Privacy Policy

Privacy Policy

 

The purpose of this Privacy Policy is committed to protect and respecting personal date of Natural Person and person data we are receiving from Legal Person .

 

PURPOSE OF THE PERSONAL DATA PROCESSING

 

– To provide services related to tourism

– Identification of the Natural Person

– Support with visa and insurance

–  Implementation of the travel services agreement

– Keeping of accounting documents

– Claims Handling

– Provision of information to state and municipal authorities in cases specified in regulatory enactments

 

FROM WHOM WE MAY COLLET THE PERSONAL DATA (Controller and Processor and the Data Subject)

  • When we talk about Data Subjects and Personal Data in this Privacy Policy, we mean Personal Data which may identify you or which could be used to identify you such as your name and contact details, your travel arrangements and booking reference for example. In this Privacy Policy, references to the Data Subject as ‘you’ or ‘your’ means the Client Company (including its affiliates), its employees as well as NB DMC SIA employees.  Reference in this notice to ‘our’, ‘us’ or ‘we’ NB DMC SIA.
  • For the purposes of the General Data Protection Regulation (GDPR), NB DMC SIA will process your personal data on behalf of your employer.  Where travel or associated services are delivered to you as part of an arrangement between your employer and NB DMC SIA, then due our status as an agent, the relevant service provider will be responsible for the security of personal data it received and for compliance with applicable law. NB DMC SIA is not responsible for the acts or omissions of such service providers. The Data Subject’s employer is the Data Controller for these purposes. The Data Controller is the Client Company of SIA NB DMC, and NB DMC SIA in turn acts as the Processor of the Data Subject’s Personal Data. Pursuant to a written contract with the Data Controller, NB DMC SIA as Processor, will use the Personal Data of the Data Subject, provided by the Client Company, to facilitate travel arrangements for the Data Subject. It is this contract of service which forms the ‘Legal Basis’ for the processing of Personal Data carried out by NB DMC SIA.
  • For the purposes of the General Data Protection Regulation (GDPR), NB DMC SIA will process your personal data on behalf of Tour operator and Agency.  Where travel or associated services are delivered to you as part of an arrangement between your Tour operator or Agency and NB DMC SIA, then due our status as an Destination management company, the relevant service provider will be responsible for the security of personal data it received and for compliance with applicable law. NB DMC SIA is not responsible for the acts or omissions of such service providers. The Data Subject’s Tour operator or Agency is the Data Controller for these purposes. The Data Controller is the Client Company of SIA NB DMC, and NB DMC SIA in turn acts as the Processor of the Data Subject’s Personal Data. Pursuant to a written contract with the Data Controller, NB DMC SIA as Processor, will use the Personal Data of the Data Subject, provided by the Client Company, to facilitate travel arrangements for the Data Subject. It is this contract of service which forms the ‘Legal Basis’ for the processing of Personal Data carried out by NB DMC SIA.

 

  • There are circumstances where NB DMC SIA also become a Data Controller. If NB DMC SIA collects additional Personal Data directly from a Data Subject, NB DMC SIA will be acting under a ‘Legitimate Interest’ to legally process the data to facilitate travel arrangements for the Data Subject and to fulfil the contractual requirements for its Client Company. In circumstances where NB DMC SIA Direct collects Personal Data from the Data Subject, NB DMC SIA will obtain that Data Subject’s express consent. NB DMC SIA also acts as a Data Controller for any Personal Data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.

 

CATEGORIES OF THE PERSONAL DATA

The Personal Data we collect about you will only be the data specifically required to fulfil travel-related agreement. We are collecting following data:

  • name, surname
  • birth date or personal code
  • bank data
  • address and phone number, e mail when its reasonable
  • identification document number and nationality when its reasonable

 

PEROSNAL DATA RECEIVING CATEGORIES

–  Cooperation partners of NB DMC SIA related with provision of tourism services, for example: airline company, hotel, ferry or similar)

– 3th parties of whom NB DMC SIA  has concluded service contract such as information technology providers, accounting services, legal service providers, and similar

– institution,  law enforcement bodies;

– Employer of the person who travel if he is going on a business trip

– Employer of the NB DMC SIA who are responsible for the travel operations.

– other persons related with provision of services of SIA NB DMC and provision of company’s daily operation, incl. archiving, providers of hosting service

 

IN WHICH COUNTIRES DO WE PROCESS YOUR PERSONAL DATA

  • Personal data are processed in European Union/European Economic Area (EU/EEA), however, according to the services chosen by the Client they can be transferred and processed in countries outside EEA. Transfer and processing of personal data outside EU/EEA can take place if this has a legal ground, e.g. to perform a legal obligation, to conclude or perform a contract, or in accordance with Client’s consent and adequate safety measures are taken.

HOW WE PROTECT YOUR PERSONAL DATA

  • NB DMC SIA protects your Personal Data against unauthorised access, unlawful use, accidental loss, corruption or destruction.  We use technical measures such as password protection to protect your data. We also use operational measures to protect the data, for example by restricting access to only those in personnel who need to access your data.

Mindful of technological development, we keep these security measures under review and NB DMC SIA Direct may therefore need to implement adequate alternative technical and organisational measures.

 

YOUR RIGHTS

  • As a Data Subject you are entitled to know who has your Personal Data, what they are using it for, to see copies of all Personal Data held by NB DMC SIA to amend, correct or delete such data. You may also limit, restrict or object to the processing of your data.  In each case, the request must be in writing to NB DMC SIA Direct using the details below.
  • By providing personal data to us, you agree that this Privacy Policy will apply to how we handle your Personal Data.  Under certain circumstances, you have the right to withdraw your consent to our use of your Personal Data at any time.  However, please note that if you do not provide us with your Personal Data, or if you withdraw your consent this may result on an inability by NB DMC SIA to fulfil its contractual requirements to provide your travel arrangements or the level of service we are able to provide may be negatively impacted.

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).  NB DMC SIA cannot make bookings for you without this information.

 

COOCKIES

What is a cookie?

  • Cookies are text files containing small amount of the information which are downloading to your device when you are visit NB DMC SIA website. Cookies are useful because they allow to recognise your device, preferences and can be used to improve your online experience. You can find more information about cookies at abooutcookies.org

 

Contact of SIA NB DMC

info@nordicandbaltic.com