The protection of your personal data is of utmost importance to ASIA LUXURY TRAVEL. This Privacy Policy aims to inform you about how ASIA LUXURY TRAVEL, whose entities may act as data controllers or processors, collects and processes your personal data that you submit or disclose to us, where the General Data Protection Regulation (“GDPR”) applies.
ASIA LUXURY TRAVEL routinely collects, uses, stores, and transfers various types of data, including Personal Data. We are committed to ensuring the privacy of Personal Data throughout our business and making sure that our employees and business partners also implement the necessary measures to protect it.
This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. It applies where the GDPR is applicable and is accessible on our website and through other channels.
We encourage you to read this Privacy Policy carefully. If you do not agree with its terms, please do not provide us with your personal data. Note that we may be unable to provide you with our services without this data, which could impact your customer experience.
1. PERSONAL INFORMATION
This refers to a combination of data such as your name, address, passport number, telephone number, email address, travel preferences, and any special needs/ disabilities/ dietary requirements that you provide or are provided to us. It also included your social preferences, activities, and information about other people you represent (e.g., those on your booking). Data is collected when you contact us, make a booking, use our website(s)/apps, connect with us via social media, or engage with us or our partners in other ways.
2. PROCESSING YOUR PERSONAL DATA
2.1. Data Processing Purposes
We may collect and process your personal data for the following purposes and share it with ASIA LUXURY TRAVEL companies, subcontractors, and service providers acting as data controllers or processors:
- Contract fulfillment and legal obligations (Articles 6(1)(b) and (c) GDPR): Required by authorities for immigration or border control; necessary information for airlines or accommodations.
- Legitimate interests (Article 6(1)(f) GDPR): For business operations, service quality, customer care, risk management, and security.
- Consent-based processing (Article 6(1)(a) GDPR): For marketing or third-party sharing, with opt-in mechanisms.
- Explicit consent for sensitive data (Article 9(2)(a) GDPR): For processing health, allergy, or religious data necessary for travel arrangements.
Data will be retained as needed for service provision and legal compliance, including tax and commercial regulations.
2.2. Children
Our services are primarily intended for adults. However, we may process data of minors under 16 when they are part of a booking. When required by GDPR, we will seek consent from a parent or legal guardian before processing a child’s sensitive data.
2.3. Links to Other Sites
Our websites may contain links to third-party sites. We are not responsible for the privacy practices or content of those sites. Please review their privacy policies before submitting any data.
2.4. Data Transfers
Your data may be stored or processed outside the European Economic Area (EEA), including by staff or suppliers (e.g., guides, transport providers). In case of business restructuring, your data may be transferred to new entities.
2.5. Service Providers
We may disclose personal data to third-party providers for services such as flight and hotel bookings, safety management, and more, including outside the EEA, as required by local authorities.
2.6. Legal Compliance and Security
We may disclose data as required by law or to protect national security, enforce terms, prevent fraud, or safeguard our operations. Disclosures are made in good faith when reasonably necessary.
2.7. Data Protection Measures
We take all reasonable steps to ensure secure data handling and storage. By providing your data, you consent to such processing and transfer.
3. OUR RECORDS OF DATA PROCESSES
We maintain detailed records of data processing in accordance with GDPR (Article 30) and cooperate with supervisory authorities (Article 31).
4. SECURITY MEASURES
We use technical and organizational measures to secure data from unauthorized access, alteration, or destruction. Data is retained only as long as necessary for processing or legal purposes.
5. NOTIFICATION OF DATA BREACHES
We have procedures to identify, assess, and report data breaches promptly. In the case of a qualifying breach, we will notify authorities and affected individuals per Articles 33 and 34 of the GDPR.
6. HIGH-RISK DATA PROCESSING
We assess and mitigate high-risk processing (Article 35). If required, we consult with Data Protection Authorities (Article 36) to ensure lawful processing.
7. YOUR RIGHTS
You have the right to:
- Access your personal data.
- Request correction of inaccurate data.
- Request deletion (subject to conditions).
- Restrict processing (subject to conditions).
- Object to processing (subject to conditions).
- Request data portability.
- Receive copies of data transfer agreements (e.g., Standard Contractual Clauses).
To exercise your rights or ask questions, contact us at: sales@asialuxurytravels.com
Request handling procedure:
We will acknowledge your request and respond within a reasonable timeframe.
- Our team will assess and verify the request, including your identity.
- If valid, we will process it and notify you of the outcome.
- For excessive or repeated requests, a reasonable administrative fee may apply.
8. COMPLAINTS
If you have concerns about how we process your data, contact our Data Protection Team at sales@asialuxurytravels.com . Complaints will be acknowledged within one week and answered within one month (extendable to two months if necessary). You may also contact a Data Protection Authority or take legal action.
9. CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy from time to time. Changes will be posted on our website, and for significant updates, we will notify you and request consent where applicable.
10. CONTACT
Questions, comments, or requests regarding this Privacy Policy are welcome at: sales@asialuxurytravels.com
