Privacy Policy
1. PRIVACY POLICY OVERVIEW
1.1. At TravelGo OÜ ("TravelGo", "we", "us", or "our"), we collect, use and are responsible for certain personal information about you. When we do so, we are subject to the General Data Protection Regulation 2016/679 ("GDPR"), which applies across the European Union, and we are responsible as "controllers" of that personal information for those laws.
1.2. This Privacy Policy applies to all B2B clients and suppliers of TravelGo and the individuals who are, or who work for or on behalf of, our clients and suppliers (together referred to as "B2B Partners") or any personal data provided via any websites, web applications, mobile applications or similar devices, channels, platforms, service applications or other applications operated by or on behalf of us or which reference this Privacy Policy.
1.3. This Privacy Policy describes how we collect, use and process personal information in performing our obligations to, and managing our business relationship with, our B2B Partners.
1.4. Please note that we are not the controller of any personal information provided directly by individuals to whom a booking is made through another travel services provider. The data controllers in these cases will be the relevant travel services provider via which a booking was made. In these circumstances, it is the travel services provider's responsibility to ensure they have authorisation for TravelGo to use your personal data to fulfil our obligations in respect of providing the service requested. In such cases, if you are a traveller and have any queries regarding the use of your personal data or wish to access your personal data, you should contact the relevant data controller directly (or contact us, and we will try to assist with directing you to the appropriate person).
1.5. In respect of all persons to whom this Privacy Policy applies (see 1.2 above) (referred to as "you" and "your" in this Privacy Policy), we are the data controller of your personal data, i.e. we are the controller of how all personal information we are holding about you is stored, processed or transferred. We will only deal with your personal data by the terms of this Privacy Policy.
1.6. We are always happy to answer any questions you may have or to provide you with any additional information that you may need. Please see the "Contact Us" section below for details on how to get in touch with us.
1.7. We review this Privacy Policy regularly to ensure that we’re transparent about how we use your personal information. Any changes to this Privacy Policy will be reflected on our website and will take effect on the publication date.
2. WHO WE ARE?
2.1. We are TravelGo OÜ (company number 14439165), whose registered office is at 11415, Valukoja tn 8-110, Estonia, Tallinn. We are a B2B travel agency and act as a travel aggregator for airline tickets and different travel products in partnership with leading airlines, metasearch engines and other service providers. We provide our B2B Partners with the best deals via API. We refer to these services and our websites as "Services" in this Privacy Policy.
2.2. For the GDPR, and to the extent that we process the personal information of our B2B Partners, we are an independent "data controller". Any personal information we collect and process in this context is necessary to enable us to manage our business relationship with our B2B Partners, supply our Services and perform our business functions and activities, including:
• our provision of Services;
• the facilitation of payments for Services;
• marketing our Services; and
• our compliance with our policies, procedures and legal obligations.
We are firmly committed to ensuring the privacy of the personal information we collect and maintaining safeguards to protect personal information in our care. There may be instances where your local data protection laws impose more restrictive information handling practices than the practices set out in this Privacy Policy. Where this occurs, we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.
3. PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
3.1. In respect of all persons to whom this Privacy Policy applies (see 1.2 above), most of the information we hold about you comes from the way you engage with us, for example by doing any of the following:
• filling in forms or making a general enquiry via our website;
• registering your interest in partnering with us;
• providing information in the course of negotiating and entering into contractual agreements with us; and
• corresponding with us by phone, email or otherwise.
However, we may also collect information:
• from publicly accessible sources;
• directly from a third party, e.g.: sanctions screening providers; credit reference agencies;
• from a third party with your consent, e.g. your bank;
• from cookies on our website;
• via our IT systems, e.g.: automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
3.2. The information we collect when you engage with us for any of the purposes described above may include, for example:
• your name and contact information, including email address and phone number and company details;
• the Internet Protocol (IP) address attached to your device;
• your browser type and version, time zone setting, browser plug-in types and versions, operating system and certain device information;
• information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page;
• your billing information, transaction and payment information.
4. USES MADE OF THE INFORMATION
4.1. We use information held about you in the following ways:
• to provide you with Services that you request from us;
• for internal record keeping;
• to manage our business relationships with our B2B Partners;
• to communicate with our B2B Partners about the Services;
• to market, promote and drive engagement with the Services;
• to provide and improve customer support and to respond to requests;
• for research and development;
• to ensure security and protect our business interests;
• to comply with our legal obligations and policies.
5. OUR LEGAL GROUNDS FOR PROCESSING YOUR INFORMATION
5.1. We will only process your personal information for the purposes set out in this Privacy Policy and, in each case, in accordance with data protection law, e.g.:
• for the performance of our contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party. A "legitimate interest" is when we have a business or commercial reason to use your information (for example for internal record keeping, analysis to help us manage our business or marketing purposes), so long as your rights and interests do not override this; or
• to comply with our legal and regulatory obligations; or
• where you have given consent.
6. PROMOTIONAL COMMUNICATIONS
6.1. We may use your personal information to send you updates (by email, text message, telephone or post) about our Services.
6.2. We have a legitimate interest in processing your personal information for promotional purposes. We do not usually need your consent to send you promotional communications. However, we will ask for this consent separately and clearly where consent is required.
6.3. We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the TravelGo group for marketing purposes.
6.4. You have the right to opt-out of receiving promotional communications at any time by contacting us via email: [email address].
We may ask you to confirm or update your marketing preferences if you instruct us to provide other products or services in the future or if there are changes in the law, regulation, or structure of our business.
7. HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT
7.1. We will only share personal information we collect with a third party if it is necessary for us to provide our Services. We have contractual provisions with all third parties. We share personal information to ensure they handle it with care, comply with all applicable laws, and do not use this personal information for any other purpose.
7.2. We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, fraud detection, analysis, and other services for us, which may require them to access or use our information collected from you. Suppose a service provider needs to access this information to perform services on our behalf. In that case, they do so under close instruction from us, including policies and procedures designed to protect personal information.
7.3. We work with a global network of partners who help us market and promote our Services (for example, by providing consulting and sales services), generate leads for us, help us improve our Services and resell our Services. We may share personal information we have collected with these partners in connection with these Services, such as to assist with marketing and promotions or as part of our agreement with them.
7.4. In exceptional circumstances, we may share personal information we have collected with a third party if we believe that sharing is reasonably necessary to:
• comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements;
• enforce our agreements, policies and terms of service;
• protect the security or integrity of our Services;
• protect TravelGo, our customers or the public from harm or illegal activities; or
• respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
7.5. We share and transfer personal information with our affiliated entities as part of our global operations. We may also share or transfer information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. Our B2B Partners will be notified via email, a prominent Policy on the Services if a transaction occurs and any necessary choices concerning B2B Partner information.
8. TRANSFERRING YOUR PERSONAL INFORMATION
8.1. We collect information globally. As part of our global operations, we may transfer, process and store B2B Partner information with our affiliates and suppliers in countries outside of your country of residence.
8.2. To continue providing our Services, we may need to disclose information to recipients in other jurisdictions, including to our related entities, suppliers, or third-party service providers. To the extent that such a disclosure includes the personal information of our B2B Partners in the EEA, we implement adequate or appropriate safeguards to ensure it is adequately protected.
8.3. In dealing with transfers from the EEA to countries that the European Commission has not approved, we will rely on the EU Commission-approved Standard Contractual Clauses (SCCs) and the need to process your personal information to provide the Services to safeguard the transfer of your personal information. The SCCs form part of our Data Protection Terms with our B2B Partners.
9. YOUR RIGHTS
9.1. We want to assure you that you have control over the information you choose to provide to us. Subject to certain exemptions and depending on the applicable data protection laws (including, in some cases, upon our legal basis for processing your information), you have several rights over your personal information. Below is a summary of these rights and how you can exercise them:
• You have the right to be informed of how we collect and handle your information, as we seek to do in this Privacy Policy.
• You have the right to request access to the information that we hold about you.
• You may have the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly used, machine-readable format in certain circumstances (where we are processing this information on the basis of your consent, or where the processing is conducted based on a contract).
• You have the right to request we correct any personal information we hold about you if you think it is incorrect, or incomplete.
• In certain circumstances, you may have the right to ask us to limit or cease our processing of the personal information we hold about you, e.g. if you contest the accuracy of the data.
• You may have the right to object to our processing of your personal information when such processing is based on our legitimate interests. Before using your personal information for our legitimate interests, we balance these interests against your rights and freedoms; however, if you consider that you have grounds to object to this, you can explain this to us, and we will review your request.
• In cases where we process your personal information based on your consent, you can withdraw your consent at any time by contacting us. This does not affect the legality of any processing before you withdraw your consent.
• If you have unresolved concerns, you also have the right to complain about us to the relevant data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Please note that, notwithstanding the rights listed above, we reserve the right to retain certain information for our record-keeping purposes, and to defend ourselves against any legal claims.
9.2. You can exercise your rights anytime by contacting us using the details in the "Contact Us" section below.
9.3. We will respond within 30 days of receipt when you make such requests. Suppose there is a delay or dispute as to whether we have the right to continue using your personal information. In that case, we will restrict any further use of your data until the request is honoured or the dispute is resolved. We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested by you. We reserve the right to charge a fee when the law permits (for example, if your request is manifestly unfounded or excessive).
9.4. Your request and choices may be limited in some instances. For example, fulfilling your request would reveal information about another person or if you ask to delete information that we are permitted by law or have compelling legitimate interests to keep. You will not be discriminated against for having exercised your rights.
9.5. If you have unresolved concerns, you may also have the right to complain to a data protection authority in the country where you live, work, or feel your rights were infringed. A list of data protection authorities in the EEA can be found on the European Data Protection Board.
10. KEEPING YOUR PERSONAL INFORMATION SECURE
10.1. We use reasonable technical and organisational measures to secure the personal information we hold.
10.2. We use reputable data hosting service providers to host the information we collect. We take steps to ensure that any personal information we store with our data hosting service providers is adequately safeguarded (including contractual provisions, appropriate supervision and assessment where necessary).
10.3. We cannot guarantee the security of any information or data you provide online. If a severe security incident involving your personal information, we will notify you and report the incident to the relevant authorities as required by applicable law.
11. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
11.1. Information we collect from our B2B Partners will be retained for the duration of our contractual relationship, and for a reasonable period thereafter. We retain this information as reasonably necessary to:
• maintain our business records (for analysis, security, tax and/or audit purposes);
• handle any complaints or disputes regarding the Services;
• comply with our legal obligations and protect or defend our legal rights;
• enforce our contractual obligations and agreements; and
• support our business operations and continue to develop and improve our Services.
11.2. Where we retain information for Service improvement and development, we take steps to eliminate identifiable information. We only use the information to uncover collective insights about our Services, not to analyse personal characteristics specifically.
11.3. We retain information about your marketing preferences for a reasonable period from the date you last expressed interest in our Services, such as when you prior opened an email from us or ceased using the Services. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.
11.4. Once personal information is no longer needed to fulfil the purpose for which it was collected, we will take reasonable steps to securely destroy or de-identify that information unless we are prevented from doing so by law. Suppose destruction or de-identification is impossible (for example, because the information has been stored in backup archives). In that case, we will securely store your information and isolate it from further use until secure deletion is possible.
12. HOW TO COMPLAIN
12.1. We hope we can resolve any query or concern you may raise about our use of your information. GDPR also gives you the right to complain to a supervisory authority, particularly in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
13. MANAGE COOKIES
13.1. You can find more information about our use of cookies, and how you can manage cookies, in our Cookie Policy (https://www.travelgo.tech/cookie-policy).
14. CHANGES TO THIS PRIVACY POLICY
14.1. We may change this Privacy Policy from time to time. We will post any changes on this page, and if the changes are significant, we will notify you by emailing you. We encourage you to review this Privacy Policy whenever you use the Services to stay informed about our information practices and how you can help protect your privacy. If you disagree with any changes to this Policy, you will need to stop using the Services.
15.CONTACT US
15.1. Don't hesitate to contact us by post or email if you have any questions about this Privacy Policy or the information we hold about you.
By post: TravelGo OÜ, 11415, Valukoja tn 8-110, Estonia,Tallin.
By email: info@travelgo.tech.