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Data Protection Notice Data Protection Notice for Alesia LTD
Data protection is a matter of trust, and your trust is very important to us. We respect your privacy. Therefore, we attach great importance to the protection of personal data and compliance with the laws in collecting, processing, and using your data. In order for you to feel secure when dealing with your data, we strictly adhere to legal regulations. On this page, we would like to inform you about how we collect and use your data.
We have implemented appropriate technical and organizational measures to prevent the unauthorized processing of personal data, as well as their loss, destruction, or alteration.
If you object to the collection, processing, or use of your personal data in whole or in part, please send your revocation via email or by post to the contact details provided below:
Alesia LTD
Our contact details are also available in the imprint.
2.1. User Account If a user wishes to create an account on our website, they will need to provide the following information:
email address
username
password
Voluntarily provided information:
profile picture
name
date of birth
travel destination preferences for our notifications, such as flight departure times, destinations, preferred months, budget, and travel categories.
The user can also link their account with Facebook, Google, or Apple. In this case, the following data will be transmitted to us:
name
email address
profile picture
age group
language
country and other publicly visible data from the Facebook profile.
Purpose: to register comments on the website and receive personalized offers.
Registration with a Google account
Setting up a user account is entirely voluntary. The data is processed solely based on the user’s consent in accordance with Art. 6(1)(a) of the GDPR and used only for profile creation.
The data in question will be stored until the user deletes their account from the website. The user can delete the account at any time by logging into the website and clicking on “User Account” under “Account Settings.”
2.2. Newsletter Subscription For sending newsletters, we have engaged Iterable Inc., 71 Stevenson Street, 3rd Floor, San Francisco, CA 94105, USA, as the data processor.
Purpose: for advertising campaigns and sending offers from our website.
Processed data:
email address (required)
first and last name (optional)
subscription date (automatically recorded)
selected country for which the subscription was made (automatically recorded)
If a user subscribes to the newsletter, their behavior within the newsletter is tracked (email opens and link clicks).
Once subscribed to the newsletter, actions taken within our newsletter are recorded (email opens and link clicks).
As soon as you open and/or click a newsletter, pseudonymous data is stored solely for the optimization of content and offers on our website. To tailor our newsletter to your needs, we use cookies that store and potentially track the links you choose (retargeting). In this way, you will mainly receive offers and information that match your actual interests. By subscribing to our newsletter, you consent to this process. Of course, you have the option to object to retargeting at any time.
The legal basis for sending the newsletter is the user’s consent in accordance with Art. 6(1)(a) of the GDPR.
By registering, you also consent to the processing of your data in the United States in accordance with Article 49(1)(a) of the GDPR. The European Court of Justice considers the United States as a country with an inadequate level of data protection according to EU standards. In particular, there is a risk that your data may be processed by US authorities for control and monitoring purposes, possibly without recourse.
You can unsubscribe from our newsletter at any time. At the bottom of each newsletter, you will find the link to unsubscribe. Once you unsubscribe from the newsletter, you will no longer receive offers from us, and your personal data will not be further used and will be immediately deleted. Your data will be stored for an additional 3 years before being deleted. The legal basis for retaining the data is our legitimate interest in providing evidence that email delivery was done with your consent, in order to protect the company against any claims.
2.3. Contact via Contact Form or Email Processed data:
first and last name
email address
messages sent to us
Purpose: processing personal data is necessary to handle the contact request, prevent misuse of the form, and ensure the security of our technical information systems. The legal basis for processing the data is the user’s consent in accordance with Art. 6(1)(a) of the GDPR.
User messages and our information are kept for a period of three years to demonstrate the adequacy of the information.
2.4. Customer Support Processed data:
name
messages
phone number (if contact is made by phone)
Purpose: processing personal data is necessary to handle the contact request, prevent abuse, and ensure security. The legal basis for processing the data is the user’s consent in accordance with Art. 6(1)(a) of the GDPR. If data processing is necessary for the conclusion of a contract, the legal basis for data processing is Art. 6(1)(b) of the GDPR.
2.5. Blog Comment Function Processed data:
username (required)
profile picture (if provided)
comment timestamp
comment content
Leaving comments is entirely voluntary. The collection of the user’s aforementioned data is necessary to prevent misuse of the services. The legal basis for processing the data after the user submits a comment refers to our legitimate interests in accordance with Art. 6(1)(f) of the GDPR and serves the security of our role as website operators.
If the user deletes their account from our website, the comments will no longer be marked with their username and profile picture, but the text will be retained.
2.5. WhatsApp Messenger Service Messages are sent and received using the Meta Cloud API.
The WhatsApp newsletter is sent using the Vonage B.V. service.
Address: Vonage B.V., Prins Bernhardplein 200, 1097 JB Amsterdam, Netherlands
GDPR compliance: https://www.vonage.com/legal/privacy-policy/
Purpose: for direct communication and sending offers from our website. All pseudonymized data: phone number, profile picture (optional), first and last name (optional), Messenger ID (automatic), messages or questions sent to us.
By sending a start message to HolidayPirates (hereinafter referred to as “Sender”), I express my consent, pursuant to Art. 6(1)(a) and Art. 7 of the GDPR, for the Sender to use my personal data for direct communication and necessary data processing, using the respective selected messaging service. To use this service, an existing messenger account with the respective provider is required. The provider of this messaging service is:
WhatsApp, Inc., 1601 Willow Road, Menlo Park, California 94025, United States, with data processing described at https://www.whatsapp.com/legal/privacy-policy-eea
I am aware that the respective provider may receive personal data (including communication metadata) that may be processed on servers located in countries outside the EU (e.g., the USA) that do not guarantee a level of personal data protection equivalent to that of the EU. Further information is described in the above-mentioned privacy policies of the respective messenger providers. The Sender has no precise knowledge or influence over the data processing by the respective provider.
Your consent to data processing can be freely revoked at any time by sending “STOP” in the respective messaging service. To have all your stored data removed, send a message with the text “DELETE” via the messaging service. This operation may take up to 24 hours.
2.6. Facebook Messenger Service Travel offers sent via Facebook Messenger are done using the Jumper.ai tool provided by Vonage B.V.
Address: Vonage B.V., Prins Bernhardplein 200, 1097 JB Amsterdam, Netherlands
GDPR compliance: https://www.vonage.com/legal/privacy-policy/
Purpose: for direct communication and sending offers from our website. All pseudonymized data: phone number (optional), profile picture (optional), email address (optional), first and last name (optional), Messenger ID (automatic), gender, time zone (optional), date of birth (optional), locale, messages or questions sent to us.
The user acknowledges that the provider may receive personal data (including communication metadata) that will be processed on servers located in countries outside the EU (e.g., the USA) that do not guarantee a level of personal data protection equivalent to that of the EU. Further information is described in the privacy policy of the aforementioned messenger provider. The Sender has no precise knowledge or influence over the data processing by the respective provider.
By accepting the opt-in request, you authorize the Sender, in accordance with Art. 6(1)(a) and Art. 7 of the GDPR, to use your personal data for direct communication and necessary data processing based on the respective messenger. To use this service, an existing messenger account with the respective provider is required. The provider of this messaging service is:
Facebook Messenger
Address: Meta Platforms Inc, 1 Hacker Way Menlo Park, California 94025
Privacy policy: https://www.facebook.com/about/privacy/
The user acknowledges that the respective provider may receive personal data (including communication metadata) that will be processed on servers located in countries outside the EU (e.g., the USA) that do not guarantee a level of personal data protection equivalent to that of the EU. Further information is described in the privacy policy of the aforementioned messenger provider. The Sender has no precise knowledge or influence over the data processing by the respective provider.
Your consent to data processing can be freely revoked at any time by sending “DISISCRIVITI” in the respective messaging service. To have all your stored data removed, send a message with the text “CANCELLA TUTTI I MIEI DATI” via the messaging service. This operation may take up to 24 hours.
2.7 Instagram Messenger Travel offers sent via Instagram Messenger are done using the Jumper.ai tool provided by Vonage B.V.
Address: Vonage B.V., Prins Bernhardplein 200, 1097 JB Amsterdam, Netherlands
GDPR compliance: https://www.vonage.com/legal/privacy-policy/
Purpose: for direct communication and sending offers from our website. All pseudonymized data: profile picture (optional), first and last name (optional), user ID (automatic), messages or questions sent to us.
The user acknowledges that the provider may receive personal data (including communication metadata) that will be processed on servers located in countries outside the EU (e.g., the USA) that do not guarantee a level of personal data protection equivalent to that of the EU. Further information is described in the privacy policy of the aforementioned messenger provider. The Sender has no precise knowledge or influence over the data processing by the respective provider.
By accepting the opt-in request, you authorize the Sender, in accordance with Art. 6(1)(a) and Art. 7 of the GDPR, to use your personal data for direct communication and necessary data processing based on the respective messenger. To use this service, an existing messenger account with the respective provider is required. The provider of this messaging service is:
Instagram Messenger
Address: Meta Platforms Inc, 1 Hacker Way Menlo Park, California 94025
Privacy policy: https://www.facebook.com/about/privacy/
The user acknowledges that the respective provider may receive personal data (including communication metadata) that will be processed on servers located in countries outside the EU (e.g., the USA) that do not guarantee a level of personal data protection equivalent to that of the EU. Further information is described in the privacy policy of the aforementioned messenger provider. The Sender has no precise knowledge or influence over the data processing by the respective provider.
Your consent to data processing can be freely revoked at any time by sending “DISISCRIVITI” in the respective messaging service. To have all your stored data removed, send a message with the text “CANCELLA TUTTI I MIEI DATI” via the messaging service. This operation may take up to 24 hours.
2.8 Booking Travel with Our Partners , your data will be transmitted to them for processing the booked trip. As a tour operator, Our partners acts as an independent data controller under data protection law.
During the booking process with our partners, you can consent to the processing of your data by Alesia. If you do so, you agree that Alesia may use the data to send you personalized travel offers via email in the form of a newsletter. Detailed information can be found in section 2.2 of this document.
Shared data: data shared during the booking process, including name, email address, phone number, address, and date of birth.
Purpose: customer service, marketing campaigns.
Please let us know if there’s anything else I can help you with.
Cookies are small text files stored on the user’s computer or mobile device by a website that the user visits using their browser.
We use cookies to manage and provide our services. For example, we use them to offer our web-based services, improve the user experience, analyze how our services are used, and personalize them. Cookies help simplify the login process, tailor our content to the user’s interests and preferences, and discover the most frequently asked questions. We may also use cookies to display content related to our services. Additionally, cookies are used to store user settings, such as language preferences, to ensure a secure user experience and further customize our services.
If a user books a trip with one of our partners through our website, the corresponding personal data will be transmitted to the partner. This includes cookies used to record the booking process. Through cookies, our partners are informed that the user has booked the solution through our website. To improve the user’s experience, our partners may utilize information related to the booking.
Important information about cookie usage:
When visiting our website, the user is informed about the use of cookies and provides consent for the processing of personal data collected in this context, such as search terms, page visit frequency, or clicks performed. This data processing is also covered by this data protection statement. The user can accept all cookies or choose to specifically reject all or part of the services. This way, the user has maximum control over the processing of their data and only utilizes what they truly want.
The legal basis for processing personal data when using cookies for analytical purposes is the user’s explicit consent in accordance with Article 6(1)(a) of the GDPR.
The user can completely or partially disable cookie recording and the corresponding service usage by using the corresponding control element on the website, displayed at the bottom of the page (the “Service Management” button). This allows the user to disable all cookies or only selected ones.
Cookies necessary for technical reasons are automatically recorded (Bugsnag, Inc., 939 Harrison St, San Francisco, CA 94107). They cannot be disabled but do not process personal data. The data processing under Article 6(1)(f) of the GDPR is based on our legitimate interest in providing technical functionality.
In our online offerings, we integrate videos from the YouTube platform provided by Google Ireland Ltd. To provide the service, Google may store and process the user’s IP address.
In our online offerings, we integrate videos from the Vimeo.com, Inc. platform. To provide the service, Vimeo may store and process the user’s IP address. If you disable Vimeo in the cookie banner, no service from Vimeo will be loaded. To do so, simply click the “Service Management” button at the bottom of the website and deny the service.
Our website may also integrate content such as images, videos, or text from the Instagram service. If the user is logged in to Instagram, the platform may associate the opening of content with the user’s profile. If you disable Instagram in the Service Management section, their services will not be loaded. To do this, simply click the “Service Management” button on the website and block the corresponding service.
Google Tag Manager does not record personal data but helps us integrate and manage our tags. Tags are small snippets of code that are primarily used to analyze traffic and visitor behavior, track the effectiveness of online advertising and social channels, enable remarketing and targeting to specific user groups, and test and optimize websites. Google Tag Manager does not access this data.
If you disable it on the website under “Service Management,” all tracking tags implemented with Google Tag Manager will be deactivated.
The following tracking services are integrated into Google Tag Manager:
Google Analytics
If the user has not blocked “Alesia Website Tracking” in Service Management, Google Analytics, a web analytics service provided by Google Ireland Ltd., will be used on our website.
Address: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4
Purpose: Analyze user behavior on the website for:
Data processed: Pseudonymized ID
Google Analytics uses cookies, which are text files stored on the user’s device that allow the analysis of website usage. Typically, the information collected through cookies is sent to a Google server in the USA and stored there.
We have enabled IP anonymization. Within the EU and the European Economic Area and in other countries participating in the agreement, the user’s IP address is abbreviated. Only in exceptional cases is the IP address first transmitted to a Google server in the USA in full and then abbreviated. This abbreviation removes the personal reference from the user’s IP address. The user’s IP address transmitted by the browser is not associated with other data stored by Google.
The data collected by Google on our behalf as part of the contract for data processing is used to analyze individual users’ website usage, such as generating reports on website activity to improve it. This allows data, sessions, and interactions across multiple devices to be associated with a pseudonymized user ID, enabling the analysis of user activities regardless of the device used.
The user’s personal data is deleted or anonymized after 38 months. The user can also refuse the use of Google Analytics on our website by simply blocking Alesia Website Tracking in “Service Management.”
The legal basis for data processing under Article 6(1)(f) of the GDPR is our legitimate economic interest in providing technical functionality, optimization, and service development.
5.2. Demographics Address: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Purpose:
Data processed: Pseudonymized ID
Demographics is only used if the user has given their consent under Article 6(1)(a) of the GDPR on our website in Service Management.
The user’s personal data is deleted or anonymized after 38 months.
5.3. Optimize If the user has not declined “Optimize” in our Service Management, Google Optimize, a website optimization tool, will be used on our website.
Address: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Purpose:
Data processed: Pseudonymized ID
Google Optimize is a sub-service of Google Analytics. For more information on its operation, refer to the “Google Analytics” section mentioned above.
Optimize is used only if the user has given their consent under Article 6(1)(a) of the GDPR on our website in Service Management.
The user can refuse the use of Google Optimize at any time on our website by simply clicking the “Service Management” button at the bottom of the page and blocking the service.
The user’s personal data is deleted or anonymized after 90 days.
5.4. Meta Pixel If the user has not blocked “Meta Pixel” in Service Management, our website uses Facebook Pixel. As Facebook and Instagram are connected, the data is processed simultaneously by Instagram.
Address: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Address: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA
Purpose:
Data processed:
Our legitimate interest in processing the data under Article 6(1)(f) of the GDPR is driven by our economic interest in managing our online offering profitably.
The user’s personal data is deleted or anonymized after 180 days.
The user can also refuse the use of Facebook Pixel on our website by simply clicking the “Service Management” button at the bottom of the page and blocking the service.
5.5. Google Ads If the user has not blocked “Google Ads” in Service Management, Google Ads tags will be used on our website.
Address: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Purpose: Analyze user behavior to better understand their interests and provide improved content. Use custom audiences for advertising campaigns and personalized ads.
Data processed:
Button click data – includes all buttons clicked by website visitors, including their actions and subsequent page visits (user behavior tracking)
Our legitimate interest in processing the data under Article 6(1)(f) of the GDPR is driven by our economic interest in managing our online offering profitably.
The user’s personal data is deleted or anonymized after 180 days.
The user can also refuse the use of Google Ads tags on our website by simply clicking the “Service Management” button at the bottom of the page and blocking the service.
5.6. Pinterest Address: Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland
Purpose:
If the user uses Pinterest functions on our website, data is automatically transmitted to Pinterest to better understand the user’s interests and improve the displayed advertising.
Data processed:
Cookie data for logging purposes (when the user uses Pinterest, some information, such as log data mentioned above, is automatically stored. For example, information transmitted automatically by the user’s browser when visiting a website or automatically sent by the user’s mobile app when used. Cookie data is also used, e.g., to store language settings or other preferences so that the user does not have to make the same choices at each Pinterest login. Some cookies are associated with the user’s Pinterest account (including personal information such as the provided email address), while others are not.)
Device type
Pinterest is used only if the user has given their consent under Article 6(1)(a) of the GDPR on our website in Service Management.
The user’s personal data is deleted after 30 days.
5.7. Twitter (Twitter Social Plugin) Address: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA
Purpose: Users have the ability to directly share our offers on Twitter. The data is used to improve Twitter’s products and services and provide relevant advertising, particularly personalized proposals and ads.
Data processed: Twitter may receive information such as websites visited by the user, their IP address, browser type, operating system, and cookie data.
Twitter is used only if the user has given their consent under Article 6(1)(a) of the GDPR on our website in Service Management.
The user’s personal data is deleted or anonymized after 18 months.
5.8. Facebook Social Plugins (Facebook, Instagram) Address: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Purpose: The data is used to improve Facebook’s products and services and provide relevant advertising.
Data processed: Facebook user ID, website URL, date and time, and other browser information.
Facebook social plugins are used only if the user has given their consent under Article 6(1)(a) of the GDPR on our website in Service Management.
The data is retained until it is no longer necessary for providing Facebook’s products and services or until the user’s account is deleted, if earlier. Search history is deleted after 6 months.
If the user applies as a tester for Alesia LTD, the following personal data will be collected in accordance with Article 6(1)(a) of the GDPR:
The purposes of collecting this data are:
After the survey, the collected data will be blocked for further use and deleted after 12 months.
Regarding fan pages on social media platforms, Alesia LTD states that they have no control over the personal data processing carried out by the platform operators. The platform operators may save cookies on the user’s browser to store usage behavior and interests for market research and advertising purposes. The platform operators use the obtained usage profiles, typically independent of individual devices, to display personalized advertising to the user. In some cases, the user may have provided consent to the platform operator for data processing. The legal basis for this processing is specified as Article 6(1)(a) of the GDPR.
The processing of data may also involve individuals who are not registered users of the corresponding social media platform. In some cases, the user’s data may be processed outside the European Union, which could make it more challenging to enforce rights.
When Alesia LTD independently processes user data, they are directly responsible. The legal basis for such processing is their legitimate interest (Article 6(1)(f) of the GDPR) in representing their company externally, using effective information channels, and communicating with users.
For more information on data processing within the scope of data protection rights, opt-out options, and the application of data subjects’ rights, the privacy policies of the respective platform operators should be consulted.
Regarding Facebook and Instagram fan pages, the provided addresses are for Meta Platforms Ireland Limited and Instagram Inc., respectively. The data processing is based on an agreement on joint processing of personal data under Article 26 of the GDPR (https://www.facebook.com/legal/terms/page_controller_addendum).
The legal basis for the processing activities described by our company is as follows:
Consent: When specific purposes require user consent, the legal basis is Article 6(1)(a) of the General Data Protection Regulation (GDPR).
Contractual Necessity: If data processing is necessary for the performance of a contract with the data subject (e.g., providing specific services or products), the legal basis is Article 6(1)(b) of the GDPR.
Compliance with Legal Obligations: If our company is subject to a legal obligation that requires the processing of personal data (e.g., for tax compliance), the legal basis is Article 6(1)(c) of the GDPR.
Additionally, we collect, use, store, and share user information when necessary:
(a) to comply with applicable laws, respond to legal proceedings, or government requests; (b) to enforce our terms and applicable policies; (c) to identify, investigate, prevent, and address fraud, illegal activities, security issues, or technical problems; (d) to protect the rights, property, and safety of our users, Alesia LTD, or others.
