Privacy policy

Introduction

At ADERO Travel B.V., we take the protection of personal data seriously. This Privacy Policy explains which personal data we process, why we process it, with whom data may be shared, and what rights you have. We act in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy legislation.

Article 1 – Data Controller

ADERO Travel B.V. is responsible for processing personal data in connection with its travel design, booking and intermediary activities.

Website: www.aderotravel.nl

Email for privacy requests: info@aderotravel.nl

The current registered office details and Chamber of Commerce registration number are published on the website and in the legally required business information. If ADERO Travel acts solely on behalf of another party for a particular processing activity, the respective roles will be determined separately.

Article 2 – Scope of this Policy

This Privacy Policy applies to website visitors; individuals requesting information or travel proposals; customers and fellow travellers; contacts at suppliers and business partners; and individuals contacting us by email, telephone, forms or other channels. It describes processing carried out by ADERO Travel itself. Airlines, hotels and other independent service providers may have their own privacy policies governing their processing.

Article 3 – Personal Data We Process

Depending on the services provided, we may process: name, form of address, date of birth, nationality, contact details, country of residence and billing information; names and details of fellow travellers; destinations, dates, preferences, budget, travel history where provided by you, and accommodation and transport choices; booking references, ticket details and payment status; passport, visa or entry-related information only where necessary; correspondence, complaints and requests; business contact details; and technical website information such as IP address, browser information and cookie preferences where applicable. We do not request more information than is reasonably necessary for the relevant purpose.

Article 4 – Special Categories and Sensitive Personal Data

For certain trips, information about accessibility, dietary requirements, health or special assistance may be necessary. We process health information or other special categories of data only where there is a valid legal basis and an applicable exception to the statutory prohibition on processing, such as explicit consent where appropriate. We ask travellers not to send medical records or other sensitive information unless this is necessary and has been agreed in advance. Copies of passports and identity documents are not routinely requested or retained; where required by a supplier or by law, we limit the information to what is necessary.

Article 5 – Purposes and Legal Bases

We process personal data for: (a) responding to enquiries and designing travel proposals – performance of a contract or taking steps at the data subject's request before entering into a contract; (b) reserving, managing and providing travel services – performance of a contract; (c) invoicing, administration and compliance with tax retention obligations – legal obligation; (d) customer contact, service improvement, fraud prevention and protecting our legal position – legitimate interests, following a balancing assessment; (e) newsletters or non-essential cookies – consent where required; and (f) compliance with lawful requests from competent authorities – legal obligation. Where consent is the legal basis, it may be withdrawn without affecting the lawfulness of earlier processing.

Article 6 – Travel Enquiries and Design Fee

When you request a tailor-made trip, we process the information needed to identify your preferences, design an itinerary, compare suppliers, present a travel proposal and administer any Design Fee. If no trip is booked, we retain information no longer than necessary to complete the assignment, address potential disputes and comply with applicable retention obligations. Payment and offsetting of the Design Fee upon a confirmed booking are processed for contractual and administrative purposes.

Article 7 – Bookings and Fellow Travellers

For bookings, we process the information necessary to arrange tickets, accommodation, transfers, car hire and activities. We ask the lead booker to inform fellow travellers about this Privacy Policy and to provide only the information necessary for the booking. For minors, we process data through a parent, guardian or other authorised representative where required. We do not use fellow travellers' details for independent marketing purposes without an appropriate legal basis.

Article 8 – Recipients of Personal Data

Where necessary, we share information with airlines, hotels, carriers, car rental companies, cruise operators, local travel organisations, activity providers, reservation and ticketing platforms, payment service providers, hosting and IT providers, accounting and professional advisers, insurance or travel guarantee scheme parties where applicable, and competent authorities where legally required. We share only the information necessary for the relevant task. We enter into legally required arrangements with processors. Suppliers may also act as independent data controllers.

Article 9 – Transfers Outside the European Economic Area

Because ADERO Travel arranges international travel, it may be necessary to transfer personal data to parties outside the European Economic Area, including parties in the destination country. We assess the rules applicable to each transfer. Where no adequacy decision exists, we use appropriate safeguards, such as Standard Contractual Clauses, where legally applicable; in specific cases, a statutory derogation for a transfer necessary to perform a contract may apply. The level of protection may vary by country. Further information about relevant safeguards may be requested through our privacy contact.

Article 10 – Payments and Financial Information

For payments, invoicing and refunds, we process necessary billing and transaction details, such as name, billing address, payment status, amount and, where relevant, a partially masked bank account identifier. Payments made through external payment providers are also governed by those providers' privacy policies. ADERO Travel does not store complete payment card details unless demonstrably necessary for a particular service and arranged lawfully and securely.

Article 11 – Website, Cookies and Similar Technologies

The website may use functional cookies and similar technologies necessary for its operation and security. For analytics or marketing cookies that do not qualify for a statutory exemption, we request prior consent. Where applicable, consent can be changed or withdrawn through cookie settings. The cookies actually used, their providers, purposes and retention periods are described in a separate, up-to-date cookie overview. This Policy does not assert that any particular analytics or advertising tools have already been installed.

Article 12 – Newsletters and Marketing Communications

We send marketing emails only where permitted by applicable rules, for example based on consent or the statutory exception for existing customers. Each marketing email includes an easy unsubscribe option where required. Unsubscribing does not affect essential booking and service communications.

Article 13 – Retention Periods

We do not retain personal data longer than necessary for the purpose for which it was collected, unless a statutory retention obligation or a legitimate need, such as handling a dispute, requires longer retention. Financial records are retained for the applicable tax retention period, generally seven years. Booking details and correspondence are assessed in light of necessity, contractual obligations and potential legal claims. Marketing data is deleted or anonymised when the legal basis ceases and no other valid retention obligation applies. Specific technical retention periods are explained in the cookie overview or in information about the relevant service.

Article 14 – Security

ADERO Travel takes appropriate technical and organisational measures to protect against loss, unauthorised access, unlawful processing and unauthorised alteration. These may include access restrictions, strong authentication, secure connections, supplier management and periodic reviews of data flows. No electronic processing is entirely risk-free. Incidents are assessed and, where legally required, reported to the Dutch Data Protection Authority and affected individuals.

Article 15 – Your Privacy Rights

Depending on the circumstances, you have the right of access, rectification, erasure, restriction of processing, data portability and objection to processing based on legitimate interests. You may object to direct marketing. Where processing is based on consent, you may withdraw it. We may request additional information to verify your identity without collecting unnecessary data. We generally respond within one month and will inform you if the statutory deadline is lawfully extended. Rights may be limited by statutory exceptions.

Article 16 – Complaints and Supervisory Authority

For questions or requests, please contact info@aderotravel.nl. If you believe we are processing your personal data incorrectly, we welcome the opportunity to investigate your complaint. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl. This does not affect other legal remedies.

Article 17 – Automated Decision-Making and Profiling

ADERO Travel does not make decisions based solely on automated processing that produce legal effects or similarly significant effects for travellers, unless such processing is separately introduced with the legally required information and safeguards. Travel preferences may be used to prepare a suitable personalised proposal; this does not necessarily constitute automated decision-making within the meaning of Article 22 GDPR.

Article 18 – Links and External Websites

The website and travel documents may contain links to websites or systems operated by other parties. ADERO Travel is not responsible for the privacy practices of independent third parties. We recommend reviewing their privacy policies before providing personal data to them.

Article 19 – Changes to this Privacy Policy

ADERO Travel may update this Privacy Policy when its services, legal requirements or processing activities change. The current Policy will be made available on the website. For material changes, we will provide additional information to data subjects where legally required or reasonably appropriate. No version number or publication date is included in this document.

Article 20 – Contact

For privacy questions, access requests, objections, corrections or erasure requests: ADERO Travel B.V. Email: info@aderotravel.nl

Website: www.aderotravel.nl Current office and registration details are available through the official business information.