This Privacy Policy explains how personal information is collected and used in connection with the Platform and with the Products and/or Services requested or purchased through it. It is incorporated by reference into the Terms and Conditions.
"SEASONS", "we", "our", "us" are used in this Privacy Policy in the same sense as in the Terms and Conditions, unless a section states otherwise. This Privacy Policy describes our practices regarding personally identifiable information or personal data ("personal information/ PI").
Terms and definitions used in this Privacy Policy shall correspond to the terms set in the Terms and Conditions, except if otherwise set herein. The definitions below are written to stay correct if a product, a service or a contractual document is renamed, replaced, extended or newly introduced.
| Term | Meaning |
|---|---|
Platform | means this website, its extensions, mobile versions, mobile applications and any email, voice call, text, chat, messenger and social media account related to this website and/ or the brand SEASONS, which is operated by the Platform Operator. By its nature the Platform connects Platform users with the Travel Agents and allows them to request and purchase Products and/or Services. |
Platform user | means a person who visits or uses the Platform. Platform users can stay in this status and never request or purchase anything. Platform users also may be referred to as "you"/ "your" based on the context. |
Platform Operator | a company responsible for operating the Platform, which performs activities including, but not limited to:
Relations with the Platform Operator fall under the Terms and Conditions. The Platform Operator does not itself sell Products and/or Services. The Platform Operator also may be referred to as "SEASONS", "we", "us", "our" based on the context. The Platform Operator's details are set in the Terms and Conditions. |
Travel Agent | the party acting as intermediary between you and the Travel Providers, which sells or arranges Products and/or Services and with which you conclude the contract for them. Relations with a Travel Agent are covered by the Terms and Conditions, which play the main role in the processing of personal information of Clients. A Travel Agent also may be referred to as "SEASONS", "we", "us", "our" based on the context. Which Travel Agent applies to your request, and its company details, are set in the Terms and Conditions. |
Travel Provider | an independent third party that actually supplies the underlying product or experience - for example an airline, a hotel or other accommodation provider, a rental car company, a restaurant, a yacht or boat operator, an event organiser, a private guide or any similar supplier. A Travel Provider processes personal information under its own terms and privacy policy. |
Client | an individual who requests or purchases Products and/or Services, or on whose behalf other persons (an authorised representative, a guardian, a spouse, a parent etc.) requested or purchased, and an individual who actually receives them (guest, visitor, passenger, participant etc.) without prejudice to the person who paid (a payment card holder). Clients also may be referred to as "you" / "your" based on the context. |
Products and/or Services | means any product, service, benefit, arrangement, membership, subscription, feature or other offering that is requested through, arranged through, facilitated through or made available in connection with the Platform, by the Platform Operator, by a Travel Agent or by a Travel Provider, whether it exists today or is introduced, renamed, extended, combined, split or replaced later. Products and/or Services include, by way of example and without limitation:
|
Terms and Conditions | means all terms, conditions, schedules, agreements, policies, notices and other contractual documents that govern your use of the Platform and your request for or purchase of Products and/or Services, whatever each of them is called, as in force from time to time, including any of them that is amended, supplemented, replaced, renamed, split, merged, repealed or newly adopted. The Terms and Conditions currently include, by way of example and without limitation:
Where this Privacy Policy refers to the Terms and Conditions, it refers to the document among them that governs the relationship in question. |
Privacy policy | a legal statement explaining how the Platform Operator and/ or a Travel Agent processes and protects personal information of Platform users and/ or Clients. This document is that statement. |
This Privacy Policy covers the personal information of:
Where you provide us with the personal information of another person, you confirm that you have their agreement to do so and that you have told them how their information will be used. You should also respect any objection they raise.
In majority cases the service is request-based. There is no self-service search engine, no price comparison tool and no online booking checkout. You tell us what you are looking for by telephone, by email, by messenger or by completing a request form on the Platform; the applicable Travel Agent then comes back with pricing, availability and terms for your review.
Two consequences follow, and both shape this Privacy Policy. First, the purchase contract is formed directly between you and the applicable Travel Agent or Travel Provider, not with the Platform Operator, so for Trvael Agents are covered with the Terms and Conditions and this Privacy policy, but Travel Providers apply their own terms and privacy policies to that purchase. Second, most of the information about your request reaches us through conversation - calls, emails and messages - rather than through forms, which is why call records and message threads are described throughout this Privacy Policy as a core part of future transaction.
This Privacy Policy aims to give you information on how we collect and process your PI, including any PI you may provide through the Platform, when you request or purchase Products and/or Services or sign up to our newsletter.
It is important that you read this Privacy Policy together with the Terms and Conditions, and with any other privacy policy, notice or fair processing policy we may provide on specific occasions. The Terms and Conditions are the source of the detail about the relationship itself; this Privacy Policy does not repeat it. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
We keep this Privacy Policy under regular review, updating it at least once in 12 months. We might make minor amendments which shall not adversely affect your privacy, except if laws set otherwise. In case of material changes we will publish the amended policy on the Platform and, as far as possible, notify you either by email or by pop-up window when you use the Platform next time. Amendments shall enter into force on the Effective Date. The actual version is published on the Platform.
When you give us PI, you are telling us that the information is true, accurate, complete and current. You are also telling us that you have the authorisation to provide it to us.
It is important that the PI we hold about you is accurate and current. Please keep us informed if your PI changes during your relationship with us.
We may collect, use, store and transfer different kinds of PI about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your PI, but is not considered PI in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your PI, so that it can directly or indirectly identify you, we treat the combined data as PI which will be used in accordance with this Privacy Policy.
Certain information is mandatory for particular Products and/or Services. For example, passport details are required for a flight booking, and some destinations require visa or health-card details. Where you do not provide such information when it is requested, the applicable Travel Agent may be unable to complete your booking, or you may be denied boarding or entry. This mirrors what the Terms and Conditions tell you at the moment of purchase.
Because of the nature of the Products and/or Services, a request may reveal sensitive information about you or about a person named in your request. Examples include dietary restrictions and allergies for a restaurant reservation; accessibility, mobility or health needs for a transfer, an accommodation or an event; a request for assistance in identifying beauty, spa, wellness or medical service providers for your own further enquiry; details of a wedding, birthday or other private celebration that reveal family or relationship information; religious or cultural observances affecting a booking; and immigration or citizenship details. We use such information only for the purposes of arranging and rendering what you requested, including the related communication and customer support, and for security and safety purposes, including compliance with law requirements.
We do not knowingly collect PI from minors, except where the minor is a traveller or a participant named in a booking or a request. Where a booking names an underaged child or dependent, the parent or legal guardian making the booking is deemed to accept the Terms and Conditions on their behalf. If we become aware that a minor is attempting to submit PI outside such a booking, we will remove this information from our records. If you are the parent or legal guardian of a minor who has given us PI, please contact us so we can delete it.
Where we or a Travel Agent collect PI required by law or under the terms of a contract, and you fail to provide that PI when requested, the contract may not be capable of being performed. In this case the Products and/or Services may have to be cancelled, and you will be notified if this is the case at the time.
We use different methods to collect PI from and about you, including through:
We collect your PI directly from you (using live chat, online forms or via voice call/ messenger). Any contact data (emails, phones etc.) provided by you throughout any interaction will be treated as your personal contacts and saved in your record for future communications, unless specifically requested not to be stored (one-time communication only). For example, when you provide us with your PI by requesting a quote, registering or booking Products and/or Services, contacting our customer support. This includes PI you provide when you:
When we chat with you (e.g. WhatsApp, Facebook, regular SMS etc.) the chat might be accidentally closed/ removed, there might be interruptions, slow internet connection etc. We may contact you later via automated phone and text messages or email (if available) in order to restore our communication started within the chat. No purchase necessary. You can opt out from further communication by replying to SMS/ email or notifying us during the phone call.
One of the main collection methods are VOICE CALLS. We have a vested interest to ensure you have chosen the best possible option. Voice calls are an exclusive opportunity to provide you with immediate customer support and disclose additional product features you might not notice on the Platform. Usually, we call back on your request. Sometimes there might be unfinished conversations regarding a current request (misunderstanding in live chat, email system error, poor internet connection etc.), which require immediate response. We don't make unwanted telemarketing robocalls or any annoying advertising campaigns. You can opt out of this communication at any time by contacting us via phone or email.
As a call-to-book service, most of our orders are arranged and confirmed via voice calls using the phone numbers submitted during the initial contact. Call records made before and during the order are kept as evidence that Clients requested and confirmed the purchase of the specific Products and/or Services and are used to establish the business relationship between you and us (Platform operator and/or Travel Agent). Additionally, if you agreed to purchase the current Products and/or Services from the current Travel Agent, the Platform operator will share your contact details (email and phone) with this Travel Agent in order to finalise your purchase (email the authorisation (booking) form, render post-sale services, resolve disputes, marketing promotions, surveys etc.).
We also collect your PI passively. For example, we collect information about you over time and across different websites when you visit the Platform. We also use tracking tools like cookies and beacons. As you interact with our Platform, we will automatically collect Network Activity Information about your equipment, browsing actions and patterns. We collect this PI by using cookies and other similar technologies. For additional information, please refer to our Cookie policy. Platform features may make use of your device attributes and settings that will allow us to determine your physical location (country, state). Such technologies may include IP address mapping or other technologies. We use this information to enhance and personalise your experience and provide you with offers and services that may be of interest to you. We do not have control over your device settings, but we do recommend enabling location services on your device so you can take advantage of the location-based features and functionality offered.
We collect your PI using service providers. This can include when you log in using a service provider platform, such as Facebook. In addition, we also integrate service providers' software that collects information about users for security reasons. The categories of PI we have collected/disclosed/sold for a business purpose in the preceding 12 months you can find HERE.
We will use your PI for the following purposes:
To provide you and improve our Platform and services, to better understand the users of our Platform and services, and to protect our property and to prevent damage to it.
If you have ever requested a price quote or purchased our services, we treat you as a Regular (loyal) Customer. Regular Customers have plenty of benefits:
According to our policy, we may contact you as a Regular Customer via email/phone saved within previous requests and transactions. Such cases may be, for example, when you have accidentally provided the wrong email/phone or when you cannot be reached via the email/ phone left in the last request/ purchase. If you want to opt out, please contact us.
We and our partners use your PI to process your bookings and store your itinerary information where applicable.
We use your information for marketing purposes. These activities may include:
If you participate in our Referral Programme and (1) forward an email / SMS with a referral Code to your friends or (2) share friends' contacts (email, phone, social media account etc.) with us, we presume that you have notified your friends in advance about sharing their PI with us and that their PI will be processed in accordance with this privacy policy.
You shall respect any objections received from your friends regarding processing their PI (email, phone etc.) for marketing purposes.
If you keep ignoring friends' objections and don't report it to us, we disclaim all responsibility which may be imposed on us as an advertiser. We won't unsubscribe a friend's email/ phone if it was not specifically requested by your friend.
To communicate with you, including as follows:
In certain cases we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance or to enforce the terms of use of the service.
The use of your PI may be necessary to perform the services and provide the Products and/or Services that you have requested. For example, if you make a booking on our Platform, we need to collect PI from you in order to complete the booking.
We may rely on your consent to use your PI for certain direct marketing purposes. You can withdraw your consent at any time by contacting us.
We have set out below a description of all the ways we plan to use your PI.
| Purpose | Activity | Category of PI | The legal basis of processing | Data storage period (criteria) |
|---|---|---|---|---|
To complete the transaction, provide the Products and/or Services requested by you or otherwise perform a contract - MAIN ACTIVITY | To fulfil preparatory steps for entering into the contract for the Products and/or Services (see also the Terms and Conditions); to register you as a new or a regular Client and to start the business relationship | Identifiers | contractual obligations | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (for example the flight date, the car drop-off date, the hotel check-out date, the event date or the date the service was delivered). |
To process and deliver your order related to the MAIN ACTIVITY, including but not limited to: (a) Managing payments, fees and charges; (b) Collecting and recovering money owed to us; (c) Providing to you post-sale customer support; (d) Sending booking confirmations, alerts and similar communication | Identifiers | contractual obligations | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (for example the flight date, the car drop-off date, the hotel check-out date, the event date or the date the service was delivered). | |
To render other services related to the MAIN ACTIVITY: customer support (to answer your inquiries, restore data entry (auto-save tool), arrange and re-arrange what you requested, route and reservation changes, refunds, chargebacks, bank card verification) | Identifiers | legitimate interests | Until the termination of the agreement for the MAIN ACTIVITY; no longer than it is necessary to fulfil the current request or to prevent possible negative consequences, as well as protecting / exercising our legal claims; OR no longer than it is necessary to resolve issues related to customer support. | |
To record your request - the date and time, the contact details, a summary of the request and the preferred form of response - and, where the request is taken by telephone, to repeat it back and register the oral confirmation | Identifiers | contractual obligations | Until the termination of the agreement, and afterwards not more than the maximum survival period of legal claims set in the applicable legislation. | |
To operate recurring plans forming part of the Products and/or Services: to confirm the plan, take the recurring fee, apply the withdrawal period, and renew or terminate the plan | Identifiers | contractual obligations | For the term of the plan and afterwards not more than the maximum survival period of legal claims set in the applicable legislation, counted from the end of that term. | |
To verify identity and authority: a short registration or identity-verification of a Client designated by another person before the Products and/or Services are provided, and reasonable verification of the authority of a person authorised to act on behalf of a Client | Identifiers | contractual obligations for a designated Client; legitimate interests for the verification of an authorised representative | No longer than it is necessary to complete the verification and to protect / exercise legal claims arising from acting on the request. | |
For solely internal uses that are based on your relationship with us or compatible with the context in which PI was collected | To manage our relationship with you, which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey; (c) Sending holiday greetings; (d) Improving staff communication culture | Identifiers | legitimate interests | Until opted out, except evidence of opting out used for our legal claim protection; OR no longer than it is necessary to resolve issues related to the customer experience. |
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you; to make suggestions and recommendations to you about Products and/or Services that may be of interest to you | Identifiers | consent, where the advertising relies on tracking technologies or on direct marketing communication; otherwise legitimate interests | Until the consent was withdrawn or until opted out, except evidence of the consent and its withdrawal used for our legal claim protection. | |
To use data analytics to improve the Platform and the Products and/or Services, marketing, customer relationships and experiences; to achieve internal administrative purposes within the group of companies, part of which is the Travel Agent (maintenance and security of ICT resources; management of data protection systems etc.); to undertake internal research for technological development and demonstration | Identifiers | legitimate interests | No longer than: it is necessary to investigate the incident, AND/OR for preventing or remediating any negative consequences, AND/OR protecting / exercising our legal claims. | |
To handle complaints, claims and chargebacks | To record a complaint or claim, examine the relevant records, review it and answer; to use information relating to you, including recordings of customer service calls, to dispute chargeback claims | Identifiers | legitimate interests | Not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the date the complaint, claim or chargeback was raised. |
To keep the Products and/or Services usable for everybody | To assess whether the use of a recurring plan is excessive or is not for genuine personal use, and to act where a Client or an authorised person communicates with staff or with a Travel Provider in an abusive, threatening or discriminatory manner | Identifiers | legitimate interests | No longer than it is necessary to assess the case, apply the decision and protect / exercise legal claims. |
To detect, handle and/or prevent technical errors and security incidents, protect against malicious, deceptive, fraudulent or illegal activity | To administer and protect our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); to identify and repair errors that impair existing intended functionality | Identifiers | legitimate interests | No longer than it is necessary to investigate the incident, no longer than for preventing or remediating any negative consequences, as well as protecting / exercising the Travel Agent's legal claims. |
To maintain backup and archive systems and restore data (if necessary) | Identifiers | legitimate interests | No longer than the backup or archived system is restored to an active system, shared with third parties or next processed for (commercial) purposes other than technical maintenance and IT security. | |
To comply with a legal obligation | (a) To manage tax matters; (b) Bookkeeping and accountancy of transactions; (c) To manage consolidated reports and annual financial reports; (d) To comply with the requirements of licences, registrations and permissions obtained by us, including industry standards (airline safety rules, PCI DSS etc.); (e) Anti-money-laundering and fraud prevention requirements | Identifiers | legal obligations | According to the requirements of the applicable legislation. |
To comply with law requirements of improving border controls (security) and combating illegal immigration | Identifiers | legal obligations | Not more than the applicable legislation provides after the flight date. | |
To fulfil the requirements of international agreements (e.g. passengers' data (PNR) on fighting serious crime and terrorism) | Identifiers | legal obligations | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (for example the flight date, the car drop-off date, the hotel check-out date, the event date or the date the service was delivered). | |
To exercise or defend legal claims | (a) To manage complaints; (b) To comply with requests, subpoenas and other enforcement notices issued by regulators, courts and law enforcement agencies; (c) To protect and exercise the legal claims of the Travel Agent and its partners before a court, authority or law enforcement agency | Identifiers | legitimate interests | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (for example the flight date, the car drop-off date, the hotel check-out date, the event date or the date the service was delivered). |
To use PI in aggregated form for statistical and analytical purposes | To analyse information to secure or improve the Products and/or Services | Aggregated information, including Identifiers and Network Activity Information | legitimate interests | No longer than the statistical / analytical report was created or IT security / maintenance measures are applied. |
To manage your requests, especially when you exercise your rights set herein | (a) To record incoming requests; (b) To answer the requests in a timely manner; (c) To store them so that the correct chronology of communication is sustained | Identifiers | legitimate interests | Not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the request's submission date. |
To comply with the requirements of a request regarding objection to processing personal data for direct marketing purposes (maintenance of the Unsubscribe list) | Identifiers | legal obligations | Not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the request's submission date. |
| Purpose | Category of PI | The legal basis of processing | Data storage period (criteria) |
|---|---|---|---|
MAIN ACTIVITY: perform operating activities on the Platform, including Platform administration and publishing, updating and deleting content and information about possible Products and/or Services on the Platform; users' attraction and assistance with Platform navigation, including redirecting them to the current Travel Agent | Identifiers | contractual obligations (Terms and Conditions) | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (for example the flight date, the car drop-off date, the hotel check-out date, the event date or the date the service was delivered). |
To render web-based services upon your request (newsletter subscription, price quotes, itinerary review etc.) | consent | Until the consent was withdrawn, except evidence of the consent and its withdrawal used for our legal claim protection. | |
To provide you with value added advertising related to the MAIN ACTIVITY, including our newsletters and advertising on third party websites and social media platforms | consent, where the advertising relies on tracking technologies or on direct marketing communication; otherwise legitimate interests | Until the consent was withdrawn or until opted out, except evidence of the consent and its withdrawal used for our legal claim protection. | |
To ensure the security of the Platform, the services and your data, including troubleshooting, data security analysis, fraud prevention, error testing, system maintenance, support, reporting and hosting of data | legitimate interests | No longer than it is necessary to investigate the incident, no longer than for preventing or remediating any negative consequences, as well as protecting / exercising the Platform Operator's legal claims. | |
To enhance the quality of the services and the customer experience, e.g. conducting surveys, improving staff communication culture, sending holiday greetings | legitimate interests | Until opted out, except evidence of opting out used for our legal claim protection; OR no longer than it is necessary to resolve issues related to the customer experience. | |
To exercise, establish and protect the Platform Operator's and our partners' legal claims | legitimate interests | not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the purchase date (for example the flight date, the car drop-off date, the hotel check-out date, the event date or the date the service was delivered). | |
To manage your requests, especially when you exercise your rights set herein, including maintenance of the Unsubscribe list | legitimate interests for managing the request; legal obligations for the maintenance of the Unsubscribe list | Not more than the maximum survival period of legal claims set in the applicable legislation. The period starts on the request's submission date. | |
To achieve internal administrative purposes within the group of companies, part of which is the Platform Operator (maintenance and security of ICT resources; management of data protection systems etc.); to use PI in aggregated form for statistical and analytical purposes | legitimate interests | No longer than the statistical / analytical report was created or IT security / maintenance measures are applied. | |
To maintain backup and archive systems and restore data (if necessary) | legitimate interests | No longer than the backup or archived system is restored to an active system, shared with third parties or next processed for (commercial) purposes other than technical maintenance and IT security. |
We will only use your PI 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.
As a customer-oriented business we respect and value your expectations. As a result, you are able to make announcements and queries at any time regarding your concerns in privacy matters. Each of our marketing emails has an opt-out button and you can change preferences or unsubscribe from such communication at any time. You cannot unsubscribe from servicing emails and administrative messages.
Travel Agents. When you ask for a price quote or place an order, we pass your request and your contact details to the applicable Travel Agent, so that it can come back to you with pricing, availability and terms and can complete your purchase. The Travel Agent is the party you contract with. It processes your PI under this Privacy Policy alongside any specific notices and disclaimers demonstrated to you prior to accepting the Terms and Conditions.
Travel Providers. To fulfil a booking or a request, the applicable Travel Agent shares the information necessary for that specific request with the relevant Travel Provider - for example an airline, hotel, restaurant, yacht operator, event organiser or private guide. Where a booking involves more than one Travel Provider, the information is shared with each of them, and each processes it under its own privacy policy. Requests are also discussed with Travel Providers by our staff and by the Travel Agent's staff where that is needed to check availability and conditions.
Authorities relevant to your itinerary. Where required by applicable law, the applicable Travel Agent shares information with government, aviation, border security or law enforcement authorities relevant to your itinerary.
Associated companies. We may share your PI with the associated companies, as well as combine it with other information to organise internal workflow, enhance our efficiency, provide and improve our Platform, products and services.
Corporate affiliates and change of control. We may share your PI with our corporate affiliates and if SEASONS itself (or part of its business) is sold or otherwise changes control, owners would have access to your PI for the uses set out herein.
Service providers. We may share your PI with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information (for example, IT development and maintenance, data storage and security services, communication and request management tools, marketing services, providing legal advice, analytical services, accounting programs, etc.).
Payment service providers and vendors. If you book through the Platform, we may share your PI with the payment service providers, acquirer banks and the vendors you have booked with. This can include online travel agencies, Global Distribution Systems (e.g. Amadeus, Galileo, Sabre etc.), hotels, airlines, car rental companies, restaurants, event organisers, guides, yacht and transfer operators, eSIM providers and travel insurance (including medical protection and similar products) providers. These third parties will process your PI as data controllers in accordance with their own privacy policies. If you contact our customer support, they may need to share information about your request with the relevant vendor in order to assist you.
Business partners. We may share your PI with various business partners. Some of these business partners may use your PI for fraud detection, including, but not limited to Identifiers, Contact Data and Network Activity Information, also to detect, prevent or otherwise address fraud, security or technical issues. We may also share your PI to ask our partner to create a survey, form, application or questionnaire, so we know the degree of your satisfaction with our services. Some of these business partners may use your PI for online behavioural advertising purposes, or to offer you services or products that we believe you may be interested in. We may also share your information as otherwise described to you at the time of collection. We may also share anonymous aggregated usage information with partners.
We enter into confidentiality and PI processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.
Itineraries and arrangements shared by you. If you use or have itineraries or arrangements as part of our service, you can send or grant access to them to anyone you choose. Your itinerary may contain enough details (for example, booking reference codes) to allow the recipient to cancel or modify your booking, perform a check-in, etc. You should only share your itinerary with people you trust. If you choose to display your itinerary on publicly viewable web pages, that information may be collected and used by others.
Legal consultants. We may share your PI with our legal consultants, if it is necessary to represent us in relations with external actors (e.g. plaintiffs, authorities, courts etc.) in order to exercise, establish and protect SEASONS's and partners' legal claims.
Information shared in public. If you provide us a testimonial or a review of your trip or arrangement, you authorise us to publish it on all our Platforms under the screen name you provided. You also authorise us to aggregate it with other reviews.
Authorities. We may disclose PI if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your PI if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.
We may also share anonymous aggregated usage information with others.
Our services are rendered remotely and across borders, so your PI may be transferred to, stored in and accessed from a country other than the one you are in. A request you make can only be fulfilled if the information travels to the Travel Agent and to the Travel Provider that will actually deliver it, and those are often in different countries. The Terms and Conditions say the same thing at the moment you buy: providing personal information for a request or a purchase means agreeing to the cross-border transfer necessary to process it.
Whenever PI is transferred to another country, it is done only where a transfer ground is available and where the level of protection of your PI is not undermined - for example by relying on an official adequacy decision, on standard data protection clauses agreed with the recipient, on the performance of the contract you asked us to perform, or on your consent. You can read the detailed description of the grounds relied on and the safeguards applied here.
Our servers and data centres are located in the U.S. and our service providers may be located there and in other countries. By providing us PI, you agree that your PI may be transferred to and stored in these countries. These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your PI may be subject to access requests from governments, courts or law enforcement in those countries according to the laws in those countries. Subject to the applicable laws of such countries, we will provide the necessary safeguards to maintain protection of your PI.
We have a security program intended to keep the PI stored in our systems protected from unauthorised access and misuse. Our systems are configured with data encryption, or scrambling technologies and firewalls constructed to industry standards. We also use Secure Socket Layer (SSL) technology that protects the PI you send over the Internet. PI may only be accessed by persons within our organisations, or our service providers, to carry out the uses indicated in this Privacy Policy.
We have put in place appropriate security measures to prevent your PI from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your PI to those employees, agents, contractors and other service providers who have a business need to know. They will only process your PI on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected PI breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Although we strive to protect your personal information through reasonable technical and organisational measures, please be aware that no method of electronic communication or storage is entirely secure, and there might be a risk that unauthorised parties may intercept or access your information. By using our services, you acknowledge and accept these inherent risks and agree to take appropriate precautions to safeguard your data.
We will only retain your PI for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. The criteria applied to each purpose are set out in the purpose tables above. We may retain your PI for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for PI, we consider the amount, nature and sensitivity of the PI, the potential risk of harm from unauthorised use or disclosure of your PI, the purposes for which we process your PI and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
If you click through to third party websites or other platforms, our privacy policy does not apply.
Under certain circumstances set by applicable law, you are entitled to:
We might operate under different brands, so the rights set out above are exercised in each brand separately.
Due to the remote nature of our services, it is important for us to keep communicating through the same email (Verified Email) which was used by you to request a price quote, purchase Products and/or Services or request Products and/or Services. The Verified Email is the key communication channel for us, so we can give quick answers and not divulge your data to any malicious person. You might also submit a request through a voice call, but we must still use the Verified Email to reply, due to law requirements and in order to protect our legal claims. If you submit your request through an authorised agent or by using a third party service we will ask for additional verification by contacting you via the Verified Email.
NONDISCRIMINATION. We shall not discriminate (deny services, charge different prices, provide different levels of quality) against you because you exercised any of the rights set herein. This right might be limited in case the difference in prices or levels of quality is reasonably related to the value provided to you by your PI. We might obtain your opt-in consent and provide to you financial incentives, so you agree to provide additional PI or not to request the deletion of your PI.
FEES and DENIALS. You will not have to pay a fee to access your PI (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive (more than twice in a 12-month period) or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We might also refuse to act on your request when we are not in a position to identify you and verify your request or the requested fee was not paid. We may need to request specific information from you to help us confirm your identity and ensure your right to access your PI (or to exercise any of your other rights). This is a security measure to ensure that PI is not disclosed to any person who has no right to receive it. We may also contact you (via email, phone or messenger) to ask you for further information in relation to your request to speed up our response.
TERMS. We try to respond to all legitimate requests within one month. Occasionally it could take us 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. The maximum response time shall not exceed 90 days.
CONTACTS. If you have any questions about this privacy policy or plan to exercise your rights, please contact us at privacy@seasons.global
Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals.
Technical and strictly necessary cookies. In most cases our Platforms use cookies and terminal access technologies in order to ensure technical feasibility to connect our Platform with your device and provide services requested by you. This type of tracking is integrated by default into our Platforms. In case, you try to block/ turn off any of such technologies you might not receive some essential part of services, requested by you. Some examples of such technologies are:
Functionality and preferences cookies. Such Cookies help us to optimize and make more user-friendly our Platforms, enhance security level, facilitate faster and more convenient use of Platforms, receive valuable statistics in anonymized way, including, but not limited to:
In case we are collecting Cookies for statistical purposes, we are committed to apply a “functional separation” principle, so the results of the processing shall be without any negative impact to Your privacy or there should not be any decisions made against You. Retention period of Functionality Cookies usually is very short. In case of longer periods, please, be aware that we always assess the risk level of such processing, so it does not adversely affect Your privacy. Under the strict supervision we might allow service providers to collect Functionality Cookies on our Platforms in order to provide us with aggregated statistics. In such cases we require service providers to aggregate or erase data obtained from Your device.
Advertising and targeting cookies. We and our third party vendors, including Google and Facebook, use Advertising technologies to serve ads based on a Your prior visits to our Platforms. Where permitted by law and based on your consent, previously unlinked or pseudonymous browsing histories and device identifiers may be combined and linked to your customer account record upon login or completion of a purchase. For example:
We and our advertising partners may also use web beacons (single pixel GIF images). These web beacons are placed in the code of a Web page or an email newsletter. When you access a partner site within our mobile applications, we may track your activity on that site.
Your browser gives you the ability to control optional tracking technologies. How to do this varies from browser to browser. You should view the Help menu on the browser you use for further information. Your opt out choice is stored in opt out cookies only in that browser, so you should separately set your preferences for other terminal equipment (browsers, computers, mobile apps or devices) you may use. If your browser blocks tracking technologies, your opt out preferences may not be effective. Deleting browser cookies can remove your opt out preferences, so you should visit this page periodically to review your preferences. If you block or delete tracking technologies or opt out of online behavioral advertising, not all of the tracking that we have described in this policy will stop.
Please also note that opting out of a third party tracking technologies does not mean that you will no longer receive or be subject to online advertising or marketing. It means that the third party service from which you opted out will no longer deliver ads tailored to your web preferences and online behavioral. You may also opt out of optional tracking technologies by visiting opt-out website like www.aboutads.info or cookiesandyou.com/disable-cookies/
