Privacy Policy - Smart Travel

Last date of revision: 23/10/2018

WHO DOES THIS PRIVACY STATEMENT APPLY TO?

This Privacy Statement applies to

Smart Travel - Gent

Smart Travel bvba

9000 Gent, Keizer Leopoldstraat 1C

0876.347.785

Smart Travel nv is part of the international group UNIGLOBE Travel, a worldwide specialist in (business) traveling and the world's biggest independent travel organisation. Uniglobe Travel is worldwide active through a franchise network in more than 60 countries. Belux Travel provides services both to private individuals (‘business-to-consumer’ model) and companies (‘business-to-business’ model).

Smart Travel nv is active in the Belux (Belgium and Luxemburg). The Belux Market is operated through on the one hand the coordinating organisation of Belux Travel nv and on the other hand a franchise network consisting of travel agencies, who are all located in Belgium.

All these travel agencies ("the Travel Agencies") and Belux Travel nv are separate and independent legal entities. Depending on the processing activity in the context of which your personal data are processed, they may be qualified as a separate data controller or a joint data controller with one or more of the other Travel Agencies or Belux Travel nv. The Travel Agencies and Belux Travel nv don't have any liability for the other entities' acts or omissions.

Belux Travel nv and the Travel Agencies ("We" or "Belux Travel") want to be a great and careful company. We endeavour to protect and process the personal data that are entrusted to us in an open and transparent manner, in particular with respect of the applicable law and especially the General Data Protection Regulation 2016/679 from 27 April 2016 ("GDPR").

WHAT IS COVERED BY THIS PRIVACY STATEMENT?

With this Privacy Statement we would like to inform you about why and how we process your personal data as data controller when we perform our activities or when you use this website and the forms and applications on it, who we give this information to, what your rights are and who you can contact for more information.

When we refer to “the Site”, we mean the webpages commencing with the following URL: smarttravel.uniglobe.be(with www) https://www.uniglobe.be/smarttravel-gent uniglobesmarttravel.be smarttravel.be

The Site may include links to other websites. Whilst we try to only provide links to sites that share our high standards concerning data protection, we are not responsible for the content and the policy concerning data protection of these websites. This Privacy Statement only concerns data collected by Belux Travel.

When clicking on links on the Site, we strongly recommend you to first read the Privacy Statement on the relevant websites before disclosing any personal data.

Be aware that when you visit our pages on Facebook or on Instagram, whether or not via the link on our website, cookies are being processed by Facebook respectively Instagram. Based on that, we can obtain more information - in a completely anonymous way - about the public who visits our social media pages. For more information about why and how personal data are processed in that framework, we refer to the Privacy Policy and the Cookie Policy on the website of these platforms:

Cookie Policy Facebook: https://www.facebook.com/policies/cookies/

Cookie Policy Instagram: https://help.instagram.com/1896641480634370

For which purposes do we process personal data

WEBSITE VISITORS

We process your personal data for legitimate business reasons. These purposes include, but are not limited to:

- the good organisation of our services;

- dealing with enquiries, requests and complaints transmitted through online forms (the contact form etc.);

- gathering statistics about the use of this Site;

- improving the performance and design of this Site.

(POTENTIAL) TRAVELERS

We process your personal data for legitimate business reasons. These purposes include, but are not limited to:

- customer management;

- order and supply management;

- invoicing and accounting;

- the provision of information on traveling, through personalised messages, newsletters or travel alerts;

- the good organisation of the trips;

- booking of flights, hotels, cars, and other reservations in your name;

- taking out of travel insurances in your name;

- managing your preferences and making a profile;

- obtaining credit card data or other financial specifics for payment;

- producing reports for suppliers of services in connection with the trips;

- producing reports on business trips for your employer, with details about the destinations you have travelled to, the costs, the class of services, the hotels and the duration of the stay, the used car rental companies and the duration of the rent;

- dealing with enquiries, requests and complaints;

- dispute management;

- public relations;

- direct marketing;

- statistics and market research;

- security;

- logistics;

- respecting legal obligations.

(CONTACTS AT) CUSTOMERS, SUPPLIERS, BUSINESS CONTACTS OR ANY OTHER PERSONS WHOSE PERSONAL DATA ARE PROCESSED IN THE CONTEXT OF OUR BUSINESS ACTIVITIES

We process your personal data for legitimate business reasons. These purposes include, but are not limited to:

- customer and supplier management and management of business contacts;

- order and supply management;

- invoicing and accounting;

- the provision of information on traveling, through personalised messages, newsletters or travel alerts;

- booking of flights, hotels, cars, and other reservations in your name;

- taking out of travel insurances in your name;

- the good organisation of the trips;

- producing reports for suppliers of services in connection with the trips;

- dealing with enquiries, requests and complaints;

- dispute management;

- public relations;

- direct marketing;

- statistics and market research;

- security;

- logistics;

- respecting legal obligations.

APPLICANTS

The purpose for processing your personal data is to register your application for an employment in our company, and, if this application leads to start our selection procedure, make a profile of you, meaning that we will process all the necessary data that is required for us to assess your job application in view of a potential recruitment. This assessment can also include an assessment by a third party.

In case of positive assessment and decision to hire, we will also process your personal data to prepare an employment contract.

In case of a decision not to hire you, we will retain your personal data for a period of time as well, in particular in order to be able to contact you if any future job opportunities would match your profile and to be able to defend us in the framework of any disputes.

Finally, your data can be processed in the framework of our security policy and respecting our legal obligations.

What are the legal grounds for processing your personal data?

WEBSITE VISITORS

When you contact us through the online contact from, your personal data will in principle be processed for the purpose of our legitimate interests (namely the importance to treat your questions, requests and complaints in the best possible manner).

In this respect, we will always determine case by case whether our interests are not overridden by your interests, fundamental rights and freedoms. If you want more information about this, you can always contact us.

(POTENTIAL) TRAVELERS AND (CONTACTS AT) CUSTOMERS, SUPPLIERS, BUSINESS CONTACTS OR ANY OTHER PERSONS WHOSE PERSONAL DATA ARE PROCESSED IN THE CONTEXT OF OUR BUSINESS ACTIVITIES

We process your personal data for the abovementioned purposes:

- when necessary for the conclusion and the performance of contracts to which you are party, including (but not limited to) accounting, invoicing, making bookings and reservations and provision of all other services in the framework of the organisation of the trips;

- when necessary for compliance with our legal obligations;

- for the purposes of the legitimate interest of our company and/or of a third party, including (but not limited to) the smooth progress of our business activities and the organisation of the trips, client management, supplier management, etc. and after balancing the interests. If you want more information about this, you can always contact us.

If we have the legal obligation to obtain your free, informed, specific and unambiguous consent to process your personal data for certain purposes (e.g. market research activities or sending a newsletter), we will only process your data for such purposes to the extent that we have obtained such consent from you.

APPLICANTS

The processing of your personal data is necessary in order to take steps prior to entering into an employment contract and is in our legitimate interests, i.e. the interest to assess you before deciding on making an offer of employment, which is, according to us, also in your interest (or in any case this does not override our interests). Retaining your data for a period of time in order to contact you in case of any future opportunities is also in our legitimate interests.

WHICH RIGHTS DO YOU HAVE?

You have several rights concerning the personal data we process about you. In particular, you have the right to:

- access your personal data and receive a copy of them;

- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;

- ask that we delete your personal data, or restrict the way in which we use such data, if you believe that there is no (longer a) lawful ground for us to process it;

- withdraw your consent to our processing of your personal data (to the extent such processing is based on your consent);

- restriction on data processing, if you would contest the processing or the correctness of the processed personal data, or if you wish to keep certain personal data in view of a possible legal claim, while Travel Belux no longer need the personal data for the purposes mentioned in this Privacy Statement;

- receive your personal data, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or the performance of a contract);

- object to our processing of your personal data for which we use legitimate interest as a legal basis, in which case we will cease the processing unless we have compelling legitimate grounds for the processing.

In order to exercise the above rights, you can email us at gdpr@uniglobetravel.be.

Your request must include sufficient information to enable us to identify you, and must be sufficiently specific with regard to the right you want to exercise and the requested information.

You may also use these contact details if you wish to make a complaint to us relating to the processing of personal data.

If you are unhappy with the way we handle your personal data, you have the right to file a complaint with the Data Protection Authority (In Belgium: Drukpersstraat 35, 1000 Brussel, tel +32 (0)2 274 48 00, email contact@apd-gba.be).

HOW DO WE OBTAIN YOUR PERSONAL DATA?

WEBSITE VISITORS

We may obtain personal data about you when you use the Site and the applications offered on it.

The Site can also use cookies to gather statistics about the visits to this Site in order to improve its performance and design. For more information about the cookies we use and how you can control them, please consult the cookie section.

We may obtain personal data about you in the framework of the execution of our activities and the organisation of trips.

We will mainly obtain such personal data because you give them to us (e.g. when you request information, book a trip, fill in a profile sheet or the profile tool).

Further we may also obtain your personal data because others give these to us, e.g.:

- airlines, hotels, car rental companies or other service providers in the framework of traveling;

- a family member, your employer or an authorized representative when this person requests information, books a trip for you or represents you in any other way;

- etc.

Finally, we may also obtain personal data because they are publicly available or by the way you interact with us or data about you can also be generated by us (e.g. camera surveillance records).

When we obtain your personal data from external parties, we make reasonable efforts to enter into contractual clauses with these parties obliging them to respect the data protection legislation. This can be done by obliging this party to provide you with all necessary information or - if necessary - to obtain your consent for processing the personal data as described in this Privacy Statement.

(CONTACTS AT) CUSTOMERS, SUPPLIERS, BUSINESS CONTACTS OR ANY OTHER PERSONS WHOSE PERSONAL DATA ARE PROCESSED IN THE CONTEXT OF OUR BUSINESS ACTIVITIES

We may obtain personal data about you in the framework of the execution of our activities.

We may obtain such personal data because you give them to us (e.g. via the Site, by contacting us, by handing over your business card, by registering for our newsletter, etc.), because others give them to us (e.g. your employer or service providers we rely on in the framework of our activities), or because they are publicly available.

We may further also obtain personal data from you by the way you interact with us or data about you may also be generated by us (e.g. camera surveillance records).

When we obtain personal data from external parties, we make reasonable efforts to enter into contractual clauses with these parties obliging them to respect the data protection legislation. This can be done by obliging this party to provide you with all necessary information or - if necessary - to obtain your consent for processing the personal data as described in this Privacy Statement.

APPLICANTS

We obtain your personal data because you give them to us, or because these are transferred by an other entity of our group.

We may further also obtain personal data from you by the way you interact with us or data about you may also be generated by us (e.g. camera surveillance records).

WHICH PERSONAL DATA DO WE COLLECT?

WEBSITE VISITORS

The main personal data which we collect via the Site, relate to the contact form. Via the Site you can contact us to obtain more information, to ask questions or to receive advice. In this context, we process the following data: your name, your company, your e-mail address, your phone number, your city and your message.

The Site may also use cookies to gather statistics about the visits to the Site in order to improve its performance and design. For more information about the cookies we use and how you can control them, please consult the cookie section.

(POTENTIAL) TRAVELERS AND (CONTACTS AT) CUSTOMERS, SUPPLIERS, BUSINESS CONTACTS OR ANY OTHER PERSONS WHOSE PERSONAL DATA ARE PROCESSED IN THE CONTEXT OF OUR BUSINESS ACTIVITIES

The personal data that we collect may, among other things, include:

- standard identification data and contact details (e.g. name, address (private/work), phone number (private/work), email address (private / work);

- personal characteristics (e.g. age, gender, date of birth, place of birth, nationality, language, national identification number, pass port number,...);

- the data that you filled in or filled in on behalf of you in the profile sheet or via the profile tool (data concerning health, travel preferences, meal preferences, frequent flyer and other membership numbers, ...);

- data concerning the trips you have booked (e.g. travel destinations and data,...);

- financial specifics (e.g. name of the holder of the payment card, bank account number, payment card number, expiry of the payment card, ...);

- employment data (e.g. your employer);

- data you transmitted via forms (e.g. contact forms) and all other possible services and communication channels we offer;

- data about the services you prefer;

- data about how you use our services;

- data you provide us with when you show interest in our trips and accompanying services;

- data about how you interact with us and other similar information;

- camera surveillance records when you visit one of our sites;

APPLICANTS

As mentioned above, you can apply via the application form on our website.

For the purposes of our recruitment and selection procedure, the processing of personal data may further include the following:

- standard data related to your identity (name(s), first name(s), address…);

- personal data (date and place of birth, nationality, gender, phone number, email address, hobbies and interests, …);

- your picture if you provide it to us voluntarily;

- data with regard to your professional experience (profile, data on previous employers, termination of last employments and work carried out, special projects, …), including reference checks if you have provided us with references in your CV;

- data with regard to your education (diploma’s, certificates, internships, special trainings,…)

- language skills;

- if applicable, whether or not you possess a work and/or residence permit for the European Economic Area (EEA);

- any other personal data that you present us with as part of your application, in your CV or motivation letter, related to the exercise of the role;

- digital assessment through the internet (social media presence), insofar as this presence is open for us to see;

- any other personal data (than mentioned above) that require processing by virtue of the law;

- camera surveillance records when you visit one of our sites.

You are not required to provide us with these data. However, not doing so might adversely affect your chances of being hired.

WHO MAY WE TRANSFER YOUR PERSONAL DATA TO?

We may transfer your personal data to third parties who we believe reasonably need access to these data with a view to the achievement of one or more purposes of the purposes mentioned above. This may include the following third parties:

- suppliers of services in the context of traveling (such as airlines, hotels, car rental companies,...)

- other Uniglobe offices in Belgium;

- external service providers we rely on for various business services, such as IT support, insurance, surveillance;

- our mother company Uniglobe,

- law enforcement and government authorities in accordance with the applicable legislation;

- external professional advisers (e.g. lawyers or consultants).

In the framework of the execution of our agreements and booking of trips for customers and travellers in countries outside the European Economic Area, data may be transferred to suppliers of services (airlines, hotels, car rental companies,...) located in the countries involved. If it does not concern a country that offers an equivalent level of protection, the transfer will take place on the basis of the execution of the agreement with or on behalf of the person involved (art. 49 (b) GDPR).

WHICH COOKIES DO WE USE AND HOW CAN YOU MANAGE THEM?

This Site uses Cookies. Cookies are small text files that are stored by your browser onto your computer or mobile device when you visit this Site.

You can find more information about cookies by visiting the following website: www.allaboutcookies.org.

The Site uses analytical cookies to gather statistics about your visit to this Site in order to improve its performance and design. They collect information about how many times you visit this Site, how long a visit takes, etc.

The analytical cookies on the Site are provided by Google Analytics from Google Inc. For more information about Google Analytic’s cookie practices, please click on this link: Google Analytics. Google will not use your IP address in combination with other data. To prevent the use of Google Analytics, you can always install the Google Analytics opt-out browser add-on.

Certain data may also be used to offer personalised advertisements through Google AdWords Remarketing or Google Tag Manager from Google Inc. When visiting this Site, you will be asked to accept the use of advertisement cookies via the cookie pop-up screen. You can easily accept or reject these cookies by clicking on “I agree” or “I do not agree”.

For more information about how Google uses cookies for personalised advertisements, please click on this link: Google advertising cookies. You can use Ads Settings to manage which Google advertisements you see and make use of the opt-out option.

You can enable, disable and/or delete cookies via your browser. The cookie settings are usually found in the “options” or “settings” menu of your browser. In order to understand these settings, the following links may be helpful. You can also always use the “Help” option in your internet browser for more information:

- Cookie settings in Internet Explorer

- Cookie settings in Firefox

- Cookie settings in Chrome

- Cookie settings in Safari

ARE YOUR PERSONAL DATA PROTECTED?

We employ strict technical and organizational (security) measures to protect your personal data from access by unauthorized persons, against unlawful processing, abuse, damage, loss and destruction, both online and offline.

We pay special attention to the protection of the data concerning payment and your payment cards (such as the name of the cardholder, your payment card number, the expiry date of your payment card and the service number). We respect within this framework the requirements of the ‘Payment Card Industry Data Security Standards’ (PCI DSS), a global standard with regard to security of data in order to protect confidential information concerning payment cards against theft. The compliance with these rules was certified by the Europe DSS Wizard Tool of Trustwave.

The technical and organization (security) measures include among others:

- instructions and training to relevant staff to ensure they are aware of our data protection obligations when they are handling personal data;

- organizational and technical restriction of the access to personal data on a strictly ‘need to know’ basis, and monitoring thereof;

- technological security measures and network security, including passwords, fire walls, anti-virus software and encryption;

- physical security measures, such as locked closets and alarm systems.

Although we take appropriate security measures once we have received your personal data, the transmission of data especially over the internet (including by email) is never completely secure. We endeavour to protect your personal data, but we can never fully guarantee the security of the personal data transmitted to us or by us.

We limit access to your personal data to people who we believe reasonably need to come into contact with that information in order to carry out their jobs.

In the event of a personal data breach, despite these measures, we will take all steps reasonably necessary in accordance with the GDPR.

How long will your personal data be retained?

WEBSITE VISITORS

Your personal data will not be retained longer than necessary for the purposes described above.

As a general rule, personal data obtained through the contact forms on our websites are stored for a period of 5 years.

Personal data processed for direct marketing purposes, for example for our newsletters, are in principle stored for a period of 3 years as from the last contact with the individual concerned.

Depending on the specific situation, we may however retain your personal data for a longer period. This will in particular be the case if any of the following periods is longer : (i) as long as is necessary for the involved activity or service; (ii) any retention period that is required by law; or (iii) the end of the period in which litigation or investigations might arise.

(POTENTIAL) TRAVELERS AND (CONTACTS AT) CUSTOMERS, SUPPLIERS, BUSINESS CONTACTS OR ANY OTHER PERSONS WHOSE PERSONAL DATA ARE PROCESSED IN THE CONTEXT OF OUR BUSINESS ACTIVITIES

As a general rule, the personal data processed in the framework of the sale and the use of our services are stored for a period of 10 years as of the end of the contractual relationship (including after-sales services).

Personal data processed for direct marketing purposes, for example for our news letters, are in principle stored for a period of 3 years as from the last contact with the individual concerned.

Email traffic is in principle stored for a period of 15 years on our server and back-ups during a period of 15 years. Camera surveillance records are stored for a period of 30 days unless the images serve as evidence in (judiciary or criminal) proceedings because irregularities have been detected on the images.

APPLICANTS

We will only hold your personal data for as long as it is necessary for the purposes mentioned above. In case the recruitment does not result in an employment relationship, your personal data will be retained for a maximum period of 5 years after the end of the job application procedure for the purposes described above.

Are your personal data used for automated decision-making?

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

As a rule, your personal data will not be used for automated decision-making. We do not base any decisions about you solely on automated processing of your personal data.

How to contact us?

If you have any questions about this Privacy Statement and this Site in general, you can contact us by emailing us at gdpr@uniglobetravel.be.

CHANGES TO THIS PRIVACY STATEMENT

We may modify this Privacy Statement from time to time. To let you know when we have revised the Privacy Statement for the last time, we will amend the revision date at the top of this page for each modification. The modified Privacy Statement will then be applicable as from this date.

Please frequently consult this page in order to be informed of changes and additions. If we would dispose of your email address, we will also inform you electronically about all changes to this Privacy Statement.