This privacy policy (hereinafter, "Privacy Policy") has been drafted by GRUPO ATLANTGO in order to comply with the duty of transparency in the processing of personal data that may be carried out by the companies that make up the ATLANTIGO GROUP, in accordance with the provisions of 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 (hereinafter referred to as "GDPR"), and the other regulations that complement it.

 The information contained in this Privacy Policy allows you to consult the details of the different processing of your personal data that may be carried out as a result of accessing and using the www.mana-uw.com website (hereinafter, the "Website"), as well as the different legal or commercial relationships that you may maintain with the companies that are identified below with MANAUNDERWRITING, S.L.U.

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1. Data controllers

Through this website you will www.mana-uw.com be able to contact the following companies of the ATLANTIGO group, so the person responsible for the processing of the personal data you provide us will be, depending on the case:

 MANA UNDERWRITING, S.L.U.

NIF: B88549134

Domiciled at C/ Irún 7, 1 28008 Madrid and authorised by the Directorate General of Insurance, Reinsurance and Pension Funds (DGSFP), Code AS0106.

Email: lopd@mana-uw.com

Hereinafter, the "Data Controller" or "MANA"

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2. Need to provide personal data

We inform you that mere access to the Website does not imply an obligation to provide any personal information, except as provided in the Cookies Policy.

However, the use of some services or functionalities of the Website does require you to provide certain personal data, indicated in the corresponding forms, and implies its processing for the purposes and legal bases indicated in this Privacy Policy.

The refusal to provide the data required in these cases may mean that it is impossible to provide some services or functionalities, or to process the applications or contracts made, especially in those cases in which they are identified as mandatory.

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3. Liability of the data subject

The interested party guarantees:

1. That you are over eighteen (18) years of age and that the data you provide to the DATA CONTROLLER are true, accurate, complete and up-to-date. To this end, the user is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to their real situation.
2. That it has informed the third parties of which it provides its data, if it does so, of the aspects contained in this document. Likewise, it guarantees that it has obtained its authorisation to provide your data to the DATA CONTROLLER for the purposes indicated.
3. That the data and information provided are truthful and accurate. To this end, the user is liable for any false or inaccurate information provided in the communication of the data provided and for any damages, direct or indirect, that this may cause to the DATA CONTROLLER or to third parties.

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4. Purpose of processing

The personal data provided by users may be processed in accordance with the purposes detailed below and on the basis of legitimacy indicated:

1. Contact with users

Purpose: when you give your consent by sending forms made available to you on the website, by sending messages through the contact channels, your data will be processed in order to respond to queries or requests sent, to provide you with assistance, to maintain contact, to manage communications with you, to improve the quality of technical and commercial service, To deal with possible complaints.

Legal basis: the legitimacy of the processing described is the existing contractual relationship and the consent granted by the user, which can be withdrawn at any time without affecting the lawfulness of the processing prior to its withdrawal.

Data processed: identification data (name and surname), contact data (e-mail, telephone) and others (subject, and data provided in the contact request).

2. Web statistics.

Purpose: when you give your consent for the processing of your data provided through the installation of statistical, advertising and/or behavioural data storage and retrieval devices (hereinafter, "Cookies") when you access the Website, these will be used to compile aggregate data reports, for statistical and analytical purposes by MANA, as reflected in the Cookies Policy. The statistics prepared will be aimed at carrying out an evaluation of the performance of MANA's business, as well as keeping an effective control of its efficiency. In this sense, the result of the processing for statistical purposes will not be personal data, but aggregated and anonymised data. 

Legal basis: the legitimacy of the processing described is consent, which you can withdraw at any time without affecting the lawfulness of the processing prior to its withdrawal.

Data processed: the data indicated in the Cookies Policy will be processed.

3. Preparation of service proposals and budgets.

Purpose: when requesting a quote on the services that are the object of MANA's activity, it will be necessary to process your personal data in order to manage them in order to proceed with the contracting of the services offered, insurance contract, through us.

Legal basis: this processing is necessary for the application of pre-contractual measures, this being the legal basis that legitimises the processing.

Data processed: identification data (name, surname) and contact details (telephone and email).

 4. Commercial contact and newsletter. Satisfaction surveys,

Purpose: the purpose of sending commercial communications will be to provide commercial information from MANA on its products or services and on issues related to tourism and the insurance sector.

Legal basis: for non-customer users, it is based on the consent they have provided for this purpose. For users who have already contracted with us, our legitimacy to send communication is with offers similar to those already contracted is based on the exception contained in art. 21.2 of Law 34/2002, of 11 July, on information society services and electronic commerce, without the need for their express consent. 

In both cases, the interested parties may at any time express their opposition to this type of processing, communicated to any of the addresses informed in this privacy policy, both at the time of collection of the data and in each of the commercial communications that we send to them, without in any case the exercise of this right conditioning the execution of the contract that may have been carried out prior to this exercise.

In order to carry out satisfaction surveys and market analysis, our legitimacy is based on the legitimate interest of the Data Controller, in order to better meet your expectations as a customer and enhance the quality of the service received. You may object at any time to this type of processing in the manner described in the previous section.

Data processed: for this purpose: identification data (name, surname). Contact details (telephone and email).

5. Preparation of statistics and risk assessments.

Purpose: for the preparation of statistics and risk assessments for statistical-actuarial purposes and for the development of new products, it responds to the legal obligations provided for in insurance regulations (among others, Royal Decree 3/2020 of 4 February regarding the distribution of insurance). ‍

Legal basis: The legal basis for the transfer of data to third parties is made up of provisions of the insurance regulations that either protect the legitimate interest of the entity or impose specific obligations on it for the development of its activity, both in relation to the insurance contract (Law 50/1980 on Insurance Contracts), as well as in the insurance distribution regulations (Royal Decree 3/2020, of 4 February, with regard to the distribution of insurance) and other regulations governing the activity.

Data processed: forthis purpose, data relating to personal characteristics (age) and data relating to the contracting of the product (type of sale, destination, duration of the trip and amount of the booking) will be processed.

6. Security of systems AND NETWORKS

Purpose: MANA will process your data to prevent fraud and guarantee the security of the network and information.

Legal basis: this processing is necessary for the satisfaction of MANA's overriding legitimate interest in resisting accidental events or unlawful or malicious actions that compromise: the availability, authenticity, integrity and confidentiality of the personal data stored or transmitted in its information systems and networks; and the security of related services offered by, or accessible through, these systems and networks by public authorities and providers of security technologies and services.

Data processed: this purpose will require MANA to process the data described in this Privacy Policy.

7. Selection processes.

Purpose: your personal data will be processed for the purpose of assessing and managing your candidacy and, where appropriate, carrying out the necessary actions for the selection and hiring of personnel, in order to offer you positions that fit your profile.

Legal basis: the legitimacy for the processing of your data by MANA in open selection processes will be the application of pre-contractual measures, without requiring your consent.

For the conservation of the data for future selection processes, the legitimacy will be the unequivocal consent granted by the candidates for inclusion in the MANA database, which can be withdrawn at any time.

Data processed: Identification data (name, surname, ID and image), contact data (telephone, email, postal address), personal characteristics (date and place of birth, age, sex, nationality, physical characteristics, etc.) and academic/professional data (training, qualifications, student history, professional experience, membership of professional colleges or associations, profession, jobs, employee history).

8. Whistleblowing channel.

Purpose: The data will be processed exclusively for the purpose of responding to the notification of the internal complaint submitted through the online complaints channel enabled for this purpose by Grupo Atlantigo, and may not be used for any purpose other than that intended.

Legal basis: MANA is subject to compliance with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory and anti-corruption infringements, which you can find access from the website, with respect to the principle of proportionality and limitation of the purpose without, in any case, is used for a purpose other than that intended for the implementation of the system.

Data processed: if the user decided to make their complaint in a way that is not anonymous, identification data (name), contact details (telephone) and others (relating to the description of the facts they report).

5. Recipients

 Personal data may be communicated to the following entities or in the following cases:·       

To our service providers, necessary to fulfill the purposes described above and provide you with the requested services. These providers will not process your data for their own purposes that have not been previously informed by the Data Controller.

• Insurers that offer the contracted coverage and Servisegur Consultores S.L.U. for the processing of claims.
• In compliance with the legal obligations attributable to the Data Controller, your data may be communicated to the Public Administrations in the cases provided for by Law.
• To the companies belonging to the ATLANTIGO GROUP (IntermundialXXI S.L.U, IM Travel Risk Solutions, S.L.U., IM Travelers Club, S.L.U., Servisegur XXI Consultores S.L.U, Tourism & Law Abogados S.L.P), all of them with registered office at C/ Irún 7, 1º, CP: 28008, Madrid, Spain, solely for administrative-internal purposes and/or for the purposes described above.

6. Personal data of third parties.

If third-party data is provided by users, the interested parties must inform them in advance of the aspects contained in this document. Likewise, you guarantee that you have obtained your authorization to provide your data to MANA for the purposes informed in this privacy policy. In any case, the data processed will only be those that are essential and necessary.

7. Retention of your data

 Your data will be kept for the duration of the insurance contract. After its completion, they will be kept blocked for the periods legally required to attend to possible liabilities arising from their processing.

Once the legal limitation periods have elapsed, the data will be deleted.

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8. International transfers

 If you require assistance and are outside the European Union, it may be necessary to transfer your personal data to third countries in order to effectively comply with the guarantees of your insurance contract. In the event that your data is transferred outside the EEA in the future, we will apply all safeguards set out in applicable data protection regulations to maintain the confidentiality and security of your data.

10. Rights of individuals

You have the right to access your personal data subject to processing, as well as to request the rectification of inaccurate data or, where appropriate, to request its deletion when the data is no longer necessary for the purposes for which it was collected. You may also exercise your rights of opposition, limitation of processing and data portability.

You may exercise your rights by writing to the data controller, by e-mail lopd@mana-uw.com or, if you prefer, by post to the address indicated in the header (it is advisable to state the reference "Data Protection" on the envelope). In all cases it will be essential that you attach a copy of your ID card or passport. In the event that you do not obtain satisfaction in the exercise of your rights, you may file a complaint with the Spanish Data Protection Agency (www.agpd.es).

11. Updating the Privacy Policy

 The Data Controller reserves the right to modify this Privacy Policy in order to adapt it to its needs or to any new legislation that may be appropriate.

In such cases, it will publish them on this Website, so that you can access them at any time and in a simple way.

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Last updated: June 2024.