contact@turkishculturaltrips.com

Privacy Policy

Welcome to turkishculturaltrips.com, the website and online service of turkishculturaltrips.com. We respect the privacy of our users and we are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”), which describes the types of information we may collect from you or that you may provide when you use our www.turkishculturaltrips.com website.

GDPR compliant privacy policy

Our Privacy Policy defines the way our firm, Galaxy World Travel SRL, collects, withholds and use your personal information, when you visit or communicate with our website (www.galaxytravel.ro) or www.turkishculturaltrips.com)where from we obtain and collect your personal information. The present Privacy Policy is relevant since 14 May 2018.

Summary

  • Brief
  • About us
  • Data we collect when you visit our website
  • Data we collect when you contact us
  • Data we collect when you communicate with our website
  • Data we collect when you place an order on our website
  • Use of automated decision support
  • How we collect data about you from third-party sources
  • Disclosure and further use of your data
  • How long can data be kept
  • How we secure your personal data
  • Transfer of your data outside European Economic Area
  • Your rights over personal data
  • Your right to object over the use of personal information for indefinite purposes
  • Sensitive personal information
  • Privacy Policy changes
  • Special protection of children’s personal data

 The summary above has the sole purpose of giving you an overview over our Privacy Policy and how we obtain, collect and use your personal information. For comprehensive information you must read the below pages.

Data processor: GALAXY WORLD TRAVEL S.R.L.

How the company collects and obtains personal data:

  • when you provide us your personal information (E.g. by contact, connection, order or buy of any services or products of Galaxy Travel Romania, by filling a demand or an offer letter, by creating an account on our website, by signing up and subscribing to our newsletter in order to receive marketing messages in regard with our services and products, by filling in forms (online and offline) for promotions and events (E.g. tourism fairs)
  • when you visit our site some personal information are collected by cookies and third-party entities (tour companies and reseller agencies)

What personal data we collect from you: family name, first name, telephone number, residential address, email address, the type of your travel document (E.g. passport or ID), your national identity number (national insurance number), date of birth, your children’s age, workplace, employer name (if relevant) and VAT registration number (if needed).

How we use your personal data: for commercial and administrative purposes (frequently to communicate with you and to manage your orders (E.g. travel bookings) placed via our website, to fulfill the business purpose, to promote our goods and services and for legal purposes.

Sharing your personal data with third-parties: we share the minimum amount of information, necessary for the provision of our services to you (E.g. accommodation, transport and tourist assistance), to perform under our Terms of Serviceand for legal purposes.

We do not sell your personal information to third-parties.

How long do we retain your personal data: we keep personal data no longer than is necessary- we have to retain them if necessary to comply with our legal obligations (E.g.: bookkeeping up to date) or in regard to any other basisfor which we use your information (E.g.: consent, Term of Service, legitimate interests). You can find specific information of how long each data is kept in the section ‘’How long your personal data are retained’’.

How we secure your personal data: by using appropriate technical and organizational solutions like storage information on secure servers, encrypted data transfer to and from our servers using SSL technology, encrypted payments on site using SSL technology, personal data encryption, email encryption, pseuodonymisation and/ or anonymisation of personal information.

Use of cookies and similar technologies: we use cookies and similar technologies to collect personal information (E.g.: Web Beacons, strictly necessary cookies, functionality cookies, analytics cookies, targeting cookies). To know more, please visit our Cookies Policy here: https://www.turkishculturaltrips.com/cookie-policy/

Transfer of information outside the EEA: we only transfer such information if we are legally obligated or for the purposes of operating our business in order to fulfill our contract obligations for your benefit. Each time such a transfer exist, we make sure that the organization is based in a country which provide an adequate level of personal information protection or has enter into a legal agreement clause approved by the European Commission.

Use of automated decision support: we use automated decision-making support related to our website (E.g. Web Analytics, Cookies, Web Beacons or Targeting Cookies used to display targeted advertising/ offers to persons who visit our site on external websites, using services like Google AdSense.

Your rights on personal information:

  • You have the right to access that personal data and to be informed over the use of your personal information
  • You have the right to ask us to correct and/ or fill in correct personal data (right to correction)
  • You have the right to erasure of any personal data concerning you (right to erasure)
  • You have the right to restrict any use of your personal data
  • You have the right to personal data portability
  • You have the right to object to us processing your personal data
  • You have the right to withdraw the consent for processing your personal data
  • You have the right to appeal to a supervisory authority

Identity of our company:  data processor for our website is Galaxy World Travel S.R.L.(office address: Mexic 2, bl. 1, sc. C, sector 1, Bucharest, Romania). Contact us at our mail address or via our email address: office@galaxytravel.ro  or contact@turkishculturaltrips.com

Information we collect when you visit our site

We collect and process personal information from our website guests according to this section and with the section named ‘’Disclosure and further use of your personal data’’.

Personal information in web server logs

We use a third-party server to host our website. Host name is S.C Hiperstore S.R.L., who’s Privacy Policy can be found at https://simplenet.ro/confidentialitate/  . Through our host server, our website automatically register your IP address you use in order to access our website, plus other information in regard to your session, like pages you visit, requested information, date and hour of request,source of your connection on our website (E.g.: website or URL which referred you to our website), browser  version and operating system.

Use of website server logs for IT security reasons

Our server provider collects and stores your server logs to ensure the security of the IT network.  This procedure includes analyzing log files, to help and identify unauthorized access in our IT network, malware spread, prevent DDOS attacks and other cyber-attacks, through uncovering any unusual or doubtful activities.

If we don’t investigate any suspect or potential unlawful activity we don’t carry out or authorize our web provider any attempt of identifying you based on your server logs information.

The juridical basis for processing your personal data: conformation to EU General Data Protection Regulation, Article 6, paragraph 1, point c.

The legal basis:  recordings of your access to our website based on server web logs is a technical procedure in order to ensure a high level of security of personal data we collect on our website, in compliance with EU General Data Protection Regulation, Article 32, paragraph 1.

Cookies or other tracking technologies

What is a cookie: cookies are small text files sent to the user’s browser by visited websites to record information for varied reasons.

What kind of cookies do we use: strictly necessary cookies, functionality cookies, analytics cookies, targeting cookies and web beacons. For further details, please see the following: https://www.turkishculturaltrips.com/cookie-policy/

You can choose to block certain cookies or block all cookies via your browser’s settings. Please be aware that if you do not accept cookies, you may not be able to fully experience our websites features. Further information about managing cookies or your browser’s settings can be found at: www.allaboutcookies.org or by visiting our Cookie Policy.

Information we collect when you contact us

We collect and process personal information from persons which contacts us in compliance of this section or the section called ‘’Disclosure and further use of your data’’.

Email policy

  • Whenever you send us a message at out email address on our website, we collect your email address and any other personal data within the message.
  • Juridical basis: processing email is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.
  • Legitimate interest: to reply and answer to your messages and email inventory.
  • Juridical basis: processing is necessary for the performance of a contract or preceding entering into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.
  • Why a contract is necessary: if you demand goods or services in your message or provision (estimate) for goods or services we provide (E.g. information of such goods or services), we will process your personal data for that end.

Transfers and retention of information

We use a third party email provider for retaining your emails. Our provider is Google Inc – Gmail. Please visit htpps://privacy.google.com/your-data.html for more information. Your email is retained in the EEA, on Google servers based in Frankfurt, Germany.

Contact form

  • When you contact us via contact form, we collect: first name, name, email, phone number and any other information you provide us when you fill in the contact form.
  • If you fail to provide all the information requested in the contact form  you will not be able to send it to us, consequently we will not be able to answer your request.
  • Juridical basis: processing email is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.
  • Legitimate interest: to answer your questions and messages and correspondence keep.
  • Juridical basis: processing is necessary for the performance of a contract or preceding entering into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.
  • Why a contract is necessary: if you demand goods or services in your message or provision (estimate) for goods or services we provide (E.g.: information of such goods or services), we will process your personal data for that end.

Transfers and retention of information: your messages sent via contact form will be retained within EEA on our host provider (S.C. Hiperstore S.R.L. – Romania) and/or on our email server’s provider –Google, Frankfurt, Germany. Please visit htpps://privacy.google.com/your-data.html  for more information.

Phone call

When you contact us by phone, we will collect your phone number and any other information you provide to us during the phone call.

  • Juridical basis: processing calls is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.
  • Legitimate interest: to answer your questions and messages and correspondence keep.
  • Juridical basis: processing is necessary for the performance of a contract or preceding entering into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.
  • Why a contract is necessary: if you demand goods or services in your message or provision (estimate) goods or services we provide (E.g.: information of such goods or services), we will process your personal data for that end.

Mail

When you contact us by mail, we will collect any information you provide to us in any mail communications you send to us.

  • Juridical basis: processing mail is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.
  • Legitimate interest: to answer your questions and messages and correspondence keep.
  • Juridical basis: processing is necessary for the performance of a contract or preceding entering into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.
  • Why a contract is necessary: if you demand goods or services in your message or provision (estimate) goods or services we provide (E.g.: information of such goods or services), we will process your personal data for that end.

Information we collect when you interact with our website

We collect and process personal information from persons which contacts us in compliance of this section or the section called ‘’Disclosure and further use of your data’’.

E- Newsletter

When you sign up for our newsletter and opt to receive offers, events, prize draws via e-newsletter form or any other form where you give us your consent on processing your personal information.

Consent: you give us your consent to receive our e-newsletter by registering using the above mentioned steps.

Transfers and retentionof personal information

To administer and provide our E- newsletter we use a service provided by a third party. This service is provided by Active Soft. Please visit https://www.mailagent.ro/ro/politica-confidentialitate/ for more information. Personal information send to us for subscribing to our e-newsletter  is retained in EEA, Romania.

Registration on our website

When you register and create an account on our website, we collect your name, first name, email address, phone number.

If you fail to provide us all the information requested in our signup form, you will not be able to register or create an account on our website.

Juridical basis: processing your personal information is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: we register and administrate your accounts on our website in order to allow you to access your shopping history, bills and preferences of touristic services.

Transfers and retention

Personal data you offer to us via registration form on our website is retained in the EEA on our server provider host, SC Hiperstore S.R.L., Romania. Please visit https://simplenet.ro/confidentialitate/  for more details.

Place order information we collect on our website

We collect and utilize personal information from each person that place an order on our website in compliance with this section and the section called ‘’Disclosure and further use of data’’.

Personal data we collect when you place an order

Necessary information: when you place an order of goods or services on our website we collect name, first name, date of birth, email, phone number, billing addressand information of other persons included in reservation, including children. For companies we collect company name, tax registration number plus unique registration code at The National Trade Register Office, Romania.

If you do not provide us this information, you will not be able to buy goods or services on our website or enter into a contract with us.

Juridical basis for processing: to perform a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.

We need the mandatory personal information collected by our checkout form to establish who the contract is with and to contact you to fulfill our obligations under the contract, including sending you receipts and order confirmations.

Legal basis: compliance with a legal obligation (EU General Data Protection Regulatory, Article 6, paragraph 1, point c).

Legal obligation: we have the legal obligation to issue you with an invoice for the goods and services you purchase from us, where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose.

Our goods and services

You can subscribe to receive marketing messages related to our goods and services, via email, text message, phone call or mail by filling in the form and ticking the boxes that specify the consent for receiving such correspondence. We will send marketing communications related to our goods and services only if you accept to sign in.

Juridical interest for processing personal data: consent (EU General Data Protection Regulatory, Article 6, paragraph 1, point a.

Consent: you give us your approval to send information about our goods and services by subscribing such to receive such information, in accordance with the steps described above.

Personal information collected or obtained from third parties

We receive third parties personal information about you. Third parties from whom we receive personal data are, generally, group companies, affiliates, business partners or persons who purchase our services (and) in your name.

Also, it is possible that third parties we had no anterior contact may provide us information about you.

 Information will obtain from third parties will generally be your name and contact details, but will include any additional information about you they provide to us.

Juridical basis for processing: essential to perform a contract or to take steps at your request to enter into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.

Reason why is necessary to enter into a contract: where a third party has passed on information about you to us (such as name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you.

Juridical basis for processing: consent, in compliance with EU GDPR, article 6, paragraph 1, point a.

Consent: where you have asked that a third party to share information about you with us and the purpose of that information is not related to the performance of a contract or services by us to you, we will process that information based on your consent, whom you grant by asking that third party to send personal information to us.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interests: where a third party has shared information about you and you have not consent for the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For instance, we will have a legitimate interest in processing information about you in order to fulfill responsibilities resulting from a subcontract with a third party, if third party has a contract with you, our legitimate interest is fulfilling our obligations specified in subcontract.

We also obtain information about you from third party if you have violated or could violate any of our legal rights. Such, we will have legitimate interest for processing that information to investigate and follow up any potential breach.

Information we get by error

If by error we get information about you from a third party and/or we do not have a legal basis to process that information, we will delete all the information received.

In certain circumstances (for instance, to verify the information we have about you or to obtain missing information about you in order to provide you a service), we will obtain information about you from certain accessible sources, EU or non-EU, such as institutions or public authorities.

In certain circumstances, we will also obtain information about you from private sources, EU and non-EU (E.g. insurance companies). That information will be processed only by your express consent.

Juridical basis for processing: essential to perform a contract or to take steps at your request to enter into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.

Reason why necessary to perform a contract: in certain circumstances, in order to perform a contract or to enter into a contract with you, we will access information about you from public sources in order to offer you a high level services., such as obtaining and/or verifying your email address on your website, in case you demand information via email and we don’t need/ need confirmation of your email address.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point a.

Consent: we can collect information about you from third parties when you agreedwith them to communicate that information to us, by approval, for instance when you tick a box which specify that you agree to share your information with us.

Automated decision support

We use automated decision support on our website. We consider that using automated decision support has no juridical effect upon you or any similar outcome.

You have the right to object on use of automated decision support and profiling, as specified in this section.  You can choose not to accept cookies and similar technologies, as mentioned in the specific section of this privacy policy. You can choose not to accept some cookies and similar technologies, as described in this section. You can do that by opt out to cookies and similar technologies. If you do not wish for your real IP address to be processed (as given by your internet service provider), you can use a VPN (Virtual Private Network) or another free service for anonymous communication (E.g. Tor).

For more details about managing cookies and similar technologies (including legal basis) and how to opt out cookies and similar technologies, please visit: https://www.turkishculturaltrips.com/cookie-policy/ .

Automated decision support

Disclosure and further use of your data

This section explains the circumstances under which we will disclose your data to third parties and any other further use of your data.

Disclosure of your information to our service providers

We use third parties to provide us services, as necessary for our legitimate business to function or for our business needs. Those third parties process information on our behalf.

Third parties

  • telephone service provider (mobile and landline)
  • email service providers
  • IT service providers
  • Website builders
  • Web hosting providers
  • Marketing services providers
  • Email marketing providers

Your information will be shared with these service providers, in order to provide you a service you requested, no matter whether area request to visit our site or an order of goods and services from us.

We do not post publicly our providers identity, for competitiveness reasons. For more information about our providers identity, please contact us directly by fill in our contact form (https://turkishculturaltrips.com/contact/  or by email (contact@turkishculturaltrips.com) and we will supply the information requested if you have a legitimate reason.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: if we share your information with third parties in other context then entering a contract with you (or your request to enter a contract with us), we will share your information with third parties, in order to manage and administer our business properly.

Juridical basis for processing: essential to perform a contract or to take steps at your request to enter into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.

Reason why necessary to perform a contract: in certain circumstances, in order to respect our legal obligation or to enter into a contract with you, we will share information about you with third parties.

Disclosure of information to other third parties

We disclose your information to third parties in certain circumstances.

We disclose your information to third parties, like Google Inc, Facebook.  Google collects information by using Google Analytics on our website. Google and Facebook utilize those information, including your IP addresses and cookies information, for multiple purposes, like improving our website experience or your browsing experience. Google and Facebook collect data anonymously.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: improving the quality of our services.

We share and disclose your information with third parties, which are linked or associated with our business functionality and is necessary for us. Third parties: consultants, affiliates, business partners, independent contractors or insurance companies. Details about each third party see below.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: running and managing our business effectively.

Consultants

Occasionally, we seek guidance from consultants (lawyers, audit firms, PR specialists and survey research companies.

We will share your information with this third parties only if is strictly necessary in order to offer us consultancy. Our consultants are based in Romania.

Affiliates

Affiliates are persons or companies with whom we work to promote our business through varied means.

Our affiliates disclose information to us and we will disclose your information to them, in the case you showed interest to our goods or services and to respect our legal obligations to you. Our affiliates are based in Romania.

Business partners

Our business partners are companies we collaborate and who deliver goods and services similar to ours. Those services are complementary to our business or they help us deliver goods and services that we can’t deliver alone. We share information with our business partners when you ask for services they provide alone or in connection with our services, in order to fulfill our legal obligations to you. Our business partners operate in tourism services, accommodation services and transport services. Our business partners are based in EU and non-EU countries.

For more details about the security of your information when transferred outside EEA, please consult the section ‘’ Data transfer outside the EEA’’ from this privacy policy.

Independent contractors

From time to time we collaborate with independent contractors when needed for our business to function properly. Your information will be disclosed to independent contractors only if is reasonably necessary to perform services to our business.  We activate in tourism industry and our independent contractors are travel guides, travel assistants or locals from countries we visit.

Insurers

We will disclose your information to insurers we collaborate only if is reasonably necessary (E.g. if you opt in for insurance when you buy a tourism package or later on, when you file a complaint or when we receive a request/ we make a request in accordance with our disclosure policy, as mention in our contract with the insurers.

Our insurers are located in Romania.

Legitimate interest: running and managing our business effectively.

Juridical basis for processing: to perform a contract or to take steps at your request to enter into a contract, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point b.

Reason why necessary to perform a contract: we need to pass information about you to third parties, such as business partners or insurers, to fulfill our legal obligations to you or to take steps at your request to enter into a contract with you.

We do not indicate the identity of third parties we collaborate with from security reasons or competitiveness reasons. If you want to know more about our third parties collaborators, please contact us directly via our contact form at https://turkishculturaltrips.com/contact/  or via email (contact@turkishculturaltrips.com ) and we will provide you information requested if you have a legitimate claim and only if we disclosed your information to such third parties.

We will disclose your information in case of a real or potential merger, acquisition or asset sale or any similar action, real or potential.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: disclosing your information to a potential buyer, seller or any similar entity, in order to allow a transaction.

Disclosure of your information on legal basis

We disclose personal information to indicate to a relevant authority a criminal offence or a threat to national security.

If we suspect a real or potential criminal action, in some circumstances, we will have to contact a relevant authority (E.g. if we suspect fraud, cyber-crime, threats or any similar activity directed to us or third party collaborators). In case of such an event, we will have to process your information if you were involved or affected by any means.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: to prevent violation of law or any potential criminal activity (E.g. fraud).

Use or potential use of our legal rights

We will use your information if we need to practice or potential practice our legal rights, including, for example, change of information with a debt recovery company, if you do not pay the total amount specified in the contract you have enter with us. Our legal rights can be contractual (when you have entered into a contract with us or non-contractual (E.g. legal rights resulting from copyrights or delictual liability).

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: to enforce our legal rights or to take action to ensure our legal rights.

Litigation and legal procedure or potential legal procedure

We may have to use your information if we are involved in litigation with you or a third party, for example, to conclude litigation (via mediation or arbitration). We may also use your information to apply a court order or a similar judicial proceeding.

Juridical basis: processing is necessary for our legitimate interest, in compliance with EU General Data Protection Regulatory, Article 6, paragraph 1, point f.

Legitimate interest: settlement of legal disputes or potential legal disputes.

Compliance to laws, regulations and other legal imperatives

We will use and process your information to comply with our legal obligations (E.g. we may have to reveal your information in base of a court order or subpoena, if we receive such a mail).

Juridical basis for processing: compliance with a legal obligation (EU General Data Protection Regulatory, Article 6, Paragraph 1, Letter c.

Legal obligation: we have a legal obligation to disclose your information, in compliance to national or international legislation to which we are subject (E.g. an international convention to which Romania is party).

Juridical basis: processing is necessary for our legitimate interest, in compliance with General Data Protection Regulatory, Article 6, Paragraph 1, point f.

Legitimate interest: if we have legal obligations to comply with legislation of countries with different laws then Romania, we have a legitimate interest to do so.

How long to we keep your personal data

This section determines how long we keep de data we collect from you. We set specific retention periods where possibly and where not possibly, we have specific criteria in order to determine the retention period.

Retention periods for personal data

Website server log information:  we retain your website server log information for a period of 6 months.

Purchases: when you place an order for goods and services on our website, we will retain that information for 6 years, following the end of the current financial year. We have to do so because we have a legal obligation to keep accounting records.

Correspondence: when you contact us or make an inquiry, for whatever reason, via email, contact form or calls, we will retain your information for as long as needed or we will erase your data at your express demand, applicable with our legal obligations.

Newsletter:  we retain the information you used to subscribe to our newsletter as long as you remain our subscriber and you do not unsubscribe. We do not retain that information if we cancel our newsletter.

Criteria for retention periods

On any other circumstance, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose and use of your information both now and in the future (such as whether it is necessary  to continue to store the information in order to continue to perform our legal obligation under a contract with you or to contact you in the future)
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation)
  • whether we have any legal basis to continue to process your information (such as your consent)
  • whether we have any legitimate interest  to continue to process your information
  • the levels of risk, cost and liability involved in order to continue to hold your information
  • security of your information

We take appropriate technical and organizational measures to secure your information and protect it against unauthorized or unlawful use and accidental loss or destruction, including:

  • sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where applicable and anonymised basis wherever possible
  • using secured servers to store your information
  • verifying the identity of any person who requests access to your information preceding  to permit access to your information
  • using Secure Socket Layer (SSL) to encrypt any information you send to us via any forms on our website
  • transferring your data via closed systems or  encrypted data transfers

Transmission of information to us via email

Transmission of information via internet is not entirely secure and if you send us information via internet (email or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, loss of profits, harm to reputation, expenses, debts or any other form of loss or damage suffered by you as a result of your decision to send us information by such means.

Data transfer outside the European Economic Area (EEA)

We activate in tourism sector. In order to fulfill our legal obligations specified in the contract you have entered with us (travel booking) we have to transfer your information to our contractual partners, some of which are based outside the European Economic Area.

Your data will be transfer outside the European Economic Area only when you purchase vacation packages in countries situated outside the EEA or when our travel service providers selected by you are based outside the EEA.

Securities (protections) utilized: contractual clauses as mention in section ‘’Data transfer from European Union countries to non-EU countries’’ from EU GDPR, article 46, Paragraph 92, point c.

Subject to certain limitations, you have the following rights in relation to your information, which you can exercise , sending a mail with your request at our address: Mexic 2, bl. 1, sc. C, sector 1, Bucharest, Romania or by email at contact@turkishculturaltrips.com :

  • to request access to your information and information related to our use and processing your information
  • to request the correction or deletion of your information
  • to request that we restrict our use of your information
  • to receive information which you have provided to us in a structured, commonly used format and machine-readable (E.g.  a CSV file) and the right to have that information transferred to another data controller (including a third party controller)
  • to object to processing of your information for certain purposes (for more details, please consult the section below called ‘’Your right to object to processing your information for certain purposes’’)
  • to withdraw your consent to our use of your information at any time where we need your consent to use or process your information
  • Please remember that if you withdraw your consent to processing your information will not affect the lawfulness of our use and process of your information based on the consent you have given to us prior the moment you withdraw your consent.

In compliance with Article 77 from General Data Protection Regulatory you also have the right to file a complaint with a supervisory authority, in particular in the member state, work place or of an alleged breach of the General Data Protection Supervisory. In Romania, the supervisory authority is www.dataprotection.ro

Verifying your identity when you request access to your information

In case you file a request to access your information, we are legally compelled to use all reasonable measures to verify your identity. Those measures are built for the purpose of protecting your information and reduce the risk of identity fraud, identity theft or unauthorized access to your information.

How we verify your identity

When we possess appropriate information about you in our data base, we will try to verify your information utilizing that information. If we cannot identify you using that information or in the case we don’t have enough information about you, we might have to ask you copies or certificates of certain documents in order to verify your identity, before granting you access to your information. We will confirm the exact information we need to confirm your identity in your specific circumstances when and if you file such a request.

Right to object to processing your information

You have the following rights in relation to your information which you can apply by sending a letter to Galaxy World Travel SRL (Mexic2, bl. 1, sc. C, sector 1, Bucharest, Romania) or by email (contact@turkishculturaltrips.com ):

  • to object to us using or processing your information by us to carry out a task in the public interest or in our legitimate interest, including analyzing or predicting your behavior based on your information, and
  • to object to us using or processing your information for direct marketing purposes (including any profiling implied in connection to direct marketing)

You may also exercise your right to object utilizing and processing your information for direct marketing purposes:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instruction from your browser after clicking that link
  • sending to us an email at contact@turkishculturaltrips.com  asking that we stop sending you marketing communications or by including in your request the word ‘’UNSUBSCRIBE’’

For more information on how to object to our use of information collected from cookies and similar technologies, please consult our cookie policy here: https://www.turkishculturaltrips.com/cookie-policy/

Sensitive personal information

‘’Sensitive personal information’’ data that consists of racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data which allow the unique identification of that person, data concerning health or data concerning a person’s sex life or sexual orientation.

In specific circumstances, we collect ‘’Sensitive personal information’’ of health, trade union membership and children’s data (family name, first name, age, Personal Identification Number, passport serial number and passport number).

Personal information about health are provided to us by our customers when they have special requests regarding travel transport services or accommodation services they want to purchase from us (E.g. allergies- special menus at hotel , disabilities- wheelchair access at hotel, etc.)

We process personal information of trade union membership as we have partnerships with certain trade unions and the members of those trade unions may benefit of special facilities and discounts.

We process children’s data in order to deliver in optimal conditions the services purchased by the children’s legal guardian.

However, if you send to us sensitive personal information by mistake or by voluntary, we will assume that we have your express consent to process your personal information in compliance to GDPR, Article 9, Paragraph 2, point c. After processing, your sensitive personal information will be deleted.

Privacy Policy updates

We periodically update and adjust our Privacy Policy.

Minor updates to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date mentioned at the beginning of it. Processing of your personal information will be made in compliance with the updates agreed in the new Privacy Policy from the effected date stated.

Major updates to our Privacy Policy or of the purposes we process your information

Upon major changes to our Privacy Policy or intention to use your information to new or different purposes then the original purpose we collected your information, we will notify you via email (if possible) or via a notice on our website. We will explain the reasons for the update and purpose and any other relevant information before using your information for the new purpose.

Children’s data privacy

We collect data for persons under the age of 18, only by the express consent of children’s legal guardian, in order to deliver in optimal conditions the services purchased by the children’s legal guardian.

We may receive information about persons under the age of 18, if a third party is victim of fraud or phishing. If we are notified about such an event, we will immediately verify that information. If protection laws require, we will immediately obtain the express consent of the children’s legal guardian to use that information or, if we do not immediately obtain the express consent of the children’s legal guardian, we will delete the information from our servers. If you would like to announce us about receiving information of persons under the age of 18, please contact us via email (contact@turkishculturaltrips.com )