Privacy Statement
Welcome to
the
Bookingmaster
.travel
website (the "Website"). This Privacy Statement outlines
Booking Master
Travel Ltd.'s ("we", "our"
or the "Company") practices with respect to information collected
from users and customers who access the Website or communicate with us in any
other way, including without limitation, our API, support calls, emails and
letters and so on (collectively: "the Service"). This Privacy
Statement is based on our goal to provide our clients and visitors with quality
information in our field of practice while maintaining personal privacy.
1. Overview
1.1. In this
Privacy Statement we will explain to you about the information we collect from
you when you visit our Website or communicate with us directly in any other
way. In collecting this information, we are acting as a data controller and, by
law, we are required to provide you with information about us, about why and
how we use your data, and about the rights you have over your data. Please note
that we may also act as a data processor in certain instances, if our business
partners provide us with information for their own processing needs. It is
important to note that such information is provided to us only for the purposes
of processing it in accordance with the instructions of our business partners.
We cannot process this information for our own needs and cannot decide on any
new purposes for its processing without our business partner's instructions.
Therefore, such information is not subject to the provisions of this Privacy
Statement.
1.2. As you use our Website or communicate with us in any other way or provide
us with information in order to access and/or use our services, we may collect
and process information related to you as an individual and which allows you to
be identified, either directly or together with additional information. This
information can be collected by us both when you choose to provide it (e.g.,
when you request any services provided by us over the Website or when you
submit an enquiry via our Website) or simply by analysing your behaviour on the
Website.
1.3. For certain services, such as for when you book any of the travel products
offered on our Website, you will be asked to provide certain personal
information. It is not mandatory for you to provide us with any of your
information, including personal information; however, if you will choose not
to, we may not be able to provide you certain services requested by you and
your usage of our Website may be limited in scope.
Any personal information you provide us with or which we collect is provided or
shared on a voluntary basis.
2. Who are we?
We are Booking
Master Travel Ltd. Our address is
Makarios III Ave.,3 Loukaides Court, 4th Floor Mesa Geitonia
4000 Limassol Cyprus
.
You can
contact us either by post at the above address, by email at
hotels@bookingmaster.travel
3. What information do we collect, How we use
it and for how long we retain it?
We generally
collect two types of information:
The first type of information is un-identified and non-identifiable information
pertaining to a user(s), which may be made available or gathered via the user's
use of the Services ("Non-personal Information"). We are not aware of the
identity of the user from which the Non-personal Information was collected.
Non-personal Information which is being collected may include your aggregated
usage information and technical information transmitted by your device,
including certain software and hardware information (e.g. the type of browser
and operating system your device uses, language preference, access time and the
domain name of the website from which you linked to the Services; etc.), in
order to enhance the functionality of our Services. We may also collect
information on your activity on the Service (e.g. pages viewed, online
browsing, clicks, actions, etc.). The second type of information is
individually identifiable information, namely information that identifies an
individual or may with reasonable effort identify an individual ("Personal
Information"). Such information may include:
3.1. When you submit an enquiry via our Service (including, without limitation,
booking a travel product or purchase of other products), we ask you for your
name, contact telephone number and email address. In order to complete
purchases we may also ask for identification number and VAT registration
number; address; bank details and/or credit card information; and any
additional information requires for billing (e.g. authorization codes, passport
number or national ID number).
3.2. If you sign up to receive our newsletter, we will ask for your name and
your email address.
3.3. We also record your IP (Internet Protocol) address, which is the internet
address of your computer.
3.4. If we combine Personal Information with Non-personal Information, the
combined information will be treated as Personal Information for as long as it
remains combined.
We process Personal Information for the following purposes:
Retention of data
We keep
Personal Data for as long as necessary to provide our services, respond to
requests, comply with our legal obligations and resolve disputes. Retention
periods shall be determined considering the type of information that is
collected and the purpose for which it is collected for, bearing in mind the
requirements applicable to the situation and the need to destroy outdated,
unused information at the earliest reasonable time.
Note that we do not retain your credit card information.
Clients and End User data
As part of
our Services, the Personal Data of clients and end users of our customers may
be shared with us. This data may include, for example, specific information
regarding travel arrangements for individual clients.
Such data is provided to us solely by the customer and is processed by us as a
"data processor", acting under the sole direction of its customers. Therefore,
in processing such information we will act in accordance with the provisions of
a data processing agreement we will sign with our customers and in accordance
with their documented instructions and the provisions of this Privacy Statement
will not apply directly to such processing.
4. Our legal basis for processing your
information
We collect
and process your Personal Data based on your consent, where it is necessary for
the performance of contract between us and where it is necessary for our
legitimate interest.
5. Who will be able to access your personal
information?
5.1. In the
framework of our activity and for the purposes specified above, your
information, including your Personal Information may be shared with the
following: suppliers of Travel Products offered on our Site, providers of
infrastructure services, payment service providers, other third party providers
who assist us in providing our Service such as storing or processing
information on our behalf (e.g. on cloud computing services) or assist us with
our business operations, to authenticate your access and to provide and improve
our Service.
5.2. In addition, your information, including Personal Information, may be
disclosed to third parties in the event we shall enter a corporate transaction.
5.3. We may also disclose Personal Information if we have a good faith belief
that disclosure of such information is helpful or reasonably necessary to: (i)
comply with any applicable law, regulation, legal process or governmental
request; (ii) enforce our policies, including investigations of potential
violations thereof; (iii) investigate, detect, prevent, or take action
regarding illegal activities or other wrongdoing, suspected fraud or security
issues; (iv) to establish or exercise our rights to defend against legal
claims; (v) prevent harm to the rights, property or safety of yourself, our
users, us or any third party; or (vi) for the purpose of collaborating with law
enforcement agencies or in case we find it necessary in order to enforce
intellectual property or other legal rights.
6. International transfers of data
Please note
that some data recipients may be located outside the EEA. In such cases we will
transfer your data only to such countries as approved by the European
Commission as providing adequate level of data protection or enter into legal
agreements ensuring an adequate level of data protection.
7. Your rights as a data subject
7.1. You can
ask us if and what information we hold about you, and you can ask us to correct
it if it is inaccurate, incomplete or out of date. If we have asked for your
consent to process your personal data, you may withdraw that consent at any
time, and, if we process your personal data solely on the basis of your
consent, we will stop processing, subject to our overriding rights, if
applicable.
7.2. If we are processing your personal data for reasons of consent or to
fulfil a contract, you can ask us to give you a copy of the information in a
machine-readable format so that you can transfer it to another provider.
7.3. If we are processing your personal data for reasons of consent or
legitimate interest, you can request that your data be erased.
7.4. In certain circumstances, you have the right to ask us to stop using your
information for a period of time if you believe we are not doing so lawfully.
Please note that these rights are not absolute and may be subject to our own
legitimate interests and regulatory requirements.
8. Your right to complain
If you have a
complaint about our use of your information, we will prefer you to contact us
directly in the first instance so that we can address your complaint.
If you are a resident of the EU, you may also lodge a complaint with the
relevant supervisory authority.
9. How do we safeguard your information?
We take great
care in implementing and maintaining the security of the Website and your
information. We employ industry standard procedures and policies to ensure the
safety of the information we collect and retain, and prevent unauthorized use
of any such information, and we require any third party to comply with similar
security requirements, in accordance with this Privacy Statement. Although we
take reasonable steps to safeguard information, we cannot be responsible for
the acts of those who gain unauthorized access or abuse our Site, and we make
no warranty, express, implied or otherwise, that we will prevent such access.
10. Updates to this privacy policy
We regularly
review and, if appropriate, update this privacy policy from time to time, and
as our services and use of personal data evolves. If we want to make use of
your personal data in a way that we haven't previously identified, we will
contact you to provide information about this and, if necessary, to ask for
your consent.
We will
update the version number and date of this document each time it is changed.
updated January 2020
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