1. PRIVACY POLICY
A) OVERVIEW
This privacy policy (this “Privacy Policy“) sets out the privacy policies and practices for Elegant Cultural Tours, Ltd.and its subsidiaries and affiliates (collectively “ECT“, or “We”) with respect to how ECT collects your personal information. It also describes how ECT maintains, uses, and discloses personal information. This Privacy Policy applies to information collected from you by ECT or our affiliates via this website (“The Site”) or our affiliates, various subdomains, as well as other places where we may collect personal information from (telephone conversations, on-site interviews, application for the tours, etc.). This Privacy Policy also sets out how you can access certain information that we may collect about you. In this Privacy Policy, “personal information” means information or opinion about an individual whose identity is apparent or can be reasonably ascertained from the information or opinion as further defined under applicable privacy laws. Please note that the Site may contain links to other third-party websites that are not controlled or operated by ECT. This Privacy Policy does not apply to such third party websites, and ECT is not responsible for the content of such third-party websites or the privacy practices of such third parties. Therefore ECT encourages you to request and review the privacy policies of any third parties upon disclosing your personal information to such parties or when visiting such third party websites. This Site is not intended for children. The only circumstances in which ECT collect data relating to children is when you make a booking of arrangements and there are children in your party.
B) CONSENT
BY SUBMITTING PERSONAL INFORMATION TO ECT OR ITS SERVICE PROVIDERS, YOU AGREE THAT ECT MAY COLLECT YOUR PERSONAL INFORMATION AND YOU CONSENT TO THE USE, DISCLOSURE AND TRANSFER OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW, WITH THE ADDITION OF OUR
GENERAL TERMS AND CONDITIONS. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting ECT at the address provided below. If you refuse or withdraw your consent, you acknowledge that ECT may not be able to provide you or continue to provide you with certain services or information that may be of value to you.
C) REVISIONS TO THIS PRIVACY POLICY
We reserve the right, in our discretion, to change, modify, add or remove portions of this Privacy Policy at any time and from time to time, without prior notice to you. However, we will treat your continued use of the Site and our tours following such revision as your acceptance of the revised terms. All revisions will be posted to the Site and will apply to any personal information collected on or after the date posted. We will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law. This Privacy Policy was written on June, 24th 2020. Any further historic versions can be obtained by contacting us.
D) UPDATES OF YOUR INFORMATION
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change during the course of your relationship with us. When we change the pop-up window’s text on the Site, you will be asked to reconfirm that you accept our Cookies upon your next visit to the Site.
E) WHAT INFORMATION WE COLLECT
We may collect personal information in connection with your use or purchase of our products and services, through your use of the Site, your purchase of our services and tours, or on/site interviews, telephone calls, or else which may include information provided in connection with the following activities:
- Registering or filling in forms on the Site. This includes information you may provide when you request additional information about our products and services or sign up to receive our newsletters and emails.
- Your usage of the Site and your IP address, for the purpose of informing user experience and providing personalized ads.
- Requesting information or assistance from us. ECT may keep a copy of any communications or correspondence you may send to it, including any email communications.
- Participating or responding to consumer surveys or requests for consumer’s opinions, concerns, and preferences regarding ECT’s products, tours, and services.
- Using other features of the Site that may be offered from time to time, and may require such information in order to utilize the feature.
- Telephone calls, on-site interviews, and else.
THE PERSONAL INFORMATION
You represent and warrant that you have the right and authority or have obtained all necessary consents to provide any information, including any personal information of another individual that is provided by you to ECT. The Information we may collect: 1. Identity data This includes data relating specifically to your identity, such as your first name, maiden name, last name, or similar identifiers, marital status, title, date of birth and gender, and any other personal information that you choose to include in your submissions of your goals to us, or in other communications to us. 2. Contact data This includes data relating to how you may be contacted, such as your home address, business address, email address, and telephone numbers. 3. Financial data This includes data relating to your means and methods of payment, such as your bank account and payment card details. ECT doesn't retain or store credit card and bank account details. 4. Transaction data This includes data relating to the transactions you have carried out with ECT, such as details about payments to and from you and other details of products and services you have purchased from us. 5. Special categories of personal data During different interactions, we may collect special categories of personal data about you as detailed below. This may be because you want us to have the information, or we may obtain this inadvertently as a result of a group you travel with. It may also be because we need to know certain personal data about you, which is special category data, in order that we can provide you with the best possible service and advise you whether a trip is suitable for you. Health is one of the best examples of this. E.g. If ECT receives a group booking from a specific religious association, we will inadvertently have details of the religious beliefs of those individuals. The same goes for groups from political associations and trade union associations. E.g. ECT is sometimes asked whether certain medication is allowed to be taken into certain jurisdictions, which discloses certain medical conditions. Other special categories of personal data, which we may end up receiving from you include details about your: • dietary requirements (which may also disclose your religious or philosophical beliefs) • health • race or ethnicity • sex life or your sexual orientation • political opinions • trade union membership • genetic and biometric data
TECHNICAL INFORMATION
ECT may also collect information that may not be personal information, which may include, but is not limited to, your IP address, the frequency of visits to the Site, the routes by which you access the Site and use of any hyperlinks available on the Site, your 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 Site. ECT or its service providers and agents may process and use aggregate data for various purposes including, but not limited to, analysis of this data for trends and statistics, or demographic data which we may use for various reasons of the development of the Site and the Sites’ features, assessing patterns of use, or planning and evaluating marketing initiatives. 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. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
MARKETING AND COMMUNICATIONS INFORMATION
This includes your preferences in relation to whether or not you want to receive marketing from us and also your communication preferences. We collect and process the above data only where it is strictly necessary to do so. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided them with your explicit consent to do so. You are not under any obligation to consent to our processing your sensitive personal data. If you are happy to consent to the use of your sensitive personal data by ECT, you will also be able to withdraw your consent at any time (as described below).
IP ADDRESS
An IP address is a computer’s numeric address within a network. We may record your IP address when you visit or use services or features on the Site. ECT may use your IP address for the purposes noted above, and also to help diagnose problems with ECT’s server, or to administer the Site. We may also use your IP address to identify you when we feel it is necessary to enforce compliance with this Privacy Policy or the
General Terms and Conditions or to protect the Site, tours, systems, information, employees, service providers, business partners, users, customers, and others.
CHILDREN’S PRIVACY
We recognize the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. The Site is not intended for children under the age of 18. We do not target our services, tours, or the Site to children under 18. ECT does not knowingly collect personal information from children under the age of 18.
F) HOW WE COLLECT YOUR INFORMATION
VIA DIRECT INTERACTIONS
You may give us your identity, and contact data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes the personal data you provide when you: • make a booking of arrangements • request a quote for arrangements • subscribe to our newsletter or other publications • request marketing • enter a survey • give us some feedback, or during an on-site interview on one of our tours
VIA AUTOMATED TECHNOLOGIES OR INTERACTIONS
As you interact with the Site, ECT may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, or other similar technologies. Please see ECT’s
Cookies Policy below.
VIA THIRD PARTIES
We may receive personal data about you from various third parties such as Google. In the future, we may share client data with specialized companies or another research agency for the purpose of identification of the profile of our client base.
G) PROTECTION OF YOUR INFORMATION
ECT has 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 instructions by ECT and they are subject to a duty of confidentiality. Nevertheless, while on internet keep in mind that transmissions are never completely private or secure. You understand that any messages or information you send to the Site may be read or intercepted by others.
If you have any questions about the security of personal information collected by ECT, including any requests to exercise your legal rights, please contact us via
Some sections of the Site are not confidential and are available for public viewing. Any submissions that you may post to publicly available blogs or other publicly available features of the Site are not confidential and may be viewed by other users of the Site. By making personal information publicly available where the Site allows you to do so, you consent to such publication by ECT or its service providers and agents.
H) USE OF YOUR PERSONAL INFORMATION
We will only use your personal data when the law allows us to. Upon our collection of your personal information, we may use such personal information internally, separately or in combination with pre-existing information, for the following purposes:
- To perform the contract we are about to enter into or have entered into with you;
- Where it is necessary for the legitimate interests of ECT (or those of a third party) and your interests and fundamental rights do not override those interests;
- To develop, enhance, market, sell or otherwise provide information, products or services;
- To establish and conduct commercial relationships, including to process purchases or other transactions and to conduct or administer other transactions that you may engage in with us;
- To contact you and to respond to any communications that you may have had with us;
- To troubleshoot problems with the Site;
- To customize your experience on the Site;
- To develop and manage our business and operations;
- To enforce ECT’s General Terms and Conditions or comply with this Privacy Policy;
- To detect and protect ECT and other third parties against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with ECT’s policies and contractual obligations;
- To engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving ECT;
- As permitted by, and to comply with, any legal or regulatory requirements or provisions;
- To access, preserve, disclose and use your personal information contained in Submissions, all communications to and from you, all information relating to your use of the Site, if we are required to do so by law or legal process or if we determine, in our sole discretion, that such action is necessary to protect our rights, the rights of third parties, and other users of the Site or for purposes of responding to your request for customer service.
- For any other purpose to which you consent.
MARKETING
PROMOTIONAL OFFERS FROM ECT We may use your identity, contact, technical data, usage, and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and if you have, in each case, you have opted in to receive that marketing. THIRD-PARTY MARKETING We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at
[email protected]. Personal information collected by ECT may be transferred to, stored, and processed in Slovenia, European Union. While in another jurisdiction for processing, the information may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction.
I) DISCLOSURE OF YOUR PERSONAL
INFORMATION
We may disclose your personal information to our subsidiaries or affiliates and to third parties whom we hire to provide services on our behalf, including, but not limited to hotels, organizers of the workshops and their experts, transportation companies, restaurants, support services, website services, delivering promotional materials, contests, and answering customer questions about our products and services. These subsidiaries, affiliates, and third parties may be located overseas. We will only provide those third parties with the personal information that they need in order to deliver the services to us and/or on our behalf. In the event that we are involved in a business transaction, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving ECT, you consent to your personal information and any other information we may have collected, being transferred to another party in connection with such transaction. You also consent to ECT disclosing your personal information to legal, financial, insurance, or other advisors in connection with such business transaction or management of all or part of ECT’s business or operations; as consented to by you from time to time, including to fulfill any other purposes that are identified when the personal information is collected; or as otherwise permitted or required by law. In case of your travel outside of Europe, the UK, Australia, New Zealand, or the United States your information will be transferred to the hotels, and partners, but only as far as needed for the purpose of organizing and fulfilling the contract of the tour with us. We are using the online platform MailChimp for sending marketing emails and an e-newsletter, where personal information is saved for forwarding such news (name, surname, e-mail, country, city). The MailChimp on-line platform guarantees in its General Terms and Conditions as well as the Privacy Policy to respect the rules of the
General Data Protection Regulation (GDPR) (Decision EU 2016/679) and confirms to have received the compliance certificate with the protection shield EU-ZDA (EU-U.S. Privacy Shield Framework).
J) RETENTION OF YOUR PERSONAL INFORMATION
The personal information that you provide will be retained by ECT in accordance with applicable laws. However, we will destroy or permanently de-identify the personal information it holds if requested by you.
HOW LONG WILL ECT USE YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfill 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 they process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. The personal information of an individual, acquired by an agreement, can be processed and stored 5 (five) years after the fulfillment of the contractual obligations of both parties. The invoices are archived for 10 (ten) years after the year of the invoice in accordance with the legislation form the area of value-added tax. In addition to the above, by law, we have to keep basic information about our customers (including contact, identity, financial and transaction data) for five years after they cease being customers for tax purposes. 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 this instance, we may use this information indefinitely without further notice to you.
K) CHOICE AND OPT-OUT PREFERENCES
We collect the following information via first-party cookies: IP address and Site usage; in the case of one-on-one marketing: your first name, last name, email address, city, country, and postal code, obtained at your provision through newsletter subscription opt-in. If at any time you prefer not to receive further email communications from us (except with respect to transactional communications regarding information, products, tours or services specifically purchased or requested by you), you will have the ability to unsubscribe from such communications by means of a link provided in every broadcast e-mail that is sent to you by us. To opt-out of receiving behavior-based advertising, please visit Google’s
Ads Settings, the
DoubleClick opt-out page,
Facebook’s Ad Settings manager, and
LinkedIn’s Cookie Settings. To opt-out of personalized content, please visit MailChimp’s Website Cookies Preferences tool on their
Cookies Statement page and Google’s
User Privacy Hub. ECT and their third-party partners may use other technologies from time to time, like web beacons, pixels (or “clear gifs”), and other tracking technologies. While you may not have the ability to specifically reject or disable these tracking technologies, in most instances, these technologies are reliant on cookies to function properly; accordingly, in those instances, declining cookies will impair the functioning of these technologies.
OPTING OUT FOR MARKETING MESSAGES
You can ask us to stop sending you marketing messages at any time by following the opt-out unsubscribe links on any marketing message sent to you, or by sending an email to
[email protected].
Where you opt-out of receiving the marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of arrangements or other such transactions.
L) 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 at
[email protected]. If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis that 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.
M) ACCESS AND CORRECTION
We will take reasonable steps to ensure the personal information we hold is accurate, complete, and up to date. Upon your written request, subject to certain exceptions, we will inform you of the existence, use, and disclosure of your personal information and provide you with a copy of that information. Additionally, if you have any questions or inquiries relating to our privacy practices or procedures, or if you believe that the personal information that we hold about you is not accurate, complete or up to date, you may write to us at the address provided below. If you are able to establish that the information is not accurate, complete or up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up to date.
REQUEST FOR ACCESS AND CORRECTION, QUESTIONS OR COMMENTS
We welcome questions and comments about this Privacy Policy. Requests for access and correction of your personal information, and questions or comments should be directed to the ECT.
YOUR LEGAL RIGHTS
You have rights under data protection laws to request access to your personal data, request correction of your personal data, request the erasure of your personal data, object to the processing of your personal data, request the restriction of processing your personal data, request transfer of your personal data and the right to withdraw consent. If you wish to exercise any of the rights set out above, please contact us at [email protected]. In accordance with the valid legislation in the field of personal information protection, you have the right to revoke your consent at all times, request a review, a correction, limitation of the treatment or deletion of your personal information by informing us in writing via mail at the postal address below, or email address
[email protected].
The aforementioned address can also be used to submit your complaint regarding the treatment of your personal information. You also have the right to submit a complaint regarding your personal information directly to the competent authority, i.e. Information Commissioner of the Republic of Slovenia, still, we would kindly like to invite you to first share any concerns with us in trying to find the suitable solution. Thank you!
N) BEHAVIOR IN CASE OF INFRINGEMENT
In case of infringement of personal information protection, we shall perform internal and external measures (technical, organizational) to protect your rights and interest, notify the involved persons and notify the competent authority in the Republic of Slovenia, EU.
O) WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up the company’s response. You will be required to prove your identity at any personal inquiry and also at the beginning of the tour on-site. TIME LIMIT TO RESPOND We try to respond to all legitimate requests within one month. Occasionally, it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
P) CONTROLLER OF PERSONAL INFORMATION
| COOKIE NAME | SERVICE | VALIDITY | DESCRIPTION |
| _ga | Google Analytics | 2 years | Registers a unique ID that is used to generate statistical data on how the visitor uses the Site; will store a random numerical value |
| _gid | Google Analytics | Per session | Registers a unique ID that is used to generate statistical data on how the visitor uses the Site; will store a random numerical value |
| _gat | Google Analytics | Per session | Used by Google Analytics to throttle request rate; will store a random numerical value |
