GDPR Privacy Notice - kukitours.com

The following Privacy Policy applies to this website under the domain name kukitours.com but also to its subdomains *.kukitours.com.
General Data Protection Regulation (GDPR), Article 13 and 14 of Regulation EU 2016/679.

What is the purpose of this notice?

This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing by kukitours Ltd. when using this website.

This document has been designed using the guidance procedures provided by the Information Commissioner Office (ICO) and in relation to the statutory requirements with regards to our obligations to the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

The website https://kukitours.com (hereinafter referred to as the “Site” or “Website”) is owned by kukitours Ltd (“kukitours”, “we”, “our”, or “us”). kukitours operates and respect your privacy and is committed to complying with this Privacy Policy, which describes how kukitours, as a travel and software company, collects and uses the personal data you provide to us. This Privacy Policy describes what personal data we collect about you, how we collect it, how we use it, with whom we may share it, and what choices you have regarding our use of your personal data. We also describe the measures we take to protect the security of your personal data and how to contact us.

This Privacy Policy applies to kukitours’s travel services provided to you, including via kukitours websites that display or link to this Privacy Policy (hereinafter collectively, the “Services”). Once you leave our websites for others, the privacy policies of the other websites or applications shall apply.

We encourage you to read this Privacy Policy carefully and in its entirety as it relates to your rights regarding the processing of your personal data. As a user of our Services, you understand and agree that we collect, use, and disclose your personal data in accordance with this Privacy Policy.

Who is the Data Controller for personal data?

kukitours is the Data Controller as it collects personal data directly from a Data Subject. In these circumstances, kukitours will be acting under a ‘Legitimate Interest’ to legally process the data for the management of travel for the Data Subject and to fulfill the Service provided. kukitours also acts as a Data Controller for any personal data held regarding its own employees and legally processes this data under its Contract of Employment with those Data Subjects.

What personal data does kukitours collect?

In the course of providing its Services, kukitours collects, uses, and discloses personal data. Personal data is any information that can be used to identify you or that we can link to you. You, as a traveler or user of the Services, may be asked to provide certain personal data when you use our Services. The provision of personal information is voluntary but mandatory in order for us to fulfill the service. Depending on our websites and services, we might collect personal data, such as:

Names, contact and personal information of the travelers or person making an online travel booking (work and home/mobile phone, email, address, gender, Age);
Traveler bookings details: ferry companies, ferry names, dates and hours of departures, arrivals, tickets prices, accommodation types chosen, car rental type, accommodation type, hotel or accommodation name, the location of the holiday, car rental type);
Travel documentation (e.g. passport/visa/drivers license number, expiration dates, citizenship, date of birth, place of birth, gender, vehicle license plate);
Payment data on a safe server; and
Logins, user IDs, employee IDs, passwords, IP addresses, and browsing information.
Other personal data supplied by you via email/contact forms, affiliations requests, Job requests, Curriculum Vitae and by registering to our communities.

If you submit any personal data relating to other people in connection with the Services (e.g. if you make a reservation for another individual), you represent that you have the authority to do so and we will collect, use, and disclose such personal data in accordance with this Privacy Policy.

How does kukitours collect personal data?

kukitours collects personal data:

Directly from you when you access various parts of our Websites and Services, including when you communicate with us via email or other channels;
From other sources, for instance, the company which you are an employee of or are otherwise traveling on behalf of (“Company”), including such Company’s third parties who may send us your personal data on your or your Company’s behalf; and
From the network of websites accessible through or utilized by our Services and our company, including third party suppliers and our kukitours related companies, affiliates, subsidiaries, joint ventures, partners, subcontractors, and agents. This includes personal data we collect automatically through our websites, for instance by using cookies and similar technologies.

The provision of personal information is voluntary.

How does kukitours use personal data?

kukitours collects and uses your personal data for specified, explicit, and legitimate purposes as described in this Privacy Policy and does not process your personal data further in a manner that is incompatible with those purposes.

kukitours limits the use of personal information to the purposes identified in this Policy and for which the individual has provided implicit or explicit consent. We retain personal information for only as long as it is necessary to fulfill the stated purposes, except with the consent of the individual or as required by law.

kukitours uses personal data to:

Provide its Travel Services and fulfill its obligations to travelers or companies representing the travelers (e.g. complete and administer travel reservations, assist in managing the travel, provide reporting, provide notices about your account and the Services, inform you of updates to our websites and applications and other changes to our products or Services).
Communicate with you, for instance by email, post, and phone or via kukitours’s websites and to provide you with customer service.
Understand how our websites are used and provide a customized experience as you use our Services, such as by providing interactive or personalized elements on our Services and providing you with content based on your interests (see our “Cookies” policy https://kukitours.com/cookies-policy/ for more information).
Fulfill a request made by you or your Company (e.g. reporting, questions, or other requests about your personal data).
Send you newsletters, marketing emails, and other information or materials that may interest you, as well as showing personalized advertisements. Where required, we will obtain your consent before sending such marketing messages or showing personalized advertisements.
Carry out our obligations and enforce your, our, or other’s rights as we believe reasonably necessary (e.g. billing and collection, fraud prevention, comply with legal obligations, and respond to legal proceedings or requests from legal authorities and law enforcement or other third parties).

Who does kukitours disclose personal data to and why?

Personal data collected is shared with or disclosed to:

kukitours and its related companies, affiliates, subsidiaries, joint ventures, partners, subcontractors, and agents as necessary to fulfill and support the Services, including bookings and assistance, ticket insurance, responding to requests, and assessing or offering promotions.
Your Company for reporting, auditing, tracking and other purposes as necessary with your Company, including those of its personnel they request we send or make personal data available too.
Third party service providers you or your Company request we send personal data to (e.g. providers who secure compensation for delayed, canceled ferries on behalf of travelers; safety and tracking information providers;).
Third party service providers to complete travel arrangements and reservations and fulfill the Services (e.g. ferry companies, car rental agencies and other ground transportation companies, hotels, cruise lines, destination management companies, and other related travel suppliers for booking/ticketing purposes; industry reporting authorities; equipment and technology vendors, including, without limitation, online booking tool providers; visa and passport providers; credit card companies and payment collection and processing companies).
Other third parties as we believe is reasonably necessary for accordance with applicable laws, including laws outside your country of residence to (i) satisfy laws, regulations, or governmental or legal requests and processes; (ii) identify, contact, or bring legal action against someone who may be violating our terms of use or policies or otherwise enforce our terms and policies; (iii) operate the Services properly; or (iv) protect kukitours and those it serves, including pursuing available remedies or to limit damages that may be sustained (e.g. exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction).

How does kukitours store and protect personal data?

When you are conducting financial transactions with your credit card via our online system, your credit card details are not transmitted to us, but to our partner organization (PayPal). The procedure is carried out and completed by a trusted associate (PayPal), who provides all adequate guarantees regarding electronic transactions. Hence, we have no access to your bank account or any other details of your credit card. From the beginning to the end of your online session all your information and personal details are encrypted under the encryption protocol Secure Sockets Layer – SSL. Every time you log or complete payment via PayPal, the interaction between your computer and PayPal systems is encrypted via protocol SSL TLS v.1.2.

kukitours has adopted the following principles to govern its collection and processing of Personal Data:

Personal Data shall be processed lawfully, fairly, and in a transparent manner.
The Personal Data collected will only be those specifically required to fulfill travel, accommodation, or other travel-related requirements. Such data may be collected directly from the Data Subject or provided to kukitours via his /her employer. Such data will only be processed for that purpose.
Personal Data shall only be retained for as long as it is required to fulfill contractual requirements or to provide statistics to our Client Company.
Personal Data shall be adequate, relevant, and limited to what is necessary for relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
The Data Subject has the right to request from kukitours access to and rectification or erasure of their personal data, to object to or request the restriction of processing concerning the data, or to the right to data portability. In each case, such a request must be put in writing.
The Data Subject has the right to make a complaint directly to a supervisory authority within their own country. kukitours Data Protection compliance is supervised by:
Moutopoulos Olivier, Operations manager
kukitours Ltd
32 '6-ti Septemvri' Str., Sofia, Bulgaria, Zip Code 1000
legal.privacy kukitours.com
Personal Data shall only be processed based on the legal basis except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedent. If the Data Subject has provided specific additional Consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfill travel requirements).
kukitours will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision-making processes.

How long does kukitours keep my personal data?

kukitours retains personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law. When determining how long to retain personal data, we take into account the necessity of the personal data for the provision of our Services, applicable laws, and regulations, including data protection laws, and our legal obligations. We may retain records to investigate or defend against potential legal claims. When retention of the personal data is no longer necessary, the data will be deleted or aggregated for analytic purposes.

What about links to third party websites and services?

Our Services may contain links to third party websites. Some of these websites may allow you to purchase products and services, register to receive materials, or receive new product and service updates. In many cases, you may be asked to provide contact information such as your name, address, email address, phone number, and credit/debit card information. If you use these third party websites and/or provide your personal data and information, the privacy policy and terms of service on those websites are applicable. We encourage you to carefully read such policies on third party websites before submitting your personal data. kukitours is not responsible for and expressly disclaims any and all liability related to the actions of such third party websites, their privacy policies, or the terms and content of such websites.

Does kukitours collect personal data of children?

kukitours does not collect personal data directly from children. Individuals under 18 years of age should not use our Services to submit any personal data about themselves. However, if a booking includes children, we will collect their name and surname and gender as for any other traveler.

What are my rights with respect to my personal data?

As a Data Subject, you have rights under the GDPR. kukitours will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

You may choose what personal data (if any) you wish to provide to us. However, if you choose not to provide certain details or to provide false details, your experience with some or all of our Services may be affected.
To the extent required by applicable law, you have the right to access your personal data and confirm the processing of your personal data. Also, where applicable, you have the right to rectify inaccuracies or errors, erase, restrict the processing, object to processing, and withdraw consent to the processing of your personal data, and where applicable, the right to data portability of your personal data. In some jurisdictions, in addition to you agreeing to this Privacy Policy, data privacy or protection laws may require us to obtain separate express consent for the processing of your personal data. Your consent may also be implied in some circumstances, as permitted by applicable law, such as when communications are required to fulfill your requests.

How can I exercise my rights or make complaints?

kukitours will strive to maintain an accurate and complete record of your personal information for the purposes identified in this Policy. If you believe your personal information may be inaccurate, you may contact us to access your personal information and take steps to verify, update, correct, erase it.

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in this Privacy Policy, please send us a request at legal.privacy kukitours.com

The identity and contact detail for the Data Protection Officer within kukitours is:

kukitours Ltd.
Attn: Moutopoulos Olivier, Operations manager
Address: 32 '6-ti Septemvri' Str.
City/Zip/Country: Sofia, 1000 Bulgaria
Email: legal.privacy kukitours.com

kukitours will respond to your requests to the email address or phone number that you have registered with us or we otherwise have on file for you or any other suitable method. Depending on your request, we may review the request with you and/or your Company to assist in resolving and responding to the request.
We will provide a response within 30 days of receiving an access request.

We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal data. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority in your country (if one exists in your country).

How can I delete the data stored?

If you wish to delete your data stored by kukitours or delete your kukitours account, you may send a request by mail at info kukitours.com and we will delete all your data and accout within 30 days of receiving an delete request.

How are changes to this Privacy Policy handled?

kukitours reserves the right to revise, amend, or modify this Privacy Policy at any time and in any manner. When we post changes to this Privacy Policy, we will update the “last updated” date at the top of this Privacy Policy and we encourage you to regularly check this Privacy Policy for changes.

How safe are the transactions with my credit card through your online system?

As some people hesitate to make online transactions with their credit card, we ensure them that we do not have access to the details of their card (such as the credit card code). When you are conducting financial transactions with your credit card via our online system, your credit card details are not transmitted to us, but to our partner organization (PayPal).
The procedure is carried out and completed by a trusted associate (PayPal), who provides all adequate guarantees regarding electronic transactions. Hence, we have no access to your bank account or any other details of your credit card.
From the beginning to the end of your online session all your information and personal details are encrypted under the encryption protocol Secure Sockets Layer – SSL. Every time you log or complete payment via PayPal, the interaction between your computer and PayPal systems is encrypted via protocol SSL TLS v.1.2.

Interpretation

In this Privacy Policy, unless the context otherwise requires, the following expressions have the following meanings:|

Personal Data: (Article 4 of the GDPR)personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: (Article 4 of the GDPR): means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.
Legal Basis for Processing: (Article 6 of the GDPR): At least one of these must apply whenever personal data is processed: 1. Consent: the individual has given clear consent for the processing of their personal data for a specific purpose. 2. Contract: the processing is necessary for compliance with a contract. 3. Legal obligation: the processing is necessary to comply with the law (not including contractual obligations). 4. Vital interests: the processing is necessary to protect someone’s life. 5. Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law. 6. Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Consent: the individual has given clear consent for the processing of their personal data for a specific purpose.
Contract: the processing is necessary for compliance with a contract.
Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
Vital interests: the processing is necessary to protect someone’s life.
Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Data Controller: (Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing personal data.
Data Processor: (Article 4 of the GDPR): means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.
Data Subject Rights: (Chapter 3 of the GDPR) each Data Subject has eight rights. These are:
- The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
- The right of access; this is your right to see what data is held about you by a Data Controller.
- The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
- The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
- The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to the processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
- The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
- The right to object; the Data Subject has the right to object to the further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
- Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.

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