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.
1.1. 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
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 email@example.com
3. What information do we collect, How we use it and for how long we retain it?
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
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
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
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.
We will update the version number and date of this document each time it is changed.
updated January 2020
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