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Information regarding Art 13, 14 GDPR
We take the protection of your personal and company-related data very seriously and work hard to make sure our services are safe for you to use. We are committed to complying with statutory data protection requirements. This data protection policy describes the type of data that we collect from you, how and for what we use it, and how we protect it.
Table of Contents
1. Area of Applicability
This policy applies to the website available at www.arpanutravel.com (Please note that this policy also refers to other websites, including those in other countries for which different data protection rules apply).
The company responsible for such sites regarding the applicable data protection laws is:
İstanbul / Türkiye
And its appointed data protection officer is:
Arda Özenç ozenc@ozenc.av.tr
In the course of improving our services, we may amend or make supplements to this policy. Where this is the case, we will inform you in advance and obtain your separate consent if needed.
2. Which data we collect
“Personal data” refers to any personal information that we obtain and process through your booking on www.arpanutravel.com or through your consent for data transfer from Cashback World. These details include your full name, title, postal address (street address, zip code, city, country), telephone number(s), email address,Cashback World Member ID, gender and date of birth. . In addition, we will process data about your bookings, these are the date of booking, Destination of the trip (country and location),name and type of the accommodation, room type, name of travel service provider, check-in date, check-out date, number of people traveling, names of people traveling, billing address, number of acompanying children and their age on the date of the arrival.
3. Cookies and Web Tracking
Our websites use cookies, which are small text files that are stored on your computer and can be accessed again when you revisit our website. Cookies enable you to register for our services and help us to personalise the website for you.
You can also use some parts of our website without needing to register or log in. Even if you don’t log in to the website, we will still record certain information automatically so that we can collate data on how our website is used and how efficient it is in a bid to adjust it to our users’ needs. We will therefore collect and process information on your IP address, the time and length of your visit, the number of visits you make, which forms you use, your search settings, your display settings and your favourite settings on our website. Different cookies are stored for different lengths of time. The majority of the cookies we use are automatically deleted when you leave our website (the so-called “session-cookies”). We log access to our website and downloads of files from the website. The cookies on our websites are used exclusively for information purposes and are processed by travelWorld Austria GmbH on behalf of travelWorld Global Limited, for the purpose of analysing the data collected.
We also use the following tools:
Google Analytics This is a web analytics tool from Google Inc., 1600 Amphitheater Parkway Mountain View, CA 94043 USA, herein after referred to as “Google”, to log your online activity on our website, to find out how many users visit us and to record the number of times they access each page. This process is anonymous. Google Analytics’ cookies (gat_UA-102544931-1: Google Analytics Universal Tracking, _ga: Google Analytics Universal Tracking, __gid: Google Analytics Universal Tracking) – including the Google Analytics Tool “Anonymous IP Address” and usage data – are typically sent to a Google server in the United States and stored there. For further information, please refer to https://support.google.com/analytics/answer/6004245?hl=de. To stop your data from being logged, please visit Google Analytics at https://tools.google.com/dlpage/gaoptout?hl=de.
Google AdWords This is used to record website visits for advertising purposes (re-marketing) on Google and in the Display Network. When you visit the site, your browser saves cookies (IDE: Google AdWords Cookie) which make it possible to recognise you as a visitor when you visit other websites belonging to Google’s advertising network. On these pages, visitors can then be presented with advertisements that refer to the content previously viewed on other websites that use Google’s re-marketing feature. You can reject Google AdWords’ tracking at http://www.google.com/settings/ads.
Conversion Tracking by Google AdWords This is how we create conversion statistics that measure the effectiveness of our online advertising campaigns. The conversion tracking cookie (IDE: Google AdWords Cookie) is set when a user clicks on an ad served by Google. According to Google’s privacy policy, no personally identifiable information or company information is processed. If you do not want to be tracked, you can disable the Google Conversion tracking cookie through your Internet browser’s internet settings.
Salesforce Marketing Cloud This is how we record your behaviour on our website to be able to optimise our offer. This way, we find out how many users visit us and record the number of times they access each page. All analysed data is anonymous and is used in automatic processes to improve our offers using predictive intelligence. The behaviour of registered Members on our websites is recorded to improve the user experience and identify relevant content. Salesforce’s Cookies are typically sent to a Salesforce server in the US and stored there.
Amplitude This is an analytics tool from Amplitude, Inc., 631 Howard St., Floor 5, San Francisco, CA 94105 USA, herein after referred to as “Amplitude”, to log your interaction on our website in order to improve our services based on these insights. This process is anonymous. The logged data cannot be connected back to your personal data. Amplitude is fully GDPR compliant and travelWorld has signed a Data Processing Agreements (DPA) with Amplitude. For further information, please visit https://amplitude.com/privacy.
In addition to the cookies described in the analysis tools used, the following additional cookies are used:
“cbInfo” (Aussteller: travelWorld): This cookie stores if the user clicked on the advertising banner “Locale” (Aussteller: travelWorld): This cookie stores the user’s language settings “Logged” (Aussteller: travelWorld): Stores is user already received an early access “userToken” (Aussteller: travelWorld): Authentication cookie created for logged-in users so that they can be identified
Please note that most internet browsers are set to accept cookies by default. You can change the settings in your browser so that certain cookies are rejected or so that you are asked if you would like to accept new cookies. You will find instructions on how to do this under the “Help” function in the menu bar on most browsers. These instructions will normally tell you how to delete existing cookies as well.
Please note that you may not be able to use all the features and services on our websites if you do not accept any or all cookies.
By using our website, or, if necessary, by consent, which we obtain separately, you agree that the above cookies and tools may be used.
4. Conversion measurement with the Facebook pixel
We use the “Facebook-Pixel” by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) (fr: Facebook Cookie for Opt-Out identification) within its website with your consent. This is a cookie; a small text file that is stored on your computer which can be retrieved. It can be used to track users’ actions after they have viewed or clicked on a Facebook ad. This enables us to track the effectiveness of Facebook advertising for statistical and market research purposes. The data collected in this way is anonymous for us, so it does not provide any inference as to the identity of the users. However, the Facebook data is stored and processed so that a connection to the respective user profile can be made, and Facebook can use the data for its own advertising purposes, according to the Facebook Data Usage Guideline (https://www.facebook.com/about/privacy/). You can enable Facebook and its partners to place advertising on and outside of Facebook. A cookie for these purposes can also be stored on your computer. By using the website, you agree to the use of the visitor action pixel.
5. Sharing
On the website are integrated share buttons of the social networks Pinterest, Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Irland and Facebook & Instagram, 1601 South California Avenue, Palo Alto, CA 94304, United States. These share buttons can be recognised by their logos.
All share buttons are set up according to data protection. A direct connection is only established between your browser and the server of the operator of the respective social network once you click on the website’s respective share button (and only then). According to the operators of the social networks mentioned, no personal or company-related data is collected from the social networks unless you click on the respective share button if you are not logged in to these social networks. This data, including the IP address, is only collected and processed for logged-in Members. If you do not wish to have a record of your visit to our website allocated to your social network account, please log out of the user account of the respective social network.
At this point, we point out that as a provider of the website, we obtain no knowledge of the content of the transmitted data or how the social net-works use it. For more information on the use of social networks, see the respective social network’s privacy policy.
6. Use of data
We use your personal data exclusively in compliance with legal requirements. The personal data which you provide to us during your registration www.arpanutravel.com, as well as during your booking on our webiste, is recorded and processed exclusively within the framework of our contractual obligations (Art 6 Sec 1 lit b GDPR). Unless you provide us with this data, we are unable to conclude a contract with you. In addition, we use your data if there is a legal obligation (Art. 6 Sec 1 lit c GDPR). In addition, we use your personal or company-related data only in cases and to the extent to which you give us your specific consent (Art. 6 Sec 1 lit a GDPR).
We use your personal data to communicate with you, in order to verify your identity, to provide you with your personal Login area on our website, to handle your inquiries and bookings, and to provide you with our services.
If you have given us your separate consent, we will also use your data, in the scope of the given consent, to provide you with, for example, offers and promotions. You can revoke this consent at any time, whereby the revocation makes the further processing for the future inadmissible.
We store your personal data as long as there is a business relationship with you and, furthermore if there are legally standardized longer retention periods or if we need the data in the context of an official procedure.
7. Profiling
In order to optimize the user experience, we use the data we have stored about you to infer your needs and interests. On this basis, we can display content that is relevant to you and that better suits your needs and interests. The content corresponding to your preferences will be displayed earlier (e.g. on the homepage) or in a special way (e.g. through individual product presentations). Of course, you still have all of the website’s content at your disposal.
The selection of personalized content is generally based on all data that is stored for your customer account. In particular, these are bookings that you already made through our website. Additionally, we use clickstream data and conclusions. We use your activity on our website (e.g. which offers you click on) to draw conclusions about your interests and to show you relevant offers.
8. Personal data of minors
Our services are not aimed at minors under the age of 18. For minors, our services can only be used with the valid consent of a parent or a legal representative. We collect and use data from minors only as determined by the parent or legal representative or with their consent. If we recognize that we are processing the data of a minor without the effective consent of a parent or legal representative, we reserve the right to delete it.
9. Data security and forwarding
In order to protect your data, we use, among other things, encryption for data transmission (SSL encryption), firewalls, hacker defence programmes and other state-of-the-art security devices. When communicating via e-mail, the security of the data can only be guaranteed by us according to the latest state of the art technology.
The use of your personal and company-related data will be handled by Hotelistan Turizm Otelcilik Bilgi İşlem ve Tic.Ltd.Şti.as your contractual partner and as the responsible entitiy for the processing of your data, Hotelistan Turizm Otelcilik Bilgi İşlem ve Tic.Ltd.Şti.uses travelWorld Austria GmbH as a service provider for the processing. Your personal data and company-related data may, however, be transferred / delivered to other service providers, as well as to other companies within the Hotelistan Turizm Otelcilik Bilgi İşlem ve Tic.Ltd.Şti., Lyoness Group and/or Lyconet Group.
To carry out our services, communicate with you and manage our online presence we use the services of certain service providers. We assure you that we carefully select these service providers to ensure legal and secure data processing. In addition, we have obligated the service providers to use your personal data and company-related data only according to our instructions and in accordance withUK data protection legislation as well as the data protection legislation of the European Union. Further use of the data by these service providers is prohibited.
In addition, we will pass on your personal data and company-related data to the Hotelistan Turizm Otelcilik Bilgi İşlem ve Tic.Ltd.Şti., insofar as this is necessary for the purpose of calculating member benefits resulting from bookings made by you as part of the Cashback World program. The Hotelistan Turizm Otelcilik Bilgi İşlem ve Tic.Ltd.Şti. companies shall also only to use your personal data and company-related data for the sole purpose for which it was given, as provided for in the relevant UK data protection legislation and the Data Protection Acts of the European Union.
Insofar as this is necessary for the processing of the booking made through our platform, we pass on your personal data to the respective hotel operator or the company performing the booked service. The hotel operators and service providers shall only use your personal data for the specific purpose and in accordance with UK and European data protection legislation.
Should you purchase a travel insurance product through our platform, we will also pass on your personal data to the brokers and/or underwriters of such insurance product and such brokers and/or underwriters shall only use your personal data for the specific purpose of providing you with such products and in accordance with UK and European data protection legislation.
You can make bookings worldwide through our website. We will therefore send your personal company-related data abroad, as far as this is necessary to carry out your booking. A transfer of your personal or company-related data to the Member States of the European Economic Area, to Switzerland and to other countries with adequate level of data protection requires no further consent. If, however, your personal and company-related data is transferred to any country other than those mentioned above, we will do so within the framework of our contractual obligations (Art 6 Sec 1 lit b GDPR) or inform you and of course comply with the applicable data protection regulations, provide you with appropriate guarantees and ensure the enforcement of your rights and remedies.
In addition, we transfer your personal data, namely first and last name, title, booking number, customer number, billing address (street, house number, zip code, country), IP address, email address, telephone number, hotel name, length of stay, check-in date, Hotel address (street, zip code, country), for fraud prevention to our payment service provider Ingenico ePayments (Global Collect Services BV, Neptunusstraat 41-63, 2132 JA, Hoofddorp, KvK / CoC 34140462)
10. Your data protection rights and contact infromation
You have the right to obtain information about the personal or company-related data that we process about you and may request their correction, deletion or restriction of processing. You also have the right of objection and the right to data portability (Which means you have the right to receive the data in a structured, common and machine-readable format).
If you believe that the processing of your personal or company-related data violates the EU General Data Protection Regulation, you have the right to lodge a complaint with the Information Commissioner’s Office, the United Kingdom’s Data Protection Authority (https://ico.org.uk/) or a supervisory authority of another EU Member State.
If the use of your personal or company-related data on this website is based on your consent, you have the right to revoke your consent for the processing of this data for the future at any time without having to provide any reasons. By withdrawing your approval, your data may no longer be used. Please inform us in writing of your wish to withdraw approval (by post or e-mail) using the following address:
Hotelistan Turizm Otelcilik Bilgi İşlem ve Tic.Ltd.Şti.
Merkez Mah. Abide-i Hürriyet Cad. No: 171/8 Kat:2, 34384 Şişli/İstanbul
Mail: info@arpanutravel.com
Please also use this contact information for any questions regarding the use of your data as well as for information about the enforcement of your data protection rights.