Working draft. This text describes the actual processing carried out by Rakatanga Tour Europe S.L. It must be reviewed by counsel before being presented as “full compliance”.
Rakatanga Tour Europe S.L., tax ID B37569829, C/ Altamira 11, 36002 Pontevedra, Spain. Publisher: Pablo Álvarez. Contact: contact@rakatanga-tour.com.
Rakatanga runs adventure motorcycle trips (Nepal, Mongolia, Mustang, India and other itineraries outside the European Union). The public site, the traveller area and the agency back-office serve that activity.
There is currently no newsletter signup, mobile app or targeted advertising. No marketing programme is described here because no opt-in is already in place. Holded (accounting) is planned, not yet connected.
Identity and contact details; booking and payment data (amounts, Redsys references, not the full card number); files uploaded in the traveller area; messages with the agency; technical logs. Identity scans are encrypted at rest (AES-256-GCM).
Holded is not a recipient until it is connected.
Yes, when the trip takes place outside the EEA (Nepal, Mongolia, Mustang, India, etc.): sharing with local partners that is necessary for the contract, which you are told about before departure. Encrypted backups currently stay on the server. An upload to Cloudflare R2 object storage (US company, EU-jurisdiction bucket, file already encrypted by us) is only enabled if that EU bucket exists; it does not on this copy.
Invoices sent to us by our suppliers are read by an automatic service: OpenRouter, a company established in the United States, which passes the document to Google’s model. Each request asks for the option that forbids the service from keeping the document or using it to train its models. We do not guarantee the country in which the document is processed. These invoices contain no traveller data, and nothing is recorded until someone at the agency has reviewed and confirmed it on screen.
The back office also includes a legal assistant reserved for the agency’s team. The legal and tax questions the team asks it are sent to the same service, which passes them to the model chosen by the person (Google, OpenAI or Mistral). Each request asks for the same option, which forbids keeping the exchanges or using them to train models. Before sending, a filter rejects any question containing an e-mail address, a telephone number, an identity document number or a client’s name. The exchanges are not kept beyond the working session. Only the cost of each question is recorded, never its content.
Access, rectification, objection, restriction, portability, erasure within legal limits (including the duty to keep accounting records). Response time: one month. Complaint to the Spanish Data Protection Agency (AEPD). You can exercise these rights from your traveller area (dedicated form): the request is sent to the agency, which handles it by hand. It does not by itself destroy your billing information.
Google Analytics and advertising pixels have been removed from the site. Session cookies remain for the traveller account, the booking flow and the admin session. No advertising banner and no marketing-consent collection.
Scan access limited to the agency and the traveller concerned; AES-256-GCM encryption of identity documents at rest; download decrypted in memory, with no clear file in a web folder; daily encrypted backup (database and document folders), kept outside the web root, 7 days. If the encryption key is missing, an identity upload is refused (the scan is not written in the clear “in the meantime”).