1. Introduction

• Firstly, we would like to emphasise the fact that your data and privacy are of great importance to us. You entrust us with your data and we feel responsible for treating it with the utmost caution and confidentiality. In the following privacy policy we inform you in a clear and transparent way how we use and process your personal data.
• By visiting our website or by asking information, you agree to our privacy policy as mentioned in this policy. We can modify our policy from time to time. You can check our policy to be informed about our latest changes. Changes to this policy may also be announced on our website or by e-mail if this is possible and/or necessary.
• If you have any further questions concerning your data and privacy, you can always contact us via the contact details below in our contact section.
  

2. Who are we?

When we refer in this policy to ‘us’, ‘our’, ‘we’ or ‘Stardekk’, we refer to the legal entity Stardekk NV / PLC, a company incorporated under Belgian law with company number 0474.598.036, situated in Rijselstraat 2A, 8200 Bruges, Belgium.

3. General information

Stardekk collects and processes your data in the context of its activities. It acts in accordance with the "Law of 08.12.1992 on the protection of privacy with regard to the processing of personal data" and in accordance with the "General Data Protection Regulation", which applies throughout the European Union from 25 May 2018.

The privacy law can be consulted online on this link.

4. Collection of personal data

• Personal data are data that can be used to identify or contact a specific person. In order to offer our services we will collect and process information about our website users and about guests of our customers. Therefore, we may process all information, including personal data, that you provide to our customers or to an online travel agency in relation to a reservation.
• Personal data processed by us includes the following data (but is not limited to): name, address, e-mail address, telephone number, credit card details, date of birth and reports of our interactions and travel information.
• We store your personal data on our systems for as long as is necessary for the provision of the relevant service or as laid down in a relevant contract that you have with us. We review our retention periods for personal data on a regular basis. We may also be required to retain certain types of data in order to comply with legal obligations.

5. How do we collect your data?

• We collect personal data from and about our users of our website and our customers’ guests through our services.
• Information that you give us:
• This is information about you that you give us directly by contract, via our websites, or by contacting us by telephone, e-mail or other means of communication. It contains information that you provide when you register to use our website our services, when you make a report about a problem with our website or services, when you subscribe to a newsletter or demo session, and when you provide us with information about the nature of a question or problem;
• Information you provide regarding your reservations and the related information.
• Information that we collect about you:
• When you visit our websites we automatically collect:
• Technical information, including the Internet Protocol (IP address) that is used to connect your computer to the internet, your login information, browser type and version, time zone settings, browser plug-in types version and operating system and platform;
• Information concerning your visit, including the full Uniform Rescource Locators (URL), clickstream to, through and from website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.
• Information that we receive from other sources:
• Personal information that is provided to us by travel agencies or online travel sites using different Cubilis services and modules.
• Personal information that is provided to us by our customers by using different Cubilis services and modules.
  

6. What do we do with your data?

• We use stored information about you in order to manage contracts between you and us and for the legitimate interests of our business, for example, the processing of our customers’ guest data to be able to process reservations.
• We will use your provided information for the following objectives:
• To provide you with information and services that you request from us;
• To carry out our obligations under any contracts entered into between you and us;
• To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• To notify you about changes to our services;
• To ensure that content from our website is presented in the most effective manner for you.
• We will use the Information that we collect about you for following objectives:
• To manage our websites and for other internal operations, including troubleshooting, data analysis, testing, research, and for statistical and survey purposes;
• To improve our website to ensure that content is presented in the most effective manner;
• As part of our efforts to keep our website safe and secure.
• We may aggregate your data into an anonymised form to help us provide more useful information to our customers and to understand which parts of the website are of most interest to visitors.
  

7. Who might we share your data with?

• We may from time to time share certain personal data with strategic partners that work with Stardekk, such as the following;
• Hotels and online travel agencies through which you have arranged travel, but only the personal data that is needed for successful processing of your reservations;
• other service providers of our customers, and only at the request of the latter, but for which these service providers are bound by our privacy policy for personal data or have comparable contractual obligations with regard to the storage and processing of your personal data;
• In the event of merger, acquisition, or any form of sale of some or all of our assets, in which case personal data we hold about our customers will be among the assets transferred to the buyer.
• If we ask a third party to process the personal data of an individual on our behalf, that third party will be bound by our data privacy policy or have similar contractual obligations in relation to the storage and processing of your personal data.
• We may also disclose your personal data to third parties to:
• Comply with any court order or other legal obligation or when data is requested by government or law enforcement authorities;
• Enforce or apply our terms of use and any other agreements;
• Protect the rights, property, or safety of us, our employees, customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  

8. International transfers of personal data

From time to time, we may transfer your personal data to our suppliers or service providers based outside of the EEA for the purposes described in this policy. If we do this, your personal data will continue to be subject to one or more appropriate safeguards laid down in the General Data Protection Regulation. This may be the use of model contracts in a form that has been approved by regulators, or where our suppliers sign up for an independent privacy policy that has been approved by regulators (such as the U.S. 'Privacy Shield' scheme).

9. Your rights

• You have the right to ask us not to process, or to stop processing, your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time via unsubscribe links present on our email communication or simply by contacting us (see 'Contact' section).
• Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
• For further information about your rights within the "General Data Protection Regulation", please click on this link.
  

10. Access and update your data

• You have the right to access the personal information that we hold about you. If you submit a request for this, we will do everything possible to grant you access free of charge, except in exceptional circumstances.
• Before providing personal data to you or another person on your behalf, we may ask for proof of identify and sufficient information about your interactions with us so that we can locate your personal data.
• We strive to maintain accurate, complete, and relevant personal information for the purposes mentioned in this privacy policy. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.
• You have the right to object to us processing your personal data if we are no longer authorised to use them. You have the right to have your data deleted or to restrict processing under certain circumstances. You also have the right to have your personal data transferred in certain circumstances.
• If you would like to exercise any of these rights, please contact us using the contact details found below in the ‘Contact Us’ section.
• You also have the right to lodge a complaint with the supervisory data protection body that regulates us if you have concerns about how we use your personal information. For information on how to do this, please see the ‘Contact Us’ section.
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11. Security precautions

• We will treat your personal data with the utmost care and confidentiality in accordance with the applicable legislation and regulations. We will take all necessary security measures to prevent 'data breaches' and to guarantee the secure processing of personal data.
• If you visit other websites, please consult the privacy policy of the site you are visiting. We cannot be held responsible for the privacy policies or actions of other websites, even if:
• You have reached this external website by following links on our website;
• You have reached our website by following a link from an external website.
• We recommend that you consult the privacy policy of each site you visit and contact the owner of that site with any questions or comments you may have.

12. Cookies

• The website may use ‘cookies’ and other technologies such as pixel tags and web beacons. These technologies help us to improve and deliver a better and more personalised service by enabling us to:
• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to better customise the services according to your individual interests;
• Speed up your searches; and
• Recognize you when you return to the website.
• You may refuse to accept cookies by activating the appropriate settings on your browser. Check with your provider to find out how to disable cookies. Please note that certain features of the website may not be available if cookies are disabled.
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13. Recruiting Statement

• By sending us your CV or other personal information in response to a vacancy or as part of a spontaneous application, you confirm that we may use and transfer data as described in this privacy policy.
• You may provide personal information to us related to education, employment, contacts, preferences, job qualifications, and jobs when you submit an application. We recommend that you do not disclose sensitive personal information (e.g., height, weight, religion, philosophical or political beliefs, financial data, sexual orientation, membership of a trade union or political party) in your CV or any materials in support of your application. To the extent you provide sensitive personal information, you expressly authorize Stardekk to handle such details as specified in this Statement.
• We will use your personal information for recruitment purposes and if you are offered a job or are employed by Stardekk, we will use it for other employment-related purposes.
• We may also retain your information after the recruitment process is completed in order to contact you about potential future opportunities for a period of three years from the date of your application. However, it is possible that we may keep your data in anonymous form for longer for statistical purposes.
  

14. Contact

Stardekk will mainly process personal data on behalf of and for the benefit of its customers and is therefore a 'processor' within the "General Data Protection Regulation". Stardekk can be contacted by post or by e-mail using the following details:

• Stardekk NV
• Address: Rijselstraat 2A, 8200 Bruges, Belgium.
• Email: gdpr@stardekk.com
• Tel.: +32 (0) 50.38.38.68
  

Stardekk has chosen to appoint an external 'Data Protection Office', namely the office Mr. Franklin BV, who can be contacted by post or by e-mail using the following details:

• Mr. Franklin BV          
• Address: Lieven Bauwensstraat 20, 8000 Bruges, Belgium
• Registered under: 0702.924.851
• Email: hallo@misterfranklin.be
• Tel.: +32 (0) 50.45.60.62
• Website: www.misterfranklin.be

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The data protection authority may be contacted by using the following details:

• Commission for the Protection of Privacy
• Address: Printing press 35, 1000 Brussels, Belgium.
• Email: commission@privacycommission.be
• Tel.: +32 (0) 2.274.48.00
• Website: www.privacycommission.be

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