Privacy Notice

Last updated: 2022-07-18

Introduction

Welcome to Travel2Fit’s Privacy Notice.

Travel2Fit values your trust, respects your privacy and is committed to protecting your personal data. We encourage you to read this Privacy Notice as it will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. Travel2Fit always complies with the applicable privacy and data protection laws and with the provisions of the General Regulation on Data Protection of the EU 2016/679 as amended.

1. Important information and who we are

This Privacy Notice aims to give you information on how Travel2Fit collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our service or purchase a product.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.

2. About this Privacy Notice

This Privacy Notice sets forth the handling practices of Travel2Fit, PC, (variously, “Travel2Fit”, “we”, “our” or “us”) and its affiliates in regard to the collection, usage and disclosure of personal data or personal information that you may provide to us through using this website (travel2fit.com) (the “Website”), or by using any product or service provided by Travel2Fit (Travel2Fit Proposal Builder and ROSIE or, the “Services”). We have appointed a data protection manager (“DPM”) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPM using the details set out below.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

If you do not accept this Privacy Notice and/or do not meet and/or comply with the provisions set forth herein, then you should not use our Website.

3. Contact details

Our full details are:

• Full name of legal entity: Travel2Fit, PC.
• Name or title of DPM: Alexandra Aslanidou, Legal/Ethical Advisor
• Email address: aaslanidou@travel2fit.com
• Postal address: 45 Ethnikis Antistasis Street, 601 33, Katerini, Greece

4. Types of data we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

• Identity Data may include first name, last name, company name, job title, website URL and photograph (headshot) and other demographic data that you provide to Travel2Fit.
• Contact Data include billing address, email address and telephone numbers.
• Financial Data include bank account and payment card details.
• Transaction Data include details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data include your username and password, purchases made by you, your preferences, feedback and survey responses.
• Client Data cover the personal data about a client (generally the traveler) which may be added to Travel2Fit by virtue of being a client of a Travel2Fit Account holder, and is limited to name, email address and travel schedule. For purposes of this Privacy Notice, clients have the right to request that Travel2Fit delete all information pertaining to them from our Site and Services, either by contacting us directly or by requesting that your travel professional contact us on the client’s behalf. The travel professional that uploads the Client Data shall be authorized to have any Client Data removed from the Travel2Fit system, with or without client knowledge or permission.
• Usage Data include information about how you use our website, products and services.
• Marketing and Communications Data include your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

User Content (as defined in the Travel2Fit Terms of Use) is, to the extent that it doesn’t include any personal information as detailed in this Privacy Notice, shall not be subject to the terms of the deletion policies of Travel2Fit as it does not include any personal information.

5. How is your personal data collected?

We use different methods to collect data from and about you are including through:

• Direct interactions. You may give us your Identity, Contact, Client and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. create an account on our website;
2. use the Travel2Fit Proposal Builder;
3. use our revenue-management system ROSIE;
4. request marketing to be sent to you; or
5. give us feedback.

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

1. Technical Data from analytics providers, advertising networks or search information providers.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators.
4. Identity and Contact Data from publicly availably sources.

6. How is your personal data used?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

In addition to the purposes and uses described above, we use information in the following ways:

• To identify you when you visit our websites.
• To provide our Services.
• To improve our Services and offerings.
• To promote the security of our Website and Services.
• To conduct analytics.
• To respond to inquiries related to support, employment opportunities, or other requests.
• To send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
• For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you sign up for Services, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your Services. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

7. Lawful basis for processing your personal data

The processing of your personal data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities:

• Consent. By using our Services, you consent to our collection, use and sharing of your personal data as described in this Privacy Notice.
• Legitimate interest. We will process your personal data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your personal data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Travel2FIT and you; detect and correct bugs and to improve our Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; check your credit and perform risk assessments; provide you with information about experiences that you may be interested in.
• As required by law. We may also process your personal data when we are required or permitted to by law.

8. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you. When you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transaction.

9. Cookies

In order to improve our services and provide more convenient, relevant experiences to our customers, we may use “cookies,” “web beacons,” and similar devices to track your activities. A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the server that gave it to you. It functions as your identification card and enables us to record your passwords and preferences. It cannot be executed as code or deliver viruses. A web beacon is a small transparent .gif image that is embedded in an HTML page or email used to track when the page or email has been viewed. Most browsers are initially set to accept cookies, and most services that include similar devices are typically initially activated to collect data. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.

10. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

11. Disclosures of personal data

In addition to the specific situations discussed elsewhere in this Privacy Notice, we may have to share your personal data in the following situations:

• Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
• Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this privacy notice.
• Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
• Service Providers. We share your information with service providers. Among other things service providers help us to administer our website, send e-mail communications, conduct surveys, provide technical support, detect fraud, process payments, and assist in the fulfillment of our services. Our service providers will be given access to your personal information as is reasonably necessary to provide the Website and related Services. Our service providers are contractually obligated to use your personal information only at our direction and in accordance with our Privacy Notice; to handle your personal information in confidence; and to not disclose your personal information to unauthorized third parties. Service providers who violate these obligations are subject to appropriate discipline including, but not limited to, termination as a service provider.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Except as otherwise stated in this Privacy Notice, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Data with third parties without your consent.

12. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

14. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This grants you the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate reasons to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You may exercise these rights by contacting us at hello@travel2fit.com.

Please not that we will respond to any such request in a timely manner as specified by the GDPR. If we need more time to fulfill your request, we will let you know in advance. We will not exceed the legally specified time limit under any circumstance. Please, note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

15. Other important information

The following additional information relates to our privacy practices:

• International Data Transfers. Our company operates globally and has a global infrastructure. We utilize cloud computing which means your personal data may be transferred to a country with data protection laws not as strong as where you reside. We will transfer your Personal Data to countries deemed having adequate levels of data protection as determined by the European Commission.
• Third Party Websites and Services. We have no control over the privacy practices of websites or applications that we do not own. We are not responsible for the practices employed by any websites and/or services linked to and/or from our Website, including the information and/or content contained therein. Please remember that when you use a link to go from our Website to another website and/or service, our Privacy Notice does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on our Website, are subject to such third-party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal data. If you are using a third-party website and/or service and you allow them to access your personal data, you do so at your own risk.
• Changes to our Privacy Notice. In general, changes will be made to this Privacy Notice to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Notice at any time, with or without advance notice, so please review it periodically. We may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. Your continued use of the Website after any modification to this Privacy Notice will constitute your acceptance of such modifications and/or updates. You can determine when this Privacy Notice was last revised by referring to the date it was last “Updated” above.

By using our services, you consent to our Privacy Notice.