This Policy applies to the processing of personal data collected by ESCALA VACATIONS, (hereinafter, the “Company”) in order to warrant the personal data protection rights from Users.



a. “Personal Data means any information relating to and identified or identifiable natural person or legal entity, including, without limitation, name, address, telephone number, e-mail address, IP address, business contact information, social security number, driver’s license number, credit card information, financial account number or other financial information, or medical or health-related information.

b. “Processing of Personal Data shall mean and include any operation or set of operations which is performed upon Personal Data by the Company, whether or not by automatic means, such as collection, recording, organization, storage, accessing, consultation, use, transmission, transfer, or destruction.

c. “Useris a client or any third party that has provided Personal Data to the Company in order to require its services.



The Processing of the Personal Data will have the following purpose:

a. Provide the services offered by the Company to Users and keep records of such relationship;

b. Verify the identity of Users and contact them;

c. Administration and billing;

d. Customer service and support;

e. Comply with legal, regulatory and contractual obligations;

f. Promotion and publicity;

g. Implement security measures in order to prevent frauds;

h. Provide Personal Data to suppliers and/or contractors that work on behalf of the Company in order to execute the services required by Users. The Company will ensure that suppliers and contractors are contractually required to take appropriate technical and organizational measures to protect Personal Data against unauthorized or unlawful processing and against accidental loss or destruction of, or damage to, Personal Data.

Personal Data is protected under data protection law and Users have the following rights:

a. Right of Access: Users have the right of access to their Personal Data processed by the Company;

b. Right to Rectify the Personal Data: In case Personal Data is inaccurate or incomplete, Users have the right to require any rectification of their Personal Data processed by the Company.

c. Right to be Forgotten: Users may require to the Company to delete their Personal Data in certain circumstances, such as, when Personal Data is no longer necessary to be collected by the Company in relation to its original purpose or when Personal data have been unlawfully processed.

d. Right to Restriction of Processing: Users have the right to obtain restriction of the processing of Personal Data in certain circumstances, such as, when the Company is verifying the accuracy of the Personal Data.

e. Right to Data Portability: Users have the right to receive, move, copy or transfer their Personal Data to another company when the Company is processing the Personal Data by automated means.

f. Right to Withdraw Consent: Users have the right to withdraw their consent to process the Personal Data by the Company. However, if Users do not agree to provide their Personal Data, the Company may not be able to provide its services to such Users.



In case of any queries or claims about the processing of Personal Data, the Company shall provide the information required by Users within ten (10) working days from the date it is received. Users shall send any query or claim to the Company through a written communication, providing its identification and complete description of the events.



The Company will ensure the security of the Site and Personal Data by taking appropriate technical and organizational measures against unauthorized or unlawful processing, accidental loss, destruction and damage. Only Company’s personnel and contractors will have access to Personal Data subject to confidentiality obligations.



If any of the terms and conditions of this Policy is deemed unlawful, void or for any reason unenforceable, then that provision shall be void and shall not affect the validity or enforceability of the remainder of the terms and conditions herein established.



The Company may revise this Policy at any time by amending this page. Users are expected to check this page from time to time to take notice of any changes we make, as they are binding on Users. Some of the provisions contained in this Policy may also be superseded by provisions or notices published elsewhere on the Site.



This Policy shall be governed by and construed in accordance with the laws of the State of Florida, United States of America. The Users shall submit to such jurisdiction any legal action related to this Policy.



Users may submit their queries and/or claims through the following email address:


Effective Date: March 2nd, 2020.


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