1. Introduction:
- AERIVI (hereinafter referred to as “AERIVI”, “we”, “us”, or “our”), is committed to protecting your privacy and ensuring the security of your personal data.
- This Privacy Policy describes how we collect, use, process, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and Portuguese Law No. 58/2019 of August 8th.
- By using our services (including our website, applications, and any interactions with us), you consent to the data practices described in this policy.
2. Personal Data We Collect:
- We may collect the following categories of personal data:
- Identification Data: Name, address, email address, phone number, date of birth, passport details, identification documents.
- Booking and Travel Information: Flight preferences, hotel preferences, driver service requirements, activity interests, travel dates, travel companions, dietary restrictions, and accessibility needs.
- Payment Information: Credit/debit card details, billing address (processed by secure payment processors).
- Communication Data: Records of correspondence and communications with us (emails, phone calls, chat logs).
- Website and Usage Data: IP address, browser type, operating system, and browsing activity on our website (using cookies and similar technologies – see our Cookie Policy).
- Marketing Preferences: Whether you wish to receive marketing communications from us.
- Special Categories of Data: In limited cases (e.g., health information related to accessibility needs or dietary restrictions), we may process special categories of personal data with your explicit consent.
3. Purposes of Processing Your Personal Data:
- We process your personal data for the following purposes:
- To process and manage your bookings for private flights, hotels, private drivers, and activities.
- To communicate with you regarding your bookings, enquiries, and customer service requests.
- To personalise your travel experience and offer tailored recommendations.
- To process payments and prevent fraud.
- To manage and improve our website and services.
- To send you marketing communications (with your consent where required).
- To comply with legal and regulatory obligations.
- To handle any complaints or disputes.
4. Lawful Bases for Processing Your Personal Data:
- We will only process your personal data when we have a lawful basis for doing so, which may include:
- Consent: Where you have given us explicit consent to process your personal data for a specific purpose (e.g., marketing, special categories of data).
- Contract: Where processing is necessary for the performance of a contract with you (e.g., to fulfill your travel bookings).
- Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject.
- Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests (e.g., improving our services, preventing fraud, direct marketing in certain circumstances).
5. Sharing Your Personal Data:
To provide our services, we may need to share your personal data with the following categories of recipients:
- Service Providers (Partners): Airlines, hotels, private driver companies, and activity providers who are essential for fulfilling your bookings.
- Payment Processors: Secure third-party providers who process your payment details.
- IT and Website Service Providers: Companies that support our website and IT infrastructure.
- Marketing and Communication Service Providers: Companies that assist us with marketing communications (with your consent).
- Legal and Regulatory Authorities: When required by law or to comply with legal obligations.
- Our Professional Advisors: Lawyers, accountants, and other professional advisors.
We will ensure that these third parties process your personal data in accordance with applicable data protection laws and have appropriate safeguards in place.
6. International Data Transfers:
- Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) where our service providers or partners are located.
- In such cases, we will ensure that appropriate safeguards are in place to protect your personal data, such as:
- Transferring to countries deemed by the European Commission to provide an adequate level of data protection.
- Implementing Standard Contractual Clauses approved by the European Commission.
- Relying on other legally recognized transfer mechanisms.
7. Security of Your Personal Data:
- We have implemented appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
- These measures include [This section needs to be specific to AERIVI’s actual security measures, e.g., encryption, access controls, secure servers, staff training].
- We regularly review and update our security measures to ensure ongoing protection.
8. Retention of Your Personal Data:
- We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- The retention period will depend on the specific type of personal data and the purpose of processing. For example, booking data will be retained for the duration of the travel arrangements and for a period thereafter to handle any queries or legal claims. Marketing data will be retained until you withdraw your consent.
9. Your Rights as a Data Subject:
Under the GDPR and Portuguese law, you have the following rights regarding your personal data:
- Right to Access: You have the right to request access to the personal data we hold about you.
- Right to Rectification: You have the right to request that any inaccurate or incomplete personal data be corrected.
- Right to Erasure (“Right to be Forgotten”): You have the right to request the deletion of your personal data under certain circumstances.
- Right to Restriction of Processing: You have the right to request the restriction of the processing of your personal data under certain circumstances.
- Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
- Right to Object: You have the right to object to the processing of your personal data in certain situations, including for direct marketing purposes.
- Rights in relation to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us using the contact details provided in Section 2. We may require you to verify your identity before responding to your request.
10. Cookies and Similar Technologies:
- Our website uses cookies and similar technologies to enhance your browsing experience and collect usage information. Please refer to our separate Cookie Policy for detailed information about the cookies we use, their purposes, and how you can manage your preferences.
11. Links to Third-Party Websites:
- Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites and encourage you to review their privacy policies before providing any personal data.
12. Changes to this Privacy Policy:
- We may update this Privacy Policy from time to time to reflect changes in our data processing practices or legal requirements. We will post any updates on our website and, where appropriate, notify you by other means. The “Last Updated” date at the top of this policy indicates when it was last revised.
13. Contact Us:
- If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us at: info@aerivi.com