Effective date: February 20, 2020
TransferNTour processes the personal data it has been provided with lawfully, in goodwill and with transparency with regard to the Data Subject, in compliance with the principles and requirements of European General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “GDPR”).
It is important to know that:
However, your Personal Data will always be processed in full in accordance with the regulatory provisions in force at the time of data collection, unless otherwise required by the mandatory legal framework and/or should be applied retroactively.
“Personal Data” is any information relating to an individual who is identified or can be identified, directly or indirectly.
“Processing Personal Data” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Data Subject” is any individual whose Personal Data is processed.
“Platform” is the (mobile) website and application for mobile smartphones, tablets or similar devices, created and administrated by TransferNTour Ltd. The Platform provides to the users free information as well as the possibility to make an online reservation and to purchase a various range of travel services provided by Service Providers with individually defined price, such as: shuttle transfers; private transfers with driver; private, group or shared transfers by helicopters and air jets; private and organised sightseeing tours; wine&food tasting tours; long and short cruise and sailing services etc. (hereinafter referred to as " Services").
“Usage Data” is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Types of Data Collected Personal Data
While using our Platform, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personal, identifiable information may include, but is not limited to:
TransferNTour does not process personal data revealing racial or ethnic origins, political opinions, religious or philosophical beliefs/affiliations, or trade union membership, nor genetic data, bio metric data to uniquely identify a natural person, medical data or data concerning a natural person’s sex life or sexual orientation.
Signing up for the Platform via external tools (“Login with Facebook “, “Login with Google “, “ Login with Twitter “)
When a User uses the tools to establish a link between his account in the Platform and his Facebook, Twitter or Google account, he authorizes TransferNTour to receive partial data from his account in the respective external service, allowed by the User to be provided through its settings in the respective external service, wherein:
The information that we can receive and process as described above is determined entirely by the User – through its settings within the respective external service (Facebook, Twitter, Google) in which he has an account and which account has decided to link with your TransferNTour Account in the Platform. User registration with these external services is accepted as consent to the processing of the data provided through them.
Posting reviews by Users
In certain cases, the Users have the opportunity to publish their reviews and evaluations for the Service Provider in connection with the service provided through our Platform. These Users reviews are publicly available and publicly visible on the Platform, including content, publisher name, photo (if not forbidden by profile settings), and link to the account itself.
TransferNTour will never tolerate or accept comments of discriminative abusive, inappropriate and insulting content. Any verbal abusive content, especially in relation to nationalist, gender, sexual orientation, race, political and/or religious affiliations and/or other issues of similar concern, will automatically be removed and deleted from public view. Depending on the severances of the misconduct, we maintain our right to take any legal action against such provocatively discriminative behaviors in relation to human rights laws and discrimination legislative acts.
Purposes and Legal Basis for Process Personal Data
Your personal data will be processed for at least one of the following purpose s:
The legal bases for processing your personal data to achieve the above purposes are as follows:
Disclose Personal Data with Third Parties
We may disclose personal data to the following third parties:
Retention of Personal Data
TransferNTour will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Children Personal Data
The services provided on the Platform are intended for persons over the age of 18. If you are a person under 18 years old, you cannot use our services without providing us with express written permission from a parent or guardian. If you use our Platform without such permission, you hide important information from us and mislead us. In this case, we are not responsible for any circumstances or events that have arisen as a consequence of such misconduct on your part. We may collect and use the information of children only as provided by the parent or guardian or with their consent. If you are a parent or guardian and you are aware that your children have provided us with Personal Data, please contact us.
If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our Platform.
Rights of Data Subjects
If we process your Personal Data, you have the following rights:
The requests, inquiries, and objections shall be sent personally by the natural person or by a person explicitly authorized by them through a notarized Power of Attorney.
Cookies are small files that contain information about browsing activity.
Whenever you visit our Platform, cookies are sent to the device you’re using to access the website/application. Your device automatically stores the cookie in a file that’s located within your web browser.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Links to Other Sites
TransferNTour is not liable for the data protection obligations and handling processes of Personal Data when the Users make the choice to log in from their social media and/or any other third-party accounts, such as Facebook, Twitter and Google Accounts. The User must acknowledge that we cannot control or impose any data management method or policy of our own in those third-party parties, and the management responsibility for compliance with data protection standards and regulations lies upon the third-party.