Privacy Policy

Effective Date: August 01, 2025

1. Introduction

The company responsible for processing your data according to this Privacy Policy is WEBSKY TECH S.L. (“Company”), with NIF B55739825, located at Av. de la Via Augusta, 15-25 08174 Sant Cugat del Vallès, Barcelona, Spain. The Company is committed to protecting your personal information and processing it responsibly and in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

Data Processing Roles

Data Controller: WEBSKY TECH S.L. acts as a data controller when customers sign up for our product and services, including Paximizer. We determine the purposes and means of processing their data for providing services, communication, improvement, and marketing (with consent).
Data Processor: When customers use our products and services to manage data of their clients, the Company processes personal information on behalf of these customers, who act as the data controllers. Processing is performed strictly under customer instructions and in accordance with our Data Processing Agreement.

2. What personal information we collect and process

As used in this Policy, “Personal Data” or “Personal Information” refers to any information that relates to, identifies, or can reasonably be used to identify an individual, directly or indirectly. We collect information relating to various groups of individuals. Below is a breakdown of the types of data we collect from each group.

2.1.Information we process on behalf of customers when they use our product

Our product allows our customers to create and share marketing, sales and customer service content. When customers use our product, they may process Personal Data such as first and last name, email address, physical address, phone number, or other information about you. We generally store and process information about and on behalf of our customers on our servers as a data processor (or service provider) based on a customer’s instructions. Each customer is responsible for the information they process using the product and for complying with all regulatory requirements or laws that require notice, disclosure and/or consent prior to transferring the Personal Data to the Company for processing purposes. If you have questions about the Personal Data we process on behalf of a customer, please contact the customer directly and refer to their policies.

When our customers input your travel information into Paximizer, we may also collect:

Basic profile data (name, date of birth, gender)
Contact details (email, phone numbers)
Document information (passport details, ID numbers)
Travel details (bookings, itineraries, preferences)

2.2. Website and Product Users

When you interact with our websites or applications, we may collect:

Profile information (name, email, job title)
Device and usage data (IP address, browser type, operating system)
Interaction data (pages viewed, features used, time spent)
Marketing preferences
Cookie and tracking technology data
Form submission data

2.3 Business Contacts and Contractors

When working with us as a service provider or business partner, we may collect:

Business details (name, position, company)
Contact information (corporate email, phone number)
Financial information (bank account details for payment)
Contract details and service history
Communication records

2.4 Job Applicants

When you apply for a position with us, we may collect:

Personal identifiers (name, date of birth, place of birth)
Contact information (email, phone, address)
Professional background (work history, education, qualifications)
Assessment information (interview notes, test results)
References and background check information (where legally permitted)
Right to work verification

2.5 Employees

For our team members, we collect:

Personal details (name, date of birth, identification numbers)
Contact information (personal and emergency contacts)
Employment details (position, department, performance records)
Financial information (salary, banking details, tax information)
Professional development information
Device and system access logs

3. How we use your personal information

3.1 When Acting as a Data Controller

When we act as a data controller, we determine the purposes and means of processing personal information. We use personal information for the following purposes:

Provision of Services: We collect and process personal information to create and manage user accounts, facilitate travel arrangements through Paximizer, process payments, provide customer support, respond to inquiries, and personalize user experiences to enhance service delivery.
Business Operations: We analyze usage patterns to improve the performance and quality of our products and services, ensure the security and integrity of our systems, maintain business records, conduct internal audits and investigations, and enforce our terms, conditions, and policies.
Communications: We process personal information to send service notifications, updates, and legally required communications. We also respond to user requests and questions, provide information about products, services, or features, and—where appropriate and with consent—send marketing and promotional communications. Additionally, we conduct surveys and collect user feedback to better understand and improve our offerings.
Legal and Compliance Obligations: We process personal data as necessary to comply with applicable legal obligations, establish, exercise, or defend legal claims, prevent fraud and abuse, verify identities, and perform due diligence activities.

3.2 When Acting as a Data Processor

When our customers use our products and services to manage passenger data, we process personal information strictly on their behalf, in accordance with our customers' instructions and the terms of our Data Processing Agreement. In this capacity, we may process information such as passenger names and contact details, travel arrangements, identification documents, and travel preferences or special requests. We do not use this data for any purpose other than to fulfill our contractual obligations to our customers.

3.3 Sources, Purposes, and Legal Bases for Processing Personal Information

We collect personal information through a variety of channels, depending on predefined purposes or in compliance with applicable data protection laws. Personal information is collected directly from users of our web resources, potential or existing clients, their authorized representatives, or interested third parties, for purposes such as entering into contracts, maintaining communication, conducting analytics, providing information, and delivering services. We also collect information directly from individuals applying for employment with the Company, in connection with candidate assessment, selection for available positions, and maintaining a talent pool. Personal data is obtained directly from employees to fulfill obligations under labor, accounting, and social security laws, as well as to meet employer responsibilities and ensure workplace safety. Additionally, we collect information from contractors and business partners to meet our contractual obligations, and from third parties providing services to the Company under confidentiality and data processing agreements.

We may receive personal information from government authorities when necessary to comply with legal requirements and obligations. Furthermore, we may gather data from publicly available sources for purposes such as conducting analytics, hypothesis development and testing, and the creation of personalized service offers.

We process personal information only where there is a lawful basis to do so. This includes cases where:

The data subject has provided explicit consent for one or more specific purposes;
Processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject prior to entering into a contract;
Processing is necessary to comply with a legal obligation to which the Company is subject;
Processing is necessary to protect the vital interests of the data subject or another natural person;
Processing is necessary for the performance of a task carried out in the public interest;
Processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, provided that such interests are not overridden by the data subject’s fundamental rights and freedoms, particularly where the data subject is a child.

4. How we share your personal information

4.1 Service Providers:

We may share Personal Data with trusted third-party service providers who assist us in operating, maintaining, and improving Paximizer, our website, and related services. Examples of service providers include those offering:

Data hosting and cloud infrastructure,
Application development, maintenance, and support,
Marketing and communication services,
Customer relationship management and support,
Payment processing.

These providers are contractually obligated to use your Personal Data solely for the services they provide to us and must maintain the confidentiality and security of your information in accordance with applicable data protection laws and our own policies.

4.2 Business Partners:

We may share your Personal Data with our selected business partners to:

Provide you with relevant offers or promotions,
Support sales and customer service activities,
Perform joint marketing initiatives,
Improve our services and partner programs.

All partners are required to adhere to confidentiality obligations and may only process your Personal Data for the purposes described..

4.3 Advertising and Analytics Partners:

We may allow advertising networks and analytics service providers to collect information about your interactions with our websites and services to deliver personalized advertising and analyze usage trends. Where required by law, we will obtain your consent before sharing information for these purposes. You may opt out of certain types of data sharing with advertising partners by adjusting your cookie preferences or contacting us directly.

4.4 Corporate Transactions:

If Websky Tech S.L. is involved in a merger, acquisition, sale of assets, bankruptcy, or other business transition, your Personal Data may be transferred as part of that transaction. In such cases, we will provide notice before your Personal Data is transferred and becomes subject to a different privacy policy.

4.5 Legal Obligations and Protection of Rights:

We may disclose your Personal Data if required to do so by law, regulation, or legal process (e.g., a court order or subpoena).

We may also disclose data if we believe it is necessary to:

Protect the rights, property, or safety of Websky, Paximizer users, or others,
Detect and prevent fraud,
Respond to law enforcement or government authority requests.

4.6 Affiliates and Group Companies:

We may share your Personal Data with our subsidiaries, and affiliates under common ownership and control, for purposes consistent with this Privacy Policy, such as internal business operations, service improvement, and support.

5. How we transfer your personal information

At WEBSKY TECH S.L. we process your data within the European Economic Area and generally we have service providers located within the European Economic Area or in countries determined to have an adequate level of data protection. When we transfer personal data outside the European Economic Area (EEA), we implement appropriate safeguards, which may include:

Standard Contractual Clauses approved by the European Commission
Binding Corporate Rules
Transfers to entities certified under an approved framework such as the EU-U.S. Data Privacy Framework (where applicable);
Other legally valid contractual mechanisms approved under GDPR Article 46.

6. How we store and secure personal information

We implement appropriate technical and organizational measures to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:

Technical Safeguards

Encryption of data in transit and at rest
Robust authentication and access controls
Regular security testing and monitoring
System redundancy and backup procedures
Advanced threat protection systems

Organizational Controls

Employee data privacy training
Access limitation based on need-to-know principle
Regular security audits and assessments
Incident response procedures
Vendor security assessment

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, including to meet legal, regulatory, tax, accounting, or reporting requirements. How long we keep specific types of information depends on the nature of the data and the purposes for which we process it.

When we no longer have a legitimate business need to retain your personal data (for example, to comply with legal obligations, resolve disputes, or enforce agreements), we will either delete or anonymize it. If deletion or anonymization is not immediately possible—due to technical limitations or legal requirements—we will securely store your data and isolate it from further processing until deletion is feasible.

You may request earlier deletion of your data, as described in the “Privacy Rights and Choices” section, subject to applicable legal exceptions.

7. Your Privacy Rights

Depending on your location and applicable data protection laws, you may have the following rights regarding your personal information:

Right to Access: You can request confirmation of whether we process your personal information and obtain a copy of that information.
Right to Correction: You can ask us to correct or update inaccurate or incomplete personal information we hold about you.
Right to Deletion: In certain circumstances, you can request that we delete your personal information, such as when it is no longer needed for the purposes for which it was collected.
Right to Restrict Processing: You may request that we limit the processing of your personal information in certain situations, such as when you contest its accuracy or object to its use.
Right to Data Portability: Where applicable, you can request a copy of your personal information in a structured, machine-readable format and request that it be transferred to another service provider.
Right to Object: You can object to our processing of your personal information in certain cases, including where we are relying on our legitimate interests. You can also object to receiving direct marketing communications at any time.
Right not to be subject to automated decisions: You may have the right to request human review of decisions made solely through automated processing, where such decisions have a significant legal or similar effect.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request in accordance with the laws that apply to your jurisdiction and within any legally required timeframes.

Limitations

Please note that these rights may be subject to limitations. We may retain or continue processing certain information if, for example:

We are legally required to retain it;
It is necessary to defend legal claims;
It is needed to protect the rights of another person;
There are other overriding legitimate interests or legal bases.

If your personal information was collected or processed on behalf of one of our clients using Paximizer, that organization is responsible for managing your data. In such cases, please direct your privacy-related requests to them as the primary data controller.

8. Children Privacy Policy

Anyone providing data through the forms on this website and accepting the processing of such states that he/she is at least 14 years old. Access to, and use of the website is prohibited for anyone younger than 14. If, at any time, the Data Controller detects that a person younger than 14 years of age has provided personal data, we will cancel said data. In addition, parents or tutors may in any event write to WEBSKY TECH S.L. to block any access account created by minors in their charge who have registered by falsifying their identity.

9. Cookies

A cookie is a small file that is downloaded and stored on the user’s computer when he/she access a website. Cookies allow the website, amongst other things, to store and recover information on the browsing habits of the user or of his/her computer and, depending on the information they contain and the way in which you use your computer, they may be used for user recognition. The user has the option to prevent the generation of cookies, by selecting the corresponding option in his/her browser program. You can obtain more information by reading our Cookies Policy.

10. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. The updated version will be indicated by an updated "Last Modified" date at the top of this page. We encourage you to review this Privacy Policy regularly. For significant changes, we will provide a more prominent notice, which may include an email notification to our customers or a banner on our website.

11. Contact Information

If you have questions about this Privacy Policy or our data practices, please contact us:

General Inquiries:

Email: [email protected]

Web: https://websky.tech/contacts

Phone: 93 737 78 18

Data Protection Officer:

For specific privacy concerns or to exercise your data rights, you can contact our Data Protection Officer at [email protected].