Privacy Policy
Smart Travel OÜ Privacy policy

1. Preface
a) Smart Travel OÜ is a provider of travel and tourism services. The personal data received are used for the daily activities in order to provide the user with the requested services and information.
While doing this we comply with the General Data Protection Regulation (GDPR-directive EU 2016/679) and the Estonian Personal Data Protection Act (PDPA).
With this privacy policy we wish to inform the user about the purposes and the methods of the processing the personal data provided by the user through the website www.smarttravel.ee and concerning the protection of natural persons with regard to the processing of personal data, as well as the free circulation of such data.

b) Smart Travel OÜ assumes that the user is informed and care about the use of his/her personal data and we guarantee that Smart Travel OÜ strictly follows the regulations about the usage and processing of the user data.

2. Owner of data usage
Smart Travel OÜ, Jaaniku 6 12013, Tallinn-Estonia

3. Data collecting sources

The user data are collected by Smart Travel via the following sources:

-Comment of contents on Smart Travel’s Facebook social media
Personal data: name and facebook ID

-Contact of user/contact form
Personal data: email and name

-Statistics / Google Analytics
Personal data: usage data

-Personal data can also be supplied freely directly from the user

Smart Travel does not provide newsletter services and direct marketing services and the Smart Travel’s website does not use Google Adsense, therefore there are not user data collected via these channels/sources.

4. Collection of and use of personal data

4.1 Source: Comment of contents on Smart Travel’s Facebook social media and website
a)The comment services allow the user to formulate and make public his/her comments regarding the content and posts published in the Smart Travel’s Facebook media.
In case, among the personal data provided by the user, there is an email, this can be used to send notifications of comments regarding the same content or post. The user is responsible for the content of his/her comments. If the user get in contact with Smart Travel in order to get travel information or travel quotations, the article 4.2 of this privacy policy applies.

b)Our website www.smarttravel.ee and Facebook media channel collect data automatically. The collected data may include the browser used by the user, the IP address, the location of the user computer and other user data. Smart Travel utilizes these data to improve the online environment.

4.2 Source: website contact form and freely direct contact
a)By filling out the contact form with his/her data, the user agrees to their use in order to receive from Smart Travel information, quotation, or any other kind of information specified in the contact form.

b)Smart Travel OÜ is a provider of travel and tourism services and the data collected are mainly coming from its customers. The personal data received are used exclusively for the daily activities in order to provide the user with the requested travel services and information.
The provision of the user personal data is mandatory for this purpose. The user refusal of submitting the data will entail the impossibility for Smart Travel to follow up the user request.
The treatment of the data, in order to achieve this purpose, does not require the consent of the user since the legal basis for the treatment, according to the current legislation, consists in the fulfillment of a request formulated by the user.
In any case, the user personal data will be processed until the end of the journey/travel services and, beyond that date, they will be kept exclusively for the period of time necessary to comply with the current legislation (including the provisions for the prescription of rights).
Smart Travel is an intermediary of services and co-operate with tourism operators partners like hotels, restaurant, tourism guides, coach/bus/train/ferry companies etc and tour operators partners. Therefore, in order to process the services to the user following his/her request, Smart Travel has to share personal data information with its partners (tourism operators and tour operators).
We trust that our service providers partners process the user personal data in accordance with the GDPR. Each party involved in the provision of the service is allowed to use the user personal data solely for the purpose of providing the tourism service.
We do not sell user personal data to or share them with third parties, except those that we need to share them with in accordance with the law or for the purpose of performance of the services requested by and provided to the user.

c)As a Tour Operator and travel services provider, Smart Travel offer a large portfolio of tourism/travel services including: accommodation, transfers, coach tours, restaurant booking, bus/train/ferry trips, guides services, entrance to tourism sites ect. The services are provided within the European Union but also outside the European Union.
In order to provide the travel services following the user request, Smart Travel might collect several user personal data like: email, name, gender, date of birth, telephone number, passport/ID document number and expiry date, residence address, food allergies and intolerances. The list of personal data may vary depending on requirements established in different countries and on the type of tourism service required.

d)Following the provision of the services, Smart Travel has the right to send a feedback e-mail message to the user when the user has purchased services from Smart Travel or asked for an offer regarding a service. Smart Travel sends feedback e-mail messages only to identify service problems or issues and with the purpose to improve its services. If there is a natural disaster or an emergency situation, Smart Travel has also the right to contact the user to make sure that the user is doing fine and check if any assistance is needed.

e)Smart Travel is a company located in Estonia, a member of the European Union. Most of the user data we collect are mainly treated within the European Union. If, in order to provide a tourism service, Smart Travel has to supply the user data outside the European Union, we inform the user that we do not have any power to guarantee that the treatment of the personal data will comply with the EU GDPR regulations.

4.3 Source: Statistics / Google Analytics
The services contained in this channel allow Smart Travel to monitor and analyze the traffic data and are used to keep track of the user behavior.
Google Analytics is a web analytics service provided by Google Inc.. Google uses the collected personal data for the purpose of evaluating the use of Smart Travel website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to insert and personalize the advertisements of its advertising network.
The user personal data are collected automatically through Smart Travel’s webiste, including: IP address, the time of the request, the method used in forwarding the request to the server, the country of origin, the characteristics of the browser and the operating system used by the user, the various temporal information of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, the parameters relating to the operating system and the IT environment of the user. The user personal data are mainly used to optimise the provision of the services of Smart Travel’s online environment.

4.4 The user personal data are used mainly for providing travel services and with the consent of the user

4.5 The user assumes the responsibility for the Personal Data of third parties obtained, published or shared through the Smart Travel online environment and warrants that he/she has the right to communicate or publicize them, freeing Smart Travel from any liability to third parties.

4.6 Smart Travel can also share the user personal data if legally required following an investigation of criminal offences, a compliance with judicial demands or the fulfilment of the user vital needs.

5. Data retention period
The user personal data will be processed until the end of the journey/travel services and, beyond that date, they will be kept exclusively for the period required by law and until the date of expiry of claims (including the provisions for the prescription of rights). At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised. The data are kept by Smart Travel and third parties do not have access to the data stored by Smart Travel.

6. User rights
This privacy policy has the purpose to inform the user about which personal data are collected and how they are used by Smart Travel.
For additional questions, please contact us by email info@smarttravel.ee

The User may exercise certain rights with reference to the data processed by Smart Travel.

In particular, the user has the right to:

-Withdraw the consent at any time. The user can withdraw the consent to the processing of his/her personal data previously expressed.

-Access to his/her data. The User has the right to obtain information about the data processed

-Verify and request amendments. The user can verify the accuracy of his/her data and request correction and amendments.

-Request the limitation of the personal data processing. When certain conditions are met, the user may request the limitation of the processing of his/her data. In this case, the Smart Travel will not process the data for any other purpose other than their conservation.

-Obtain the cancellation or removal of his/her personal data. When certain conditions are met, the user can request the cancellation of his/her data

-Receive his/her data or have them transferred to another data usage owner.

-Place a complaint. The user can submit a complaint to the competent personal data protection authority or to a judicial branch.

7. Personal data storage and security
The processing of the user personal data will take place, in compliance with the provisions of the GDPR, using paper, computerized and electronic means with any suitable methods to guarantee security and confidentiality.

8. Questions
For any query please contact us by email info@smarttravel.ee

Last Update: May 2018