Privacy policy

Avigo GmbH – Privacy policy – UK Market
(Version 0.2 – 15 January 2018)


We respect the privacy of our customers therefore we are committed to the following privacy policy, which is designed to give you peace of mind and confidence.

This privacy policy, as amended from time to time, applies to all visitors of our Website and all Bookings made with Avigo. By using our Website and by making a Booking, you confirm that you have read the privacy policy in full and agree to it.


1. DEFINITIONS

For the purpose of this privacy policy the following words have the following meanings:

"Avigo", "us", "we" or "our" means Avigo GmbH, a limited liability company duly incorporated in Germany with registration at the local court Cologne under company number HRB 89524 and with its registered office at Schanzenstrasse 6-20, 51063 Cologne, Germany;

Booking” means the binding reservation for the chosen services and products at the moment you click the 'Book Now' button on our Website;

DER Touristik” means DER Touristik Group GmbH, a limited liability company duly incorporated in Germany with registration at the local court Cologne under company number HRB 89529 and with its registered office at Humboldtstrasse 140-144, 51149 Cologne, Germany and all its subsidiaries with a a direct or indirect shareholding/participation of at least 50 %;

"Personal Information" means information that relates to a living individual who can be identified from that information or from that information together with other information which is held by or is likely to be held by us;

"Website" means www.avigo.com (including all sub-pages);

"you" or "your" means any and all persons visiting our Website and named on the Booking and in the booking contact's travel party including any person who is added or substituted to a Booking at a later date.

2. PROTECTION OF YOUR PERSONAL INFORMATION


2.1 By disclosing your Personal Information by means of using our Website, writing an email or letter, over the telephone or any other form of communication, you consent to the collection, storage and processing of your Personal Information as stated in this policy.

2.2 In order to operate the services requested Avigo and DER Touristik shall be the joint data controllers of your Personal Information.

2.3 The Personal Information that we collect from you shall be obtained, processed and transmitted in compliance with UK data protection legislation, including European data protection legislation applicable in the UK at the date of your agreement to this privacy policy.

2.4 From 25 May 2018, the General Data Protection Regulation ("GDPR") (Regulation (EU) 2016/679) shall be incorporated within UK data protection legislation. The GDPR shall expand the definition of personal data under UK data protection legislation to include specific categories of personal data and 'sensitive personal data' including information relating to ethnicity, economic and social conditions, biometric data and online identifiers (IP addresses). By accepting this privacy policy, and in accordance with the GDPR, you consent and authorise us to request from our suppliers and process any such personal data and/or sensitive personal data relating to you and/or the members of your travel group as is necessary for the purposes of providing services to you in accordance with this privacy policy.

2.5 Any Personal Information you provide to us when using our Website, shall be understood to have been obtained, processed and transmitted in strict compliance with UK data protection legislation; in accordance with this, you are hereby informed and give your express consent to the inclusion of this information in personal data files held by us and to the processing of the same for the purposes mentioned in clausCOLLECTION OF YOUR PERSONAL INFORMATIONe 4.

2.6 In accordance with UK data protection legislation, you have the right to access and amend the use of your Personal Information by contacting us in writing an email to privacy@avigo.com or by regular mail to Avigo GmbH, Schanzenstrasse 6-20, 51063 Cologne, Germany. Your request must include a signed registered letter specifying the action requested and a photocopy of your national ID document or passport. If you have any questions about this privacy policy or treatment of your Personal Information, you can contact us at the above email or postal address.

2.7 We declare and guarantee that we have introduced the necessary technical and organisational measures to guarantee the security of your personal data and thus prevent their alteration, loss, processing and/or unauthorised access.


3. COLLECTION OF YOUR PERSONAL INFORMATION

3.1 We may collect, store and use the following kinds of Personal Information:

(a) information that you provide by filling in any booking forms or other forms on our Website or which you give us by writing an email or letter, over the telephone or any other form of communication including your name, (home or office) address, (business or private) email address, (mobile, home or office) telephone number, date of birth, nationality, credit card details (i.e. credit card holder name, credit card type and number, CVC code, expiration date) and to the extent available, preferred departure airport and other booking preferences;

(b) information about your computer and about your visits to and use of this Website including where you have clicked on any of our advertising links or banners. This information may include but is not limited to your IP address, geographical location, browser/platform type and version, Internet Service Provider (ISP) and (for users of our service through a mobile device) Unique Device Identifier, operating system, referral source/exit pages, length of visit, page views, website navigation, date/time stamp information and details like the number and location of (mouse) clicks on a given page, mouse movements, scrolling activity and the (search) words you use and the text you type while being on and using our Website;

(c) information that you provide to us for the purpose of registering with us;

(d) information that you provide to us for the purpose of subscribing to our Website services, email notifications and/or newsletters; and

(e) any other information that you choose to send to us.

We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

3.2 If you provide information to us about any person other than yourself, you must ensure that they understand how their information will be used and that you are authorised to disclose it to us, and consent its use on their behalf, before doing so.

4. USE OF YOUR PERSONAL INFORMATION

4.1 Personal information submitted to us via this Website will be used for the purposes specified in this privacy policy or in relevant parts of the Website.

4.2 We may use your Personal Information to:

(a) manage, administer, mediate and contract your holiday bookings made and other services offered through our Website and/or our call-centre;

(b) send you email notifications confirming your bookings made via the Website and/or our call centre as well as for modifications and cancellations;

(c) send you email notifications with important travel documents for your holiday bookings as well as changes to your holiday bookings;

(d) deal with enquiries and complaints made by or about you relating to the Website, your bookings and/or the services offered by us or our suppliers;

(e) provide accounting, billing and audit services, credit or other payment card verification; and

(f) screening purposes, immigration and customs control purposes, safety, security, health, administrative and legal purposes.

(g) manage and administer the Website;

(h) to analyse and improve the services offered on our Website and to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate for marketing and strategic development purposes;

(i) improve your browsing experience by personalising the Website;

(j) enable your use of the services available on the Website including providing you with login details so you may access details of your bookings;

(k) send you general (non-marketing) commercial communications including communications about any important changes to the Website and/or surveys we may ask you to complete;

(l) provide third parties with statistical information about our users – but this information will not be used to identify any individual user;

(m) deliver marketing and adverts to you that show our services and deals that we think you will be interested in including via targeted advertising on third party websites and/or platforms;

4.3 We may monitor, record, store and use any telephone, email or other communication with you for monitoring purposes, in order to check any instructions given to us by you, for staff training purposes, for crime prevention and to improve the quality of our customer service.

5. DISCLOSURES OF YOUR PERSONAL INFORMATION

5.1 We may disclose Personal Information about you to any of our employees, officers, agents, suppliers, partners or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy policy or whom we have appointed to process information on our behalf or manage aspects of our Website. Please note we must disclose Personal Information about you to the relevant suppliers of your travel arrangements in order to provide the services contracted.

5.2 Your Personal Information may be sent to governmental authorities and border control and security agencies. This is known as Advance Passenger Information, sometimes known as APIS, and is a requirement to operate your holiday booking.

5.3 In addition, we may disclose your Personal Information:

(a) to the extent that we are required to do so by law;

(b) in connection with any legal proceedings;

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and

(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling.

5.4 Except as provided in this privacy policy, we will not provide your information to third parties.

5.5 You expressly agree to such disclosures of Personal Information.


6. INTERNATIONAL DATA TRANSFER

6.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we and/or our suppliers operate in order to enable us to use the information in accordance with this privacy policy.

6.2 Information which you provide may be transferred to countries which do not have data protection laws equivalent to those in force in the UK and the European Economic Area (EEA), in particular where your booking destination is outside the EEA. Please note, if we cannot pass this information to the relevant accommodation and/or service providers, whether in the EEA or not, we cannot provide the services to you.

6.3 Information may be transferred to companies contracted by us to perform services in connection with this Website who are based outside the EEA including in the United States, where such organisations have signed up to the US Safe Harbour Principles and/or contracts providing an adequate level of protection have been signed.

6.4 Personal Information that you submit for publication on the website as a review will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

6.5 You expressly agree to such transfers of Personal Information.


7. COOKIES AND WEB BEACONS

7.1 We use cookies on our Website to give you the best possible experience when you use our Website. Most websites use cookies (small lines of text) to make their website function correctly. All information gathered by cookies is completely anonymous and cannot identify you personally.

7.2 A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

7.3 Our cookies are categorised into four main types based on the International Chamber of Commerce guide for cookie categories:

(a) Strictly necessary cookies

Strictly necessary cookies are essential to our Website working correctly. These cookies do not gather any information for marketing purposes or to remember where you have been on the internet.

We use these cookies to:
Enable the booking form to function correctly
We do not use these cookies to:
Allow you to connect to social sites
Use information for tailored advertising with third parties
Improve the performance of our site
Gather personally identifiable information such as name and location

(b) Functionality cookies

Functionality cookies are vital to our Website functioning correctly and are used to improve your visit to the Website. For example, these cookies allow us to remember what holidays you have searched for including hotels and other activities you have previously looked at to help make your holiday search quicker and easier.

We use these cookies to:
Remember what holiday details you have searched for
Remember your language and currency settings
Remember your order details
We do not use these cookies to:
Allow you to connect to social sites
Use information for tailored advertising with third parties
Improve the performance of our site
Gather personally identifiable information such as name and location

(c) Performance cookies

Performance cookies collect information about how you use our Website and whether you experience any issues/errors during your visit to the Website. This information is only used to help us improve our Website experience, fix issues on the site quickly, and make the site easier to use.

We use these cookies to:
Improve the performance of our site
Gather Website traffic information
Gather sales information for our affiliate partners
We do not use these cookies to:
Allow you to connect to social sites
Use information for tailored advertising with third parties
Gather personally identifiable information such as name and location

(d) Targeting cookies

Targeting cookies are based on services provided by third parties, for example, Facebook 'Likes' and Google +1 share buttons. The services provided by these third parties are based on recognising your visit to the Website.

We use these cookies to:
Use information for tailored advertising with third parties
Gather Website traffic information
Allow you to connect to social sites
We do not use these cookies to:
Gather personally identifiable information such as name and location


7.4 We use both “session” cookies and “persistent” cookies on the Website. We will use the session cookies for such purposes as to keep track of you whilst you navigate the Website. We will use the persistent cookies for such purposes as to enable our Website to recognise you when you visit. Session cookies will be deleted from your computer when you close your browser. Persistent cookies could remain stored on your computer for the periods specified below.

7.5 We work with advertising partners to serve ads that we believe are most likely to be of interest to you, based on information about your visit to this and other websites (this information is anonymous in that it does not include your name, street address, email address or telephone number). In order to do this, our advertising partners may need to place a cookie on your computer.

7.6 Some of our Website pages and HTML-formatted e-mail newsletters may use web beacons in conjunction with cookies to compile aggregate statistics about website usage. A web beacon is an electronic image, called a single-pixel (1x1) or clear GIF and is used like cookies to recognize certain types of information on your computer, such as your cookie number, time and date of a page view, and a description of the page where the web beacon is placed.

7.7 If you wish to decline our cookies you can also do so by changing your browser settings. Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.

7.8 More information about cookies, including how to change your browser settings, can be found at www.allaboutcookies.org


8. ADOBE ANALYTICS AND ADOBE TEST & TARGET


8.1We create pseudonymous usage profiles using Adobe Analytics (Omniture) to customize our Website. Adobe Analytics (Omniture) uses cookies, which are text files that are stored on your computer and that allow an analysis of your use of the Website. The information generated by the cookie about your use of this Website is usually transmitted to and stored by an Adobe server in the USA. Since we have activated the IP anonymization on this Website, the server setting made by us ensures that the IP address is anonymized prior to geolocation. The last octet of the IP address is replaced by zeros. Before storing the information generated by the cookie, the IP address is replaced by individual generic IP addresses. Adobe will use this information to evaluate your use of the Website, to compile reports on Website activity, and to provide us with other services related to Website activity and internet usage.

8.2 You can contradict the creation of the pseudonymous user profiles at any time. There are several ways to do this:

(a) One way to object to web analytics through Adobe Analytics (Omniture) is to set an opt out cookie that instructs Adobe not to store or use your information for web analytics purposes. Please note that with this solution, the web analysis will only be done as long as the opt out cookie is saved by the browser. If you want to set the opt out cookie now, please clickhere.

(b) You can also prevent the storage of the cookies used for profiling by setting your browser software accordingly (see clause 7.7 for details).

8.3 We use Adobe Test & Target software to perform A / B testing. Using the tool, it is possible to compare the original version of the Website with a modified variant (e.g. different design and content), and then determine which of the versions leads to improved performance. You can find more information about the functions of Adobe Test & Target here.

8.4 With Adobe Target, no personal information, such as the full IP address, is stored and processed by our Website. Only information is processed that does not allow conclusions about individual persons. A single profile about your usage behavior does not take place either. You have the option to disable Adobe Test & Target on this Website by opting outhere.


9. THIRD PARTY WEBSITES

The Website contains, and our email communications may contain, links to other websites. We are not responsible for the privacy policies or practices of third party websites including use of cookies on such third party websites and you should refer to the third party’s privacy policy for more information.

10. POLICY AMENDMENTS

We may update this privacy policy from time-to-time by posting a new version on our Website. You should check this page occasionally to ensure you are happy with any changes. Your continued use of the Website shall constitute your agreement and acceptance of the changes to this policy.