Privacy Policy

Last modification: 25 April 2022

Integrated Transfer Systems SL, (“Bravo Transfers”, “we”, “our” or “us”) offer a range of services related to the reservation, arrangement and supply of transport services such as transfers between airports and hotels (“Services” or specifically “Transport Service” when referring to the ride itself). Our Services are provided through our own websites, mobile apps, emails and text messages (“Platforms”). We also makes these Services available through our business partners’ websites, social media and other platforms.

This Privacy Policy (“Policy”) explains how we collect, use and protect personal information about you (“Personal Data”) when you visit our Platforms and book our Services, or when you contact us by email, live chat, phone or post. We also include contact information if you have any questions about our Privacy Policy. This Policy applies to all customers and users who contact us or access the Services offered via Platforms that reference this Privacy Policy, such as the website www.bravotransfers.com and the Bravo Transfers app, along with any pages or services that we include in the future. It is subject to applicable regulations on data protection and e-commerce.

You declare that any Personal Data you provide during your use of the Platforms is accurate and, if that Personal Data changes, you agree to inform us or directly update that Personal Data within the Platforms. If you provide Personal Data from third parties, you agree to obtain the prior consent of the parties in question and inform them about the content of this Policy.

We reserve the right to update this Policy at any time as our business evolves, as well as to comply with changing legislative or legal requirements. You can contact our Data Protection Officer at privacy@bravotransfers.com.

1. Who is responsible for processing your data (the data controller)?

Unless specifically indicated otherwise, the data controller responsible for processing Personal Data under this Policy is Integrated Transfer Systems SL, with registered offices at Ronda Universidad, 31, 2-1, 08007 Barcelona (Spain) and Spanish Tax Identification Code (CIF) B66867128.

2. What Personal Data do we collect?

The data we process is collected:
– From the forms that you fill out and from the requests that you make on the Platforms; for example, when you register, sign up to our newsletter or make a booking on our website. We also process the data included in requests that we receive by email, social media or via our call centre.
– From profiles and analytics collected from users (registered or otherwise) browsing the Platforms.
– From your interest in our sales campaigns; for example, in contests or promotions.
– From the social media profile which you decide to use to log into our Platforms.

The data we collect is provided either directly by you or by third parties who process requests on your behalf; for example, the person making the booking, the company for which you work, or other travel agencies.

The data categories which we process typically consist of:
– Identification and contact details,
– Personal preferences such as language selection,
– Financial and transaction-related details,
– Date of birth and nationality if explicitly required,
– Data related to your browsing, for example the IP address from which you connect to a Platform and your approximate location, weblogs, pages visited or actions taken on that Platform. For this purpose, we use cookies and similar technologies which may track your browsing. Further information about our cookies policy is available at www.bravotransfers.com/cookie-policy
– Data regarding your booking history,
– Sales tracking data and, where appropriate, data related to your preferences and sales profile,
– Identification and contact details collected from the social media profile which you used to log into our Platforms.
– Data generated by your use of social media networks which you have decided to share with us (for example, likes and comments).

3. Why do we process your data?

We process your data for the following purposes:
– To manage our relationship with you,
– To process your requests and provide the Services,
– To assess the quality of our services, including optional satisfaction surveys,
– To comply with our legal obligations; for example, in accounting and tax affairs.

The data of Platform users is also processed for the administration, management and control of the Platform itself and its restricted access areas, as well as for statistical purposes and the enhancement of the Platform and our Services.

For reasons of security and quality control, calls made to our call centre and our agents may be recorded. If you do not wish the call to be recorded, please inform the agent who takes your call. We process Personal Data for the following commercial purposes:
– To send commercial messages to our customers and users about our products or services,
– If you have requested a quote or have started but not completed a booking process on the Platform or via our call centre, the data provided may be used to commercially follow-up your request. To this end, our agents may contact you by email or by phone, for example to resolve possible incidents in the booking process,
– If you show interest in our promotional campaigns, your data will be processed with your consent in order to manage and control them.

3.1 Booking with Bravo Transfers

When you make a booking, you can choose to register with an email address and password, register with an existing social media profile or checkout as a guest. In each case a user account is created which stores the Personal Data that you provide, allowing you to correct or update your Personal Data, retrieve details of your bookings and checkout more easily in the future. When you make a booking, we will send the necessary Personal Data to the service provider selected to perform the transport service so that they can process your booking. The legal basis for this processing is Article 6(1)(b) GDPR. The legal basis for the transfer of your personal data outside of the EU is Article 49(1)(b).

3.2 Facebook Connect

We offer you the option of registering and signing in through your Facebook account. If you register via Facebook, Facebook will ask you for your permission to release certain data in your Facebook account to us. This may include your first name, last name, and e-mail address so your identity can be verified, as well as general location, a link to your Facebook profile, your time zone, your date of birth, your profile picture, your “Like” information, and your friends list.

This data will be collected by Facebook and transmitted to us. You can control the information that we receive from Facebook through the privacy settings in your Facebook account.

This data will be used to establish, provide, and personalise your account. The legal basis is article 6, par. 1 a, b, and f of the GDPR.

If you register with us through Facebook, your account will automatically be connected to your Facebook account and information about your activities on our Platforms, if applicable, will be shared on Facebook and published on your timeline and news feed.

3.3 Advertising

Our advertising partners and us use your Personal Data to conduct personalised and non-personalised advertising on our Platforms, social media services and on third party websites for our products and the products of third parties. We use cookies, other technologies and online advertising exchanges and advertising networks to do this. When you consent to the use of advertising and marketing cookies, we share details of your interactions with our Platforms with our advertising partners so that they can use this to perform personalised advertising. If you do not consent to the use of advertising and marketing cookies, you may still be shown advertising from third parties when you use our Platforms, however this advertising will not be personalised.

Some of our advertising partners provide opt-out options (detailed below) where you can opt out of having them use your data for advertising. You can also opt out of some advertising by using these links:

– https://www.youronlinechoices.eu/
– https://youradchoices.ca/choices/
– https://www.aboutads.info/choices/
– https://optout.networkadvertising.org/
Alternatively, you can prevent cookies from being set in your browser and app settings, or by not consenting to the use of marketing and advertising cookies.

We work with the following advertising partners (the links will take you to further information about them, their privacy policies and opt out solutions): Criteo, Google Ad Manager and Google DoubleClick.

3.3.1 Google AdWords and Conversion Tracking

We place Google AdWords display advertisements and use Google conversion tracking for the purposes of personalised online ads based on interests and location.

Advertisements are displayed based on search requests on websites in the Google ad network.

When a user clicks on an ad, Google places a cookie on the user’s device. For more information on the cookie technology used, please see Google’s statements on website statistics and their data privacy policy.

With the use of this technology, Google, and we as their customer, receive the information that a user has clicked on an ad and was redirected to our Platforms. The information acquired this way is solely used for statistical analysis related to ad optimisation. We do not receive any information that would allow us to personally identify a visitor. The statistics provided to us by Google include the total number of users who have clicked on one of our ads and, where applicable, whether they were redirected to a page on our Platforms that has a conversation tag. These statistics allow us to track which search terms most often lead to our ads receiving clicks, and which ads lead to users contacting us via contact forms or making bookings on our Platforms.

If you do not want this, you can prevent the storage of the cookies required for this technology by, for example, using the settings in your browser or your app. Should you do so, your visit will not be incorporated into user statistics.

You also have the option to choose the types of Google ads or deactivate interest-based ads on Google through ad settings. Alternatively, you can deactivate third-party use of cookies by using the Network Advertising Initiative’s opt-out tool.

3.3.2 Google Dynamic Remarketing

We use the dynamic remarketing function of Google AdWords on our Platforms. This technology allows us to place automatically generated ads oriented towards target groups after you visit our Platforms. Ads are oriented towards products and services that you clicked on during your last visit to our Platforms.

Google uses cookies to generate interest-based ads. In this process, Google typically stores information such as your web request, IP address, browser type, browser language, and the date and time of your request. This information only serves the purpose of mapping the web browser to a specific device. It cannot be used to identify an individual.

If you do not want to receive user-based advertising from Google, you can disable the placement of ads by using Google’s ad settings.

For more information about how Google cookies are used, please refer to Google’s privacy statement.

3.3.3 Facebook family Custom Audiences

The product Facebook Custom Audiences (Facebook Inc. 1601 S. California Avenue, Palo Alto, CA, 94304) for Facebook and Instagram is also used as part of usage-based online advertising. An irreversible and non-personally identifiable checksum (hash total) is generated from your usage data, which can be transmitted to Facebook for analysis and marketing purposes. A Facebook cookie is set in this process. In doing so, information about your activities on the Platforms (such as surfing behaviour, subpages visited, etc.) is collected. Your IP address is stored and used for geographical modulation.

For more information about the purpose and extent of data collection and further processing and use of data, as well as privacy settings, please refer to the privacy policy for Facebook and Instagram.

4. Who may we disclose your data to?

In general, we will only disclose your Personal Data with your prior consent, when it is necessary for the processing of your requests, for the provision of contracted services, or to comply with our legal obligations.

In particular:
– For the correct processing of your bookings, the data included in such bookings will be disclosed to transport service suppliers or intermediaries responsible for sourcing such transport service suppliers. This may imply the international transfer of your data, if these companies are located outside the European Economic Area.
– We may also disclose data to fraud detection platforms in order to detect and prevent fraudulent payments or bookings.

We may make use of technological solutions or services provided by companies which are outside the European Economic Area for certain functionalities of the Platforms. In this case, we shall adopt the appropriate measures to guarantee an appropriate level of Personal Data protection. In particular:
– We use an administrative platform provided by the Spanish company RideSuite SL (https://www.ridesuite.com/company/legal/privacy-policy/) and its affiliates to manage the allocation of orders to suppliers and oversee fulfilment.
– We use various services provided by Google (https://policies.google.com/technologies/partner-sites?hl=en) and its affiliates. These companies adhere to the Privacy Shield agreement between the EU and the USA. Under this agreement, personal data transferred from an EU company to a company from the United States shall be processed according to a series of well-defined protection standards and safeguards, thereby ensuring an appropriate level of protection. You may check the validity of Google’s accession to the Privacy Shield at the following link: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Please note that all information found in the blog, forums or other engagement tools available on the Platforms shall become public information, so users should take special care when deciding to post comments or share their personal details. The use of these engagement tools is subject to the conditions listed below.

You undertake to make appropriate use of the comment posting feature of the Platforms, agreeing to refrain from posting details and/or comments which:
– Engage in unlawful or illegal activities or those that are contrary to good faith and public order.
– Disseminate content or propaganda of a racist, xenophobic or pornographic nature, or any defending terrorism, or that violates human rights,
– Contain content entailing an infringement of intellectual and industrial property rights,
– Harm the image of third parties,
– Introduce or transmit computer viruses or any other physical or logical systems which may cause damage to the company’s computer systems,
– Use the email accounts or Personal Data of other users and modify or tamper with their messages.

We reserve the right to remove, or not publish, any comments or posts which fail to meet the above-mentioned standards, particularly those which violate the respect for human dignity, which are discriminatory, xenophobic, racist, pornographic, which constitute an attack against youth or childhood, public order or safety or which, in our opinion, are not suitable for publication. We shall not be held responsible for the information stored at the request of users and, in particular, regarding the opinions expressed. Neither are we responsible for the accuracy, quality, reliability and correctness of the information which users may include. Notwithstanding the foregoing, anyone whose Personal Data is included in comments or posts published on the Platforms may request, at any time, the removal of such data, as indicated in the section “What are your rights?”.

5. Legal basis for processing

The legal basis for the processing of your Personal Data is the management of the legal relationship established with you, the provision of requested or contracted services, and compliance with legal obligations, especially those applicable to accounting, taxation, tourism or traveller security and control.

The following data processing is based on a legitimate interest:
– Management of the security of the Platform and our call centre, as well as the adoption of fraud detection and prevention measures based on our legitimate interest in guaranteeing the security of our systems and transactions,
– The monitoring of statistics and quality control, including recordings of calls to or from our call centre, based on our legitimate interest to assess our services,
– The commercial tracking of your requests, the sending of commercial messages and the compilation of commercial databases form our legitimate interest to promote the Transport Services we sell, as well as your consent for receiving such messages by electronic means.
– The analysis of customer ‘s Personal Data is based on the company’s interest in processing this information for internal administrative purposes.

The following processing items are based on your consent, without the withdrawal of such consent conditioning the provision of contracted services:
– The commercial profiling of data for the sending of personalised offers and commercial messages is based on the requested consent;
– Browsing profiles based on information collected from cookies or similar technologies.

6. For how long will we retain your data?

We retain your Personal Data for as long as it is required for you to use our Platforms, to provide our Services to you, and to comply with applicable laws. We will anonymise and/or aggregate your data if we intend to use it for analytical statistical purposes over longer periods.

7. What are your rights?

You have the right to obtain confirmation about whether or not we are processing your Personal Data and, in that case, access such data.
Once you are registered on a Platform, you may check your booking history, as well as access your profile and update the Personal Data you provided at the time of registration.
You may also ask for your Personal Data to be rectified if it is inaccurate or incomplete. In addition, you may request the deletion of your Personal Data if, among other reasons, it is no longer necessary for the purposes for which it was collected.

In certain circumstances, you may request limitations upon the processing of your Personal Data. In this case, we shall only process the Personal Data in question for the formulation, exercise or defence of claims or with a view to protecting the rights of other persons. Under certain conditions, and for reasons related to your particular situation, you may also object to the processing of your Personal Data. In this case, we shall cease to process your Personal Data other than for compelling legitimate reasons which prevail over your interests or rights and freedoms, or for the formulation, exercise or defence of claims.

Similarly, and under certain conditions, you may request the portability of your Personal Data for it to be transferred to another data controller. You may revoke the consent that you had given for certain purposes, without affecting the legality of the processing based on the consent prior to its withdrawal.

To request your withdrawal from processing for commercial purposes you may:
– Update your preferences in your profile, accessible from your Platform account.
– Send an email to the following email address: privacy@bravotransfers.com.
– Use the link provided in our newsletters for this purpose.

At any time you may revoke your consent for geolocation or the installation of tracking or profiling cookies by modifying the privacy options of your web browser or your device. You may learn more about online behavioural advertising and how to manage the privacy of your browser to refuse such processes at www.youronlinechoices.eu. Further information about our cookies policy is available at www.bravotransfers.com/cookie-policy.

You also have the right to file a claim with a data protection authority. You can check the list and contact details of the European data protection agencies on the European Commission website: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

To exercise your rights, you must send us a request accompanied by a copy of your national identity document, or another valid identity document, by postal or electronic mail, to our Data Protection Officer at the addresses indicated in the ‘Who is responsible for processing your data (the data controller)?’ section. You may obtain more information about your rights and how to exercise them on the website of the Spanish Data Protection Agency (‘Agencia Española de Protección de Datos’) at https://www.agpd.es or on the website of the data protection authority of your country.