Privacy Policy

1. Introduction

fortunznlq B.V. ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website, services, or interact with us as a tour operator.

This policy applies to all personal information we collect through our website (fortunznlq.top), booking services, customer communications, and any other interactions with our company.

2. Data Controller Information

3. Information We Collect

3.1 Personal Information You Provide

• Contact details (name, email address, phone number, postal address)
• Booking and travel preferences
• Payment information (processed securely through third-party payment processors)
• Passport and identification details (when required for bookings)
• Dietary requirements, accessibility needs, and special requests
• Emergency contact information
• Communication preferences

3.2 Information Collected Automatically

• Website usage data (pages visited, time spent, click patterns)
• Device information (IP address, browser type, operating system)
• Cookies and similar tracking technologies (see our Cookie Policy)
• Location data (when permitted by your device settings)

3.3 Information from Third Parties

• Information from travel partners (hotels, airlines, local operators)
• Social media information (when you interact with our social media pages)
• Information from referral partners

4. How We Use Your Information

4.1 Service Provision

• Processing and managing your travel bookings
• Arranging accommodation, transportation, and activities
• Providing customer support and assistance
• Communicating important travel information and updates

4.2 Business Operations

• Processing payments and managing financial transactions
• Maintaining accurate records for accounting and legal purposes
• Improving our services and website functionality
• Conducting market research and analysis

4.3 Marketing and Communications

• Sending promotional offers and travel deals (with your consent)
• Personalising our marketing communications
• Conducting surveys and requesting feedback
• Managing our relationship with you

5. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: To fulfill our obligations under your booking contract
• Legitimate Interest: For business operations, fraud prevention, and service improvement
• Consent: For marketing communications and non-essential cookies
• Legal Obligation: To comply with tax, accounting, and other legal requirements

6. Data Sharing and Disclosure

6.1 Service Providers

We share your information with trusted third parties who help us deliver our services:

• Hotels, airlines, and other travel service providers
• Payment processors and financial institutions
• Technology service providers (hosting, analytics, customer support)
• Marketing and communication platforms

6.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal processes or government requests
• Protect our rights, property, or safety
• Prevent fraud or illegal activities
• Enforce our terms and conditions

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the new entity, subject to the same privacy protections.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) where our service providers are located. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the European Commission
• Standard Contractual Clauses approved by the European Commission
• Certification schemes and codes of conduct
• Other legally recognised transfer mechanisms

8. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services and support
• Comply with legal and regulatory requirements
• Resolve disputes and enforce our agreements
• Improve our services and business operations

Typically, we retain customer data for 7 years after the completion of travel services for accounting and legal purposes. Marketing data is retained until you withdraw consent or we no longer have a legitimate interest in processing it.

9. Your Rights Under GDPR

As a data subject in the EU, you have the following rights:

9.1 Right of Access

You can request a copy of the personal data we hold about you.

9.2 Right to Rectification

You can request correction of inaccurate or incomplete personal data.

9.3 Right to Erasure

You can request deletion of your personal data in certain circumstances.

9.4 Right to Restrict Processing

You can request that we limit how we use your personal data.

9.5 Right to Data Portability

You can request a copy of your data in a structured, machine-readable format.

9.6 Right to Object

You can object to processing based on legitimate interests or for marketing purposes.

9.7 Right to Withdraw Consent

You can withdraw consent for processing that relies on your consent at any time.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and staff training
• Secure payment processing systems
• Regular data backups and disaster recovery procedures

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but will notify you of any data breaches as required by law.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience, analyse website traffic, and personalise content. For detailed information about our use of cookies, please see our Cookie Policy.

You can manage your cookie preferences through our cookie consent banner or your browser settings.

12. Children's Privacy

Our services are not directed to children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@fortunznlq.top.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of significant changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have concerns about how we handle your personal data, please contact us:

15. Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the supervisory authority in your EU member state.