionalities.
a3transfer will notify its users by email or through a prominent publication of
In the event that you continue to use the tools
this will mean and will be considered as your unequivocal consent and your
irrevocable acceptance of all the terms and conditions contained in the
To view and access the a3transfer Data
Policy, just click here (link)
To request clarification and more information
including the following sentence in the title of the message: "Privacy