1. GENERAL PROVISIONS
THIS PRIVACY POLICY APPLIES TO THE RIGHTS AND OBLIGATIONS OF USERS AND VISITORS OF OUR WEBSITE. BEFORE STARTING TO USE THE WEBSITE, YOU MUST CAREFULLY READ AND COMPLY WITH THIS PRIVACY POLICY. BY USING THE WEBSITE, YOU AGREE TO THE TERMS OF OUR PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE REFRAIN FROM USING OUR WEBSITE.
The website of Limited Liability Company “ALL TRAVEL GROUP” (https://alltravelgroup.com.ua) (hereinafter referred to as the “Website”) is managed by Limited Liability Company “ALL TRAVEL GROUP”, a legal entity registered in Ukraine in accordance with the requirements of Ukrainian legislation (hereinafter referred to as the “Company”).
The Company takes all necessary measures provided by the current legislation of Ukraine aimed at protecting the confidentiality of personal data (information or a set of information about an individual who is identified or may be identified using such data), thereby creating and ensuring the most comfortable conditions for each user to use the Website services.
This Privacy Policy (hereinafter referred to as the “Policy”) establishes the procedure for the Company’s processing of personal data, the types of personal data collected, the purposes of using such personal data, the Company’s interaction with third parties, security measures for protecting personal data, conditions of access to personal data, as well as contact information for users regarding access, modification, blocking or deletion of their personal data and resolution of issues related to personal data protection.
2. COLLECTION AND USE OF PERSONAL DATA
The owner and administrator of users’ personal data on the Website is the Company. In accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 (the General Data Protection Regulation (EU) 2016/679), the Company is also the Controller (the person who determines the purposes and means of processing personal data).
When users use the Website services, the Company processes user data, including:
- data provided by the user when completing registration forms on the Website and/or during the use of the Website services (first name, last name, patronymic, email address, contact phone number; passport number);
- cookie files;
- IP addresses;
- internet browser parameters and settings (User-agent).
The Company collects only those personal data that are knowingly and voluntarily provided by you as a personal data subject for the purpose of using the Website services, which, in accordance with legal requirements, constitutes your consent to the processing of your personal data in accordance with the purposes of processing defined in this Policy.
When visiting the Website, user logins into the Website’s information system are recorded. The Company collects website usage statistics. Such information may include traffic data, user browser information, user device information, as well as the date, time, duration of Internet usage and time spent on the Website.
The Company limits itself to collecting the minimum amount of personal data necessary for the operation of the Website services for users and/or for fulfilling our obligations to the user as a personal data subject.
The Company does not collect or process users’ personal data regarding racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data related to health, sexual life, biometric or genetic data (Article 7 of the Law of Ukraine “On Personal Data Protection”).
3. PROCESSING AND STORAGE OF PERSONAL DATA
The processing and storage of personal data is carried out in data centers where the equipment ensuring the functioning of the Website services is located. Provided personal data is processed and may be stored in the personal data database and/or in separate tables of the Website database.
The personal data of our users is stored and processed on servers located in Ukraine. Personal data may also be temporarily stored and processed in other jurisdictions.
The Company reserves the right to store, process and transfer users’ personal data to our servers in various jurisdictions where our infrastructure facilities and/or service providers are located. Users’ data may also be processed by employees working for us and/or for one of our service providers. Such personnel may participate in providing our services and/or processing users’ data and/or providing user support. By providing your personal data, you, as a Website user and a personal data subject, agree to such transfer, storage and processing. At the same time, we take all necessary measures to ensure the secure handling of your personal data in accordance with this Policy.
Your personal data is used to ensure the functioning of the Website services, as well as to provide related services (including in the tourism sector — hotel bookings, ticket reservations and insurance policy issuance), exchange information and news through the Website, display advertising and ensure communication, as well as to comply with the requirements of Ukrainian legislation, including but not limited to: the Law of Ukraine “On Personal Data Protection”, the Law of Ukraine “On Ratification of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and the Additional Protocol to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data regarding Supervisory Authorities and Transborder Data Flows”, the Laws of Ukraine “On Information”, “On Advertising”, “On Protection of Information in Information and Communication Systems”, as well as other regulatory acts governing the Company’s activities.
Personal data of users permitted for processing under this Privacy Policy includes:
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- surname, first name, patronymic;
- date of birth;
- gender;
- email address (e-mail);
- phone number;
- passport details (passport series and number, country of issue, validity period);
- place of residence (country, city, address);
- payment card details;
- other data necessary for issuing and selling tickets, ordering tourist and additional/supplementary services, using the Website services, and fulfilling the Company’s obligations to the user.
4. RETENTION PERIOD OF PERSONAL DATA
Personal data is stored for a period that does not exceed the period necessary to achieve the purposes defined in Section 4 of this Policy and/or to fulfill the Company’s obligations to the user as a personal data subject, but in any case for no less than 3 years. If a personal data subject ceases to be a Website user after completing the account deletion procedure on the Website, their personal data is also deleted, provided that the Company has no other legal grounds for storing and/or processing the respective personal data.
5. USE OF COOKIE FILES
Cookies are text files or files containing a small amount of information that are sent by a web browser and stored on the user’s device. Such devices may include a computer, mobile phone, or any other device used by the user to access the Website.
Cookies may be permanent and stored on the computer until the user deletes them, or temporary (session cookies), which are stored only until the browser is closed. In addition, cookies are divided into first-party cookies (installed directly by the website being visited) and third-party cookies (installed by other websites).
Stored cookies do not identify a specific user but identify the user’s device through randomly generated identification tags.
It is important to know:
- when the user visits the Website again, cookie data is updated;
- in most cases, web browsers allow automatic storage of cookies on the user’s device by default;
- disabling cookies may result in limited access to published materials and/or improper functioning of the Website services.
The Company cares about its users and strives to make their experience on the Website as comfortable as possible. For this purpose, the Company needs to analyze user behavior, preferences and interests using cookies. Such analysis helps the Company improve the user experience when interacting with the Website, determine the most convenient interface and improve Website navigation.
According to the classification of the International Chamber of Commerce, the Company uses the following categories of cookies:
Strictly necessary cookies – required for user navigation through Website pages and for using certain Website services, such as accessing protected pages, registration and authorization, and performing searches on the Website. These cookies remember previous user actions when navigating between pages within the same session.
Performance / statistical cookies – collect aggregated information about Website usage. This data is stored on the user’s device between browser sessions. Examples of such data include the following metrics: time spent on the Website, the most frequently visited pages, understanding which Website sections and services were most interesting to the user, the effectiveness of specific advertising and/or marketing campaigns, etc. Information collected through performance cookies is used for statistical and analytical purposes. Some cookie data may be provided to third parties authorized by the web resource and exclusively for the purposes described above.
Functional cookies – used to save settings stored on the user’s device between web browser sessions. Examples of such data may include the following metrics: username, profile photo, information about submitted comments / requests / orders, Website language, location, information about whether any information has previously been provided to the user, as well as other Website settings. These cookies also allow users to watch videos, participate in surveys and voting, and interact with social networks.
In order to create comfortable conditions for using the Website, these cookies remember information provided by the user, improving the efficiency of interaction with the Website. Exclusively for achieving the purposes mentioned above, some cookie data may be provided to third parties that have received appropriate authorization from the web resource.
Targeting cookies – used to provide content that may be of interest to the user. This data is stored on the user’s device between browser sessions. Examples of such data include: tracking recommended text, graphic, audio and video content to prevent repeated display, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about visits to other resources by the user when navigating between websites, as well as other Website settings. The Website may transfer such information to third parties, including media clients, advertisers, and our partners, so that they can provide high-quality targeted advertising.
Cookie files of third-party services and analytics services:
- To ensure prompt content delivery, improve content display quality and provide detailed Website content analysis, the Company uses services owned by third-party companies, such as Facebook, Instagram, Google services and others. These companies and services may use cookies on the user’s device while the user is browsing the Website.
Please note that the Website cannot influence the operation of cookies used by the specified services. All necessary information regarding their use can be obtained by visiting the relevant resource. For example, the terms of use of Google Analytics.
Cookie management:
- Major web browsers (Mozilla Firefox, Google Chrome, Opera, Safari for macOS, Microsoft Edge) are configured to automatically accept cookies. To disable them, use the help function in your browser or visit the official web resource of the relevant browser.
If the user does not enable the use of cookies and/or deletes all cookies from their web browser, then during the next visit to the Website the user will be asked again to enable and use cookies.
6. INTERACTION WITH RESOURCES AND SERVICES OF THIRD PARTIES
On the Website pages, software scripts and functions of other Internet resources and third-party services may be embedded, as a result of which these Internet resources and third parties may receive your data. Such Internet resources may receive and process information that you have visited these pages, as well as other information transmitted by the user’s browser. Such Internet resources may include:
- banner display systems (for example, Google Ad Manager);
- social media plugins (for example, Facebook, Twitter).
The Company uses these services for prompt analysis of Website visits, internal and external evaluation of Website traffic, depth of Website browsing, and user activity. The Company does not store or process the data obtained from these services.
Accordingly, if a user does not wish for these services to have access to their personal data, the user may voluntarily log out of their account or profile and clear cookies (through their browser).
The Website may also contain links to other websites (for informational purposes only). When following links to other websites, this Policy does not apply to such websites or relations arising in connection with their use. Therefore, the Company recommends reviewing the privacy and personal data protection policies of each website before providing personal data that may identify you.
7. TRANSFER OF DATA TO THIRD PARTIES
The Company does not transfer users’ personal data to third parties, except in cases where such transfer is required by law, for example, at the request of the personal data subject, and/or in other cases provided for by this Policy (including those specified in Section 3 of this Policy), as well as in cases where the transfer of user data is necessary for the Company to fulfill its obligations to the user.
Contract performance: Processing/transfer of data is necessary for the provision of tourism services, hotel bookings, ticket reservations, and insurance policy issuance (in accordance with Article 6(1)(b) of the GDPR).
The Company takes necessary and relevant measures to protect users’ personal information that is voluntarily and consciously provided to the Company.
8. PROTECTION OF PERSONAL DATA
The Company applies generally accepted information and personal data protection standards to prevent loss, misuse, alteration, or destruction of data. In particular, the Company implements technical and organizational measures (SSL encryption, firewalls). However, despite all efforts, the Company cannot guarantee absolute protection against all threats arising outside the Company’s regulatory control.
The Company ensures compliance with all relevant confidentiality obligations, as well as technical and organizational security measures aimed at preventing unauthorized or unlawful disclosure or processing of personal data, accidental loss, destruction, or damage.
The Company provides access to personal data only to authorized employees of the Company and/or our contractors and service providers who have agreed to ensure confidentiality of such data in accordance with the Company’s requirements and applicable legislation, as well as to third parties in cases expressly required by law or provided for by an agreement between the user and the Company.
Disclosure of personal data without the consent of the personal data subject or their authorized representative is permitted only in cases established by law, in particular, when it is necessary in the interests of national security, economic well-being, and human rights.
If significant changes are made to this Policy, the Company will publish a notification on the Website and indicate the effective date of such changes. If you do not refuse to accept them in writing within the specified period, this means that you agree to the respective changes to the Policy.
PLEASE REVIEW THIS POLICY FROM TIME TO TIME TO BE AWARE OF ANY CHANGES AND/OR ADDITIONS TO THIS POLICY.
9. RIGHTS OF PERSONAL DATA SUBJECTS
As a personal data subject, you have the rights provided for by the Law of Ukraine “On Personal Data Protection”. If you are a resident of one of the European Union member states, you also have the rights defined by the provisions of the General Data Protection Regulation (EU) 2016/679 (the General Data Protection Regulation (EU) 2016/679), including:
- to access, update or delete information about you that we store;
- to correct your personal data if it is inaccurate or incomplete;
- to object to the processing of your personal data by us;
- to request restriction of the processing of your personal data;
- to receive a copy of your Personal Data in a structured format;
- to withdraw your consent to the processing of personal data at any time.
You also have the right to submit a complaint to a data protection authority regarding the collection and use of your personal data by us. For additional information, please contact your local data protection authority in the European Economic Area (EEA). We recommend that you contact us first to resolve any questions within the limits permitted by law.
You agree that the procedure for exercising your rights is governed by the terms of this Policy. The following sections of this Policy describe the methods for exercising certain of your rights.
10. ACCESS TO PERSONAL DATA
You have the right to access your personal information so that you can review the personal data we have stored, as well as make corrections to your personal data. You may request access to your personal data or request corrections by sending us an email to the address specified below in the “CONTACTS” section. Please note that we may ask you to confirm your identity before responding to such requests.
10.1. DELETION OF PERSONAL DATA
You have the right to request correction or deletion of your personal data by sending us an email to the address specified below in the “CONTACTS” section. Please note that we will not be able to provide our services and/or ensure the proper functioning of our services for you without the necessary information about you.
We may also retain part or all of the user’s data and not delete it until all possible claims and our obligations related to the processing of the user’s personal data have been fulfilled (for example, regarding service provision, fraud prevention, compliance with legal obligations, dispute resolution, execution of agreements, etc.). If we delete any data created by the User, including Personal Data, such data will be removed from the active database but may remain in our archives.
You may also withdraw your consent to further processing of Personal Data at any time. If you withdraw your consent to the processing of Personal Data and we have no other legal grounds to continue processing your data, we will stop processing your personal data. If we have legal grounds for processing your personal data, we have the right to continue using personal data within the limits established by law.
Regarding the processing of your personal data, please contact:
LIMITED LIABILITY COMPANY “ALL TRAVEL GROUP”
- EDRPOU Code: 40688170
- Registered address: Ukraine, Kyiv, 03035, Lyudmyly Protsenko Street, building 6
- Tel: +38 (044) 245 41 41
- Email: info@altg.com.ua
Personal Data Protection Authority in Ukraine:
The administrative body responsible for personal data protection in Ukraine is the Personal Data Protection Department of the Secretariat of the Ukrainian Parliament Commissioner for Human Rights. You may contact this authority with complaints or suggestions if you believe that your rights have been violated in connection with the processing of personal data.