1. Background and scope
This Privacy Notice (“Notice”) sets out how Comfort Tour processes and protects the privacy of your personal information.
We need to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.
For the purposes of the General Data Protection Regulation 6698/29677 (“KVKK”) and other similarly situated legislation we are a “data controller” (or equivalent) for the processing of personal information you provide to us in connection with:
There may be instances where your local data protection laws impose more restrictive information handling practices than the practices set out in this Notice. Where this occurs, we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.
2. What personal information do we collect?
Personal information has the meaning given under your local data protection law, and, where the KVKK applies, the meaning of personal data given under the KVKK. Personal information generally means information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual.
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf.
We therefore typically process the following types of personal information about you:
We also collect online identifiers such as your IP address and data regarding your device and the network you are using to connect with us.
When you contact us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback you have sent to us. We also collect information that is required for use in the business activities of Comfort Tour and our related entities, including for example, financial details necessary in order to process various transactions, audio, electronic and visual information (such as video surveillance footage) used for security purposes, voice recordings for quality control and dispute resolution, and relevant personal information you may elect to provide to us.
In some circumstances, we may collect personal information from you which may be regarded as sensitive information under your local data protection laws. Sensitive information may include (without limitation) your racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, membership of political, professional or trade associations (for use in booking special rates), biometric and genetic information, passwords and financial information and health information Please note that, when necessary for travel arrangements, we may collect from a responsible adult personal information relating to a child of any age, but we do not knowingly collect any such information directly from children.
We will only collect sensitive information in compliance with your local data protection laws, with your explicit consent and where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorised to do so by law. To the extent permitted or required under your local data protection laws, you consent to us using and disclosing your sensitive information for the purpose for which it was collected. For example, if you provide health information to us in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf. A further example is if you disclose your religious beliefs to us because you are interested in, for example, certain holiday packages, in which case you consent to us using and disclosing that information in connection with facilitating your request. We will not use or disclose sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.
3. How do we collect personal information?
We will only collect personal information in compliance with your local data protection laws. We usually collect your personal information directly from you during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impracticable to do so.
Generally, this collection will occur:
We may collect personal information about you:
Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.
In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveller on the booking.
Where you make a travel booking on behalf of another person (e.g. a family or group booking or a travel booking made for an employee), you agree to have obtained the consent of the other person for Comfort Tour to collect, use and disclose the other person's personal information in accordance with this Notice and that you have otherwise made the other person aware of this Notice.
You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person's personal information to us.
We make every effort to maintain the accuracy and completeness of your personal information which we store and to ensure all of your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal information or if you become aware that we have inaccurate personal information relating to you (see section 14 below). We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you, or a person acting on your behalf, provide to us.
4. How do we use your personal information?
We will only process your information, where:
In detail: Where you contact us in relation to a travel booking or query, the purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Notice (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc.).
When you book or otherwise arrange travel related products and services through us, we usually act as an agent for the relevant travel service providers (e.g. for a hotel). In this case, we process your personal information as necessary so as to provide the services you requested from us. This usually includes collecting personal information about you both for our internal purposes as described in this Notice and for the travel service provider for whom we act as agent (e.g. to provide you with the booked services). For example, if you book a flight through us, then we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.
We act as agent for or on behalf of many thousands of travel service providers around the world, so it is not possible for us to set out in this Notice all of the travel service providers for whom we act or their locations. For more information about the disclosure of personal information to travel service providers located overseas, please refer to section 6 below.
If you have any concerns regarding the transfer of your personal information to a travel service provider, or you wish to contact us for further information, please refer to the “Feedback / Complaints / Contact” section below (section 14).
Further purposes for which we process personal information include:
Where permitted by local data protection laws, we may use your personal information to send you targeted marketing activities relating to our products and services (and those of third parties) that we think may interest you, unless you have requested not to receive such information. These may include, but are not limited to, mail outs, electronic marketing and notifications as described below, and telephone calls). We will only use your personal information to send electronic marketing materials to you (including e-newsletters, email, SMS, MMS and iM) if you have opted-in to receive them or not opt-ed out of receiving them, depending upon the applicable law. You can subscribe to receive e-newsletters and other electronic promotional/marketing materials by following the relevant links on our website or requesting one of our consultants to do so for you.
Should you no longer wish to receive promotional/marketing material from us, participate in market research or receive other types of communication from us, please refer to the “Feedback / Complaints / Contact” section below (section14). You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MMS, iM or other form of electronic marketing. Please also see the “Your rights” section of this Notice to learn about your ability, at any time, to opt out or limit the use of your browsing behaviour for online behavioural advertising purposes (section 8 below).
5. Is personal information disclosed to third parties?
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this Notice and, in particular, as set out below, and in accordance with your local data protection laws. Note that, in this Notice, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.
Your personal information may be disclosed to the following types of third parties:
When you engage us to book flights on your behalf, we will provide your personal information (i.e. name, email address and/or mobile number) to the relevant airline. This enables airlines to advise passengers of irregular flight operations and disruptions (e.g. flight cancellations, schedule changes) directly.
Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law (including applicable privacy / data protection laws).
On our websites, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with us. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share personal information in accordance with their own privacy policies. We strongly suggest you review the third parties’ privacy policies if you use the relevant features.
6. Is personal information transferred overseas?
We may disclose your personal information to certain overseas recipients, as set out below. We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to appropriate or suitable safeguards as required by your local data protection laws
It is possible that information will be transferred to an overseas recipient (other than any of our overseas related entities) located in a jurisdiction where you will not be able to seek redress under your local data protection laws and that does not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by your local data protection laws, we will not be liable for how these overseas recipients handle, store and process your personal information.
(a) Our overseas related entities
Comfort Tour operates a global business, including operations in Malaysia, Hong Kong, India, China, Singapore, Vietnam,Bangladesh,Indonesia, Tanzania, Philipinnes. Your personal information may be disclosed to our overseas related entities in connection with facilitation of your travel booking and/or to enable the performance of administrative, advisory and technical services, including the storage and processing of such information. This includes enabling “single sign-on” allowing you to login to a shared account across our brands using a single set of log-in credentials, which allows us to, for example, show your reservations and bookings made through the websites, applications, and services of our group companies on your account page, and allow our group companies to show information in your respective account(s) with them.
(b) Travel service providers located overseas
In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas travel service providers. We deal with many different travel service providers all over the world, so the location of a travel service provider relevant to your personal information will depend on the travel services being provided. The relevant travel service providers will in most cases receive your personal information in the country in which they will provide the services to you or in which their business or management is based.
(c) Our third party service providers located overseas
We may also disclose your personal information to third parties located overseas for the purpose of performing services for us, including the storage and processing of such information. Generally, we will only disclose your personal information to these overseas recipients in connection with facilitation of your travel booking and/or to enable the performance of administrative and technical services by them on our behalf.
We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient, or are made subject to appropriate or suitable safeguards as required by your local laws.
We use key service providers located in India, Indonesia, Philippines, Hong Kong, USA, United Kingdom, Spain and Australia. We also deal with many different service providers all over the world, so it is not possible for us to set out in this Notice all of the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please refer to the “Feedback / Complaints / Contact” section below (section14).
7. Security of information
We are committed to safeguarding and protecting personal information and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal information provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal information transmitted, stored or otherwise processed. Comfort Tour has implemented various physical, electronic and organisational security procedures in order to protect the personal information it holds from loss and misuse, and from unauthorised access, modification, disclosure and interference. Comfort Tour regularly reviews security technologies and will strive to protect your personal information as fully as we protect our own confidential information. Comfort Tour is not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise.
We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.
8. Your rights in relation to the personal information we collect
If you wish to make a Subject Access Request to:
you can request this by contacting us as set out in section 14 below. You will receive acknowledgement of your request.
We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests or as otherwise permitted by applicable law.
We reserve the right to deny you access for any reason permitted under applicable laws. Such exemptions may include national security, corporate finance and confidential references. If we deny access or correction, we will provide you with written reasons for such denial unless it is unreasonable to do so and, where required by local data protection laws, will note your request and the denial of same in our records.
You have the right to lodge a complaint with a relevant supervisory authority.
Further correspondence regarding your request should only be made in writing to the applicable Chief Privacy Officer as set out in section 14 below.
Please note that, if you request that we restrict or stop using personal information we hold on you, or withdraw a consent you have previously given to the processing of such information, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveller's full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.
You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct, unless we subsequently become aware that it is not correct.
You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below (section14).
In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of personal information.
To the extent permissible by law, we reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal information, and for any additional copies of the personal information you request from us.
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