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PRIVACY POLICY

1. ABOUT US

Basque Escapes s.r.o., with its registered office at Kecova 2864/13, 155 00, Prague – Stodůlky, Czech Republic, ID 07142412 (hereinafter referred to as Basque Escapes), is committed to the protection of the personal data you share with us. We process the personal data you provide to us responsibly, transparently and in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the “Regulation”).

Our privacy policy is subject to the law of Czech Republic and disputes can be determined by the courts of Czech Republic.

With this document we fulfill our duty of information pursuant to Articles 12, 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation) (‘GDPR’).

This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal data.

Thank you for taking time to read this privacy policy, so you are fully aware of how and why we are using your data.

2. OUR COMMITMENT

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted.

3. OUR LEGAL BASES FOR PROCESSING

We will process your personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal data unless at least one of the following requirements are met:

  • You have given consent to the processing of your personal data for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your photos/videos of experiences of our trips on social media and sharing emails of co passengers, that have agreed to stay in touch);
  • The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
  • Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
  • Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);

4. WHO OUR PRIVACY POLICY COVERS

4.1 OUR CUSTOMERS

Our privacy policy sets out how we process personal data relating to individuals who are:

  • booking or enquiring about booking travel services with or through us; or
  • the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you); or
  • customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal data as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

4.2 EXAMPLES OF WHO THIS POLICY COVERS

We include in this privacy policy personal data we process relating to:

  • individuals who are making any enquiry or booking with us or through us, and individuals in members, officers and employees of businesses and organisations booking with or through us);
  • individuals in respect of whom any enquiry or booking is made with us by an agent;
  • where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;
  • individuals whose personal data is obtained from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).
4.3 WHEN WE ARE DATA PROCESSOR ONLY

Please however note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal data on their instructions.

4.4 TERMS USED IN THIS POLICY

When we refer to “you” and “your” in this privacy policy, we refer to you, and any such individual whose personal data we process.

When we refer to “processing” of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to “travel services” this covers all products and services which may be booked with or through us, such as bespoke accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both:

  • all such products and services which we supply or operate ourselves (including where we sub-contract); and
  • any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

5. WHAT TYPES OF PERSONAL DATA WE MAY PROCESS

This section summarises the types of personal data about you that we process:

5.1 DATA CONCERNING YOU AS AN INDIVIDUAL
  • name,
  • age,
  • photograph,
  • gender,
  • address,
  • telephone,
  • mobile,
  • e-mail,
  • social networking contact details, your social posts about any of our trips and travel experiences.
  • proofs of identity and address, copies of passports, driving licences, and utility bills
  • card and other payment details, and financial information,
  • health information relevant to your planned travel and travel insurances held,
  • results of searches carried out against you (such as to verify your identity, address, and credit status), your preferences,
  • Frequent flyer or travel partner program affiliation and member number.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy. In any e-mail you send we would ask you to insert “unsubscribe” as the subject heading.

5.2 BUSINESS RELATED INFORMATION

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you:

  • business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.),
  • your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and
  • your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).
5.3 ENQUIRY AND BOOKING INFORMATION

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:

  • records of enquiries and searches for holiday and travel products made by or on your behalf,
  • details of your personal interests,
  • needs and other data relevant to your enquiry;
  • details of results, quotes, proposals, estimates and other information given in response to enquiries;
  • details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about;
  • details of the passengers / holidaymakers travelling;
  • details of the provider of the travel services (e.g. tour operator);
  • dates and times of travel;
  • price;
  • payment details (including card details);
  • passport information and visa information;
  • sensitive information such as health, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us.
5.4 SURVEY INFORMATION

Information collected or generated out of any surveys we conduct.

5.5 COMPETITION INFORMATION

Information collected or generated out of any competitions or promotions we run.

5.6 ACCOUNT, REGISTRATION AND LOYALTY INFORMATION

Information concerning any accounts, registrations or participation in any loyalty program.

5.7 CORRESPONDENCE

Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.

5.8 WEBSITE USAGE INFORMATION

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

This information may include:

  • your IP address (a unique identifier allocated to your computer for your connection to the internet);
  • your computer device details (PC, tablet, smartphone, watch etc.);
  • the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using;
  • your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc);
  • your time-zone;
  • your browser plug-ins;
  • any web-page you came from, identified as the referrer web page address by your web browser;
  • cookies (as per our cookie policy )
  • any web-page you came from, identified as the referrer web page address by your web browser;
  • cookies (as per our cookie policy )
  • page response times;
  • download error;
  • pages and parts of pages you visit;
  • usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.;
  • services and products you viewed;
  • length of visit to website and pages;
  • page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).

This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

This information may include:

  • data inputted into forms and fields;
  • registrations for any accounts,
  • forum,
  • feedback mechanism,
  • newsletters or other features of our site;
  • usernames and passwords,
  • log-in / out history, and settings;
  • actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.

Such information will be treated as personal data and processed according to this privacy policy.

6. HOW WE COLLECT OR GENERATE YOUR PERSONAL DATA

This section sets out the ways in which we may collect or generate personal data concerning you.

6.1 VISITING OUR WEBSITE

By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information recorded on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

6.2 DATA YOU PROVIDE

Your personal data will include data you provide (or later amend), whether:

  • from correspondence with you;
  • verbally to us over the phone or in person;
  • by filing in any field or form on a website;
  • by e-mail;
  • from documents you provide us with; and
  • from updates to any information you provide to us.

This includes when you:

  • register or subscribe for any service,
  • make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise;
  • send us your comments or suggestions;
  • subscribe to any newsletter or other publication.
6.3 USER GENERATED CONTENT

We may process information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let GoBasque s.r.o. company to process this information in various initiatives. These could include any marketing activities such as:

  • print materials
  • on our website
  • email activities
  • social posts
  • provide images to our trade partners to use on their websites, email marketing and other marketing initiatives

We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods

6.4 DATA GENERATED BY US

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including:

  • in connection with responding to and dealing with any enquiry, booking or complaint; or
  • in performing any booking or other contract with you; or
  • through the analysis of your personal data; or
  • data gained from your use of our website according to our cookie policy.

7. WHAT DO WE USE YOUR PERSONAL DATA FOR ?

This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.

7.1 OPERATE OUR WEBSITE

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites.

7.2 PROVIDE INFORMATION AND RESPOND TO ENQUIRIES

To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

7.3 BOOKINGS AND OTHER CONTRACTS

To enable you to make bookings, and to fulfil, provide, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

7.4 PAYMENTS

To collect and make payments due and administer our accounts. This is necessary for the preparation of any contract between us.

7.5 COMMUNICATION WITH CUSTOMERS

To communicate with you concerning bookings, travel services provided, problems and complaints, and to respond to any enquiries or requests from you.

7.6 RECORD KEEPING

To keep internal records and maintain reasonable archives, concerning enquiries, bookings, contracts, travel services, and complaints. This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.

7.7 DIRECT MARKETING

To carry out direct marketing to you.

7.8 CONSEQUENCES OF NOT PROVIDING YOUR DATA

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.

8. PERIOD FOR RETAINING YOUR DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or accounting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING

We do not use or disclose your personal data for direct marketing purposes unless:

  • we have obtained your consent to do so, such as through an opt-in box on any form or website of ours; and/or
  • you have made a booking with us and there is our legitimate business interest to do so for similar products or services.

If you do not want to receive direct marketing activities anymore, you can unsubscribe by following the link at the end of every of our electronic communications.

9.1 DIRECT MARKETING BY US

We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services:

  • offered by us;
  • which can be booked with third parties through us;
  • offered by third parties selected by us. However, we will not pass any of your details to third parties without your prior and specific consent.

We will only contact you in the manner you agreed to (e.g. by email or sms).

9.2 DIRECT MARKETING BY THIRD PARTIES

From time to time we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number and preferences) to other companies which offer services that may enhance your travel experience or be able to help you to finalise your travel arrangements (“third parties”). Such third parties may then contact you directly with marketing information about services and products offered by them. Such third parties are not part of The Travel Corporation and are not bound by this privacy policy. However, we ensure that our partners will only contact you in the manner you agreed to (e.g. email, text) when providing your consent.

9.3 WITHDRAWING FROM DIRECT MARKETING

You are free to stop receiving marketing information from us at any time by contacting us by email to withdraw your consent. It would be helpful if you could insert the word “Unsubscribe” as the subject heading. When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties. You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

10. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We transfer your personal data to third parties in the following circumstances:

10.1 BOOKINGS AND PERFORMANCE OF CONTRACTS

We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;

  • to collect payments to be made by you,
  • to investigate and respond to complaints, and
  • to enforce any booking or other contract with you.

Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.

10.2 SUPPLIERS OF TRAVEL AND OTHER SERVICES

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you.

Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request.

10.3 INSURANCE

If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer.

10.4 PUBLIC FORUMS ETC.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.

10.5 LEGAL REQUIREMENTS

We may supply personal data to a government authority or regulator where required to:

  • comply with a legal requirement,
  • for the administration of justice or when required by a public enforcement body, or
  • for the purposes of customs, visas and immigration.

We may disclose your personal data where otherwise required by or permitted by law.

10.6 DIRECT MARKETING BY THIRD PARTIES

We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent. Please refer to the direct marketing section above for more information.

10.7 BUSINESS CUSTOMERS WHO ARE BUSINESSES (NOT INDIVIDUALS)

If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data.

If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

10.8 BUSINESS ACQUIRERS

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal data.

11. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

Where we provide your personal data to a third party one of the following two circumstances will apply:

11.1 PROCESSING ON OUR BEHALF

In some cases, your personal data may be held and otherwise processed by others on our behalf. We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy. The sharing of your data is necessary for the performance of any contract with you and for the efficient provision of our services.

11.2 PROCESSING ON THEIR OWN ACCOUNT

In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for your personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party and they will provide their privacy policy to you.

12. LOCATION OF YOUR PERSONAL DATA

We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area (“EEA”).

We will only send your personal data outside the EEA to companies with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our partner companies to follow the same rules when processing your personal data. This means for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA.

13. KEEPING YOUR DATA SECURE

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secured servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to the information;
  • using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions.

Unfortunately transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and prevent unauthorised access.

14. YOUR RIGHTS

You have certain rights under data protection laws, which we summarise below.

14.1 RIGHT TO INFORMATION (RIGHT OF ACCESS TO PERSONAL DATA)

You may request what personal data about you we are processing, for what purposes, from which sources we have collected it, who we disclose it to and to provide you with a copy of your personal data that we hold.

If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on the Office for Personal Data Protection website https://www.uoou.cz/

14.2 PORTABILITY

You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller.

14.3 RECTIFICATION

You have the right to have your personal data amended if it is inaccurate or incomplete.

14.4 RIGHT TO OBJECT

You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.

14.5 RESTRICT PROCESSING

You have the right to restrict the processing of your personal data if you believe that such data is not accurate, or we process it unlawfully, and if you believe that we no longer need this data for processing.

Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so.

We will inform you before the restriction of processing is lifted.

14.6 ERASURE

You have the right to have your personal information deleted or removed in the following circumstances:

  • The data is no longer necessary for the purpose for which it was originally collected or otherwise processed;
  • Where you withdraw your consent, where consent was used as the legal basis for processing;
  • Personal data has been unlawfully processed;
  • When you object to the processing and we have no overriding legitimate interest for continuing the processing;
  • Erasure is required for compliance with a legal requirement; or
  • Data has been collected in relation to the offering of online services to a child.

We have the right to refuse to act on a request of erasure if the data is necessary for:

  • Exercising the right of freedom of expression and information;
  • Compliance with a legal obligation;
  • The establishment, exercise or defence of legal claims
14.7 COMPLAINTS TO THE DATA PROTECTION AUTHORITY

The laws we comply with are regulated by the Office for Personal Data Protection https://www.uoou.cz/ . In addition to your rights above, it is open to you, if you have a complaint or a concern, to seek assistance from this supervisory authority who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

Our privacy policy is subject to the law of Czech Republic and disputes can be determined by the courts of Czech Republic.

15. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any requests or complaints, please contact us either by e-mail to info@gobasque.cz, or by post to Kecova 2864/13, 155 00 Praha – Stodulky, Czech Republic.

 

Last updated: 17 septembre 2019