transferNTour Ltd.

PRIVACY POLICY

Effective date: July 29, 2019

This Privacy Policy is issued by TransferNTour Ltd.  (hereinafter referred to as “TransferNTour”, “we”, “us” or “our”), a limited liability company formed under the laws of Bulgaria, registered in Bulgarian Commercial Register under 205699136 and having its headquarters’ address at 12 Iliyantsi blvd.1220 Sofia, Bulgaria.TransferNTour Ltd. is a data controller and recipient of personal data.

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”).

Before submitting your personal information to us, please read this Policy carefully to get familiar with the categories of personal data we collect and process, how we use this data, and who we are likely to share with. This Privacy Policy also describes your rights and how you can contact us to exercise these rights or ask us any questions about the protection of your personal data. Please also read our separate Cookie Policy which tells you how TransferNTour makes use of cookies and other similar technologies

It is important to know that:

• By registering on our Platform, you agree to the Privacy Policy and explicitly confirm that you accept it;
• If you do not wish to process your Personal Information as described in this Privacy Policy, please do not provide it to us. The provision of Personal Data is voluntary, in order to use or access the Services of our Platform. Your possible refusal to provide the necessary Personal Data to use the services on our platform would be a refusal to use or access the services concerned;
• In certain cases, your explicit consent to the processing of Personal Data may not be necessary if another legal basis is available, for example, compliance with the legal obligations ofTranserNTour, need for contract execution, etc.

This Privacy Policy may be amended, supplemented or updated, including in order to comply with the laws, regulations, case law, or changes in technical developments that may arise, or for meeting specific local legal requirements that have to be implemented for the legal framework of the Platform. 

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.

This Privacy Policy is an integral part of the Terms of Use of our Platform.

If you have any questions about this Privacy Policy or wish to exercise your rights under it, you can contact us at any time at info@transferntour.com

Definitions

“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.

“Data Controller” is a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, TransferNTour is a Data Controller of your data.

“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, shared transfers, private and organised sightseeing tours, wine & food tours, long & short hold cruise, and sailing services (“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).

“Cookies” are small pieces of data stored on a User’s device. For more information, please read our Cookie Policy, which is an integral part of the Terms of Use of our Platform.

All capitalized terms and not defined terms, used in this Privacy Policy have the same meanings as in our Terms of Use.

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:

• Basic mandatory data: names, mobile phone number, email, and address;
• Optional user information- Facebook profile, Twitter profile; Google Account (when User chooses the option of“Login with Social Account”);
• Types of Services reserved and used via our Platform;
• Cookies and Usage Data;
• IT-related information, such as your IP address, your geographic location, the name of your internet service provider, the operating system and the browser you used, the date and duration of your visit, the name(s) of the visited page(s), personal data contained in cookies and web beacons as the case may be and your login information;
• Information for payment processing purposes (including credit card details and other payment details).

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, biometric 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:

• We may receive User data such as names, gender, age, place of residence, photo/avatar, which data are added to the created user account in the Platform;
• We may receive User relationship data with other users (online friendships), which data is added to User Platform data (transferring online friendships);
• We may be able to send notifications to the User sent within the respective external service for communication or marketing purposes (for example, private Facebook notifications) via the appropriate external service. 

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:

• Reservations: we use your personal data to complete and administer your online Booking for the trip, transfer or cruise you made. This includes sending you communications in relation to your Reservation such as confirmations, modifications and reminders;
• Account management: Platform users can create a user account on our Platform. We use the information you give us to administer this account, allowing you to do several useful things. You can manage your Bookings, take advantage of special offers, make future bookings easily and manage your personal settings. Managing personal settings can allow you to keep and share lists, see previously searched services easily and to check other travel-related information you have provided. It can also allow you to see any reviews you have submitted;
• Communicating with you: we may get in touch, including by email, by phone or by texting you – which method we choose depends on the contact information you’ve previously shared with us when: a) we send you information related to upcoming bookings or a summary of previous bookings you made through our Platform; b) we respond to and handling any requests you or your Service Provider have made; c) we may contact you or a person you indicated (family member or friend) for the purposes of ‘’Panic Button’’; d) we send you a questionnaire or invite you to provide a review about your experience with our Platform or the Service Providers;  
• Marketing activities: we may use your Personal Data to contact you for marketing activities like sending you regular news of transfer/tour/cruises, related products, and services. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send. 
•  Improving our services: We may use Personal Data for analytical purposes (e.g. to improve the functionality and quality of our online services, to optimize and customize our online platform to your needs, making our site easier and more enjoyable to use). We strive to only use pseudonymized data for these analytical purposes;
• Legal purposes: In certain cases, we may need to use your information to handle and resolve legal disputes, for legal investigations or to comply with lawful requests from law enforcement.

The legal bases for processing your personal data to achieve the above purposes are as follows:

• Contractual basis: it is necessary for TransferNTour to take measures at your request prior to entering into a contract or for the performance of any contractual obligations towards you specifically to finalize and administer your booking/reservation. If the required personal data is not provided, TransferNTour cannot finalize the Transfer, Tour or Cruise Booking, nor can we provide customer service;
•  Your consent: if no other legal basis can be applied where needed under applicable law, TransferNTour will obtain your consent prior to processing your Personal Data for direct marketing purposes, for example – when you want to receive bids, promotional and marketing messages from third parties or for us to use web beacons and third-party cookies. When processing is done based on your consent, you have the right to withdraw your consent at any time, but this will not affect the lawfulness of the processing based on the consent prior to its withdrawal;
•  Legal obligations: it is necessary for TransferNTour to be able to comply with legal or regulatory obligations, such as to allow us to comply with applicable laws and any regulatory obligations, and to respond to requests and comply with requirements from public authorities. 

Disclose Personal Data with Third Parties

We may disclose personal data to the following third parties:

• Service Provider: In order to complete your reservation/booking, we transfer relevant reservation details to the Service Provider you have booked. Depending on the Reservation and the Service Provider, this can include your name, contact details, payment details, the names of the guests traveling with you and any preferences or other information you specified when you made your Reservation;
• Third-party support companies: IT hosting companies, support services, and customer relationship management system providers, payment service providers, and gateways. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose;
• Regulatory authorities including tax authorities; and law enforcement agencies, courts and other tribunals where we are under a legal obligation to disclose your information or we are permitted to do so to protect or defend our rights.

Your information, including Personal Data, may be transferred to countries where the data protection laws may differ from those of the countries within the European Union. Where required by European law, we shall only transfer Personal Data to recipients offering an adequate level of data protection.TransferNTour will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Retention of Personal Data

TransferNTour will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (e.g. if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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:

• Right to access to your personal data: You have the right to obtain confirmation from us as to whether or not your Personal Data are being processed, and, where that is the case, to receive access to the Personal Data and information;
• Personal data rectification right: If you find that the Personal Data we process for you are inaccurate, you are entitled to require us to rectificate this Personal Data, as well as the supplementation of incomplete personal data;
• Right to erasure personal data (the right to be forgotten): In certain circumstances, such as if your Personal Data is unlawfully processed or you have withdrawn your consent (if the processing of Personal Data is based on consent) and there is no reason for us to continue their processing, you have the right to request us the erasure of your Personal Data;
• Right to the restriction of processing: In certain circumstances, such as if you have doubts about the accuracy of your Personal Data or have objected to our legitimate purpose for processing your personal data, you have the right to request us to restrict the processing of your Personal Data until a solution is found;
• Data portability right: If your personal data is processed by automatic means in your consent or in order to perform our contractual relations, you are entitled to obtain the personal data that concern you and which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transfer this data to another data controller;
• Right to object to processing: In certain circumstances, such as if you have a legitimate interest in processing your Personal Data, you have the right to object, for reasons of your specific situation, to such processing;
• Right to lodge a complaint with a supervisory authority: You have the right to complain about the processing of your personal data by us with your local data protection authority.

You may direct your requests, inquiries, and objections to us at the following email address: info@transferntour.com, support@transferntour.com. 

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

We use cookies and similar tracking technologies to track the activity on our Platform and hold certain information.

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. 

When you revisit a site, the website will respond in a more personalized way, remembering your preferences, providing faster page load times and so forth. If you want to learn more about what cookies are, how they are used and what your choices are, please read our Cookie Policy.

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

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. TransferNTour is not responsible for the content of this external site, its services and functionality, and its data protection policy. We strongly advise you to review the Privacy Policy of every site you visit.

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.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Final Provisions

More information on how the Platform works can be found in the TransferNTour Terms of Use from which this Policy is an integral part. 

Contact Us

If you have any questions about this Privacy Policy, please contact us at: info@transferntour.com; support@transferntour.com.