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1. GENERAL PROVISIONS

 1.1.   We care about your privacy and the security of your data, so we have developed this Privacy Policy (hereinafter the “Privacy Policy”), which explains how we process and protect your personal data, as well as informs you of your rights.
 

1.2.   In this Privacy Policy “You” means the person who uses our services through our Website (www.globetrott.com) and/ or Mobile Application (GlobeTrott Travel), visit our Social Accounts, contacts us via electronic communication channels, as well as the person who represents the organization that we conduct business with.
 

1.3.   In this Privacy Policy, the term “personal data” (hereinafter referred to as “Personal Data”) means any information or set of information by which we may directly or indirectly identify you, such as your name, email address, telephone number, etc.
 

1.4.   We process Personal Data in accordance with the provisions of the General Data Protection Regulation No. 2016/679 (EU) (hereinafter – “GDPR”) and the requirements of the legal acts of the Republic of Lithuania, as well as the instructions of the authorities.


1.5.   The Privacy Policy applies when you visit the GlobeTrott website, available at https://www.globetrott.com/ (hereinafter the “Website”), use our mobile application (hereinafter the “App”), engage with our social media accounts on Facebook, LinkedIn and Instagram and other social networks (hereinafter “Social Accounts”), use and upload content to our content management system (hereinafter ”CMS”), order and use the services we offer, contact us by phone and other electronic means, subscribe to our marketing materials and newsletters, apply for a job position at the Company.


1.6.   Our Website, newsletters and the App may contain links to third party websites, applications, platforms, or social network accounts. This Privacy Policy does not apply to third party websites, applications, or services. Please review their privacy policies before submitting your Personal Data to these third parties. We do not control and are not responsible for the third parties’ content, services, or data processing.


1.7.    If You order our services, use our App or CMS, visit our Website or Social Accounts, contact us, subscribe to our newsletter, we consider that you have read and agree to the terms of the Privacy Policy and the purposes, methods, and procedures for the use of Personal Data set out therein. If you do not agree with the Privacy Policy, you may not use the Website, the App or CMS, Social Accounts, subscribe to our newsletter, contact us for offers of our services, etc.

 

1.8.   Please note, most of the information you provide through the CMS, such as the uploaded tour content, will be made publicly available in accordance with the agreement signed between Local Expert and GlobeTrott.

 

1.9.   This Privacy Policy is subject to change, so please visit the Website or App from time to time to read the latest version of the Privacy Policy published.

2. WHO ARE WE?

2.1.   We are UAB GlobeTrott Travel, legal entity code 305390703, address Spindulio g. 5-27B, LT-76163 Šiauliai, Lithuania (hereinafter the “Company” or “us”).

 

2.2.   We manage our services, the App, the CMS, the Website and Social Accounts and act as a Personal Data Controller in offering and providing services, performing the Company’s day-to-day operations, or complying with legal requirements.

 

3. OUR PRIVACY POLICY PRINCIPLES

 3.1. We collect and process the minimum amount of Personal Data that is necessary to provide you with our services, and in accordance with applicable legislation.  

3.2. When processing your Personal Data:

3.2.1.   We comply with the requirements of current and applicable legislation, including GDPR;

3.2.2.   We process your Personal Data in a lawful, fair, and transparent manner;

3.2.3.   We collect your Personal Data for specified, clearly defined and legitimate purposes and do not process them in a way incompatible with those purposes, except to the extent permitted by law;

3.2.4.   We take all reasonable steps to ensure that Personal Data that is inaccurate or incomplete, in accordance with the purposes for which they are processed, would be rectified, supplemented, suspended, or destroyed without delay;

3.2.5.   We hold them in such a form that your identity can be established for no longer than is necessary for the purposes for which the Personal Data are processed;

3.2.6.   We do not provide Personal Data to third parties or disclose them, other than as set forth in the Privacy Policy or applicable law;

3.2.7   We ensure that your Personal Data is processed securely. 

 

4.   YOUR PERSONAL DATA WHICH WE COLLECT AND PROCESS?

4.1.   We may collect, process, store and transfer various types of Personal Data. We aim to collect the minimum amount of Personal Data that is required for us to offer and provide our services, as well as to fulfil our contractual obligations, while pursuing our or third parties legitimate interest, in compliance with legal regulations or obligations.

 

4.2.   We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

 

4.3.   Your Personal Data is collected in the following ways:

4.3.1.   Direct interaction - when you provide us with your Personal Data by registering on the App, the CMS, ordering our services, contacting us by e-mail, telephone or via social accounts, etc.;

4.3.2.   Automated technologies or interactions - when we collect your Personal Data based on your interactions with our services, such as the operating system (“OS”) running on your device, internet protocol address (“IP Address”) (which may be used to obtain your geolocation), the history of how You use of our services, etc.;

4.3.3   Third parties or publicly available sources - when we receive Personal Data from other parties, such as public registers, state or local government institutions or bodies, as well as other third parties, to whom you would have given consent to share your personal data. 

 

4.4    The person providing Personal Data (whether their own or on behalf of others (such as employees, representatives, etc.)), is responsible for the correctness, completeness, and relevance of such Personal Data. If the person is providing Personal Data on behalf of others, they must have the consent of the data subject to be providing us with such data. We may ask you to confirm if you have the right to provide us with Personal Data on behalf (for example, by filling in service order or registration forms) and where necessary provide proof of your identity and proof of others consent (for example, a person inquiry about receiving his/her Personal Data).

 

4.5.   We may collect statistical data about your activity on the App. We assure you that this kind of data does not directly or indirectly reveal your identity and it will only provide us with statistical, depersonalized information. Aggregated and depersonalized data will not be treated as personal data. Also, insights from such data analysis may be published. 

 

4.6.   With your consent, we may collect your geolocation data. This data helps us deliver a better, more tailored service, enables some functionalities of our services, and offers more relevant content. You can withdraw your consent on sharing geolocation data with us at any time by changing the settings on the App or your mobile device. If you do not give your consent, you will still be able to use the App and the services, subject to some limitations in functionalities. We will use the above data to analyse your engagement with the App, assign you to a specific profile and analyse the behaviour of similar profiles.

 

4.7.    When you log in to the App using your social media account, we will receive (unless you change your settings within your social media account), your public profile information (i. e. your name, e-mail, and profile picture, etc.).

 

4.8.    We will monitor our information sharing onto other social platforms through social share buttons as engagement and interaction with Company products (App and Website). This information might be linked to your profile as a behavioural indication that will be associated with your profile.

 

4.9.    If you use the in-App payment system to pay for our Services, the applicable payment platform provider will collect data on the payment in accordance with its privacy policy. Please check it before processing the payment. We will obtain information from the payments platform provider on what Services have been purchased and use this information to make payments to persons who have provided Content to our App. GlobeTrott will not be collecting or processing any Personal data related to payments and as such will not be liable for any data leaks or breaches that the third party provider might have, to the extent the incident happened without GlobeTrott fault”. 

 

4.10.   When providing our services, we may use automated decision-making based on the processing of data in certain cases, for example, to ascertain your needs in relation to the service and your compliance with the service requirements. Automated decision-making refers to the processing of personal data using, for example, software code or an algorithm that does not require human intervention. We regularly review the criteria and models of the automated decision-making methods we use to ensure their fairness, efficiency, and impartiality. We do not use automated decision-making processes based on profiling, which may give rise to legal consequences or have a similarly significant impact on the rights or freedoms of data subjects. Nevertheless, you have the right to request human intervention to express your views or object to the results of automated decision-making, in which case your situation will be assessed by our specialist.

4.11.    We process your Personal Data for the following purposes and under the following conditions:

You have the right to refuse or withdraw your consent to the processing of your Personal Data at any time when these are processed based on your consent. 

4.12.    In some cases, Personal Data may be stored for a longer period if the storage of personal data is required to protect our or any third parties’ legitimate interests, e. g. in case of a legal dispute, or if we are obligated to do so by law. 

4.13.    Through our Social Accounts we can share information about ourselves, our events, news, surveys, as well as information about new team members we are looking for. Anyone who engages with our Social Accounts is also subject to the privacy policies of the social network that is used. When you contact us via Social Accounts, depending on the privacy settings you choose, we may see certain user account information such as profile name, first name, surname, image, gender, e-mail address, location. If a user chooses to communicate with us by posting information on our Social Accounts (e.g. posts a comment in the comments section of our Social Account or posts a message on our Social Account profile), depending on the privacy settings chosen, the posted information may be made public (for example, visible on our Social Account to other users).

 

4.12.   In some cases, we may send you messages related to ordering or providing our services, for example, informing you about the confirmation of the service order, the expiration date of the ordered services, changes in the provision of services, the App updates. Such notices are necessary for the proper provision of our services and are not considered promotional notices.

 

4.15.   You have the right to change and update the information provided to us. In some cases, we need to have accurate, up-to-date information about you, so we may ask you periodically to confirm that the information we hold about you is correct.

5.   TO WHOM AND WHEN DO WE TRANSFER YOUR PERSONAL DATA?

5.1.   We will only transfer your Personal Data as described in this Privacy Policy.
 

5.2.   We may transfer your Personal Data to our service providers, which may include our partners or consultants (professional service providers such as accountants, legal consultants, audit firms etc.), trusted services providers when they provide services to us, to you on our behalf and under our instructions (IT, cloud, security services providers, providers of other key operational systems such as banking modules, etc.). We will control and shall remain responsible for the use of your personal data at all times. You can access the list of our service providers and partners here.

5.3.   We normally process Personal Data within the European Economic Area, but in some cases, your Personal Data may be transferred outside the European Economic Area (hereinafter “EEA”). Your Personal Data will only be transferred outside the EEA under the following conditions:

5.3.1.   Data are transferred only to our reliable partners who ensure the provision of our services to you;

5.3.2.   Data processing or provision agreements have been signed with such partners, which ensure the security of your Personal Data;

5.3.3.   The Commission of the European Union has decided on the eligibility of the country in which our partner is established, i.e., an adequate level of security is ensured; or

5.3.4.    You have given your consent to the transfer of your Personal Data outside the European Economic Area.

5.4.   We may also transfer your Personal Data to:

5.4.1.    State or local government institutions and authorities, law enforcement and pre-trial investigation institutions, courts and other dispute resolution institutions, other persons performing functions assigned by law, in accordance with the procedure provided for by the legislation of the Republic of Lithuania. We provide these entities with mandatory information required by law or specified by the entities themselves;

5.4.2.    Other third parties, such as payment institutions, etc.;

5.4.3.    If necessary, to companies that intend to buy or would buy the Company's business or would conduct joint activities with us or would cooperate in another form, as well as to companies established by us.

6.   WHAT RIGHTS DO YOU HAVE? 

6.1.   As a data subject, you have the following rights with regards to your Personal Data:

6.1.1.  To know (to be informed) about the processing of your Personal Data (right to know);

6.1.2.   To access your Personal Data and the way it is processed (right of access);

6.1.3.   To request the correction, depending on the purposes of the processing of Personal Data, or supplement incomplete Personal Data (right to rectification);

6.1.4.   To request for your Personal Data to be deleted or  for suspension of your Personal Data processing activities (excluding storage) (right to erase and right to “be forgotten”);

6.1.5.   To request us to restrict the processing of Personal Data for one of the legitimate reasons (right to restrict);

6.1.6.   To request for your Personal Data to be transferred (right to transfer). This right will be exercised only if there are grounds for its exercise and appropriate technical measures to ensure that the transfer of the requested Personal Data does not pose a risk of security breach to the data of other persons;

6.1.7.   The right to object the processing of your personal data when we process Personal Data based on a legitimate interest of the Company or a third party, including profiling. If you object, we will only be able to further process your Personal Data for compelling legitimate reasons that take precedence over your interests, rights, and freedoms, or to make, enforce or defend legal claims;

6.1.8.   Withdraw your consent to the processing of your Personal Data when this data is processed or intended to be processed for direct marketing purposes, including profiling as far as such direct marketing is concerned (based on the Personal Data you provide, profiling may be carried out for direct marketing purposes in order to offer you individually tailored solutions and proposals. You can revoke your consent to the processing of personal data by automated processing, including profiling, or object to it at any time).
 

6.2.   We may refuse to implement your rights listed above, except for refusal to process your Personal Data for direct marketing purposes or in other cases where Personal Data are processed with your consent, where GDPR provisions allow us to disregard your request, or where in cases provided for by law, the prevention, investigation, and detection of criminal offences, breaches of official or professional ethics must be ensured, as well as the protection of the rights and freedoms of the data subject, us and others.
 

6.3.   You can exercise some of your rights as a data subject by changing the settings of the user account and the information contained therein. You may submit any request or instruction related to the processing of Personal Data to us in writing by e-mail privacy@globetrott.com. When you make such a request, we may, to better understand the content of your request, ask you to complete the necessary forms, as well as provide an identity document or other information that will help us verify your identity. If you make a request by e-mail, depending on its content, we may ask you to come to us or make a written request.
 

6.4.   Upon receipt of your request or instruction regarding the processing of Personal Data, we will, no later than within 1 month from the date of the request, provide a response and perform the actions specified in the request or inform you why we refuse to perform them. If necessary, the specified period may be extended by a further 2 months, depending on the complexity and number of applications. In this case, we will notify you of such an extension within 1 month of receiving the request.

 

6.5.   If Personal Data is deleted at your request, we will retain only copies of information that is necessary to protect the legitimate interests of us and others, to comply with government obligations, to resolve disputes, to identify disruptions, or to comply with any agreements you have with us. 

 

7.   WILL WE SEND YOU NEWS? 

7.1.   By subscribing to our newsletter, you give us consent to send you promotional offers and information about our services, as well as invite you to participate in various surveys, so we could continuously improve the quality of our services. 
 

7.2.   We may also send in-app messages and pop-up notifications for the above-mentioned purposes. You have an option to opt-out from receiving such notifications.
 

7.3.   We can collect information about engagement with our promotional materials, such as open rate, links clicked and so on. This information is collected to offer you relevant and more tailored news. For this purpose, we may use cookies or other tracking technologies which are described in this Privacy Policy. 
 

7.4.   We may send you information about our partner’s services and promotional offers, on many occasions these offers will include affiliate partnership links - and if users make purchases, we will be compensated accordingly. 
 

7.5.   Your contacts may be passed on to our partners/processors who provide us with communication automation platforms and/ or quality assessment services.
 

7.6.   If you wish to stop receiving promotional information from us, you can easily withdraw your consent by (1) clicking the “unsubscribe” button within the newsletter, (2) updating your App settings to stop notifications and (2) sending an e-mail to privacy@globetrott.com with your request.  
 

7.7.   Withdrawal of consent does not automatically oblige us to destroy your Personal Data or provide you with information about the Personal Data we process, such requests must be made separately. 

 

8.   HOW WILL WE ORGANISE GAMES, PROMOTIONS, CONTESTS?

8.1.   Participation in any games, promotions or contests we publish is optional. To participate in a contest, game, or promotion that we announce, you are required to provide the required information, including your Personal Data. 
 

8.2.   You have the right to refuse to withdraw your consent to the processing and use of your Personal Data for this purpose at any time. You may do so by writing to us at the email address provided or by any other means (for example, by clicking on the relevant link in the email). If you withdraw your consent, you will be removed from the list of participants and will no longer participate in the game, promotion, or contest.
 

8.3.   If you participate in our games, contests, and promotions, we have the right to contact you using the contact details provided and/or to publish information about you as a winner on the Website, Social Accounts, or other publicity channels we specify in the rules of the game, contest, or promotion.
 

8.4.   We may use a software application based on automated decision making to process registrations and/or to determine winners. This will be notified in the rules of the game, promotion or contest or will be apparent from the links we provide. In this case, if you do not wish to be subject to automated decision making, you will not be able to participate in the game, promotion, or contest.

 

9.   HOW DO WE PROTECT YOUR PERSONAL DATA?

9.1.  Your Personal Data is processed responsibly, securely and is protected from loss, unauthorized use, and alteration. We have put in place physical and technical measures to protect the information we collect from an accidental or unlawful destruction, damage, alteration, loss, disclosure, as well as from any other unlawful processing. Security measures for personal data shall be determined considering the risks arising from the processing of Personal Data. 
 

9.2.   Although we will do our best to protect Your Personal Data, we cannot guarantee the full security of Personal Data shared or transmitted to the Website or App. However, once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
 

9.3.   Our employees and partners cooperating with us have made a written commitment not to disclose or distribute your Personal Data to third parties.

 

10.   HOW DO WE USE ANALYTICAL DATA, COOKIES AND OTHER TRACKING TECHNOLOGIES?

10.1.   We always improve our Website, App, services and user experience. Therefore, we must know what information is most relevant to the Website and the App visitors, how often they connect, what browser and device they use, what content is mostly read, what region visitors come from, and similar demographics and statistics. For this, we use Google Analytics tool, which lets us collect and analyse the relevant data. You can learn more about how Google Analytics works and the information it allows us to collect and analyse here. You may opt-out from collection of data by Google Analytics, as described here. You, also, can change your browser settings to prevent Google Analytics from analysing information. 
 

 10.2.   Cookies are small files that are stored in the browser of a Website visitor’s device when you browse websites. Other technologies, such as pixels, local storage, etc. may be used for similar purposes. Cookies are widely used to make websites work or to function better and more efficiently. In this policy, all the above technologies are referred to as “cookies”.
 

 10.3.   We use cookies to analyse information flows and user behaviour, to promote trust and ensure security, as well as to ensure the proper functioning of the Website, the App, the CMS, and its improvement. Cookies are also used to memorize your chosen settings so that the content displayed to you on the Website and the App, could be personalized according to your preferences.
 

10.4.   You can choose whether you want to accept cookies. If you do not agree to cookies being stored on the browser of your computer or other devices, you can mark it in the cookie acceptance bar or change the settings of your browser (all at once or one by one or in groups). To opt-out of cookies on your mobile device, you must follow the official instructions for that device. You can control and/or delete cookies as you wish – for details, see http://www.youronlinechoices.com/  and http://www.AllAboutCookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. But if you do this you may have to manually adjust some preferences every time you visit the Website or the App while some services and functionalities may not work. 
 

10.5.  You may opt-out of the use of third-party cookies for advertising purposes by visiting the Network Advertising opt-out page at http://www.networkadvertising.org/managing/opt_out.asp.

 We may use mandatory cookies that are necessary for the operation of the Website, analytical cookies, functional cookies to analyse Website traffic, memorize user preferences and adapt them to the Website so that we can provide enhanced features, performance cookies, third-party cookies that use third parties, advertising cookies to display personalized and general advertising to you.
 

10.6.   We may use mandatory cookies that are necessary for the operation of the Website, analytical cookies, functional cookies to analyse Website traffic, memorize user preferences and adapt them to the Website so that we can provide enhanced features, performance cookies, third-party cookies that use third parties, advertising cookies to display personalized and general advertising to you.
 

10.7.    Cookies we use:

11. CONTACT US

11.1.   If you have any questions about the information provided in this Privacy Policy, please contact:

 E-mail: privacy@globetrott.com 

 Address: Spindulio g. 5-27B, Šiauliai, Lithuania.

11.2.   If you wish to make a complaint about our processing of Personal Data, please provide it to us in writing, providing as much information as possible. We will cooperate with you and try to resolve any issues immediately.

11.3.   If you think that in accordance with the GDPR your rights have been violated, you can submit a complaint to our supervisory authority – the State Data Protection Inspectorate, more information and contact details can be found on the Inspectorate’s website (https://vdai.lrv.lt/). We strive to resolve all disputes promptly and peacefully, so we invite you to contact us first.

 

12.   FINAL PROVISIONS

12.1.   We may change this Privacy Policy. We will notify you of any changes on the Website and the App by posting an updated Privacy Policy or by other usual means of communication. Amendments or modifications to the Privacy Policy will be effective from the updating date specified in the Privacy Policy unless a different effective date is specified.

12.2.   If you continue to use the App, the Website, the CMS, order services from us, contact us after we have changed the terms of the Privacy Policy, you will be deemed to have agreed to the changed terms of the Privacy Policy.