Last revised: 7 June 2021

Introduction

JourneyHero Holdings Company Limited built the JourneyHero app (App) to assist users (hereinafter, “Users”) with purchasing travel and travel-related products (hereinafter, the “Service”). This Service is provided by JourneyHero Marketing Company Limited (JourneyHero) at no cost and is intended for use as is. This page is used to inform Users and potential Users regarding our policies with the collection, use, and disclosure of personal information collected while using the Service. If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The personal information that we collect is exclusively used for providing and improving the Service. We will not use or share your information with any third-party except as described in this privacy policy (hereinafter, the “Privacy Policy”). The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at www.journeyhero.net unless otherwise defined in this Privacy Policy.

Information Collection and Use

For a better experience while using our Service, JourneyHero collects and holds your personal information when registering for (optional), or logging in our App (optional), using the Service, engaging with us on social media, submitting applications forms or requesting information from JourneyHero. The information that we request will be retained by us and used as described in this Privacy Policy.

When using our App, we may request the following information:

• Name;
• Email address;
• Telephone / Mobile Phone;
• Any other contact details;
• Passport details;
• Credit card details (only when making online reservations);
• Travel Preferences;
• Location Information;
• Technical Information;
• Dietary requirements (which may disclose religious beliefs);
• Health/medical/mobility requirements;

Why Personal information Is Collected

Personal information in our App is collected for the following reasons:

• In order to be able to process your online reservation, contact you if necessary and to identify you when your travel arrangements are delivered or changed.
• To be able to assess your eligibility to a number of fares or special discounts.
• To be able to develop and recommend products and services based on an understanding of your interests and needs.
• To be able to provide you with customised services and targeted offers according to your preferences.

Log Data

We want to inform you that whenever you use our Service, in a case of an error in the App we collect data and information (sometimes through third-party products) on your phone called “Log Data”. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App when utilizing our Service, the time and date of your use of the Service, and other statistics. The Log Data will not contain personal information and no personal information shall be transferred to servers on the Cloud for analysis but Log Data which does not contain personal information may be transferred to Cloud servers for the express purpose of improving the Service.

Cookies

“Cookies” are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory. The Service does not use these Cookies explicitly. However, the App may use third-party code and libraries that use Cookies to collect information and improve their services. You have the option to either accept or refuse these Cookies and know when a Cookie is being sent to your device. If you choose to refuse the Cookies, you may not be able to use some portions of this Service.

Disclosure of your Personal Information

We may disclose your personal information with third-party companies  and individuals and their employees (including suppliers of travel arrangements, some of whom may be located outside the EEA)  (hereinafter, “Third-parties”) that are involved in the fullfilment of our Service to you,  for the following reasons:

• To facilitate our Service;
• To provide the Service on our behalf;
• To perform Service-related tasks;
• To assist us in analyzing how our Service is used; or
• Other reasons as they case may be for the fullfilment of our Service to you

We may disclose your personal information to any third party that may act as joint data controllers or data processors to JourneyHero which will be the data controller for your data when you obtain our services. For a full list of the Third-parties who may receive this information, please email us at security@journeyhero.net. All Third-parties that act as joint data controllers or data processors to JourneyHero respect and protect the security of your personal information in accordance with the applicable law (including the GDPR) and apply appropriate security measures and safeguards.

We may disclose your personal information outside of our Organization: (a) in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets; and (b) if JourneyHero’ business is bought by a third party, in which case personal information held by it about its customers will be one of the assets to transfer to the buyer.  However, any such transfer will only be on terms that the confidentiality of your personal information is protected and that the terms of this Privacy Policy will continue to be complied with by the recipient.

We may also disclose your personal information to any member of our group, which means other branches of JourneyHero and its subsidiaries.

In addition, JourneyHero may need to release personal information, when such release is necessary to comply with the law or protect the rights, property or safety of JourneyHero, our customers, or others.

Modifying or deleting your Personal Information

All the personal information that you provide to our App may be modified or removed any time you wish, by accessing the appropriate options in our App.

Transfer of Personal Information to Third Parties

Where we disclose your personal information with internal or external third parties, this may involve transferring your personal information outside the European Economic Area (EEA). We will transfer your personal information in accordance with standard contractual clauses (European Commission: Model contracts for the transfer of personal information to third countries) to ensure your personal information is protected and transferred securely in compliance with the applicable law, including the GDPR.

Your Data Protection Rights

The General Data Protection Regulation (GDPR) gives you a range of rights in relation to the personal information that we collect from. You have the right to:

1. Access your personal information: This right enables you to receive a copy of the personal information we hold about you, as well as information on if, how, why and by whom your personal information is processed. You will not need to pay a fee to access your personal information (you shall receive one electronic copy via e-mail) unless we can justifiably demonstrate that the request is unfounded, repetitive or excessive in which case we may also refuse to comply with your request in these circumstances. We will respond to all legitimate personal information access requests within a reasonable timeframe, but we may need to obtain further information from you in order to confirm your identity and the legitimacy of the request.
2. Request update of the personal information: This enables you to obtain correction of any inaccurate to update your personal information, to have any inaccurate personal information corrected and to have incomplete personal information completed, including by means of providing a supplementary statement.
3. Object to processing of your personal information: You may object to processing of your personal information where we are relying on consent or our legitimate interests (or those of a third party) as the justification for processing the personal information. Unless we have a legitimate interest that overrides your interest, we will stop processing your personal information. In the case of processing your personal information for marketing purposes, we will stop processing the personal information for such purposes, if requested by you.
4. Erasure of your personal information (right to be forgotten): This enables you to ask us to delete personal information in the following circumstances:

• where there is no justifiable and/or lawful reason for us continuing to retain and process it (i.e. where the processing of the personal information is no longer necessary for any of the reasons the personal information was collected or the deletion is required by the law);
• where you have successfully objected to the processing of the personal information by the App
• where your personal information have been unlawfully processed.

We may not always be able to delete the personal information such as if there is an ongoing contractual relationship between us or if we are legally required to retain the Personal information, etc.

1. Restrict the processing of your Personal information: you shall have the right to obtain from us restriction of processing where one of the following applies:

• the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of the personal information;
• the processing is unlawful, and you oppose the erasure of your personal information and request the restriction of their use instead;
• we no longer need the personal information for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have objected to processing pursuant pending the verification whether our legitimate grounds override those of yours.

1. Request the transfer of your personal information to you or to a third party: We will provide to you, or a third party you have chosen, your personal information in a structured, machine-readable format.
2. Withdraw consent: Where we are relying on consent to process your personal information you may withdraw that consent.

You can exercise these rights at any time by sending us an email to security@journeyhero.net.

Security

We value your trust in providing us your  personal information, thus we are striving to use commercially acceptable means of protecting it.

It should be noted that for security purposes, no records of credit card information are kept on the cloud and the storage on the App device is not through JourneyHero but is through Apple Pay, PayPal or Visa Checkout. We never keep credit card information because we use only secured tokenised services without the credit card.

In addition, our App is protected by firewalls to ensure that only you can access your Personal information. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee your  personal information’s absolute security.

Third Party Links

This Service may, from time to time, contain links to and from other sites of third-parties. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by JourneyHero and they have their own privacy policies. Therefore, we strongly advise you to review the privacy policy of those websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children’s Privacy

These Services are not to be used by anyone under the age of 18. We do not knowingly collect  personal information from children under 18 years of age. In the case we discover that a child under 18 has provided us with  personal information, we immediately delete all  personal information related to this User from our servers. If you are a parent or guardian and you are aware that your child has provided us with  personal information, please contact us so that we will be able to do necessary actions at the email address: security@journeyhero.net.

Changes to This Privacy Policy

To ensure that the highest level of privacy is being offered constantly to all our customers, our Privacy Policy is regularly reviewed and updated, taking into account any changing requirement such as changes in technology or legislation. Therefore, we strongly recommend that you refer to our privacy policy page from time to time to become aware of any modification and how these changes may affect you. We will notify you of any changes by posting the new Privacy Policy on this page. When an updated version of the Privacy Policy is released, your continued access to the App means that you agree to the updated content and agree to abide by the updated Privacy Policy.

More Information

This Privacy Policy is not designed to form a legally binding contract between JourneyHero and users of our App or Service. Instead, it is a guide to our online protection standards – although of course we do consider it of utmost importance to abide by the principles stated here.

If you have privacy questions which are not answered by this page Privacy Policy or any other concerns about how we use your Personal information, please email us on security@journeyhero.net.

If you wish to report a complaint of if you feel that JourneyHero has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Office address:

23 Stasinou Street, 5th Floor, 2404 Engomi, Nicosia, Cyprus

Postal address

P.O.Box 23378, 1682 Nicosia, Cyprus

Tel: +357 22818456

Fax: +357 22304565

Email: commissioner@dataprotection.gov.cy

JourneyHero Marketing Company Limited registered in Cyprus (Number: HE421894) whose registered address is at 23 Stasinou Street, 5th Floor, 2404 Engomi, Nicosia, Cyprus VAT number: 10421894S (JourneyHero) is part of JourneyHero Holdings Company Limited, the world’s disruptor in online travel & related services.