Last updated January 05, 2024
We want you to feel comfortable on www.cheaptravelall.com (our “website”) and not have to worry about the security of your data. That is why data protection is an important part of our corporate philosophy.
In this Privacy Policy, you will find all the information about which Personal Data we collect and process and for what purpose. Equally, we will also inform you of your data protection rights and how you can assert them.
GENERAL PRINCIPLES
What is Personal Data?
Personal Data is “any information relating to an identified or identifiable natural person. This includes, for example, name or address data, telephone number, mobile number, or online identifiers such as your device id and your IP address.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party for data processing is Cheap Travel All, Acacia One GmbH, Ebmatingerstrasse 14, 8126 Zumikon, Switzerland (“Cheap Travel All”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us by email using info@cheaptravelall.com or write to us at the above address.
What law applies?
Our use of your Personal Data is subject to both the Swiss Federal Data Protection Act, as amended (“nDSG”) and the EU`s General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.
Further and under consideration that the nDSG has been modeled on the basis of the GDPR, no conflict should arise pursuing a uniform approach. However, should ambiguity occur the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your personal data. The association SwissPrivacy.Law has published a comparison table between the nDSG and the GDPR which can be consulted by visiting here.
What are the Legal Bases for processing Personal Data
In accordance with the nDSG and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
Who is the competent data protection authority?
The supervisory authority in Switzerland is: The Swiss Federal Data Protection and Information Commissioner, Feldeggweg 1, CH-3003 Bern, Switzerland, www.edoeb.admin.ch
How long will you keep my data?
We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with Switzerland’s Commercial Law and Fiscal Code and others for up to 8 years. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
WHAT PERSONAL DATA DO WE PROCESS?
Technical Data
When you access our website, some access data is recorded automatically and stored in a log file on our website’s server. This means if you browse and simply have a look at our website, we process a) the IP address of your computer, b) the date and time of your access, c) the name and URL of the accessed file, d) the browser used, e) the amount of bytes transferred, f) the status of the page request, g) the session ID and g) the referrer URL. The legal basis for processing is our legitimate interest.
Hosting
We use the hosting services of Hostinger International, Ltd, (61 Lordou Vironos str., 6023 Larnaca, Cyprus) for the purpose of hosting and displaying our website. Hostinger does so on the basis of processing on our behalf, and that also means that all data collected on our website is processed on Hostinger’s servers. The basis for processing is our legitimate interest, and the initiation and/or fulfillment of a contract.
Content Management System
We use the Content Management System (CMS) of WordPress by Automattic Inc (60 29th Street Suite 343 San Francisco, CA 94107 US), to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to our website is transferred to WordPress. The legal basis for this processing is our legitimate interest.
Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in Switzerland`s Unfair Competition Act (as amended) (“UCA”), the Telecommunications Act (as amended) (“TA”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Cookie consent
We have integrated the consent management tool “Complianz | GDPR/CCPA Cookie Consent” by Complianz BV (Kalmarweg 14-5, 9723 JG, Groningen, Netherlands) to obtain consent for data processing or the use of cookies or comparable functions. With the help of Complianz, you have the option to give or withhold your consent for certain cookies. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
Fonts
We use Google Fonts by Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA, and Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland), on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google server is established when our website is accessed. The connection to Google established when you call up our website enables Google to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.
Google Maps
Our website uses Google Maps API of the provider Google LLC to visually display geographical information. When using Google Maps, Google also collects, processes and uses data about visitors’ use of the map functions including their IP address. You can find more information about data processing by Google in the Google privacy policy. The integration of Google Maps represents a legitimate interest.
Contacting us and using our services
You can contact us in various ways and data is always collected in the process. You provide us with most of the data that we process when you contact us such as your name, and email address. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted again, provided that there is no legal obligation to retain it.
We process various data as part of the provision of our search, find and compare services and for the initiation and fulfillment of the contractual relationship between you and us. If you are using our search, find and compare services, we process your coarse location obtained from your IP address and all travel information required as part of the fulfillment of the services exclusively for the purpose of processing and handling the contractual relationship.
If you are interested in an offer of one of our Affiliate Partners and want to look at a certain feature of their offer in more details you will be redirected to the relevant Affiliate Partner’s website, and as such your IP address may be transferred by means of a necessary PHPSESSID Cookie to the relevant Affiliate Partner. We have no influence or control over the data collected and processed by the relevant Affiliate Partner when you are being redirected and you can learn more about data processing at the relevant Affiliate Partner’s privacy policy. The basis of processing is our legitimate interest.
Lastly, we process data in the context of administrative tasks as well as organization of our operations, financial accounting, commission management and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services.
The legal basis for processing the above is our legitimate interest, the provision or initiation of a contractual service.
DATA SHARING
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
Internal
If necessary, we transfer your Personal Data within Cheap Travel All. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.
External bodies
Personal Data is transferred to our service providers in the following instances:
● in the context of fulfilling our contract with you,
● to use marketing services and to advertise our services online,
● to communicate with you,
● to provide our website, and
● to state authorities and institutions as far as this is required or necessary.
International transfers
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
SECURITY OF YOUR DATA
In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorized persons, we use appropriate technical and organizational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
MARKETING
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of email using the services of Mailchimp (Intuit France SAS, 7 rue de la Paix, 75002 Paris, France) but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
We also participate in Affiliate Programs. Affiliate programs are designed to provide a means for website owners to earn advertising fees by advertising and linking. As such our website may contain affiliate marketing links, which means we may get paid commission on sales of those products or services we write about. You will never be charged a fee through one of our affiliate links, however you may get a discounted rate of the relevant affiliate’s goods or services and we will make a small commission. Our editorial content is not influenced by advertisers or affiliate partnerships.
SOCIAL MEDIA
General
We are present on social media on the basis of our legitimate interest (currently Facebook and Instagram ((Meta Platforms 1601 Willow Road Menlo Park, CA 94025 and 4 Grand Canal Square Grand Canal Harbour Dublin 2 Ireland), X (formerly Twitter) (X Corp, Market Square, 1355 Market St suite 900, San Francisco, CA 94103, USA) and YouTube (Google) (1600 Amphitheatre Parkway Mountain View, CA 94043, US, and Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland)). If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
Market research and advertising
In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.
When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
ADVERTISING
We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website – for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.
We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website. The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.
YOUR RIGHTS AND PRIVILEGES
Privacy rights
Under the nDSG and GDPR, you can exercise the following rights:
● The right to access;
● The right to rectification;
● The right to erasure;
● The right to restrict processing;
● The right to object to processing;
● The right to data portability;
● The right to complaint to a supervisory authority
Updating your information
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can withdraw consents you have given at any time by contacting us.
Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
WHAT WE DO NOT DO
● We do not request Personal Data from minors and children;
● We do not use Automated decision-making including profiling; and
● We do not sell your Personal Data.
VALIDITY AND QUESTIONS
This Privacy Policy was last updated on Friday, 05th January 2024, and is the current and valid version. However, we may update this policy for a number of reasons, such as to reflect a change in the law or to accommodate a change in our business practices and the way we use cookies. We recommend that you check here periodically for any changes. If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.
