White Label Travel LTD, as described in this Policy (hereinafter: "We", "Our", or "Us") collects, stores, processes, uses and discloses personal information about you in connection with your use of WLT web sites, WLT apps, your use of our connected products (if and when available), or when you visit our stores or visit our social media pages, in your jurisdiction. 1. What type of personal information do we collect?
For the purposes described in this Policy, WLT may collect the following categories of personal information:
a) Identification and Contact information (such as name, address, phone number or e-mail address), when you are willing to provide them for instance to sign up for an online account or fill out a customer information, to participate in an event, subscribe to our newsletter or to make an inquiry for our services.
b) Demographic information like your gender and birthday.
c) Preferences and interests which you choose to disclose in the course of contacts with our Travel advisors (which may include your preferences about our services, your lifestyle, or basic information on your family circle).
d) information, which may include health information, related e.g. to possible adverse effect caused by food in restaurants and hotels we will offer to you or related to your mobility and/or other health information.
e) If you use our web sites, we may collect information about the browser you are using, the device with which you visit our website and your browsing behaviour.
f) If you use our mobile app (if such is available now or in a future), we may collect your GPS location, subject to your consent when required. We might also look how often you use the app and where you downloaded it. We may collect information about the browser you are using, and your browsing behaviour.
Your personal information is collected either directly from you (e.g., if you left an enquiry for our services or subscribed to our newsletter or otherwise interact with our Travel advisors), or from you passively (e.g., when using tracking tools like browser cookies), or from third parties (e.g. through social media platforms).
We use the information described above for the purposes specified at the time of collection or hereafter in this Policy:
a) to improve our understanding of your interests and concerns, and to improve our services: we may use your information to make our website, apps and services better. We may use your information to customize your experience with Us and to tailor our marketing activities to fit your needs and interests as we believe that it is also in our legitimate interest to better serve you and respond to your needs.
b) to provide you with our services, to respond to your requests or questions, and manage your complaints: for example, we use your information to work with air companies, hotels, and other services providers. Or, we may use your information to communicate with you about your account or our relationship: we may contact you about changes to the Site or about service updates.
c) for security purposes: we may use information to protect Our company, Our customers, Our associates, and Our websites or apps against fraud, theft or any wrongdoing which may affect our activity as it is our legitimate interest to ensure the security of our activity online and offline.
f) for marketing purposes: we may use your information to contact you, subject to your consent when applicable, about new services, hotels, destinations and special offers we think you will find valuable.
g) for analytics purposes, we may use your information to analyse the e-reputation of WLT or Our services and to measure the effectiveness of our online campaigns, as it is our legitimate interest to preserve WLT's image and optimise our marketing campaigns.Do we share your personal information with third-parties?
We share the information we collect as follows:Legal Disclosures.
We may disclose a user’s information (including personal information) where we believe that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a warrant or administrative request, a court or regulatory order, or other valid legal processes. We may also disclose personal information where we believe it is necessary to identify, contact or bring legal action against someone who may be violating the Terms of Service for our Service, to detect fraud, for assistance with a delinquent account, as evidence in litigation in which we are involved, or to protect the safety and/or security of our users, the Service or the general public.Service Providers.
We may contract with independent contractors, vendors and suppliers to provide specific services related to the Service, such as hosting and maintaining the Service, providing payment processing and fraud screening, data analysis, and developing applications for the Service, email services and marketing enrichment services. We may disclose a Service user’s information to these service providers as necessary for those service providers to provide their service. Similarly, we may share your information with our mentor partners to allow them to contact you in connection with the service.Aggregate and De-Identified Information.
We may also provide aggregate, anonymous or de-identified information about users and the Service for marketing and research purposes. For example, we might inform third parties regarding the number of unique users who visit the Service, the demographic breakdown of our registered users of the Service, and the educational progress of categories of users.
How we use your personal data?
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 (i.e. in order to service your travel enquiry or your booking).
- 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you if you have not previously enquired or booked a holiday with us and in order to share your personal data with any third party for their marketing communications. We will also rely on your consent to our use of special category data as outlined in the paragraph “Special Category Data” above.
You have the right to withdraw consent to marketing at any time by contacting us or in the case of email marketing, including our newsletter, if you unsubscribe.Purposes for which we will use your personal data.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We may collect certain information through cookies, web beacons and other automated means. A cookie is a text file which is stored in a dedicated area of your device’s hard drive, for instance when you visit online service, when you read an email or while installing or using a mobile app. A cookie allows its sender to identify the device on which it is stored during the period of validity of consent, which does not exceed 13 months.What type of cookies do we use?
a) Some cookies may be functional to collect information which will allow Us to facilitate your browsing such as languages preferences or memorizing log-in.
b) Other cookies also collect information on your behaviour by collecting referring URLS (where our visitors come from, which banners they clicked on and which directed them to our website), pages accessed, times of websites visits. Such information will allow Us to enhance our web site, have a better understanding of the services you would prefer, and offer you more personalized communications and/or more personalized content on our website.
Social networks which offer these functionalities may identify you even though you do not use these functionalities on our website. Indeed, such functionalities allow social network platforms to track information about your browsing on our website whenever your social network account is active while browsing our website.
We do not control how these platforms collect your personal data while you are browsing our website. We invite you to read the Privacy policies of these social networks to find out how they use information they collect (including for advertising purposes) through these buttons. These Privacy policies should provide you information about how to manage your preferences on your social networks account. Acceptance of cookies
Except for functional or security cookies, the use of cookie on a Device depends on the user’s choice, which can be made at any time. Protecting your personal information
We will provide an adequate level of protection for the personal data and make sure that appropriate technical and organizational security measures are in place to protect the personal information (including education and training of relevant personnel) against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
However, to the extent that the Internet is not completely secure, we cannot guarantee that any of your personal information stored or sent to us will be completely safe. We encourage you to use caution when using internet to access our web sites or social media.Changes to this policy
Our Policy may change from time to time to reflect changes in Our processing of your personal information. We will notify you of any material changes as required by law. We will post an updated copy on the Site.Contact us
If you would like Us to update the information We have about you or your preferences, or if you have any questions about the protection of your personal information please contact Us by email at email@example.com
Last update on 15/08/2023