At Across Europe, your right to privacy is of paramount importance to us. We are subject to certain data protection laws that govern how we collect, use, retain and disclose your personal data. We can assure you that every effort is made by us to ensure the security of your personal data and to keep you informed about why we collect your data, what we do with it, and how long we keep it for (among other things). We regularly review and, where necessary, update our privacy information.
About us and this policy (Privacy Policy):
Across Europe ltd., Registration address: 1715 Sofia, Mladost 4, bl. 435, entr. 3, floor 1, app. 64, BULSTAT: 131294992, VAT No.: BG 131294992 represented by Sirma Lechevalier and Joanna Kaymakchieva.
We are the data controller of the personal data, which we collect, use and process. We are required by the law to implement and maintain a privacy policy to inform our customers about the personal data we collect as part of ensuring and demonstrating how we comply with the law.
Accordingly, this Privacy Policy explains how we use the personal data we collect. It also explains each basis upon which we collect that data and the purpose(s) for which we use it, together with your associated rights. If you have any queries about how we handle your personal data under this Privacy Policy or otherwise, please contact us at the above address.
Categories of personal data we collect
This will depend upon the nature of your transaction with us. Usually we will collect data where you make a booking with us, but we may collect data in certain other scenarios, as set out below. In certain cases, providing particular information will be mandatory if you would like to take advantage of our services (such as a travel booking – see the section headed ‘Uses and legal grounds’ below). We will tell you where that is the case. We will also make clear where providing information is optional.
Direct Bookings
In the case of a direct booking, we will require your name, date of birth, postal address, telephone number and email address where you are the lead name for the booking, together with the names and dates of birth of any other party members.
If you are the lead name, please ensure you have the consent of the other members of your party to provide the above details to us and make them aware that this Privacy Policy is publicly available via our website (though please note that we will be processing each of your personal data in performing our contract with you – see the section headed ‘Uses and Legal Grounds’ below).
If you are a party to a group travel booking but are not the lead name, please note that we will have obtained your details from the lead name for your booking and we will process your personal data in accordance with this Privacy Policy.
Special category (or ‘sensitive’) personal data
We may also require certain sensitive information from you, regarding your health, dietary and /or access requirements for example in relation to any particular request you make with regard to your booking. We may also require sensitive information about you, which is relevant to any investigation we need to undertake in relation to any personal injury claim you make against our company in order to comply with our legal obligations.
Indirect bookings
In the case of an indirect booking (i.e., where you make a booking through a travel agent), we will only receive the names and dates of birth of the lead name and the other party members for that booking, to enable us to enable us to process the booking.
Types of data in the event of a dispute
In the event of a query and / or dispute, we may require more personal information from you (and the other members of your party) to assist us with our investigation. Please see the sections headed ‘International transfers’ and ‘Data sharing’ below for further information.
Uses and legal grounds
Core Uses
Depending on the nature and extent of your relationship with us, we will use your personal data for one or more of the purposes listed below:
- Bookings: In order to process and administer your travel booking, i.e. performing your holiday contract with us (see further detail in this section below).
- Marketing: In order to email you information about existing or new products and services similar to those you have received from us previously and/or that you have expressly confirmed you would like to receive from us (see further detail in this section below).
- [Advertising and behavior monitoring: please see the sections headed ‘Cookies’, ‘Google Analytics’ and ‘Website Retargeting’ below.]
We will always tell you in advance, where we require your personal data for any new purpose. Should that be the case, we will provide you with all relevant information and if appropriate seek your consent to the new purpose and processing.
Legal grounds
We make use of your data for the purposes set out above on the basis of one of the following legal grounds in relation to each purpose:
- Consent: With your clear, affirmative consent. Where we ask you to give your consent to any use we would like to make of your data, for example to enable us to provide you with holiday updates by email, as mentioned above, you will always be given the option to withdraw your consent at any time (which in the above example will involve unsubscribing from our marketing emails) and, in the event of your doing so, your withdrawal of consent will be recorded (and in the above example you will be removed from our mailing list).
- Legal obligation: In order to comply with any legal obligation, we may be subject to (for example, in order to comply with any court orders).
- Legitimate interests: Where we consider it in our legitimate interests to do so having carefully assessed and balanced our interests against your own interests, rights and freedoms.
- Vital interests: In order to protect your vital interests (likely to be relevant in an emergency only).
- Public interest: For reasons of substantial public interest (likely to be relevant in an emergency only).
Further detail: Bookings
Legal ground: performance of contract
In order to process your booking with us, keep you informed of any relevant information relating to it, and ensure that your travel arrangements run smoothly and meet your requirements, we need to collect and process certain personal details from you. As set out above, this will usually include the names and addresses of you and any other party members, and any particular health, dietary or access requirements.
International transfers
In processing your travel booking, we are obliged to pass certain information on to the relevant suppliers of your travel arrangements, such as airlines, hotels, transport companies etc. Some of these third parties may be outside the European Union and/or European Economic Area. While some countries have laws to protect personal data that are of a sufficiently similar standard to the GDPR, in other countries steps will need to be taken to ensure the appropriate level of protection is in place. These steps include, but are not limited to, appropriate contract clauses approved by the European Commission and appropriate security measures. We will ensure we comply with our own obligations to ensure your information is properly protected in this regard.
We will not however, pass any personal information (including any sensitive/’special category’ personal data) onto any persons that are not responsible for any part of your travel arrangements.
Further detail: Marketing
Legal ground: Your consent
From time to time, we may contact you with our newsletter, telling you about our latest holidays and/or special offers, which may be of interest to you. We will only contact you however where you have confirmed you would like to receive such updates, or where you have booked a previous holiday with us (or even enquired about our holidays and indicated that you would like to hear from us in this way). If we do contact you, you will always be given the option to unsubscribe from our mailing list and we will then arrange for your details to be removed.
Further detail: Cookies
Legal ground: Your consent & legitimate interests
Cookies may in some cases constitute personal data. You can find out more about cookies and how we use them on our Cookies page. Please also see the section below headed Website Retargeting.
Further detail: Google analytics
Legal ground: Your consent & legitimate interests
When you visit our website, we use a third-party service, Google Analytics, to gather standard internet log information and details of visitor behavior patterns. We do this to discover things such as the number of visitors to the different parts of our website. This information is only processed in a way, which does not identify anyone (i.e. it is anonymized so that it cannot be attributed to any particular individual). We do not make, and do not permit, Google to take any attempt to discover the identities of those visiting our website. If we want to accumulate personally identifiable information though our website, we will be transparent about it. We will make it apparent when we gather personal information and will explain what we plan to do with it.
Further detail: Website Retargeting
Legal ground: Your consent & legitimate interests
We use cookies or similar technologies to serve online advertising and to identify unique customers. We may work with advertising partners to deliver targeted advertising related to our holiday services. To facilitate targeted advertising, our third-party partners and we may utilize “cookies” (see our above “Cookies” policy) or equivalent identifiers and other audience matching technologies. We use data elements from our corporate marketing databases to assist us in presenting appropriate offers to our prospective clients.
Our advertising partners may place a pixel tag or cookie on certain pages of our website. This enables our partner companies to later display a relevant advertisement to you based on your website browsing behavior. This type of online, targeted advertising — known as “retargeting” — is used to re-engage consumers who previously visited a website. Certain information may be collected and shared with these partners, including what page you viewed, when you viewed it and whether you clicked on the advert (see our above policy on “Cookies”).
Further detail: Aggregated Data
Legal ground: Our legitimate interests
During your interaction with our website we collect data which relates to your use of our website, such as your internet protocol (IP) address, traffic data, weblogs and other communication data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Operation Data to calculate the percentage of users accessing a specific feature on our website. This data is collected to enable us to better understand the use of our website in order to improve the website user experience.
However, if we re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice. This is done to deliver more relevant marketing messages to website users who have shown legitimate interest in our products and services.
Data sharing
We will only share your personal data (including any sensitive information/special category data) with the travel service providers who are relevant to your booking, in order to meet your request(s), and will always do so in a secure manner. We also take steps to ensure that the travel service partners we work with will not share your data with any other party not connected with your booking, and will only retain it for as long as it is necessary to process your booking and /or request. We also take steps to ensure that they keep your data safe and secure whilst it is being processed. We do not sell your personal data to any third parties.
In the event of any complaint or dispute, we may need to share this data with other relevant parties, such as your hotel or airline to help us with our investigation. In the case of a serious dispute involving legal proceedings, we will need to share your data with and legal advisors in order to comply with legal obligations and to assist with the handling of the matter.
Complaints
We fully respect your right to privacy and take our responsibility for the collection of your personal information very seriously. We make every effort to ensure that your personal information is kept secure and is only used for the purpose for which it is collected. We will also only retain your data for as long as it is necessary and in accordance with the basis upon which it was collected. In the case of a complaint or a claim, we may need to retain your data for up to 5 years in order to comply with any of our legal obligations.
In the unlikely event that you have a complaint about the information which we collect about you, please write to us on office@across-europe.net.
Your Rights
Under the GDPR you have the following rights (although these rights may not apply to all circumstances):
- The right to be informed about our processing of your personal data (which we aim to give full effect to through this Privacy Policy)
- The right to have the personal data which we collect on you corrected if it is inaccurate, or completed where it is incomplete
- As set out above, the right to withdraw your consent or explicit consent (in the case of special category personal data) to our use of your data on that basis
- The right to object to the processing of your personal data in certain circumstances
- The right to restrict the processing of your personal data in certain circumstances
- The right to have to have your personal data erased in certain circumstances (i.e. the so-called “right to be forgotten”)
- The right to request access to your personal data and information about how we process it. Although this access request is free, please note that if your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee based on our administrative costs.
- The right to transfer your data (i.e. the right to “data portability”)
- Rights with regard to automatic decision making, including profiling
POLICY / INFORMATION ABOUT COOKIES
In order to ensure that you receive the most appropriate information and best services when you visit https://across-europe.net, the information and data will be collected by using the so-called “cookies”.
This helps us (and also other authorized third parties) to provide you with a personalized experience when you visit our Website. In addition, it also allows us to improve our services and make sure you can easily find what you are looking for.
We would like you to understand the manner in which we use these technologies, and therefore, this Cookie Policy clarifies the types of technologies that we use, what they do as well as your choice regarding their use.
What are cookies?
Cookies are small data units that are sent to your browser from a web server and stored on your device so that the Website can recognize your computer.
There are two kinds of cookies – permanent and temporary or “session” cookies.
Permanent cookies are stored as a file on your computer or mobile device for a long time.
Session cookies are temporarily placed on your computer when you visit our Website but they disappear when you close the page, which means that they are not permanently stored on your device.
Most companies use cookies on their websites to improve usability. Cookies cannot harm your files or increase the risk of viruses on your computer.
We and our service providers may use the following types of cookies:
Essential cookies.
These cookies are strictly necessary for our Website to perform its functions. We use these cookies for instance:
• in order to establish the authenticity and identity of our Users and when they use our Website so as to be able to provide our services;
• in order to be able to comply with our Terms and Conditions and maintain the security of our services.
Performance and functionality cookies:
These cookies are not strictly necessary, and yet they allow us to personalize your online experience on our Website. We use these cookies for instance:
• to memorize your preferences so that you do not need to enter information every time (for example, when you enter your data to access our services or when you use an inquiry form);
• to collect information about the way in which our Users use our services so that we can improve our Website and our Services and conduct market research (for instance: information about popular pages, viewing habits, number of clicks, number of shares, number of likes of a particular page, last visited pages, etc.)
Advertising cookies.
We use these cookies for instance:
• to obtain information about the way in which you use our Website, such as pages that you visit or how you respond to ads, in order to provide you with ads that are tailored to you;
• to determine which are the most popular sections of our Website;
• to follow up the use of our services and our Website (frequency and time);
• to monitor the success of a specific product / service;
• to determine how often you and the rest of the Users are visiting our Website;
• to conduct surveys so that your interaction with our Website and ourselves could be improved.
Frequently these cookies aim to deliver ads that are appropriate for you – both on our Website and beyond. These types of ads are known as “interest-based advertising.” Many of these types of cookies belong to our service providers.
Session cookies
We may also use session cookies, for instance:
• to let you navigate between the individual pages on our Website. This practice is known as “single sign-on”;
• to recognize you when you return to our Website to use our services;
How do we use cookies?
We use the information from the cookies in order to make our Website more enjoyable and user-friendly and in order to be able to provide you with personalized recommendations.
Third party cookies:
In addition, we use third-party cookies as part of our services. These cookies are managed by the respective Website and are not controlled on our part. Below are third-party cookies we use, some of which can be turned off byusing the general settings of your browser. For others, you need to visit the relevant Website and follow the provided instructions.
• Google Analytics – to generate Website traffic statistics and traffic sources.
• Social networking sites – Facebook, LinkedIn, etc .
• Communication systems.
• E-mail sending systems.
• Ad serving systems.
How to delete cookies?
You may by yourself choose whether to accept the cookies or not. If you want to know when your computer receives a cookie, you may set your browser so as to receive notification thereof. Thus you will have the opportunity to accept or reject a cookie. Your computer may be set to reject all cookies. If you want to know how to do this, visit aboutcookies.org. Please note that changes to your browser that disable the cookies’ functionality will prevent some parts of our Website from functioning properly.
Further information about your browser and cookies:
How to turn on cookies: https://www.whatismybrowser.com/guides/how-to-enable-cookies/
How to turn off cookies: https://www.whatismybrowser.com/guides/how-to-clear-cookies-browsing-history-and-cache/
Changes in our policy on cookies.
All future changes to our Cookie Policy will be posted on this page. If necessary, we will notify you of any possible changes via email in compliance with the General Terms and Conditions.
Across Europe ltd may not be held liable if the User has not read the latest version of these General Terms and Conditions.
The authorities for alternative dispute resolution within the meaning of Art. 181m, para. 4 of the Consumer Protection Act are the Conciliation Commissions at the Commission for Consumer Protection.
We would be pleased to accept any questions, comments and requests related to this Cookie Policy. Please send them to office@across-europe.net
Across Europe ltd has the right to change the technology and design of the Services being provided without prior notice.
Given the international nature of the Internet and the fact that across-europe.net is connected to that network, we does not guarantee that the information flow to and from across-europe.net will not be tracked and recorded by third parties.
Across Europe ltd manages this Website from its office in Bulgaria.
These general terms and conditions may be updated at any time, without explicit notification of the Users.
Across Europe ltd. may not be held liable if the User has not read the latest version of these general terms and conditions.
When using the services of Across Europe ltd., the customers commits to observe these general terms and conditions, as well as any other conditions set forth under the legislation of the Republic of Bulgaria and international law, even if these have not been expressly mentioned in these general terms and conditions.
THE USER HEREBY AGREES TO THE TERMS AND CONDITIONS, BY CLICKING ON EACH SINGLE OBJECT, LINK OR TAB WITHIN THE WEBSITE https://across-europe.net (WITH THE EXCEPTION OF THE LINK TO THESE GENERAL TERMS AND CONDITIONS), IT SHALL BE DEEMED THAT S/HE IS AWARE OF THE TERMS AND CONDITIONS, ACCEPTS SAME AND COMMITS TO COMPLY THEREWITH.