Last updated: May 18, 2018
1. About This Document
2. Your Consent
By using our websites, using our social media channels, posting comments about us in any forum, providing any personal data to us, making enquires with us for travel services, creating an online account or booking any travel services with us, you confirm that you agree to and consent to the terms of this document and our collection and use of your personal data, to the extent that your consent is required by any applicable law.
3. Copyright Notice
This document, and all content of our websites is Copyright© Grand European Tours (2003) Inc. All rights reserved.
4. About Us
5. Contacting Us
6. Our Commitment
We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand many of our customers care about how personal data is used by us, and we want to share with you our policies and practices.
7.1: Our customers
7.2: Examples of who this policy covers
7.3: When we are data processor only
7.4: Terms used in this policy
When we refer to "processing" your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.
When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke vacations, package vacations, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provided by a third party which we book for you (acting as agent for you or the third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.
7.5: What Laws We Comply With
We process your personal data in accordance with the following data protection law(s): The Data Protection Act 1998 (which covers protection of personal data generally).
We also seek to comply generally with the laws of the United States in relation to the processing of your personal data.
8. What Types Of Personal Data We Process
This section summarizes the types of personal data about you that we process:
8.1: Data concerning you as an individual
This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licenses, card and other payment details, and financial data, health data relevant to your planned travel, and travel insurances held, results of searches carried out against you, your preferences, frequent flyer or travel partner program affiliation and member number, and any other data provided to us by or in relation to you which concern you as an individual.
8.2: Sensitive information
In some instances it may be necessary to collect “sensitive information”, such as your religion and details of medical, dietary, mobility or factors relevant to your booking. As we are required by law to obtain your consent to the collection of “sensitive information”, we will assume that when you provide such data to us, you have consented to our collection and use of it In accordance with this policy.
8.3: Business related data
If you are an individual associated with a business or other organization that is our customer, your personal data may include the following data that we link to you: business or organization details (such as name, address, telephone numbers, payment arrangements, financial data, etc.), your relationship with that business or organization (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).
8.4: Inquiry and booking data
Data concerning inquiries and bookings made with or through us for travel services, including where you are making the inquiry or booking or are the recipient of the travel services to which the inquiry or booking relates. This data may include: records of inquiries and searches for vacation and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your inquiry; details of results, quotes, proposals, estimates and other data given in response to inquiries; details of the vacation, accommodation, travel, car hire, and other travel services booked or inquired about; details of passengers / vacationers traveling; details of the provider of travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport data and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.
8.5: Performance information
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any vacation or other travel services, and information relating to payments to be made.
8.6: Survey data
Data collected or generated out of any surveys we conduct.
8.7: Feedback and user generated content (UGC)
Information or content provided by you in relation to your feedback or experience on a past current or future trip with us.
8.8: Competition information
Information collected or generated out of any competitions or promotions we run.
8.9: Account, registration and loyalty data
Data concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.
8.11: Social media
Any data (including your social media user details, feedback, comments and photos) you post on our social media channel or any forum which relates to us.
8.12: Website usage data
We may collect data about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.
This data may also include: data inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.
8.13: Cookie Notice
What are Cookies?
Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimize user experience and for features and services to function properly.
What Cookies do we use?
There are different types of cookies. They all work in the same way, but have minor differences and we may use the following:
Session cookies last only for the duration of your visit and are deleted when you close your browser. These facilitate various tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.
Persistent cookies last after you have closed your browser, and allow a website to remember your actions and preferences. Sometimes persistent cookies are used by websites to provide targeted advertising based upon the browsing history of the device. We use persistent cookies to allow us to analyze customer visits to our site. These cookies help us to understand how customers arrive at and use our site so we can improve the overall service.
Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, and ensuring the security of your experience. Without these cookies services you have asked for, such as applying for products and managing your accounts, cannot be provided. These cookies don’t gather information about you for the purposes of marketing.
These cookies collect information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is only used to improve how a website works, the user experience and to optimize our advertising. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
These cookies allow the website to remember choices you make (such as your username). The information these cookies collect is anonymized (i.e. it does not contain your name, address etc.) and they do not track your browsing activity across other websites. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
These cookies collect several pieces of information about your browsing habits. They remember that you have visited a website and this information is shared with other organizations such as media publishers. These organizations do this in order to provide you with targeted adverts more relevant to you and your interests.
Third party cookies
8.14: How can I exercise choice regarding cookies and other types of online tracking?
Most web browsers allow some control to restrict or block cookies through the browser settings, however if you disable cookies you may find this affects your ability to use certain parts of our website or services. For more information about cookies visit https://www.aboutcookies.org.
9. How We Collect Or Generate Your Personal Data
This section sets out the ways in which we may collect or generate personal data concerning you.
9.1: Visiting our website
By visiting and using our website you or your computer may provide personal data. This includes: data which is automatically provided by your browser to our servers; data record on our web servers about your interaction with our website and pages viewed; data we capture or place on your computer or generate using cookies or other technologies on our website; and data you input into forms and fields on our website.
Cookies - Cookies collect data that includes the server your computer is logged onto, your browser type and how you gained entry to our website. Therefore, when you visit our website anonymously, details are recorded about your visit, such as, in addition to the matters described in the previous paragraph, time and date, pages accessed and time spent. This data is used in an anonymous form for statistical purposes and as such, cannot be used to identify you individually. A cookie cannot retrieve any other data from your hard drive, pass on computer viruses or capture your email address or any other personally identifiable data. You should note that accepting cookies is required if you want to view our websites, because they are essential for our site administration and security.
You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimize your visit to our site and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions. If you reject all cookies, you may not be able to use our web sites.
9.2: Data you provide
Your personal data will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any data to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising data, including brochures.
If you do not provide us with your personal data we will be unable to provide you with data or book travel services for or on your behalf.
9.3: Data obtained from third parties
We may obtain personal data concerning you from third parties, including: providers of vacations, accommodations, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organizations; from any business or organization you are associated with; and telephone numbers identified by the telephone system when you telephone us.
9.4: Data generated by us
We and any suppliers or sub-contractors working for us may generate personal data relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through analysis of your personal data or data gained from your use of our website. We may record telephone calls with you when lawful to do so.
10. What Do We Use Your Personal Data For?
This section sets out the uses which we make of your personal data:
10.1: Operate our website
Operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing accounts or registrations you have with our websites and making changes to your settings and profile at your request.
10.2: Provide data and respond to inquiries
Provide data to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.
10.3: Bookings and other contracts
Enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorized or made with us which relate to you.
To collect and make payments due and administer our accounts.
10.5: Communication with customers
Communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.
10.6: Record keeping
Keep internal records and maintain reasonable archives, including concerning as to inquiries, bookings, contracts, travel services, and complaints.
10.7: Manage and improve our business
Analyze, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyze the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this data to ascertain interests so that we can better tailor our business offerings.
10.8: Direct marketing
To carry out direct marketing to you. See next section below for further information.
10.9: User Generated Content (UGC)
Use of Reviews: By submitting content to our website by electronic mail, postings on our website or otherwise, including any reviews, questions, comments, suggestions, ideas, photos or the like contained in any submissions (collectively, “Submissions”), you grant Grand European Tours (2003) Inc. and its affiliates a nonexclusive, royalty-free, perpetual, transferable, irrevocable and fully sub-licensable right to (a) use, reproduce, modify, adapt, translate, distribute, publish, create derivative works from and publicly display and perform such Submissions throughout the world in any media, now known or hereafter devised; and (b) use the name that you submit in connection with such Submission.
Use of User Generated Content (UGC): By submitting content to our social media channels or websites you grant us a non-exclusive license to use the content you add to our websites. For example, we may use this information in any of our brochures or for our campaigning purposes or marketing materials.
Report aggregate data concerning usage of our websites to our advertisers. We may create anonymous statistical data about browsing actions and patterns, without identifying any individual.
10.11: Cooperation with government, police and judicial authorities
Provide information in response to a command or request from a government, police or judicial authority. This could include, by way of example, a government agency, police department, or court that either requires or asks us to voluntarily cooperate in providing information for their investigation of any matter or for purposes of a pending proceeding.
10.12: Anything you have specifically consented to
For any purpose for which we have obtained your consent.
11. Period For Retaining Your Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
12. Use Of Your Personal Data For Direct Marketing
12.1: Direct marketing by us
As a part of our commitment to your privacy, Grand European Tours (2003) Inc. supports and adheres to the guidelines and best practices adopted by the Direct Marketing Association's "Privacy Promise to American Consumers." We have agreed to (1) provide customers with notice of their ability to opt out of data rental, sale or exchange with other marketers; (2) honor customers' requests not to share their data with other marketers; and (3) honor customers' requests not to receive mail, telephone or other solicitations from Grand European Travel (Grand European Tours (2003) Inc.)
We may use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.
We may also use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.
You will be free to withdraw your consent to this at any time, by contacting us by phone on 1-800-552-5545 or email us at info@GETours.com.
12.2: Direct marketing by third parties
We may disclose your personal data which is contact data (such as name, e-mail, postal address) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to stop our disclosure of your personal data for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal data from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.
13. Disclosure Of Your Personal Data
We transfer your personal data to third parties in the following circumstances:
13.1: Credit Checks
We may disclose your personal data to third parties (including intermediaries) to carry out checks concerning you or enforce a booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.
13.2: Bookings and performance of contracts
We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking inquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).
13.3: Suppliers of travel and other services
We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any inquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal data to any supplier with whom we make any inquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or inquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Data provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
13.5: Business function outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal data to them as required for use for or processing as part of those purposes.
13.6: Public forums etc.
Where any facility on our website is clearly designed to make some of your personal data public (e.g. posts you make to any public forum or reviews facility) then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.
13.7: Legal requirements
We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.
13.8: Direct marketing by third parties
We may disclose your personal information to third parties to carry out direct marketing to you. See the direct marketing section above.
13.9: Customer representatives
If our customer is a business or organization, and we are holding your personal information in your capacity as an associate of that business or organization (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal data. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
13.10: Business acquirers
If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.
14. How Third Parties Will Handle Your Personal Data
Where we provide your personal data to a third party one of the following two circumstances will apply:
14.1: Processing on our behalf
14.2: Processing on their own account
15. Location Of Your Personal Information
15.1: Transfer of personal information overseas
We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and information technology and business service providers.
In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.
Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.
In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.
16. Keeping Your Information Secure
16.1: Our security measure
Our general commitment
We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organizational measures against unauthorized or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.
Transmissions between your web browser and our servers
We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.
Storage of your personal information
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.
16.2: Your security measures
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.
We encourage you to be careful about whom you give personal data to. Regarding sensitive personal data, such as payment card information, or passport numbers or log-in details, we will only ask you for such information in person or through our website, or by telephone in connection with a booking you make or made. If you are ever in doubt about who is contacting you, asking for information, or why, please do not provide the information. Instead, contact us directly to inquire about the request for information. Please let us know if someone purports to contact you in other circumstances, using our name.
16.3: How Long Do We Keep Your Personal Information For?
We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.
17. Your Rights
17.1: Access to your personal information
You may ask us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you a copy of your personal data that we hold. We may charge a fee for handling your request, in an amount prescribed by law. The law allows us, in certain cases to refuse your request, and we will advise you at the time if this is the case.
17.2: Use for direct marketing
You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or contact us by phone on 1-800-552-5545 or email us at info@GETours.com. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading. Please include your full name, email address, and mailing address.
17.3: Correction of inaccuracies
We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date.
If the data we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.
17.4: Complaints to applicable authority
The laws we comply with are regulated by the Oregon Department of Justice. In addition to your rights above, if you have a complaint or concern, you can seek assistance from such government regulator, who has powers to compel us to comply with laws and fine us for non-compliance. Before you do so, we hope you will contact us first to discuss any complaint or concerns you have.
19. Applicable Law And Disputes
This policy is subject to the law of the state of Oregon. Any dispute shall be governed by Oregon law and subject to the jurisdiction of Portland, Oregon.
20. Linked Websites
Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.