INTRODUCTION

This Privacy Policy outlines how BerliTravel uses personal data collected during the provision of the travel services we offer to you, the User, on our website, www.berlitravel.com (referred to hereafter as "the Site ").

We also explain our practices regarding the data we collect when you visit the Site, as well as when you interact with us through our collaborators’ and agencies’ Site.

Legal Applicability and Data Controller

The company responsible for controlling your personal data is BerliTravel Co LLC, with its registered office located at 3355 Lenox Rd NE, Atlanta, GA 30326. To contact the representative of the Data Controller, please send an email to: dpo@berlitravel.com

Mandatory Information and Age Restriction

• Failure to provide certain information marked as mandatory may make it impossible to manage your registration as a User or the use of certain tourist services available on the Site.
• In order to register as a User and browse the Site, you must be at least 18 years old. BerliTravel may use your personal information to verify your age and ensure compliance with this restriction.

For the purposes of applicable data protection laws, if the User resides in a member country of the  European Economic Area, the processing of their data and this Privacy Policy will be governed by the General Data Protection Regulation or Regulation (EU) 2016/679 (the "GDPR").

 Legal Basis for Data Processing

By using BerliTravel's services (whether for travel services, on the Site, or via our chatbot and/or app), you consent to the collection, use, and sharing of your personal information as described in this Privacy Policy.

The legal justifications for collecting and processing your personal data are primarily based on the following:

When you use the services provided by BerliTravel (including booking travel, browsing the Site, using the chatbot, or accessing the app), you agree to our policies regarding the collection, use, and sharing of your personal information as detailed here.

Our legal reasons for using your data:

• To provide the service: We process most of your data because it is necessary for the contract we are fulfilling with you (or the steps we take before that contract begins).
• To improve and market: We have a legitimate business interest in using your email or other provided information to send you relevant travel service offers, newsletters, and personalize our service to you, helping us grow and improve.
• When you say okay: For data gathered specifically through things like cookies or our chatbot, we will always ask for your permission first, as required by law.

Personal Information We Gather

By using Berlitrave's services, you provide us with various types of personal information, depending on your interaction with us:

• For Registration & Identification: To create an account and identify you as a User, we request your email address, full name, and province of residence.
• For Account Completion & Service Contracting: To finalize your User account and enable you to book our travel services and trips, we require additional details, including your nationality, home address, contact telephone number, and your email address (if different from the registration email).
• For Travel Package Booking: When you secure a specific travel package, we must collect essential travel documentation information, such as your full name, nationality, and passport number.
• For Financial Transactions: To process the payment for a booked trip, we collect necessary payment details, including your credit card or debit card number, expiration date, and security code. If you require a formal invoice, we will also request the relevant billing information

Information Collected from Your Use of Services 

When you interact with or use our Services, we automatically collect certain data to understand your preferences and improve our offerings:

Usage and Technical Data 

We record information related to your activity and technical environment, which includes:

• Frequency and Timing: How often, when (dates and times), and for how long you access BerliTravel's services.
• Interaction Data: When you view or click on specific content, as well as your saved preferences or general tourist interests.
• Technical Identifiers: We use login logs, monitor when you open our emails, and utilize your Internet Protocol ("IP") address to help identify you and track your service usage.

Third-Party Platforms

We may receive information about you from external platforms if you choose to register or log in via third-party services (such as Facebook or similar technologies). This data could include text, images, or other personal details you have made public or available on that external site.

Call Recording 

Please note that we provide a telephone number for direct contact. All calls may be recorded for the following purposes:

• Quality assurance and training.
• Providing information about our tourist services and addressing your specific requests.
• Facilitating the management, booking, and contracting of any travel packages you are interested in.

Here are a few ways to rewrite and reword the legal basis and chatbot data collection section, focusing on separation and clarity:

Legal Justification and Data Retention 

Legal Basis for Core Processing

The collection and processing of your personal data are necessary and justified by the contractual relationship that exists between you and BerliTravel. This legal relationship permits us to process your data to provide our services.

• Data Retention: We will retain your personal data for the entire duration that our service provision relationship is active and legally established.

Chatbot Data Collection

When you utilize our customer service chatbot, we may collect and process the information you share during the conversation. This can include your name, specific inquiries, travel preferences, and any other personal details you volunteer. This data is collected solely to allow us to assist you in a timely and personalized manner

How We Use Your Personal Data 

BerliTravel, acting as the Data Controller, utilizes your personal information exclusively for the following defined objectives:

• User Account Management: To facilitate your registration, verify your identity, and grant you access to the travel services and features available to you as a registered User.
• Contract Execution and Service Delivery: To manage, execute, and fully perform the agreement we have with you, specifically involving the contracting of trips through our suppliers. This purpose also covers addressing and resolving any subsequent requests, claims, or inquiries related to the services you have purchased.
• Essential Communication: To reach out to you via email with updates and important information regarding the platform's functionality, our product offerings, and necessary security notices, whenever such communication is essential or relevant to your continued use of our services.

Service Management, Analytics, and Other Uses 

We utilize your personal data for several operational and internal purposes:

Service Communication and Support

We will contact you via email or telephone to effectively manage the travel services you have booked or to respond promptly to requests and inquiries submitted through BerliTravel's customer service channels.

• Example: If a technical issue prevents you from finalizing a purchase, we may personally call or email you to provide assistance and complete your trip booking.

Internal Research and Aggregation

We process your information to create aggregated, non-identifiable data. This data is used solely for internal analysis and generating statistics about our operations, such as:

• Measuring the overall size and demographic distribution of our user base.
• Calculating the number of impressions or clicks a specific travel offer receives.

Recruitment and HR

We use collected data to manage the personnel selection processes we initiate and to efficiently handle the information provided by candidates seeking employment.

Automated Assistance

We leverage your information to deliver automated support through our chatbot. This includes:

• Answering general service-related questions.
• Assisting you directly within the booking workflow.
• Providing tailored travel suggestions that align with your previously indicated preferences.

Marketing, Analysis, and Your Choices 

Personalized Marketing

As an integral part of the BerliTravel service, we may use your personal information to send you tailored advertising regarding our offerings. This personalized marketing may be delivered via email or other electronic channels, either directly by us or through our trusted third-party partners.

Service Improvement and Profiling

To continuously enhance the quality of our service, we inform you that we may analyze your personal data related to your purchases, preferences, and interests. BerliTravel uses this data for:

• Internal analysis and market studies.
• Generating customer usage profiles.
• Conducting quality surveys.
• Improving the overall interaction experience with our customers.

Managing Your Communications

You have full control over the electronic communications you receive from us:

• Online Control: To stop receiving specific emails, simply navigate to the "Private Area" of your account, access the "My Subscriptions" section, and uncheck the items you wish to unsubscribe from.
• Direct Unsubscribe: Alternatively, you can always opt out of future communications by following the detailed instructions provided at the end of every marketing message.

Data Retention Period 

We will retain your personal data for the necessary duration of our active service relationship with you. Specifically, we keep your information for as long as the legal agreement for the provision of our services remains in force.

Who Receives Your Personal Data 

To achieve the purposes detailed in this Privacy Policy, it is necessary for us to share or disclose your personal data to the following categories of recipients:

1. Business Successors

We may transfer your information, including personal data, in the event of a business reorganization, merger, sale, restructuring, or other asset transfer. This disclosure will only occur provided that the receiving party explicitly commits to handling your personal information in a manner consistent with the protections outlined in this Privacy Policy.

2. Essential Service Providers and Travel Suppliers

We rely on external entities to help us deliver and improve our services to you. Data is shared with these providers for operational necessity:

• Add-onTravel Suppliers: We share data with the actual providers of the contracted trips so they can deliver the products and services you have purchased. Examples include airlines (for ticketing and operation), hotels, car rental agencies, tour guides, and tour operators.
• Operational and Support Providers: We also share data with companies that assist us with essential functions, such as:
  
  • Marketing, advertising, and communications.
  • Infrastructure and IT support.
  • Processing credit card and other payment transactions.
  • Customer service and debt collection.
  • Analyzing data to customize and optimize our service and conducting satisfaction surveys.

International Data Transfer

For service efficiency, these partners and providers may be located in countries or territories outside the (USA), including the United States. Please note that some of these locations may not offer a level of data protection equivalent to that of your home country or the European Union.

Consent to Transfers and Necessary Data

Express Authorization for International Transfers

By accepting this Privacy Policy, you explicitly authorize BerliTravel to process and share your personal data with the companies mentioned previously, and/or to transfer your data to our service providers located outside the (USA). This transfer is strictly for the purposes described herein and is essential for delivering our complete service.

When exchanging information across borders, particularly when transferring personal data to countries outside the USA or areas with strict data protection laws, we guarantee that the transfer adheres to the provisions of this Privacy Policy and is fully compliant with applicable data protection legislation.

Consent to Transfers and Necessary Data 

Express Authorization for International Transfers

By accepting this Privacy Policy, you explicitly authorize BerliTravel to process and share your personal data with the companies mentioned previously, and/or to transfer your data to our service providers located outside the USA. This transfer is strictly for the purposes described herein and is essential for delivering our complete service.

When exchanging information across borders, particularly when transferring personal data to countries outside the USA or areas with strict data protection laws, we guarantee that the transfer adheres to the provisions of this Privacy Policy and is fully compliant with applicable data protection legislation.

Data Collection Requirement

We only require the personal data necessary to enable the proper functioning of the BerliTravel Website and to successfully facilitate the tourist services you contract. Your data will not be made available to any third party not disclosed on the Website, unless you provide us with your express permission.

Member Referral ("Referral)

Users have the option to invite third parties to register as Members at www.BerliTravel.com by initiating a referral email. Any Member who utilizes this "referral" feature is solely responsible for confirming that they have obtained the necessary prior consent from the recipient to allow us to process and send the invitation. Furthermore, BerliTravel will inform the invited person of the identity of the Member who initiated the referral.

 Your Data Protection Rights 

As the Data Controller, we are committed to upholding the confidentiality of your personal information and ensuring you can exercise the rights afforded to you by law. You may exercise the following rights whenever you choose:

1. Right to Access

You possess the right to obtain confirmation as to whether we are processing your personal data. If we are, you may request a copy of that data along with comprehensive details regarding our processing activities.

2. Right to Rectification

You have the power to demand the correction of any errors in your data, to amend incomplete or inaccurate information, and to verify the accuracy of the personal details we are handling.

3. Request Deletion

You can request that your data be promptly removed if we are unlawfully processing it or if the reason we collected it in the first place is no longer valid.

4. Halt Processing

You can ask us to restrict the processing of your information if you are disputing its accuracy or if you believe our data handling is non-compliant with the law.

5. Say No to Uses

You may object to us using your data for direct marketing purposes. You can also object to other processing uses relevant to your personal situation, unless we have overriding legal reasons (legitimate interest) or need the data for legal action.

6. Automated Decision Protection

You have the right to demand that we do not make decisions about you that are based only on automated systems (like computer profiles) and which have a significant legal effect on your life. This only changes if you specifically consent, it's required for a contract, or it's allowed by law.

Submitting a Request to Exercise Your Rights

To exercise any of the data protection rights listed above (Access, Rectification, Erasure, Limitation, or Opposition), please use one of the contact methods below:

1. Email: Send an email to dpo@BerliTravel.com.
2. Physical Mail: 

Send a letter to: 

BerliTravel Co, LLC, 

3355 Lenox Rd NE, Atlanta, GA 30326..

In your communication, you must clearly specify two things:

• (i) Identity: Provide your full name and the email address you used to register with or purchase from BerliTravel.
• (ii) Rights: Clearly state the right or rights you wish to exercise.

If you believe your rights have not been respected, you may contact the Information Commissioner's Office at: https://www.usa.gov/privacyto request supervision of your rights

Cost of Exercise

The exercise of these rights is free of charge. However, if requests are deemed manifestly unfounded or excessive, we reserve the right to charge a reasonable fee to cover the administrative cost of processing your request.

Use of Cookies

We utilize cookies, which are small data files that store information about your activity while browsing this Platform. Their primary function is to enhance and simplify your navigation experience. For comprehensive details regarding the types of cookies we use, their purpose, and other relevant information, please refer to our dedicated Cookies Policy.

Policy Amendments

This Privacy Policy will be subject to updates periodically. We will make these revisions in response to evolving legal, regulatory, or internal operational necessities. When changes are made, we will notify you of the amendments (including the date they take effect) in compliance with all applicable laws.

‍

‍