1. About This Policy
2. Your Consent
By using any of our Vegan Travel websites or social media channels, providing personal information to us, inquiring to us for Vegan Travel service, creating an online account or booking any cruise or travel with us, you accept and consent to the terms of this Policy and our receipt, collection and use of your personal information. If there is information you do not wish to consent to our receipt, collection or use of, you have the ability to avoid taking and you should not take the actions described above.
3. Copyright Notice
Copyright © 2018 Vegan Travel (Germany) Limited. All Rights Reserved.
4. About Us
5. Contacting Us
If you have any question or comments about this Policy or how we process your personal information, including any complaint, please contact us by e-mail to firstname.lastname@example.org
6. Our Commitment
We respect your privacy. We aim to ensure you have a satisfactory experience with us. This includes using our websites or shops and booking with or through us. We understand you care how your personal information is used by us. We want to share with you the policies we’ve adopted. This provides you information about how we seek to handle your personal information that you provide to us.
7.1 Our customers
This Policy states out how we process personal information relating to individuals who book or inquire about booking travel with or through us or who receive travel service booked with or through us (for example, if you are a passenger for a booking or booking inquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.
7.2 Examples of who this policy covers
We include in this Policy personal information we process relating to: (1) individuals who inquire to or book with us or through us, and individuals for whom an inquiry or booking is made (such as friends, family, and tour group members, personnel of businesses and members of organizations booking with or through us); (2) individuals for whom an inquiry or booking is made with us by an agent; (3) employees or individuals who act as representatives of a customer that is a business or organization, and individuals connected to that business or organization, such as owners, partners, shareholders, and directors; (4) individuals who visit our website or other online site operated by us or by our contractors or affiliates; (5) individuals who create an online account (if applicable); (6) individuals whose personal information from other companies in our group (such as where you consented to your personal information being disclosed to other group companies for marketing purposes); and (7) individuals or businesses from any other arrangement with us.
7.3 Terms used in this policy
When we refer to "you" and "your" in this policy, we mean you, as an individual whose personal information we process.
When we refer to “process” or "processing" your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it. When we refer to "travel service" this covers all products and services which may be booked with or through us, such as cruises, accommodation, tours, transport and transfers (whether by cruise, air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and includes: (1) all products and services which we supply or operate ourselves (including where we contract or subcontract); and (2) any products and services provided by a third party which we book for you, as agent for you or the third party. Travel service also includes any service we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.
8. What Types Of Personal Information We Process
The types of personal information about you that we process include the following:
8.1 Information concerning you as an individual
This may include, but is not necessarily limited to your name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, signature, copies of passports, driving licenses credit card and other payment details, financial information, health information relevant to your planned travel, travel insurances held, results of searches carried out concerning you, your preferences, frequent flyer or travel partner programme affiliation and member number, and other information provided to us by or in relation to you which concern you as an individual.
8.2 Sensitive information
In some instances it may be necessary to collect “sensitive information,” such as your religion and details of medical, dietary, mobility or factors relevant to your booking. When you provide such information to us, you consent to our collection, retention and use of it.
8.3 Business related information
If you are an individual associated with a business or other organization that is our customer, your personal information may include the following information that we link to you: business or organization details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organization (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).
8.4 Inquiry and booking information
Information concerning inquiries and bookings made with or through us for travel service, including where you make the inquiry or booking or are the recipient of the travel services to which the inquiry or booking relates. This information may include: records of inquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other information relevant to your inquiry; details of results, quotes, proposals, estimates and other information given in response to inquiries; details of holiday, accommodation, travel, car hire, and other travel services booked or inquired about; details of passengers/holidaymakers traveling; details of provider of travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.
8.5 Performance information
Information generated concerning performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.
8.6 Survey Information
Information collected or generated out of any surveys we conduct.
8.7 Feedback and user generated content (UGC)
Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us.
8.8 Competition information
Information collected or generated out of any competitions or promotions we run.
8.9 Account, registration and loyalty information
Information concerning any account, registration, or membership with us, or participation in any loyalty programme.
Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking inquiry, or performance of any contract.
8.11 Social media
Any information (including social media user details, feedback, comments and photos) you post on our social media channel which relates to us.
8.12 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 information we collect will depend on how you interact with our website.
The information may also include: information input into forms and field; registrations for accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames, 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.
8.13 Video and audio
There may be circumstances, whether for security or other reasons, in which we make video or audio tape recordings that may include your appearance, activities and/or communications.
8.14 How We Collect Or Generate Your Personal Information
We may collect or generate personal information concerning you in various ways.
8.15 Visiting our website or telephoning us
By visiting and using our website you or your computer may provide personal information. 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. By telephoning us you may provide personal information. We may record telephone calls with you.
Cookies - Cookies collect information that includes the server your computer is logged onto, your browser type and how you gained entry to our website. When you visit our website anonymously, details are still recorded about your visit, such as matters described in the prior paragraph, time and date, pages accessed and time spent. This information is used in an anonymous form for statistical purposes and as such, is not normally used to identify you individually. We do not, from cookies, seek to retrieve other information from your hard drive, pass on computer viruses or capture your email address or other personally identifiable information. Accepting cookies is required if you want to view our websites, because we consider them to be essential for our site administration and security.
You may disable cookies or set your browser to alert you when cookies are being sent. If you disable cookies, we may be unable to optimize your visit to our site and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions. If you reject all cookies, you may not be able to use our web sites.
8.16 Information you provide
Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filling in a field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you; by e-mail; from documents you provide us; and from updates to any information provided from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty programme, or make an inquiry or booking for a holiday or other travel service whether in person, by phone, through our website or otherwise; send us your comment or suggestion; subscribe to any newsletter or other publication; or request sales and advertising information, including brochures.
If you do not provide us your personal information we may be unable to provide you information or book travel services for or on your behalf.
8.17 Information obtained from third parties
We may obtain personal information concerning you from third parties, including from: people making inquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are inquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organizations; from social media and other information sources we may examine; from any business or organization you are associated with; or from telephone numbers identified by the telephone system when you telephone us.
8.18 Information generated by us
We and any suppliers or contractors or sub-contractors working for us may generate or create personal information relating to you, including in connection with responding to and dealing with any inquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website, or through study or analysis of information provided to or obtained by us.
8.19 Video or Audio Recording for Security
We or others we contract with could use recording equipment, typically for security purposes, that electronically records activities and sounds coming within the range of the recording device.
9. What Do We Use Your Personal Information For?
We use your personal information in various ways:
9.1 Operate our website
To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes customizing your online experience by providing you more relevant online offers and updates, managing accounts or registrations you have with our websites and making changes to your settings and profile at your request.
9.2 Provide information and respond to inquiries
To provide information to you about our website, systems and services, including to respond to booking inquiries and searches for holidays and travel, and provide you updated information.
9.3 Bookings and other contracts
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce 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 transactions authorized or made with us which relate to you.
To collect and make payments due and administer our accounts.
9.5 Communication with customers
To communicate with you concerning inquiries, bookings, travel services provided, problems and complaints, and respond to submissions, inquiries or requests from you or others relating to you.
9.6 Record keeping
To keep internal records and maintain reasonable archives for future use and reference, including as to inquiries, bookings, contracts, travel services, and complaints.
9.7 Manage and improve our business
To analyze, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyze results; run promotions and competitions; undertake product or customer research/development; assist us in and help us improve our sales, editorial, advertising and marketing processes; carry out other business development and improvement activities; and provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how customers generally are using our websites and booking travel services with (or through) us. We may use this information to ascertain interests so we can better tailor our business offerings.
9.8 Direct marketing
To carry out direct marketing to you. See next section below for further information.
9.9 User Generated Content (UGC)
9.9.1 Use of Reviews: By submitting content to our website by electronic mail, postings on our website or otherwise, including any reviews, questions, comments, suggestions, ideas, photos or the like contained in any submissions (collectively, “Submissions”), you grant us and our affiliates a nonexclusive, royalty-free, perpetual, transferable, irrevocable and fully sub-licensable right to (a) use, reproduce, modify, adapt, translate, distribute, publish, create derivative works from and publicly display and perform such Submissions throughout the world in any media, now known or hereafter devised; and (b) use the name that you submit in connection with such Submission.
9.9.2 Use of User Generated Content (UGC): By submitting content to our social media channels or websites you grant us a non-exclusive license to use the content you add to our websites. For example, we may use this information in any of our brochures or for our campaigning purposes or marketing materials.
To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical information about browsing actions and patterns, and do not identify any individual.
Video and audio recordings may be examined and reviewed for purposes of reconstructing or understanding courses of events that preceded or led to a security or safety matter or other incident.
9.12 Legal Obligations; cooperation with government, police, military and judicial authorities or certain other organizations
To meet our legal obligations. Also, to provide information in response to a command or request from or to cooperate with a government, police, military or judicial authority or from a private entity acting at the request or in service of a government, police, military or judicial authority, or in some cases from an international or aid organization. This could include, by way of example, a government agency, police department, military authority or court that requires or asks us to voluntarily cooperate in providing information for their investigation of any matter or for purposes of a pending proceeding. This could also include a request to us from an international organization or aid organization, such as in the case of an emergency or for other reasons. We may also provide information to any such organizations in matters for which we request their assistance.
9.13 Anything you specifically consented to
Any purpose for which we have obtained your consent.
10. Use Of Your Personal Information For Direct Marketing
We do not use or disclose your personal information for direct marketing purposes unless we obtained your consent to this, such as through an opt-in or opt-out click box on any form or website of ours.
10.1 Direct marketing by us
If you consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, advertisements and promotions relating to travel services we provide or which can be booked with third parties through us, or which are offered by or which can be booked through any other company in the same group of companies as us (that is, within the Travel Corporation group) or third parties selected by us.
You can withdraw your consent by contacting us as detailed in this policy or as detailed in any direct marketing you receive.
11. Disclosure Of Your Personal Information
We transfer your personal information to third parties in the following circumstances:
11.1 Bookings and performance of contracts
We disclose your personal information to third parties (including intermediaries) to deal with any booking inquiry 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 apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Third parties may include suppliers, contractors or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).
11.2 Suppliers of travel and other services
We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any inquiries 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 agreed to provide to you. We may disclose your personal information to any supplier with whom we make any inquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. 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 inquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If an application is made through us for travel or other insurance to cover you, we may pass your personal information to the insurer. Information provided by you may be put on a register of claims and shared with other insurers seeking to reduce fraudulent claims.
11.4 Business function outsourcing
When we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), we may provide your personal information to them as required for use for or processing as part of those purposes.
11.5 Legal requirements or matters of cooperation
We may supply personal information to a government authority or regulator, police authority, military authority or private party acting for or on behalf of such authorities, where required to comply with a legal requirement, for the administration of justice, for purposes of customs, visas and immigration, when reasonably required to protect your interests or enforce any booking or other contract, where useful to enforce or protect our rights, or where we elect to voluntarily cooperate with a request from any such person or entity, for other reasons. We may disclose your personal information where otherwise required by or permitted by law. We may also provide information to such organizations in matters for which we request their assistance.
11.6 Customer representatives
If our customer is a business or organization, and we hold your personal information in your capacity as an associate of that business or organization (including as agent, representative, contact, employee, officer, owner, partner, or director), we may disclose to them that personal information. If our customer is making a booking or booking inquiry on your behalf, with your authority, we may disclose to our customer your personal information as reasonably required in connection with the booking or inquiry, or the subsequent performance of or payment for any booking made.
12. Keeping Your Information Secure
12.1 Our security measures
12.1.1 Our general commitment
We are committed to implementing reasonable measures trying to keep your personal information secure. We are obliged by law to put in place appropriate technical and organizational measures trying to avoid unauthorized or unlawful processing of your personal information and trying to reduce risks of accidental loss or destruction of, or damage to, your personal information. We have implemented security policies, rules and technical measures with a view to achieving this. But as part of our Policy we recognize and require you to recognize that there are no measures that guaranty security, and no measures are fully secure against those who are intent on accessing such information.
12.1.2 Transmissions between your web browser and our servers
We use Secured Socket Layer (“SSL”) software to encrypt the personal information you provide to us while it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.
12.1.3 Storage of your personal information
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.
12.2 Your security measures
For your privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mail or other communications you may send to us, including payment card information.
We encourage you to be careful about whom you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
12.3 Security Limitations
No security measure provides 100% certainty against all risks. Inadvertent disclosure is possible. Technology changes, computer hackers, organized criminals foreign and domestic, perpetrators of terror, foreign and domestic enemies, dishonesty by persons with access and human error are examples why it is impossible for us, or anyone, to absolutely assure your information cannot or will not ever be accessed or disclosed. We and our management and personnel shall not be liable for loss, injury or damage arising from or relating to disclosure of your information. Please do not give us any information that is so confidential or so personal that its release would cause you injury.
13. How Long Do We Keep Your Personal Information For?
We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you. It is possible your personal information may be maintained longer, until such time as we delete such information.
14. Your Rights
14.1 Use for direct marketing
You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or contact us email us at email@example.com.
14.2 Correction of inaccuracies
We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date.
If the information we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.
16. Applicable Law
This policy is subject to the law of Germany. You must bring any claims against us exclusively in the courts of the city of Münster.
17. Linked Websites
Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.
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