Privacy Policy


PRIVACY POLICY / GDPR REGULATION

THE LUXURY GLOBETROTTER JSC. CUSTOMER INFORMATION IN CONNECTION WITH THE GENERAL GDPR PROTECTION REGULATION (POLICY)

THE LUXURY GLOBETROTTER JSC (“We” / “Us” / “THE LUXURY GLOBETROTTER”), entered in the Commercial Register under VAT BG205747531, with registered office and address of management Sofia 1000, 28 Hristo Botev Blvd, website www.theluxuryglobetrotter.com and e-mail address reservations@ theluxuryglobetrotter.com, as a controller of personal data, strictly adheres to the provisions of the law and the General Data Protection Regulation (GDPR / Regulation). Please take the time to read this THE LUXURY GLOBETROTTER JSC CUSTOMER INFORMATION IN CONNECTION WITH THE GENERAL GDPR PROTECTION REGULATION, hereinafter referred to as the "Policy", to understand how we process and collect personal data and what are your rights and opportunities in connection with the specified processing.

1. Collection and processing of personal data 1.1. For which persons we process personal data

In connection with the implementation of our activity as a tour operator and travel agent registered under the Tourism Act and with the provision of services to our clients, we process information about the following categories of individuals ("You" / "You" / "Your" / "Data entities"):

  1. Individuals who request and / or use Our services, incl. in cases where the services are requested by another person ("Customers");

  2. Individuals who claim or otherwise act on behalf of or for the benefit of another natural or legal person Our services (eg parents, guardians, trustees, managers, procurators, proxies, etc.) ("Representatives");

  3. Individuals who send inquiries (including, but not limited to by mail, e-mail, etc.), signals, complaints or other correspondence to THE LUXURY GLOBETROTTER on their own behalf or on behalf of a person they represent;

  4. Individuals, information about whom is contained in inquiries, requests, signals, complaints or other correspondence with THE LUXURY GLOBETROTTER.

1.2. Type of personal data we process

In order to provide Our Services, we may - as the case may be - process the following categories of personal data relating to Data Subjects:

1. Identification data:

  • names on an identity document;

  • date of birth;

  • identity document data such as document number, date of issue and issuing authority,

    country of issue and other information that may be required in connection with the services

    provided (eg for hotel reservations; reservation of airline tickets, etc.)

  • signature;

    2. Contact data:

  • phone number;

  • physical address(es) for correspondence;

• electronic postal address (e-mail);

3. Additional information about Representatives: information about whom and in what capacity the Representative supplies with information about the represented client; information on representative power; information about the services requested by them;

4. Contractual and financial information, which includes information and documents regarding: requested services, incl. scope and changes in the requested services; payments due and made; overdue / unpaid liabilities; refund amounts and refunds (eg in case of cancellation, etc.), bank information (bank, IBAN, bank account holder); invoices, etc. accounting documents and data necessary for their compilation; VAT number and / or other identification, tax or registration number (PIN for individuals when issuing an invoice);

5. Other information and documents: Any other information and documentation that the Client or his Representatives provide to Us or which are respectively generated / exchanged in the process of providing the services, including any other information and documentation that may be required from third parties in connection with the services requested by the Client (hotels, transport service providers (including airlines, water, rail and road carriers, etc.)

6. In case of received inquiries (incl., But not only by mail, e-mail, etc.), signals, complaints or other correspondence, other than requesting a service - information about the person who sends the respective correspondence, in what capacity, the content of the respective correspondence, inquiry, request, etc. floor, and information on their processing and status and the final result of their processing.

1.3. What happens if you do not provide your personal information?

If you wish to use the services provided by THE LUXURY GLOBETROTTER, the personal data of the persons who will use these services and respectively the data of the person / persons representing them are required (if the services are not requested directly by the client). We use the information we have (depending on the choices you make) to provide our services.

Refusal to provide data and documents that we have specified as necessary for requesting a relevant service may constitute an insurmountable obstacle to the provision of the relevant service (eg it is not possible to book a plane ticket for an unidentified / anonymous passenger) and will make it impossible for us to satisfy and fulfill the requests sent to us.

2. Objectives and legal basis for data processing

2.1. We process your personal data for the following purposes and on the following legal grounds:

2.1.1. When necessary to fulfill our conditions for the service of your choice, ie. to take steps at the request of the Data Subject (when requesting a service) before concluding a contract with Us and to perform our service contracts, in particular:

  • acceptance, administration and processing of requests for provision of services, incl. ordering relevant services to hotels, airlines, etc .;

  • concluding, performing, amending and terminating contracts with Clients, incl. customer service and provision of the requested services;

  • implementation of communication related to the provided services;

  • administration and receipt of payments for the provided services;

• recovery of incorrectly transferred amounts;

Sometimes the Data Subject who uses Our Services or for whom Our Services is claimed may not be a party to a contract with us (eg a legal entity that claims Our Services to be used by its employees; an individual who claims Our Services, services for the benefit of family members, friends, relatives, etc.). This is the case when the service is requested by a person who requests or otherwise acts on behalf of or for the benefit of a person for whom Our services are requested. In these cases, the legal basis for processing the personal data of the end user of our services is the legitimate interest of THE LUXURY GLOBETROTTER to carry out its commercial activities and to conclude, amend, perform and terminate contracts for the provision of its services.

Exceptionally, THE LUXURY GLOBETROTTER may assist clients in filling out visa application forms in third countries for which travel is requested / booked. This is done only at the request of the client, in person and in the presence of the client (for minors in person and in the presence of a parent) in the office of THE LUXURY GLOBETROTTER. The information is filled in directly in the respective application forms / platforms of the consular services of the respective countries. THE LUXURY GLOBETROTTER does not enter or store in its systems information required for filling in such forms.

2.1.2. Where necessary to comply with legal obligations, in particular:

  • accounting, invoicing, and other financial and accounting activities necessary for the fulfillment of the obligations in accordance with the current tax and accounting legislation;

  • servicing signals, complaints, requests for the exercise of rights, as well as complaints and commercial guarantees (if applicable), including the preparation of responses to them;

  • other activities for fulfillment of our legal obligations (regulatory, licensing, consumer protection, etc.) of THE LUXURY GLOBETROTTER, including providing information to competent state, municipal and judicial authorities and assisting in inspections by competent authorities;

    2.1.3. When necessary for the purposes of Our (or other people's) legitimate interests, except when such interests take precedence over your interests or fundamental rights and freedoms that require the protection of personal data, in particular:

Legitimate interest - (1.1.) Exercising and protecting the legal rights and interests of THE LUXURY GLOBETROTTER; and (1.2.) assistance in exercising and protecting the legal rights and interests of our clients, employees, business partners and contractors of THE LUXURY GLOBETROTTER:

(a) establishment, exercise or protection of legal claims of the above-mentioned persons under item (1.1) and item (1.2), including by court order, such as filing complaints, signals, etc. under. to the competent state, municipal and judicial bodies;

(b) administration and servicing of received complaints, signals, requests, etc.;

(c) collection of receivables due to THE LUXURY GLOBETROTTER, including by legal ways and / or by assignment to third parties;

transfer of receivables to third parties (assignments) in accordance with the procedure established by law;

(d) issuing notarial invitations;

• Legitimate interest - carrying out our commercial activity and ensuring the quality of the services provided by us:

(a) administration and management of the services provided by THE LUXURY GLOBETROTTER;

(b) management and quality control of the services provided.

2.4. Consent

In addition to the above purposes, if we wish to process your personal data for other purposes for which your consent is required (eg a survey on your satisfaction with the service provided, direct marketing, etc.), we will ask you for your consent through appropriate 'forms of consent'. For such purposes, we will only process personal data that you have provided to us voluntarily in the appropriate consent form. You can withdraw your consent at any time for a future period by writing to us at the postal address or e-mail address specified in item 1. The decision whether to give your consent, for what purposes to give it and whether to withdraw your consent will in no way affect the type and quality of services provided by us, the value of the services or lead to other adverse consequences for you.

3. Security

THE LUXURY GLOBETROTTER JSC. applies technical and organizational measures to protect the data provided against accidental or intentional manipulation, loss, destruction and access by unauthorized persons. Security measures are constantly updated.

4. To whom do we provide your personal data
4.1. Your personal data may be provided to the following categories of recipients:

  • Persons providing tourist, transport and other services related to the tourist activity (hotels, airlines, guides, etc.), as much as necessary for the implementation of the requested services;

  • Insurers with whom the administrator has signed a contract for the purpose of concluding

    claimed insurances;

  • Bodies, institutions and persons to whom the administrator is obliged to provide personal

    data by the power of legal provision;

  • Merchants and service providers that support our business by providing services related to

    the technical infrastructure or assisting in payments and communication with the Client (banks and payment service providers; telecommunications service providers, postal operators, etc.)

  • Persons to whom we may have to transfer data in order to protect our rights or legitimate interests, those of our employees, the Client or related persons (state and municipal authorities; private and state bailiffs; lawyers; notaries and etc. under.);

  • To other persons, if this is provided by law or in this Policy.

    4.2. For the purposes specified in this Policy, THE LUXURY GLOBETROTTER may delegate personal data processing activities to third parties - personal data processors who process personal data on behalf of THE LUXURY GLOBETROTTER and in accordance with its instructions. Our relations with such persons are settled in accordance with the requirements of the GDPR.

    4.3. Providing your personal data outside the European Union / European Economic Area

In some cases, the nature of the service requested requires that your personal data be disclosed to recipients in third countries, ie. those located outside the European Union / European Economic Area (EU / EEA) (eg when booking a hotel in a third country, reserving airline tickets with an airline in a third country, filling in a tourist visa application form, etc.). In these cases, the transfer of your data is subject to the requirements of Chapter V of the GDPR. If the third country in which the recipient is located does not provide an adequate level of data protection within the meaning of the GDPR, then the transfer shall take place under one of the following conditions:

  • Depending on the necessity of the performance of a contract between the Data Subject and THE LUXURY GLOBETROTTER or for the performance of pre-contractual measures taken at the request of the Data Subject;

  • Depending on the necessity for the conclusion or performance of a contract signed in the interest of the Data Subject between THE LUXURY GLOBETROTTER and another person (eg a legal entity requesting Our services to be used by its employees; a person requesting Our services for the benefit of family members, friends, relatives, etc.).

    5. For how long we store your personal data
    5.1.     THE LUXURY GLOBETROTTER processes and stores information about the Data Subject until the

    respective purposes for which it is collected and processed are achieved.

    5.2. In accordance with our internal rules and procedures and applicable law, We process and store personal data within the following time limits:

    Personal data exchanged in connection with the conclusion, execution, amendment and termination of contracts for services provided by us (including requests for such services and requests for cancellation of services) for the entire period of the contract and for a period of up to 5 (five) years after its termination (respectively up to 5 years from the cancellation of the respective request).

    Personal data related to and / or contained in tax and social security control documents (eg applications and other documents governing the contractual relationship, invoices, credit and debit notices) are stored for up to 10 (ten) years from the beginning of the year following the year in which the payment of the relevant public debt related to the accounting for the relevant financial year is due;

    Personal data contained in correspondence, complaints and alerts are stored for up to 5 (five) years from the completion of the respective correspondence / signal processing.

    5.3. In case of a legal dispute or proceedings requiring data retention and / or a request from a competent state authority, it is possible to retain data for longer than the specified periods until the final conclusion of the dispute or proceedings by all instances, as well as for a period up to 5 (five) years from its completion.

    5.4. If by law or other normative act the storage of relevant information and / or the relevant documents or other information carriers is required for a longer period than the one indicated above, the normatively established longer period shall be applied for their storage. The specified deadlines may be changed in case a different requirement for keeping the information is established according to the current legislation.

    6. Rights with regard to personal data

The Regulation provides for the following rights in connection with the processing of your personal data by us:

6.1. Right to information. This Policy is intended to inform you in detail about the processing of your personal data in connection with the services provided.

6.2. Right of access. You have the right to receive confirmation whether your personal data is processed, access it and receive information about its processing and your rights in this regard.

6.3. Right of adjustment. You have the right to correct your personal data in case it is incomplete or inaccurate.

6.4. Right to delete. You have the right to request the deletion of your data if there are grounds for doing so provided in the Regulation.

6.5. Right of restriction in relation to data processing. The regulation provides for the possibility to restrict the processing of your personal data if there are grounds for doing so.

6.6. Right to notify third parties. You have the right to ask Us to notify third parties to whom your personal data has been disclosed of any correction, deletion or restriction of the processing of your personal data, unless this is impossible or requires a disproportionate effort on our part.

6.7. Right to data portability. You have the right to receive the personal data that you have provided to us and that relates to you, in a structured, widely used and machine-readable format and to transfer this data to another administrator without hindrance on our part under the conditions and prerequisites provided for this in the Regulation.

The right to data portability applies when the following two conditions are met simultaneously: - the processing is based on consent or a contractual obligation;
- processing is performed in an automated manner.

6.8. The right not to be the subject of a decision based solely on automated processing. You have the right not to be the subject of a decision based solely on automated processing, including profiling, which has legal consequences for you or similarly affects you significantly, unless the provisions of the applicable data protection legislation are in place. Grounds for this and appropriate guarantees are provided to protect your rights, freedoms and legitimate interests. We do not use such technologies in performing any of the processing of personal data set forth in this Policy.

6.9. Right of withdrawal of consent. You have the right, at any time, to withdraw your consent to the processing of personal data, if the relevant processing is based on your consent. Such withdrawal shall not affect the lawfulness of the processing on the basis of the consent given until the moment of its withdrawal.

6.10. Right to object. You have the right at any time and on grounds related to your specific situation to object to the processing of your data, based on public interest, the exercise of official powers or the legitimate interests of THE LUXURY GLOBETROTTER or a third party.

In the event of such an objection, we will consider your request and, if justified, we will comply with it. If we believe that there are compelling legal grounds for processing or that it is necessary to establish, exercise or defend legal claims, we will inform you.

6.11. Exercise of rights. You can exercise the rights described above at any time by sending a written request to THE LUXURY GLOBETROTTER - by mail to the postal address or by e-mail to the e-mail address specified in item 1 of this document, in accordance with the applicable law.

6.12. Right to appeal to a supervisory authority. You have the right to lodge a complaint with a supervisory authority if you believe that the processing of personal data concerning you violates applicable personal data protection legislation. The supervisory body in the Republic of Bulgaria is the Commission for Personal Data Protection with address: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov ”No 2; website: https://www.cpdp.bg/.

7. Additional information

The website of THE LUXURY GLOBETROTTER JSC can be visited without providing personal data. The team of THE LUXURY GLOBETROTTER JSC will answer all substantiated inquiries regarding the processing of personal data.

For questions related to this data protection policy, or if you wish to receive more in-depth information on a specific issue, please contact our team at reservations@theluxuryglobetrotter.com

Date of last change: 07 July, 2024