We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.
DT Croatia collects personal data necessary in order to perform our business function and for the execution of confirmed services in line with the General Data Protection Regulation (GDPR) (EU) 2016/679.
What information is collected by DT
“Personal Data” means any information in any media or format, including computerized or electronic records as well as paper-based files, relating to an identified or identifiable natural person that identifies an individual or from which identification or contact information of an individual natural person can be derived by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual nature person, including, but not limited to:
• a first or last name or initials
• a home or other physical address
• an email address or other online contact information
• a telephone number
• a passport, social security number, tax ID number or similar
• Internet Protocol (“IP”) address or host name that identifies an individual
• a persistent identifier, such as a customer number held in a “cookie”
• birth dates
Generally, the type of personal data we collect is the information that is needed in order to facilitate travel arrangements, bookings and other travel related services or products. For example, such data may include the traveler’s name, residential/mailing address, gender, nationality, birth date and place, passport or identity card details, credit/debit card details (including card type, card number, security number and expiry date), information about dietary requirements and health issues (if any), and other details relevant to travel arrangements or required by the relevant travel service provider(s) (e.g. accommodation, transportation and tour providers, restaurants and government institutions).
preferences or practices, criminal record and the alleged commission of an offence, membership of political, professional or trade associations, biometric and genetic information, passwords and financial information and health information, and any personal information relating to a child under the age of 13. We will only collect sensitive information in compliance with GDPR, where it is reasonably necessary for, or directly related to, one or more functions or activities (e.g. to make contracted travel arrangements), unless we are otherwise required or authorized to do so by law. For example, if health information is provided for the purpose of informing restaurants of dietary restrictions, it will only be used for this purpose. A further example is if religious beliefs are disclosed because of interest in a religious travel program in which case consent has been provided to for using and disclosing that information in connection with facilitating the request. We will not use sensitive information for purposes other than those for which it was collected, unless subsequently receiving consent to use it for another purpose.
We also collect information that is required for use in DMC business activities, including for example, financial details necessary in order to process various transactions, voluntarily completed quality control surveys, feedback and voluntarily exchange business cards at events. Website usage information is collected using cookies.
How is data collected by DT
As primarily a business to business service provider, in most cases, DT will receive personal information from a third party for whom DT is working as an agent and that is in direct contact with the individual. Most likely this will be either the agency through which the program was book or the company sponsoring the event. On certain occasions, however, the information will be collect directly from the participants themselves. Regardless of the source, information is collected by e-mail, facsimile, letter, by visiting the DT website, by web form, in person or by telephone.
When information is collected by a third party and transferred to DT, we will rely on the authority of the entity providing the information to act on the participant’s behalf and with the participant’s direct consent. By providing your personal information to us, either directly or through an employer or other agent or representative in connection with a travel booking or related service, you will be deemed to have consented to your personal information being collected by us and used and disclosed in accordance with this Policy.
If you are making a travel booking on behalf of another person, in further text participant (including but not limited to group bookings or a travel bookings made for employees), you agree you have obtained the consent of the participant for the DMC, in this case DT, to collect, use and disclose the participant’s personal information in accordance with this Policy and that you have otherwise made the other person aware of this Policy.
Information collected by DT will only be stored as long as is necessary for the successful execution of the program or in line with government regulatory requirements. After such time, all personal information will be permanently deleted.
DT should be made aware immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person’s personal information to us.
How does DT use and disclose personal data
The primary purpose for which DT uses personal data is to provide or facilitate the travel services for which we have been engaged. By continuing to use our services and/or by providing us with personal information (or allowing another person to do so on your behalf), you consent to DT using and disclosing your personal information for the purpose for which it was collected, and, where permitted by GDPR, for any related secondary purpose which is reasonably expected.
The purposes for which DT collects personal information, and those secondary purposes which use of information is directly related, includes but is not limited to:
• provision and facilitation of confirmed services
• identification of fraud or error;
• regulatory reporting and compliance;
• development and improvement of products and services
• involvement in gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the service we have provided;
• for research and analysis in relation to our business and services, including but not limited to trends and preferences in sales and travel destinations and use of our websites;
• internal accounting and administration;
• compliance with legal obligations and any applicable customs/immigration requirements relating to your travel; and
• other purposes as authorized or required by law (e.g. to prevent a threat to life, health or safety, or to enforce our legal rights).
DT Disclosure of personal data to third parties
We may disclose your personal information to third parties, as set out below, and in accordance with GDPR. By continuing to use our services and/or by providing us with your personal information (or allowing another person to do so on your behalf), you consent to that personal information being processed, transferred and/or disclosed by us for the purpose for which it was collected and, where permitted by your local data protection laws, for any related secondary purpose which we believe you would reasonably expect. Note that, in this Policy, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.
Personal information may be disclosed to the following types of third parties:
• contractors, suppliers and service providers to whom this information is necessary in order to perform their confirmed services, including but not limited to: hotels, restaurants, ground assistance staff (including but not limited to transfer handlers guides and tour escorts), rental car companies, restaurants, as well as other related travel service providers,
• in accordance with circumstances set out in the section titled “How does DT use and disclose personal data?”;
• suppliers of IT based solutions that assist DT in providing products and services to you (such as on line conference registrations and any external data hosting provider(s) we may use);
• a person making your travel booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a program organizer who has been engaged to provide outbound travel services of which you are taking part in);
• your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes;
• as required or authorized by applicable law, and to comply with our legal obligations;
• customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
• government agencies and public authorities, to comply with a valid and authorized request, including a court order or other valid legal process;
• various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
• enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
Under circumstances where travel programs include non- European countries, third parties to whom information is disclosed are outside of the European Union and not subject to GDPR, instead local data protection laws meaning you will not be able to seek redress under GDPR and they may not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by your local data protection laws, we will not be liable for how these recipients handle, store and process your personal information. By providing your personal information to us for the purpose of booking and otherwise arranging travel related products and services for you, you consent to our disclosure of your personal information to these overseas recipients for that purpose.
Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorized or required by law (including applicable privacy / data protection laws).
Access to personal data and correction
Every individual has the right to request a copy of the information hold about them by DT. If you would like a copy of some or all of your personal information, please email us at the following address: firstname.lastname@example.org. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
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How to contact us
DT Croatia – Management
Obala Stjepana Radića 25
20 000 Dubrovnik