Privacy Policy

B. General data processing by Aravago Travel GmbH

1.     Categories of personal data collected

Aravago Travel GmbH collects the following data of the Traveller and other participants:

• form of address, first name, last name, address, email address, telephone number, and date of birth;

• travel document data, such as identity card, passport, citizenship, ID card number, passport number, issuing authority and duration;

• bank and invoicing details, such as credit card details, account information, billing address and ticket voucher, etc.;

• information concerning insurance, insurance benefits, emergency contacts;

• special personal data according to Article 9 GDPR, for example, due to physical impairment, special requests or religion;

• interests, knowledge and requests;

• data relating to complaints, experience reports and warranties.

2.     Purposes of processing

These data are collected insofar as necessary:

• to be able to identify you and other participants as our customers;

• to conclude a contract;

• to correspond with you;

• for invoicing purposes;

• to manage the booking and the trip;

• to conclude travel insurance;

• for other purposes necessary in relation to individual requests.

3.     Legal bases

Your data will be processed on the basis of points (a), (b), (c) and (f) of Article 6(1) and point (a) of Article 9(2) GDPR.

·       Point (a) of Article 6(1) GDPR: The basis for data processing is consent:

If you have consented to the processing of the data, this constitutes the legal basis. You may withdraw your consent at any time.

·       Point (b) of Article 6(1) GDPR: The basis for data processing is a contract or the taking of steps at the request of the data subject prior to entering into a contract:

In this context, your data will be used to inform you about a trip and for the conclusion and performance of our contract. They will be used especially for invoicing and booking purposes, the arrangement of additional services, and the resolution of individual concerns or complaints.

·       Point (c) of Article 6(1) GDPR: The basis for data processing is compliance with a legal obligation:

The processing takes place in this context in order to comply with legal obligations such as the retention obligation.

·       Point (f) of Article 6(1) GDPR: Data processing is necessary to safeguard the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

This could be the case if the interests of a third party, in particular a child, are specifically affected during or in connection with a trip.

The legitimate interests are as follows in this regard:

• the exercise of specific fundamental rights such as freedom of expression, freedom of the press and freedom of broadcasting;

• within the context of professional freedom;

• in relation to the combatting of fraud;

• for direct marketing;

• to ensure IT security;

• to report potential criminal offences;

• if the data have been obviously made public by the data subject;

• for the establishment, exercise or defence of legal claims.

• It is also possible to consent to the processing of special categories of personal data in accordance with point (a) of Article 9(2) GDPR.
  
  
  

4.     Recipients or categories of recipient of personal data

Insofar as necessary for the provision of the contractual service owed by us or due to statutory obligations, your data may also be shared with sub-contractors or service providers in connection with your booked trip and/or service or with the authorities.

Specifically, your personal data may be transmitted to:

• service providers such as air carriers and other transport companies, providers of accommodation and cruise lines;

• travel agents;

• tour operators;

• providers of travel insurance;

• car hire companies;

• transfer services;

• public bodies (e.g. embassies of the country of destination) where obliged by law or administrative requirements.

5.     Transfer of personal data to a third country

Your personal data will only be transferred to recipients in a third country or to another international organisation (in addition) if the following guarantees are in place:

·       the third country provides an adequate level of protection for personal data according to the European Commission;

·       the recipient has signed a contract based on “standard contractual clauses” confirmed by the European Commission, which oblige it to protect personal data.

Further information concerning the protection of your personal data in the event of a transfer to a specific third country is available upon request.

6.     Duration of retention of personal data

Your data will be stored after they have been collected by Aravago Travel GmbH for as long as

• necessary, subject to compliance with the ten-year statutory retention period according to Article 1059(1) PGR;

• necessary for the fulfilment of the above-mentioned purposes of Aravago Travel GmbH;

• necessary due to legitimate interests (e.g. archival, documentation, liability issues, etc.).