PRIVACY POLICY

1. Data Controller

The controller responsible for the processing of personal data under applicable data protection law is:

Travel Protocol Worldwide Maalaoui
Martinshöhe 3a
6204 Sempach
Switzerland

Hereinafter referred to as “TPWW”.

2. Collection and Processing of Personal Data

TPWW collects and processes personal data where this is necessary in connection with an enquiry, consultation, intermediation, booking or performance of travel and other services, or where such data is voluntarily provided by the data subject.

Personal data may in particular be collected where it is:

provided in connection with an enquiry or booking;
submitted through a contact or enquiry form;
communicated by email, telephone or electronic messaging services;
required for the consultation, selection, intermediation, booking or performance of a requested service; or
generated in the course of an existing Client relationship.

The categories of personal data processed may include, in particular:

name, address and contact details;
date of birth, nationality and other identification details where required for a booking;
passport, identity document and travel document details where required for the respective service;
travel, booking and accommodation details;
travel preferences, special requests and individual requirements;
billing, payment and transaction data;
correspondence and communication data;
security-related information where required for the requested service;
voluntarily provided health data or other sensitive personal data where processing is necessary for the requested service.

Personal data is processed in particular for handling enquiries, providing consultation and communicating with the Client, preparing quotations, intermediating and booking travel services, performing and coordinating booked services, processing payments and invoices, and complying with statutory and regulatory obligations.

TPWW processes only the personal data necessary for the respective purposes or voluntarily provided by the Client or other data subject.

3. Hosting and Technical Infrastructure (Squarespace)

TPWW’s website is operated and hosted using the Squarespace platform. The provider is Squarespace, Inc., USA.

When visiting the website, technical data may be collected and processed automatically. This may include, in particular:

IP address;
browser type and browser version;
operating system used;
date and time of access;
pages and content accessed;
referrer URL;
device and connection information;
technical log and error data.

Such data is processed in particular to ensure the secure and functional operation of the website, identify and resolve technical issues and maintain the security and stability of the technical infrastructure.

In connection with the use of Squarespace, personal data may also be processed or stored outside Switzerland. The respective provider’s privacy terms additionally apply to the processing of personal data by Squarespace.

4. Cookies

TPWW’s website uses cookies and comparable technologies. Cookies are small files that may be stored on or accessed from a user’s device when visiting a website.

TPWW uses technically necessary cookies where these are required for the operation, security and basic functionality of the website.

In addition, where corresponding functions are used, analytics, statistical or other non-essential cookies may be used. Where consent is required under applicable data protection law, such cookies will only be used after the user has provided the relevant consent.

Users can manage their choices and settings regarding non-essential cookies through the cookie settings made available on the website and, where technically provided, amend or withdraw their choices at any time.

Cookies may also be restricted, blocked or deleted through the settings of the browser used. However, this may result in certain functions of the website being unavailable or only available to a limited extent.

Further information regarding individual analytics and third-party services is provided in the following sections of this Privacy Policy.

5. Google Analytics

TPWW may use Google Analytics, a web analytics service provided by Google, on its website. For users in the European Economic Area and Switzerland, the provider is generally Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables TPWW to analyse the use of its website. In this context, information may be processed relating in particular to pages accessed, access times, devices and browsers used, approximate location information and information regarding the use of and interaction with the website.

Google Analytics uses cookies and comparable technologies. Where consent is required under applicable data protection law, Google Analytics will only be used after the user has provided the relevant consent through the cookie settings made available on the website.

In connection with the use of Google Analytics, personal data may also be processed by Google outside Switzerland, in particular in the United States. Further information regarding cross-border transfers of personal data is provided in Section 8 of this Privacy Policy.

Any consent given may be amended or withdrawn with effect for the future through the website’s cookie settings.

Further information regarding Google’s processing of personal data can be found in Google’s privacy information.

6. Payment Processing and Payment Service Providers

TPWW may use external payment service providers for the processing of payments, in particular Stripe Payments Europe Ltd. and SumUp Limited.

Depending on the payment method selected, the following categories of personal data may in particular be processed in connection with the payment:

name and contact details;
billing and payment information;
payment amount and currency;
transaction and reference data;
information relating to the payment method used;
technical data required to process and secure the payment.

Where payment is processed through an external payment service provider, the data required for payment processing will be transmitted to and processed by the respective provider in accordance with the applicable data protection provisions.

In connection with payment processing, TPWW may receive and process information concerning the status and allocation of a payment as well as other transaction information required for accounting, invoicing, fraud prevention or processing the respective booking.

Payment data is processed in particular for the purpose of processing and allocating payments, handling bookings, invoicing and accounting and, where necessary, preventing and investigating abusive or fraudulent transactions.

The respective payment service provider’s privacy terms additionally apply to any independent processing of personal data carried out by that provider.

7. Disclosure of Personal Data to Third Parties

Where necessary for processing an enquiry or for the consultation, intermediation, booking, performance or coordination of a requested service, TPWW may disclose personal data relating to the Client and accompanying travellers to third parties.

Potential recipients may include, in particular:

hotels, villas, private residences and other accommodation providers;
airlines and private aviation providers;
car rental companies, chauffeur, transfer and other transportation providers;
yacht and charter providers;
providers of activities, events, hospitality, wellness and other travel or lifestyle services;
security service providers and medical institutions;
booking and intermediary platforms, reservation systems, B2B travel providers, wholesalers, distribution partners and other booking providers;
payment service providers, banks and other companies involved in payment processing;
IT, communication and other technical service providers;
public authorities or other bodies where disclosure is required by law.

Personal data will generally only be disclosed to the extent necessary for the respective purpose.

Depending on the booking model, such third parties may either be the Client’s contractual partner or may be engaged by TPWW for the procurement, booking or performance of a travel service. Personal data may therefore also be disclosed to companies with which the Client does not have a direct contractual relationship.

Where special categories of personal data, in particular voluntarily provided health or security-related information, are necessary for the requested service, such data may also be disclosed to the recipients involved in the respective service to the extent necessary.

The respective recipients process the personal data disclosed to them in accordance with applicable data protection law and, where they independently determine the purposes and means of their processing, under their own responsibility for data protection compliance.

8. International Transfers of Personal Data

As TPWW intermediates, books and coordinates travel and other services worldwide, personal data may be transferred to and processed by recipients outside Switzerland.

Such recipients may include, in particular, Service Providers, hotels, airlines, transportation providers, booking and intermediary platforms, reservation systems, B2B travel providers, wholesalers, distribution partners, payment service providers and other companies involved in the respective booking or performance of the service.

Personal data may also be transferred to countries whose data protection laws do not provide a level of protection comparable to that provided under Swiss data protection law.

Where required under applicable data protection law, TPWW takes appropriate measures to protect personal data transferred abroad, in particular by entering into recognised contractual data protection safeguards or by using other safeguards provided for by law.

Personal data may also be transferred where such transfer is necessary for the conclusion or performance of a contract with the Client or for the conclusion or performance of a contract in the Client’s interest, or where another statutory basis for the cross-border transfer of personal data applies.

In particular, where the Client requests travel services in a country that does not provide an adequate level of data protection, it may be necessary to transfer the personal data required for the booking or performance of the respective travel service to Service Providers or other companies located in that country.

TPWW generally limits the personal data transferred to the extent necessary for the respective purpose.

9. Data Retention

TPWW retains personal data only for as long as necessary for the purposes for which it was collected or processed, or where further retention is required or permitted due to statutory obligations or legitimate interests.

The applicable retention period depends in particular on the nature of the personal data, the purpose of the processing and the applicable statutory retention and documentation requirements.

Personal data relating to enquiries, Client relationships, quotations, intermediation, bookings and the performance of travel or other services may in particular be retained for as long as necessary for the administration of the respective business relationship and for the establishment, exercise or defence of legal claims.

Booking, contractual, invoicing, payment and business records are retained in accordance with the applicable statutory retention requirements.

Personal data that is no longer required for the relevant processing purposes and is not subject to any statutory or other permissible retention requirement will be deleted or anonymised.

10. Communication via WhatsApp

TPWW may communicate with Clients and prospective Clients through the WhatsApp messaging service where this communication channel is used or requested by the Client.

When using WhatsApp, personal data, including in particular telephone numbers, profile information, communication content, transmitted documents as well as technical and metadata, may be processed by WhatsApp and its affiliated companies.

In connection with the use of WhatsApp, personal data may also be processed or stored outside Switzerland. Further information regarding the processing of personal data by WhatsApp is available in the provider’s privacy information.

TPWW may use WhatsApp in particular to exchange enquiries, travel and booking information, booking approvals, confirmations and other communications relating to the Client relationship.

The Client is not required to use WhatsApp for communication with TPWW. Where possible, communication may alternatively take place, in particular, by email.

The Client should only transmit sensitive personal data and confidential documents via WhatsApp where this is necessary for the requested service and this communication channel is intended to be used for that purpose.

11. Social Media

TPWW maintains presences on social networks and platforms, in particular Instagram.

When visiting or using these presences, personal data may be processed by the respective platform operator. Such data may include, in particular, profile and contact information, information relating to interactions with TPWW’s content, as well as technical and usage data.

Where users communicate with TPWW through a social media platform, for example by direct message, comment or other interaction, TPWW may process the personal data provided in this context for the purpose of handling the respective enquiry and communicating with the user.

The respective platform operators may also process or store personal data outside Switzerland and may process data for their own purposes. TPWW generally has no control over the nature and extent of such independent processing by the platform operators.

The respective platform operators’ privacy terms additionally apply to their processing of personal data.

12. External Links

TPWW’s website and electronic communications may contain links to websites, platforms or other online services operated by third parties.

When accessing such an external link, the user leaves TPWW’s area of responsibility. The respective third party’s own privacy terms apply to its processing of personal data.

TPWW generally has no control over the processing of personal data by external providers and, to the extent permitted by law, assumes no responsibility for their content, availability, security or privacy practices.

Users are encouraged to review the privacy terms of the respective external provider.

13. Rights of Data Subjects

Data subjects have the rights granted to them under applicable data protection law in relation to the processing of their personal data.

Depending on the applicable law, these rights may include, in particular:

the right to obtain information regarding personal data processed by TPWW;
the right to have inaccurate personal data corrected or incomplete personal data completed;
the right to request deletion or destruction of personal data where the statutory requirements are met;
the right to request the restriction or cessation of certain processing activities where such a statutory right exists;
the right to obtain or have personal data transferred in a commonly used electronic format where the statutory requirements are met;
the right to withdraw consent with effect for the future where processing is based on consent;
any other rights available under applicable data protection law.

The exercise of these rights may be subject to statutory requirements, limitations or exceptions. In particular, statutory retention obligations or overriding legitimate interests may prevent the immediate deletion of certain personal data.

Requests relating to the exercise of data protection rights may be submitted using the contact details specified in Section 1. Where necessary, TPWW may request appropriate information to verify the identity of the person making the request.

Data subjects also have the right to contact the competent data protection supervisory authority in accordance with applicable data protection law.

14. Applicable Law and Jurisdiction

This Privacy Policy and the processing of personal data by TPWW shall generally be governed by Swiss law, in particular the Swiss Federal Act on Data Protection, unless mandatory provisions of other applicable data protection laws take precedence.

The courts having jurisdiction at TPWW’s registered office shall have jurisdiction over disputes arising in connection with this Privacy Policy or the processing of personal data by TPWW, unless mandatory statutory provisions provide for a different place of jurisdiction.

Any mandatory statutory rights, the jurisdiction of competent data protection supervisory authorities and any mandatory places of jurisdiction remain unaffected.