Privacy Policy
Privacy Statement
DATA PROTECTION POLICY OF MYMALDIVES360.COM
Valid: from 01.05.2022
PERSONNEL OF THE DATA PROCESSOR:
Name: Smart Trend Ltd.
Address: 2724 Újlengyel, Petőfi Sándor utca 48., Hungary
Phone: (+44)186-567-9969
Email: info@MYMALDIVES360.COM
License number: U-001955 issued in Hungary by The Government Office of the Capital City Budapest as a trade authority – https://mkeh.gov.hu/kereskedelmi/idegenforg_nyilv/utazasszerv
Represented by András Kertész, managing director
MYMALDIVES360.COM considers it extremely important to respect and enforce the rights of its customers, passengers, partners, interested parties and all other customers related to data management.
When Smart Trend Ltd. handles its customers’ personal data, it complies with Regulation 2016/679 of the European Parliament and of the Council (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free flow of such data, as well as CXII of 2011. act in accordance with the regulations of the laws on information self-determination and freedom of information.
- DEFINITIONS
data manager: the natural or legal person, public authority, agency or any other body that determines the purposes and means of personal data management independently or together with others, if the purposes and means of data management are determined by EU or member state law, the special provisions on the appointment of the data controller aspects can also be determined by EU or member state law;
data handling: any operation or set of operations performed on personal data or data files in an automated or non-automated manner, such as collection, recording, systematization, segmentation, storage, transformation or change, query, insight, use, communication, transmission, distribution or otherwise making it available , alignment or linking, restriction, deletion or destruction;
data processor: the natural or legal person, public authority, agency or any other body that processes personal data on behalf of the data controller;
The data processor of our website is Utázissystem kft. the CXII of 2011. shall process the data handled by the parties entering into a contract for the performance of data processing activities pursuant to Section 3, Point 17 of the Act and the use of the CeSYS system in accordance with the provisions of the referenced Act and other relevant legislation. In accordance with Section 10 (3) of the Act, the data processor may not make a substantive decision regarding data management, may process the personal data it comes to know only in accordance with the provisions of the data controller, may not carry out data processing for its own purposes, and is also obliged to store the personal data in accordance with the provisions of the data controller and keep.
GDPR: REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (April 27, 2016) on the protection of natural persons with regard to the processing of personal data and on the free flow of such data, and on the repeal of Directive 95/46/EC;
supervisory authority or NAIH: National Data Protection and Freedom of Information Authority;
personal data: any information relating to an identified or identifiable natural person (data subject), identifiable natural person who directly or indirectly, in particular an identifier such as name, number, location data, online identifier or the natural person’s physical, physiological, genetic, mental, special categories of personal data identifiable on the basis of one or more factors relating to their economic, cultural or social identity: personal data referring to racial or ethnic origin, political opinion, religious or worldview beliefs or trade union membership, as well as personal data relating to the sex life or sexual orientation of natural persons ;
customer: those interested in the products and services of Smart Trend Ltd. in person, on the MYMALDIVES360.COM website, by phone or in any other way, or those who enter into a contract with Smart Trend Ltd.
- SCOPE OF PROCESSED DATA, PURPOSE, LEGAL BASIS AND DURATION OF DATA PROCESSING
The data manager or the data processor only handles the personal data whose processing is strictly permitted by the client to the extent necessary to fulfill the purpose. We process the customer’s personal data in order to fulfill the obligations prescribed by law and other generally binding legislation (tax regulations, social and health insurance regulations, etc.).
For information purposes, we present individual categories of personal data:
identification data that are used to clearly and uniquely identify the customer (name, surname, address, birth number, date of birth, permanent address, identification number, VAT number) and contact data (contact address, telephone number, e-mail address and other similar information) , descriptive data (e.g. banking relationship), other data necessary for the fulfillment of the contract, data provided outside the framework of the applicable legislation (photos, use of personal data for individual purposes) are processed within the framework of the customer’s consent
PURPOSE OF DATA PROCESSING
The data manager processes only the data that is necessary to fulfill the purpose. Within the framework of our activity, we will use the customer’s personal data for the following purposes:
- for the purposes included in the declaration of consent (offer to enter into a contract, exercise of rights arising from the concluded contract and fulfillment of obligations, etc.)
- protection of the rights of the Data Controller or other affected persons (e.g. debt collection)
- fulfilling the obligations imposed on the Data Controller in accordance with the generally binding legislation and the decisions of the state administrative bodies
- job advertisement application
- protection of vital interests
SOURCES OF PERSONAL DATA
The personal data processed by the data controller comes from the following sources:
- from the express consent provided by the customer and directly from you (e-mail correspondence, telephone, chat, websites, online contact form, social networks, business cards, etc.)
- from publicly accessible registers, lists and entries (e.g. company register, commercial register, public telephone directory, etc.)
- from a third party authorized by the customer to transfer his personal data to the Data Controller
PERSONAL DATA SUBJECTS
We only process the data of the persons whose data is necessary to fulfill the purpose. Within the framework of our activity, the data of the following persons are processed:
- clients
- employees
- contracting partners
- if necessary, third parties (e.g. job seekers, etc.)
PERIOD OF DATA MANAGEMENT
We process customer data only for the time necessary to achieve the goal. The duration of data management is determined by the declaration of consent submitted by you, the concluded contract or generally binding legislation.
Inquiring about a service on the website, in person, by phone, or in another way
name
Data that is absolutely necessary to identify the customer
The legal basis for data management is the consent of the interested party. The data management lasts until the period specified by the interested party or until the consent is revoked.
e-mail address, telephone number
Data that is absolutely necessary to reach the customer later
subject of interest: period, destination, accommodation classification, board, number of passengers, number and age of children
Data required to specify the customer’s interest and provide an appropriate, personalized response, based on the customer’s own communication.
Data that is absolutely necessary to identify the customer
The legal basis for data management is the consent of the interested party. The data management lasts until the period specified by the interested party or until the consent is revoked.
e-mail address, telephone number
Data that is absolutely necessary to reach the customer later
subject of interest: period, destination, accommodation classification, board, number of passengers, number and age of children
Data required to specify the customer’s interest and provide an appropriate, personalized response, based on the customer’s own communication.
Sign up for newsletter
name
Data that is absolutely necessary to identify the customer
The legal basis for data management is the consent of the interested party. The data management lasts until the period specified by the interested party or until the consent is revoked.
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e-mail address, telephone number
Data that is absolutely necessary to reach the customer later
Using CHAT
name
Data that is absolutely necessary to identify the customer
The legal basis for data management is the consent of the interested party. The data management lasts until the period specified by the interested party or until the consent is revoked.
e-mail address, telephone number
Data that is absolutely necessary to reach the customer later
subject of interest: period, destination, accommodation classification, board, number of passengers, number and age of children
Data required to specify the customer’s interest and provide an appropriate, personalized response, based on the customer’s own communication.
Request for an individual offer
customer name
Data that is absolutely necessary to identify the customer
The legal basis for data management is the consent of the interested party. The data management lasts until the period specified by the interested party or until the consent is revoked.
e-mail address, telephone number
Data that is absolutely necessary to reach the customer later
subject of interest: period, destination, accommodation classification, board, number of passengers, number and age of children
Data required to specify the customer’s interest and provide an appropriate, personalized response, based on the customer’s own communication.
name and date of birth of those traveling together
Data that is absolutely necessary for the identification of passengers
in the case of a transfer service: arrival time, flight number, number of passengers
Data required to serve the customer’s needs in accordance with the customer’s own communication.
in case of local program selection: date of selected programs, number and age of participants
Data required to serve the customer’s needs in accordance with the customer’s own communication.
Conclusion of travel contracts, sales of plane tickets and parking tickets, accident and luggage insurance, cancellation insurance
customer name
Data that is absolutely necessary to identify the customer
The legal basis for data management is the performance of the contract and the settlement of any legal disputes arising in connection with it. The duration of data management is 5 years after the due date of claims related to the contract, in the case of accounting documents generated during the sale, Számv. TV. 8 years in accordance with § 169.
customer e-mail address, telephone number
Data that is absolutely necessary to reach the customer later
address of the customer
Data required for issuing an invoice
passenger names
Required for booking travel documents (e.g. flight ticket, accommodation).
date of birth of passengers
Required for booking travel documents (e.g. flight ticket, accommodation).
subject of the contract: travel departure and arrival time, destination, name of accommodation, name of service, list of additional services, etc.)
Defining the subject of the contract.
relevant health data
Data required to provide exceptional service. (e.g. lifestyle, nutrition, needs arising from physical characteristics, etc.)
III. ADDRESSES OF PERSONAL DATA AND CATEGORIES OF ADDRESSES
Smart Trend Ltd. usually shares its customers’ personal data with the following parties on a data controller-by-data controller basis:
- with Smart Trend Ltd. or organizations providing services for customers (e.g. insurance companies, IT service providers, WEB service providers)
- with third parties participating in the fulfillment of the travel contract (travel operator, hotel, airline, etc.)
- service providers and businesses participating in the performance of local representation (e.g. car rental companies, shipping companies, program organizing companies, etc.)
- supervisory authority and other regulatory authorities and bodies
International data transfer to third countries
Customers’ personal data may also be forwarded to data controllers and data processors in countries outside the European Economic Area, if this is necessary for the performance of the travel contract, or if the traveler has given express and informed consent (GDPR Article 49).
Smart Trend Ltd. informs the traveler prior to the conclusion of the travel contract that adequate protection of the transmitted data is ensured with regard to the recipient outside the European Union affected by the transfer of the traveler’s data:
through general data protection clauses adopted by the Commission in accordance with the investigation procedure referred to in Article 93 (2) of the GDPR;
through general data protection clauses accepted by the supervisory authority and approved by the Commission in accordance with the investigation procedure referred to in Article 93 (2) of the GDPR;
an approved code of conduct pursuant to Article 40 of the GDPR together with a binding and enforceable commitment by the third-country data controller or data processor to apply appropriate guarantees, including customer rights;
or an approved certification mechanism pursuant to Article 42 of the GDPR together with a binding and enforceable commitment by the third-party data controller or processor to apply appropriate safeguards, including with respect to customer rights. In this context, Smart Trend Ltd. strives to have its third-country partners accept the contractual data protection clauses approved by the European Commission/NAIH.
ARC. CUSTOMER RIGHTS, LEGAL REMEDIES
The specific rights that customers are entitled to in connection with individual data management and the way to exercise them are set out in II/4. described in point Below is a summary of the rights and remedies generally available to customers. The rights mentioned below can be exercised at the contact details of the data controller specified in point V.
Customer right of access
The customer can request access to personal data managed by Smart Trend Ltd. at any time.
If the customer requests that Smart Trend Ltd. provide feedback on whether it handles their personal data, Smart Trend Ltd. is obliged to provide information.
The customer’s right to receive feedback on whether Smart Trend Ltd. manages (or not) their personal data:
- covers personal data relating to the customer;
- does not cover anonymous data;
- does not cover personal data that does not concern him; and
- includes pseudonymized data that can be clearly linked to the customer.
At the request of the requesting customer, Smart Trend Ltd. provides access and a copy of their personal data. If the customer requests an additional/repeated copy of their personal data, Smart Trend Ltd. may charge a reasonable fee to pay the administrative costs incurred in connection with the fulfillment of the request, which fee will be borne by the customer.
Customer’s right to rectification
The customer has the right to correct his personal data. This right:
- does not cover anonymous data;
- covers personal data relating to the customer;
- does not cover personal data that does not concern him; and
- includes pseudonymized data clearly linked to the customer.
Smart Trend Ltd. properly corrects or completes his personal data based on the customer’s request. Smart Trend Ltd. informs the recipients of such personal data (if any) about the correction of the customer’s personal data, unless informing the recipients proves to be impossible or would require a disproportionately large effort.
The customer’s right to erasure
Under certain conditions, the customer has the right to request the deletion of his personal data managed by Smart Trend Ltd. is obliged to delete the personal data of the data subject without undue delay if:
- Smart Trend Ltd. manages these personal data and
- the customer requests the deletion of personal data and
- personal data are not necessary for the purposes for which Smart Trend Ltd. manages personal data.
Smart Trend Ltd. is obliged to delete the personal data of the data subject without undue delay, if Smart Trend Ltd. manages these personal data and the customer requests the deletion of the personal data, and the customer withdraws his consent on which the processing of his data is based, and there is no other legal basis for the further processing of the data subject.
Smart Trend Ltd. is obliged to delete the personal data of the data subject without undue delay, if the data management is necessary to enforce the legitimate interests of Smart Trend Ltd. or a third party, and the customer objects to Smart Trend Ltd. handling his personal data, and the legitimate reason underlying the processing of such personal data does not take precedence over the customer’s objection.
Smart Trend Ltd. is obliged to delete the personal data of the data subject without undue delay, if the customer requests the deletion of his personal data and the handling of such data by Smart Trend Ltd. is not illegal, or the deletion is mandatory according to the laws in force, or the customer your data is collected in relation to services related to the information society.
Smart Trend Ltd. informs the recipients of such personal data (if any) of the deletion of the personal data of the data subject, except if informing the recipients is impossible or would require a disproportionately large effort.
The customer’s right to restrict data processing
The customer can request the restriction of the processing of his personal data.
The customer’s right to request the restriction of the processing of his personal data does not cover anonymous data, it covers personal data concerning the customer; and includes pseudonymized data clearly linked to the customer.
Smart Trend Ltd. limits the processing of the customer’s personal data to the period during which it checks the accuracy of such data, if the customer requests the restriction of the processing of his personal data and the customer disputes the accuracy of such data.
Smart Trend Ltd. restricts the processing of the customer’s personal data if the customer requests to limit the processing of data whose processing is illegal and the customer opposes the deletion of such data.
Smart Trend Ltd. restricts the processing of the data subject’s personal data if the customer requests the restriction of the processing of his personal data, and Smart Trend Ltd. no longer needs this data for the purpose of data processing, and the customer uses his data to present and enforce a legal claim. or requires for protection.
Smart Trend Ltd. restricts the processing of the personal data of the data subject if the customer objects to the processing of such personal data that is necessary for the legitimate interests of Smart Trend Ltd., and the customer is waiting for confirmation that the customer’s personal data is being processed by Smart Trend Ltd. . has a legitimate reason for its handling, which does not take precedence over the customer’s objection.
Smart Trend Ltd. informs the recipients of such personal data about the restriction of the handling of the customer’s personal data, except if informing the recipients is impossible or would require a disproportionately large effort.
If Smart Trend Ltd. restricts the processing of the data subject’s personal data, it may store such personal data, process such personal data based on the customer’s consent, and process personal data to assert, enforce or defend its legal claims, or to protect the rights of a person.
The customer’s right to data portability
The customer has the right to receive the personal data concerning him that he has provided to a data controller in a segmented, widely used, machine-readable format, and he is also entitled to transfer this data to another data controller without hindrance (where technically possible) the data controller to whom you provided the personal data, if the data management is based on consent or is necessary for the performance of a contract and the data management is automated.
The customer’s right to data portability does not extend to anonymous data; covers personal data relating to the customer; does not cover personal data not related to the customer; and covers pseudonymized data that can be clearly linked to the customer
- COMPLAINT, REMEDY:
You can contact the National Data Protection and Freedom of Information Authority (NAIH) with your request for legal redress or complaint at the following contact details:
Headquarters: Hungary, 1125 Budapest, Szilágyi Erzsébet fasor 22/c.
Mailing address: 1530 Budapest, Pf.: 5.
Phone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
Email: ugyfelszolgalat@naih.hu
Website:http://www.naih.hu
- HOW CAN SOME RIGHTS BE ENFORCED?
In any matter related to the management of the customer’s personal data, whether it is a question, asserting a right, filing a complaint, or anything else, please contact Smart Trend Ltd. at the contact details found on the website MYMALDIVES360.COM.
The customer’s request will be processed by Smart Trend Ltd. without delay, but within a maximum of 30 calendar days. In exceptional cases, especially when the complexity of the request justifies it, Smart Trend Ltd. has the right to extend this deadline by another two months. Of course, the customer will be informed about the possible extension of the deadline and its justification.