Delta Voyages SA – Privacy Policy
Last modified: 19/11/2021
B. Data Protection at Delta Voyages SA
- I. Who is responsible for your personal information?
- II. What personal information do we collect about you, how do we process it and why?
- III. What happens if you do not share your personal information with us?
- IV. What is our legal basis for processing your personal information?
- V. When, how and why do we share your personal information with third parties?
- VI. How do we protect your personal information?
- VII. To what extent do we use automated decision-making?
- VIII.How long do we keep your personal information?
- IX. What are your rights?
C. Updates to this Privacy Policy
- Delta Voyages SA (hereafter « the Company », « we », « us » or « our ») is committed to protecting the privacy and security of the personal information that is provided to us or collected by us during the course of our business. We store and process personal information in accordance with the Swiss Data Protection Act (hereafter « DPA ») and – to the extent applicable – the EU General Data Protection Regulation (hereafter « GDPR »).
- This privacy policy explains how we may collect and use any personal information that we obtain about you and your rights in relation to that information.
- We may provide you with additional privacy notices where we believe that it is appropriate to do so. Those additional notices supplement and should be read together with this privacy policy.
B. Data Protection at Delta Voyages SA
I. Who is responsible for your personal information?
- Delta Voyages SA, Quai du Seujet 28, CH-1201 Geneva (UID: CHE-107.953.108), is responsible for the personal information provided to us or collected by us during the course of our business.
II. What personal information do we collect about you, how do we process it and why?
- We collect and process your personal information as follows:
1. Requesting our services
- We may collect information about you when you, or someone acting on your behalf, contact(s) us by any means, in particular by email, contact form on our website, telephone or fax, in order to request our services.
- In order to provide our services (see section 2) we may need to collect and process the following information about you:
- i) Name, gender, date of birth, passport details, contact details (postal address, email address and telephone number);
- ii) Travel preferences (for example: destination, transportation, duration of the journey, room arrangements, dietary habits, interests, travel group, other special requests, frequent flyer number etc.);
- iii) Issues you may experience or have experienced during a trip or holiday;
- iv) Feedback on your current and past travel experiences;
- v) Information on the structure, employees, internal policies and corporate identity of corporations requesting our services;
- vi) Travel insurance details;
- vii) Payment information (bank account, credit card or alternative payment methods).
- While processing a request to provide our services, we may need to collect special categories of personal information such as allergies, medical conditions, disabilities or religious beliefs. This information would be collected and processed upon your prior consent and only to the extent it is strictly necessary to deliver the travel arrangements you have purchased (see section 2).
2. Providing and improving our services
- In order to provide and improve our services, we may collect and process your personal information in/for the following ways/reasons:
- i) Plan trips and activities for individuals, groups or corporations;
- ii) Provide consultation on trips and holidays;
- iii) Book travel packages, transportation, lodging, restaurants or activities (see question V);
- iv) Conclude travel insurance policies (see question V);
- v) Contact you if we need more information or if there are changes to your travel arrangements;
- vi) Contact you to ask for your feedback on our services;
- vii) Evaluate your personal information in the context of our business acceptance process;
- viii) Provide customer care and other after sales services;
- ix) Execute payments to third parties (see question V) and invoice our services;
- x) Maintain and develop our business relationship with you;
- xi) Identify products or services you may be interested in;
- xii) Review and improve our internal processes;
- xiii) Improve our services, customer satisfaction and customer loyalty.
If you contact our emergency service Delta Voyages 24H / 24H, which is provided by QUINTY MANAGEMENT, Bucharest, we may process your information for training and quality control purposes. Please note that calls may be recorded for training and quality control purposes. In such cases, we will inform you appropriately and obtain your consent prior to the recording.
3. Safeguarding our legal rights and complying with statutory requirements
- In order to safeguard our legal rights and comply with statutory requirements, we may collect and process your personal information in/for the following ways/reasons:
- i) Ensure compliance with statutory obligations including orders issued by Swiss or foreign courts or government agencies;
- ii) Identify and investigate abuses;
- iii) Defend ourselves against claims;
- iv) Assess and assert our claims in Switzerland and abroad.
4. Using our website
- We collect, store and process personal information when you visit our website (for example: device used to access the website, browser type, operating system, Internet Protocol address, click-activity, referring website, pages visited on our website and/or date/time stamp for your visit).
- We use cookies to collect information when you access our website, in particular for processing your purchase and any possible later claims and for marketing communication purposes.
- Cookies are small text files that are placed in browser directories on your computer or mobile device when you visit our website. Our website uses session cookies and persistent cookies. Session cookies enable you to move from page to page within the website and any information you enter to be remembered. A session cookie is deleted when you close your browser or after a short time. Persistent cookies allow the website to remember your preferences and settings when you visit the website in the future. Persistent cookies expire after a set period of time.
- We use cookies in the following ways:
- i) Google Analytics: We use Google Analytics which provides us with information about how visitors use our website. Google uses cookies as part of the process to collect anonymous information, such as the number of visitors to the website, where they are from, the pages they visit and the length of time they have spent on our website;
- ii) Other Cookies: We also use cookies and tracking technology to help us assess how many persons visit our website and what they click on.
- We use social media plugin buttons on the website (for Facebook, Instagram and LinkedIn), however we do not collect any data you entered while exiting our website and using those portals. Additionally, please note that the privacy policy of those portals and accordingly the processing of your data may differ from our privacy policy.
5. Recruiting
- If you apply for a job, you may need to provide personal information including special categories of personal information (for example: name and contact details, nationality, country of residence, immigration status, work permits, educational background, employment background, job qualifications, employment references, job and educational evaluations, competency, ability and suitability for a position). With your application you expressly consent to our use of this information. We will use this information to consider your application. We may also use this information to carry out checks to verify the information you provided (including references, background, identity, suitability, excerpts from the debt enforcements register and criminal record checks). We do not use any third-party service providers in our recruiting process.
6. Newsletter
If you sign up for the Company newsletter, the Company may process your email address and other contact information you provide to the Company.
You have the right to unsubscribe from our newsletter at any time.
III. What happens if you do not share your personal information with us?
- If you fail to provide personal information required either by law, or as necessary for us to provide our services and perform our contractual duties, we may not be able to provide our services. If you fail to provide the personal information requested by us in connection with your application for a job or a recruiting event at the Company, we may not be able to further consider your employment.
IV. What is our legal basis for processing your personal information?
- We will only use your personal information if and to the extent that applicable law allows. We will therefore process your personal information for the purposes described above if:
- i) It is necessary for the performance of a contract with you or the organization you work for;
- ii) It is necessary in connection with a legal obligation;
- iii) You have given your consent (where necessary) to such use or the organization you work for has obtained your consent (where necessary) to share your information with us;
- iv) If we or a third party have a legitimate interest which is not overridden by your interests or your rights and freedoms.
V. When, how and why do we share your personal information with third parties?
- We may need to share your personal information with third-party service providers used in the delivery of your purchased services (for example: airlines, public transportation companies, rental companies, insurances, hotels, restaurants, local ground partners and agents, guides, tutors, etc.). These providers will be named on your holiday confirmation and/or in your holiday documentation.
- In order to process payments, your payment information (bank account, credit card or alternative payment methods) may be shared with our back office or payment service providers such as Viaxoft, France, since payment operations are not carried out by us.
- We use Amadeus GDS, a booking platform provided by an external service provider, for most of the flight bookings made by us on behalf of a customer. Next to Amadeus GDS, we also use internet-based third-party sales and booking providers.
- Further, we may share your personal information with third persons where:
- i) It is necessary for the performance of a contract with you or the company you work for;
- ii) It is necessary in connection with a legal obligation;
- iii) You have given your consent (where necessary) to such use or the company you work for has obtained your consent (where necessary) to share your information with us;
- iv) If we or a third party have a legitimate interest which is not overridden by your interests or your rights and freedoms.
- We use third parties who provide products and services on our behalf and may share your personal information with them, for example banks, insurance companies or technology suppliers who may have access to your personal information when providing software support such as ICON SA, Geneva.
- To the extent that third parties we use or with whom we share your personal information are located outside of Switzerland or the European Economic Area, we conclude appropriate data protection agreements (i.e. EU Model Clauses) to ensure an adequate level of data protection in accordance with data protection laws, in particular the DPA or GDPR, unless such a transfer is required for the conclusion or performance of a contract with you.
VI. How do we protect your personal information?
- We have put in place appropriate security measures to hold your personal information securely in electronic and physical form, to protect it from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. Our premises are access controlled, an alarm system is installed and our electronic databases require logins and password authentication.
- Our employees and third-party service providers who have access to confidential information (including personal information) are subject to confidentiality obligations.
VII. To what extent do we use automated decision-making?
- In general, we do not use automated individual decision-making for the performance of our contractual relationship with you. If we should rely on such processing in a particular situation, we will inform you separately, insofar we are legally required to do so.
VIII.How long do we keep your personal information?
- We will retain your personal information for as long as is necessary for the purpose for which it was collected, in particular to provide our services to you in connection to the trips you book with us. We will further retain your personal information to comply with legal and regulatory obligations (e.g. we may store your data for ten years in accordance with applicable law), for as long as claims could be brought against us and for as long as legitimate interest, including data security, requires.
- We determine how long we keep your personal information on a case-by-case basis, taking into account the purpose and context of the processing of your personal information, the type of personal information concerned and any legal and regulatory retention duties.
IX. What are your rights?
- In relation to the processing of your personal information you have rights that you can exercise under certain circumstances. These rights are to:
- i) Request access to your personal information and certain information in relation to its processing;
- ii) Request rectification of your personal information;
- iii) Request the erasure of your personal information;
- iv) Request that we restrict the processing of your personal information;
- v) Object to the processing of your personal information.
- If you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
- We may refuse or restrict your data protection rights if the relevant data protection legislation or other legislation allows or obliges us to do so, in which case we will provide reasons for our decision as required by the law.
- If you would like to exercise these rights, please contact us in writing by email to Mr. Yvan Vasina, Managing Director (yvan.vasina@delta-voyages.ch) or by letter to:
Delta Voyages SA, Quai du Seujet 28, 1201 Genève
- You will not, in general, have to pay a fee to exercise any of your rights. However, we may charge a fee for access to your personal information if the relevant data protection legislation allows us to do so, in which case we will inform you as required by the law.
- If you feel we have not handled your query or concern to your satisfaction you can contact the competent data protection authority in Switzerland, the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).
C. Updates to this Privacy Policy
We reserve the right to update and change this privacy policy from time to time in order to reflect any changes to the way in which we process your personal information or changing legal requirements. Any changes we may make to our privacy policy in the future will be posted on this website. Please check back frequently to see any updates or changes to our privacy policy.