Privacy policy

1. What information do we collect?

Personal information you disclose to usWe collect personal information that you voluntarily provide to us when you register on the services, express an interest in obtaining information about us or our products and services, when you participate in activities on the services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Contact preferences

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Trust

Payments. You may find their privacy notice link(s) here: https://www.trustpayments.com/ .

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To save or protect an individual's vital interest.We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your personal information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the 'data controller' under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a 'data processor' on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the 'data controller' responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. How do we handle your social logins?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services.

Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in India. If you are accessing our Services from outside India, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), in India, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third- party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here: http://www.traveasy.eu/data-processing-agreement . We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

EU-US and Swiss-US Privacy Shield Frameworks:We comply with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the UK, and Switzerland to the United States. Although Privacy Shield is no longer considered a valid transfer mechanism for the purposes of EU and Swiss data protection law, in light of the judgement of the Court of Justice of the European Union in Case C-311/18 and opinion of the Federal Data Protection and Information Commissioner of Switzerland dated 8 September 2020, we will continue to comply with the principles of the EU-US and Swiss-US Privacy Shield Frameworks. Learn more about the Privacy Shield program. To view our certification, please visit https://www.sectigo.com.

We adhere to and comply with the Privacy Shield Principles when processing personal information from the EU, UK, or Switzerland. If we have received your personal information in the United States and subsequently transfer that information to a third party acting as our agent, and such third party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.

With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission ('FTC'). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have any questions or concerns relating to our Privacy Shield certification, please write to us at the contact details below. We commit to resolving any complaints or disputes about our collection and use of your personal information under the Privacy Shield. However, if you have an unresolved complaint in connection with our certification, we commit to cooperating with the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner, and the Swiss Federal Data Protection and Information Commissioner, as applicable, and to comply with the advice given by them in respect of the complaint. See the following list of EU DPAs.

In limited situations, EU, UK, and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Please be sure to review the following sections of this privacy notice for additional details relevant to our participation in the EU-US and Swiss-US Privacy Shield:

WHAT INFORMATION DO WE COLLECT? To learn more about the types of personal data we collect.

HOW DO WE PROCESS YOUR INFORMATION? To learn more about the purposes for which we collect and use personal information about you.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? To learn more about the type or identity of third parties to which we disclose personal information, and the purposes for which we do so.

WHAT ARE YOUR PRIVACY RIGHTS? To learn more about the right of individuals to access their personal data.

8. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the Services within a secure environment.

10. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data, we may have collected from children under age 18, please contact us at info@traveasy.com .

11. What are your privacy rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'How can you contact us about this notice?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section ' How can you contact us about this notice?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account InformationIf you would at any time like to review or change the information in your account or terminate your account, you can:

Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our services.

If you have questions or comments about your privacy rights, you may email us at info@traveasy.com .

12. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your

privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. How can you contact us about this notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), KEVIN PATEL, by email at kevin.patel@brightsun.co.uk or info@traveasy.eu , by phone at 02034115098 , or contact us by post at:
Brightsun Travel Europe Limited KEVIN PATEL

Regus House, Harcourt Centre,
Block 4, Harcourt Road,
Dublin, D02 HW77, Republic of Ireland.

If you are a resident in the United Kingdom, we are the 'data controller' of your personal information. We have appointed Kevin Patel to be our representative in the UK. You can contact them directly regarding our processing of your information, by email at info@traveasy.eu , by visiting http://www.brightsun.co.uk, by phone at +442034115098 , or by post to:
14 Hanworth Rd,
London TW3 1UA (UK)

15. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: https://www.brightsun.co.uk/newsletter-unsubscribe .