MWR Life – Privacy Policy

This Privacy Policy provides an overview of all information regarding the processing of personal information by MWR Marketing, S.A., a company registered in accordance with the laws of Panama, hereafter referred to as MWR Life, we, our or us. 

MWR Life is strongly committed to protecting your privacy and complying with your choices. You will be in full control of all data relating to yourself. Both personal and non-personal data is  safeguarded  according  to  the  highest  privacy  and  data  protection  standards  adopted worldwide. These expressly include the California Consumer Privacy Act 2018 (CCPA) and the EU General Data Protection Regulation (GDPR). 

We strive to make you feel safe when we collect or share your data and therefore, we want to be transparent on how we collect, use, share, and store the information about you and the choices available to you as data subject. 

This Privacy Policy relates to all of the MWR Life services offered through our website.

  1. Collection and processing of personal data

To offer you the functionalities of the website and for the technical and functional management thereof.

(i)  Why?

We strive to make our website easily accessible and to offer you the best possible experience and functionalities. We process technical data of everyone who visits and uses our website in order to manage it and improve its performance. We may also need to process your personal data so that you can save your data (or preferences such as language and currency) to configure your device to give you a personalized experience. The functionalities of the website are largely made available through the use of cookies. You can read more about our use of cookies in our Cookie Policy.

(ii)  How?

We process your personal data for this purpose based on your consent. Upon visiting our website, you will be prompted to consent to the use of cookies. It is also possible to refuse all cookies, although this may affect the functionalities of the website. There are certain cookies, those indicated as ‘necessary’ that we do not need your consent for, and these will be used by default. 

(iii)  What?

We  process  all  personal  data  that  you  have  entered  on  our  website  or  that  is generated by the use of our cookies, including your IP address and which internet browser you use. 

(iv)  How long?

Storage  for  this  purpose  differs  per  cookie.  Please  read  more  on  cookies  below. However, data gathered for this purpose shall never be stored for longer than 2 years.

For answering your questions and handling complaints

(i)  Why?

If you contact us at our office, whether via email or phone, through a contact form, or via the live chat on the website, we will use your personal information to answer your question or to handle a complaint.

(ii)  How?

We  process  your  personal data  based  on  consent  and  legitimate  interest.  Where possible, we will ask for your consent before you contact us, such as through the contact form. In any other case, our legitimate business interest is formed by our intention to handle your complaints and questions carefully in order to properly run and improve our business.

(iii)  What?

We process your name, contact details, your correspondence with us about your question or complaint and all other personal information that is required to answer your question or handle your specific query and/or complaint. If you include any further personal data in any message or correspondence with us, we may process this as well.

(iv)  How long?

We keep your personal data for as long as necessary to complete your request or handle the complaint, plus an additional month, after which the data will be removed from our systems.

For relationship management and marketing

(i)  Why?

We may use the information provided by you when you contract to use our services for marketing purposes, such as the provision of newsletters. We use your personal data for the development, execution and analysis of market research and marketing strategies. Finally, we may use anonymized data to analyse our services and publish the results on our website or otherwise.  

(ii)  How?

We process your personal data for this purpose based on your consent. You can withdraw your consent at any time. Under certain circumstances we may process personal data for this purpose without your consent if we have a legitimate business interest to do so.

(iii)  What?

For this purpose, we process your contact details such as your e-mail address and personal  details  such  as  your  name,  testimonials,  use  of  our  services,  contact preferences, and correspondence with us.

(iv)  How long?

Personal  data  is  stored  for  a  maximum  of  10  years  after  the  termination  of our relationship. After this period, your personal data will be deleted from our systems.

To set up an account for you on our website

(i)  Why?

In order for you to make the best use of our services, we will set up your account on the Travel Advantage website. Please read below under Section 4 about the sharing of data with third parties.  

(ii)  How?

Data will be processed on the basis of your consent. We also process data for this purpose based on our contract with you, which is established once you accept the applicable Terms of Use. Finally, personal data is processed where this is in our legitimate business interest. 

(iii)  What?

We will process your contact details such as your email address, address, and phone number; and personal details such as your name and preferences. When setting up your own profile, you may choose to provide further personal data, such as a bio, profile image, country flag, and further details you willingly choose to include.

(v)  How long?

We will retain your personal data for this purpose for as long as you maintain your relationship with us, and for at least 7 years.

To process your payment

(i)  Why?

When you sign up to become a MWR Life member, we need to be able to perform our legal  obligations  in  order  to  deliver  our  services  to  you  and  to  establish  the commercial  relationship.  We  process  your  personal  data  to  execute  your subscription, process your payment, and for administrative purposes such as sending invoices. 

(ii)  How?

Data will be processed on the basis of your consent. We also process data for this purpose on the basis of our contract with you, which is established once you accept the applicable Terms of Use. Finally, personal data is processed where this is in our legitimate business interest. 

(iii)  What?

For this purpose, we process your contact details such as your address, telephone number  and  e-mail  address,  personal  data  such  as  name,  payment  and  credit information, order history and other data stored in our database with all relations of MWR Life.

(iv)  How long?

Your  personal  information  will  be  stored  for  up  to  7  years  after  the  end  of  our relationship with you. After this period your personal data will be deleted from our systems.

Processing of personal data for legal purposes

In some circumstances, we need to process personal data for regulatory investigations and compliance purposes. This also helps to keep our website and services safe and secure. Among other things, we want to prevent fraud and illegal activity through our services. 


  1. The categories of personal data we collect

As set out above under Section 1 of this Privacy Policy, the personal data we collect and process can be organized under the following categories. These categories are as specified under the CCPA but will apply equally to all users irrespective of their location. 

  1. Identifiers such as your first and last name, date of birth, email address, and IP address;
  2. Contact details such as your phone number and address;
  3. Financial, medical, or health details such as your bank account number or payment card number;
  4. Internet or other electronic network activity such as the device you use and the usage of our website;
  5. Commercial  details  such  as  your  booking  and/or  purchase  information  and  order history.
  6. Geolocation data such as your physical location;
  7. Inferences such as analytics and language/currency preferences;
  1. Our use of cookies

MWR Life uses cookies on its website. A cookie is a small and simple file that can be stored on the hard drive of a computer. The cookies used by MWR Life are only temporary, not permanent.

If you want to learn more about the cookies we use on our website, please visit ‘Cookie Settings’ on our website to access the cookie banner. Here, we have listed all the cookies that are active on the website, and you can indicate your preferences. 

You can set your browser to inform you as soon as you receive a cookie or to deactivate cookies. This might mean that our websites may not function optimally.

We give you the possibility to give your consent to the use of cookies when you first access the website. If you, at a later point in time, wish to disable these cookies, you can follow the instructions below. You can also set your browser to notify you as soon as you receive a cookie or to deactivate cookies. In doing so, it is possible that our website will not function optimally. 

Here  we  offer  some  specific  information  about  cookies  for  the  most  commonly  used browsers, and more specifically, how to disable these:

Cookies and Internet Explorer, see: https://privacy.microsoft.com/en- us/privacy#maincookiessimilartechnologiesmodule

Cookies and Firefox, see: https://support.mozilla.org/en-US/kb/enable-and-disable- cookies-website-preferences

Cookies and Google Chrome, see: https://policies.google.com/technologies/managing?hl=en

Cookies and Safari, see: https://www.apple.com/legal/privacy/en-ww/cookies/ Cookies and Opera, see: https://help.opera.com/en/latest/web-preferences/

  1. Which third parties get access to your personal data?

Within MWR Life, our employees, contractors, agents and directors have access to personal data, but only to the extent necessary to properly perform their individual tasks. Where necessary, these individuals are bound to the necessary privacy, confidentiality, and data protection obligations. 

MWR Life only shares personal information with third parties if it is necessary to serve the applicable purpose as set out above. When a third party processes your personal data, this is only possible according to the instructions of MWR Life. By accepting this Privacy Policy, you consent to such use of your personal information by these third-party service providers. They therefore act as our data processor. In all cases, we will ensure that third parties with access  to  your  personal  information  have  implemented  appropriate  technical  and organizational measures to maintain our intended level of privacy and security. We will conclude  the  necessary  agreement  with  the  data  processor(s),  whereby  we  include obligations to ensure that your personal data is only processed so that the data processor can fulfil his duty to provide services to us.

Under these conditions, the following third parties will have access to your personal data:

•          Information  regarding  your  use  of  the  website  and  other  information  gathered through  cookies  is  shared  with  web  analytics,  session  recording,  and  online marketing services. Read more about the use of cookies in our Cookie Policy.

•          As part of our services, we will set up an account for our members with our business partner Travel Advantage. Details shared with Travel Advantage include your full name,  contact  details,  payment  details,  and  any  other  details  you  have  provided through the sign-up form on our website. 

•          To support our operations, we make use of service providers. These service providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. They may track your online behavior over time and across different internet websites or online services.

•          Payment  service  providers  will  collect  and  process  personal  data  to  assist  with transactions that take place on our website. 

•          We use professional advisors such as insurers, consultants, and legal professionals.

In all other cases, your personal information will not be provided to third parties, unless required by law. 

  1. Transfer of your personal data 

For EU users, whenever we transfer your personal data to countries outside of the European Economic Area (EEA), we will do so in accordance with the GDPR. Any party located outside of the EEA will have to enter into the EU Standard Contractual Clauses alongside any data processing agreement they enter into. 

  1. How do we secure your personal data?

Your personal data is stored securely at all times. We value the protection or your privacy. We have therefore taken strong security measures to protect your data from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We further ensure that personal data will only be accessible to those individuals within our business who are authorized based on their function.

We have implemented technical and organizational measures to guarantee your safe visit to and use of our website. These measures include computer security and protected files and facilities.  We  regularly  make  backups.  Your  connection  to  the  website  is  safe  through activation of Secure Socket Layer (SSL). 

MWR Life has processes in place to prevent, identify, report, and handle data protection breaches. However, in the event that a breach occurs, MWR Life will, without undue delay and  if  possible,  within  72  of  becoming  aware  of  the  breach,  report  said  breach  to  the appropriate data protection authority. 

  1. What are your rights?

As the owner of the personal data, you have the following rights:

•          Right of access: You have the right to receive a copy of the personal information we hold about you to verify that we are lawfully processing the data.

•          Right to correction: You may request any incomplete or incorrect information that we may have about you to be corrected or supplemented.

•          Right to be "forgotten": If there is no good reason to keep your personal information, we will stop processing. You also have the right to ask us to delete your personal information.

•          Right to limit the processing of your personal data: You can submit a request not to process your personal data, either temporarily or permanently.

•          Right to portability: You can submit a request to transfer your personal data to a person or institution designated by you.

•          Right to object to processing: Under certain circumstances you can object to the processing of personal data altogether.

•          Right to withdraw consent: You also have the right to withdraw your previously granted permission to process your personal data or to object to the processing of your personal data by MWR Life.

•          The right to non-discrimination when you exercise any of your rights. 

•          If you are a California resident, you may request us to disclose to you:

-          The categories of personal information we have collected about you

-          The categories of sources from which the personal information is collected

-          The business or commercial purpose for collecting or selling your personal information

-          The categories of third parties with whom we share personal information

-          The specific pieces of personal information we have collected about you

Every request is subject to applicable law, which means that we may have to store the personal information.

If you want to exercise any of your rights as set out above, you can do so here at any time:

MWR Life support@mwrlife.com

We also want to remind you that you may always issue a complaint to the relevant Data Protection Authority if you have concerns about our processing of your personal data.

  1. Minors

We insist on not processing any personal data of children under the age of 18. We strongly encourage you to inform us if you have reason to believe we process the personal data of a minor. We will delete this personal data instantly.

  1. External links

Our website may display links to other websites when we believe that doing so will provide value to the viewer. Unless these other websites are affiliated with MWR Life, we are not responsible for the privacy policies that these other websites use, nor for its content and security. We advise you to inform yourself by reading the privacy policies on these websites.

  1. Changes to this privacy policy

We reserve the right to make changes to this Privacy Policy at any time. We will notify you when updates are made to give you an opportunity to withdraw previously given consent or to deny further use of your data. We may have to update the Privacy Policy in case of new developments,  activities,  online  services  or  when  applicable  legislation  changes.  Your continued use of this website or our service and/or continued provision of information to us will be subject to the terms of the then-current Privacy Policy.

  1. Questions or comments?

If you still have any questions or comments after reading this Privacy Policy, or if you have any suggestions regarding its content, you can always contact us at:

•          Email: support@mwrlife.com

•          Website: www.mwrlife.com

Please let us know if, for any reason, you believe we have not adhered to the principles in this Privacy Policy. We will do our best to promptly make corrections.