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Privacy Policy & Cookies

Last update: August 2023
 
TRAZLER has developed a website accessible at the URL trazler.com (hereafter " the Website "), giving access to the digital platform of TRAZLER. 

TRAZLER is concerned about your privacy and the protection of the personal data you provide to us via the website and hereby informs you about the processing of your personal data and your rights with regard to this data, in accordance with the provisions of Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR") and Law N°. 78-17 of 6 January 1978 on data processing, files and freedoms as amended ("LIL").

Within the framework of these regulations, TRAZLER undertakes to comply with the following principles:
1. Ensure transparency, fairness and lawfulness in the processing and use of personal data.
2. Limit the processing of personal data to specific, explicit and legitimate purposes.
3. Minimise the collection and storage of personal data in relation to the purpose of the processing,
4. Ensure the accuracy of personal data and allow for their erasure or rectification
5. Limit the retention of personal data, 
6. To ensure the security, integrity and confidentiality of personal data.
 
We inform you of the processing carried out so that you can provide us with your data in full knowledge of the facts, before confirming your reservations.
 
Content
1. Identity and contact of the data controller
2. Categories of personal data collected by TRAZLER
3. Legal grounds and purposes of the collection of your personal data by TRAZLER
4. Recipients of your personal data
5. Storage periods of your personal data
6. Your rights regarding your personal data
7. Security
8. Cookies and third party technologies
 

1. Identity and contact of the data controller

The data controller is the company TRAZLER EUROPE SAS, a legally-constituted French company with registered office at 120 avenue des Champs Elysées 75008 Paris, registered with the RCS of Paris under number 878 799 006. 
 
If you have any questions relating to this privacy policy, you can contact TRAZLER by email at support@trazler.com.
 

2. Categories of personal data collected by TRAZLER 

Personal data is information about you as a natural person that identifies you as such. You may be required to communicate this data to TRAZLER via various communication channels and  particularly within the framework of the use of the Website. 
 
The collection concerns the data of all travelers registered at the time of the booking confirmation. You warrant that all registered individuals have given their consent.
 
In the context of your relationship with TRAZLER on the Website, the following categories of personal data may be collected:
 
Contact information
First name, last name, date and place of birth, e-mail address, telephone number, login details and passwords, home address, work address, IP address, passport or identity card number, driving license number.
 
Preference information
Categories and ranking of travel services: transport, accommodation, car rental, diet and preferences, accessibility needs, family situation.
 
Order and payment information
Billing postal address, Credit card number (if this payment method is chosen).
 
Your consent is an essential prerequisite for the formation of the sales contract. Your reservation cannot be validated if you object to your personal data (first name, last name, address, passport number, etc.) being stored and transmitted to third-party service providers involved in the Organisation of your trip.
 

3. Legal grounds and purposes of the collection of your personal data by TRAZLER

TRAZLER ensures that your personal data is processed lawfully, fairly and transparently in accordance with the applicable regulations for explicit, legitimate and specified purposes. No personal information is collected without the knowledge of our users, nor is it processed for purposes of which you would not have been informed.
 
TRAZLER processes your personal data takes place in several cases:
 
Legal basis 
 
The performance of the contract between you and TRAZLER
The execution of the contract between you and TRAZLER requires the processing of personal data concerning: 
 
  • The creation and management of your personal account on the website.
  • The booking of the stay and the proper execution of the booked travel services.
  • The connection with the third party service providers who provide the travel services offered on the Website.
  • Management and follow-up of customer relations.
  • Accounting and financial management of orders (invoicing, payment).
  • Monitoring customer relations and optimizing services (sending newsletters, satisfaction surveys, managing a loyalty program, etc.).
  • Advertising targeting by TRAZLER via social networks or by newsletter/SMS (only concerns customers who have given their consent to participate in TRAZLER marketing campaigns).
  • Analysis, statistics and reporting.
 
Your consent collected by TRAZLER
If you agree to this by ticking the appropriate box, you may receive newsletters and other marketing material from TRAZLER.
 
TRAZLER will seek your consent to the use of cookies for the following purposes:
  • To allow navigation and use the functionalities of the Website.
  • To memorize browsing choices and provide enhanced/customized functionalities on the Website.
  • To measure the audience and performance of the Website.
Certain data may be processed as part of the analysis of your use of the Website in order to improve the Website and/or for marketing and/or statistical purposes. Certain data may also be processed to store your search and travel service history, accommodation, and travel preferences.
 
Compliance with legal or regulatory obligations incumbent on TRAZLER
In order to comply with its accounting and tax obligations, TRAZLER must keep information relating  particularly to the invoicing and accounting of its services.
 
Legitimate interest of TRAZLER
TRAZLER may be brought to process data for the correction of errors and bugs that may occur on the Website.
 

4. Recipients of your personal data

The recipients of your data within TRAZLER are:
 
  • TRAZLER employees in charge of the IT, administration, communication and marketing departments.
  • TRAZLER employees whose intervention is necessary for the fulfilment of the services or the follow-up of the customer relationship.
  • Suppliers of the booked travel services: tour operators, hotels, airlines, railway companies, car rental agencies, insurance companies etc. These suppliers are subject to compliance with applicable legislation and will process your data in accordance with their own privacy policies. We invite you to consult their data policies available on their websites where applicable.
  • Subcontractors commissioned by TRAZLER: back office, GDS, technical service providers, remote payment service providers, data hosting service providers, e-mailing services, data analysis services etc.
The service providers are subject to compliance with the applicable legislation. They act on the instructions of TRAZLER and may not use the data for any other purposes than those mentioned in Article 3.
 
Personal data will not be transferred to third parties who are not involved in the processing of data for the purposes described herein.
 
Data will not be transferred to service providers established outside the European Union unless the travel service booked is to a country outside the European Union and the proper execution of the trip requires the transfer of data to this local supplier established outside the EU. 
 
If TRAZLER is required to pass on data to a service provider outside the EU (when booking travel or tourism services outside the EU), TRAZLER will put in place the necessary and appropriate safeguards to ensure a sufficient level of protection for your personal data:
 
  • By signing Standard Contractual Clauses for the transfer of personal data to subcontractors established in third countries, adopted by the European Commission, and, if necessary, additional measures, in accordance with ruling C311/18 of the Court of Justice of the European Union.
  • By the existence of adequacy decisions of the European Commission, allowing the transfer of personal data to a given country.
 
In any event, apart from the cases mentioned above, TRAZLER does not transmit or sell the personal data of its users to third parties unless such disclosure is made necessary by law, an authority (for example the tax authorities or the AP) or a judge. In this case, TRAZLER undertakes, as far as possible, to inform you (unless TRAZLER is not authorized to do so, particularly in view of the legal, regulatory or judicial obligations which may be incumbent on it).
 

5. Retention periods of your personal data 

Essentially, we keep your personal data only for the time necessary for the purposes of the processing for which they were collected.
 
Your personal data will be stored from the date of booking the trip and for 3 years after the end of the trip. This retention is increased, for the data concerned, by the duration of the applicable legal requirements, i.e. five (5) years from the end of the contractual relationship.
 
Once the purposes for which the processing was set up have been fulfilled, your data will be either deleted or archived through an anonymization process.
 

6. Your rights regarding your personal data 

You are free to consent or not to the processing of your personal data and can modify the personal data that you have entered in your personal account.
 
You benefit from the following rights on your personal data, under the conditions set out in the aforementioned texts:
 
  • The access to your personal data;
  • the rectification and deletion of your personal data;
  • the limitation of processing.
  • the right to object to the processing;
  • the portability of your personal data;
  • the definition of guidelines on the fate of your data after your death;
  • the right to withdraw your consent to data processing at any time.
 
These rights can be exercised:
 
  • by sending a registered letter with acknowledgement of receipt to the postal address indicated in article 1 or
  • by sending an email to support@trazler.com;
 
In this context, your request to exercise your rights must indicate your first name, last name and email address. For the purposes of verifying your identity, you may be asked to provide a copy of a valid proof of identity in order to avoid any malicious or fraudulent act.

A response will then be sent to you within a maximum period of one (1) month following receipt of the request. Depending on the complexity of your request, this period may be extended by two (2) additional months. It will also be necessary to specify the address to which the response should be sent.

In the event that you consider that your rights are not respected with regard to the protection of your personal data or that an action relating to the conditions of processing of your personal data would be incompatible with the GDPR or the LIL, you may file a complaint with the CNIL cnil.fr.
 

7. Security

TRAZLER is committed to ensuring the security of your data in accordance with the GDPR in order to prevent your data from being distorted, damaged or communicated to unauthorized third parties.
 
TRAZLER takes the appropriate technical and organizational measures to avoid the loss, misuse, alteration and deletion of your personal data.
 
The personal data collected are treated in the respect of confidentiality by the duly authorized personnel of TRAZLER.
 
TRAZLER also ensures that each of its service providers that it uses for processing purposes implements appropriate safeguards to ensure the integrity and confidentiality of your personal data.
 
In the event of a security breach resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to transmitted personal data, TRAZLER shall notify all data controllers of the data breach to the CNIL within 72 hours as well as the data subject of the processing operation, if there is a high risk to his/her personal data.
 

8. Cookies and third-party technologies

Cookies are small text files placed and/or read on your device, for example when viewing a website or running a mobile application. They are therefore information stored in the persistent memory (hard drive for example) of your device by the browser on request of the website or a third-party script present on the website visited.
 
As a reminder, TRAZLER uses cookies and other similar technologies, in particular for the purposes of:
 
  • functioning of the Website;
  • user authentication; 
  • establishing statistics concerning the use of the Website.
 
V Cookies required
These cookies are essential for browsing a website and using its functionalities, for example to access secure areas, identify and memorize the consultation format (PC, tablet, smartphone). Without these cookies, the requested services, such as shopping carts, electronic invoicing, are not possible.
 
V Functionality cookies 
These cookies allow the Website to memorize the choices made (user name, size and fonts, language, region, etc.) and thus provide improved, more personalized functionalities. The information collected by these cookies can be made anonymous and cannot track the user's navigation on other websites.
 
V Performance cookies
These cookies collect information on how users use the Website, such as which pages are most frequently visited and any error messages transmitted from the pages of the Website. These cookies do not collect user identification information. All information collected by these cookies is aggregated and therefore anonymous. They are only used to improve the functioning of the website.
 
V Targeting Cookies or Advertising Cookies 
TRAZLER does not currently use such cookies, but it is possible that they will be used in the future. In this case, TRAZLER will revise this Policy in order to inform the user of the type of cookies used. 
 
Cookie management - How do I accept or decline cookies?
You can, at any time, modify your wishes regarding the deposit of cookies via third-party services or via the settings of your Internet browser (Google Chrome, Mozilla Firefox, MacOS Safari, Microsoft Internet Explorer, etc.).
 
You can thus authorize or refuse the deposit and/or reading of all or part of the cookies.
 
Prior consent to the deposit of cookies:
This agreement is valid for a period of thirteen (13) months from the first deposit in your device. Once this period has elapsed, the agreement will be requested again for the use of these cookies.
 
How to accept or refuse cookies?
You can manage the deposit of cookies by manually setting your browser. The configuration of each browser being different, we invite you to refer to the help menu of your browser to know how to modify your choices regarding cookies:
 
  • Microsoft Internet Explorer;
  • Apple Safari;
  • Google Chrome;
  • Firefox;
  • Opera.
 
To do so, you can follow the recommendations of the CNIL, available at the following address: cnil.fr
 
We inform you that it is however possible that, after having deactivated cookies, some pages of the Website may no longer be accessible to you.
 
We draw your attention to the fact that refusing the deposit of cookies on your terminal is also likely to alter your user experience as well as your access to certain services or features of the Website.
 
 
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