How we deal with your data

Privacy Policy
How we deal with your data
This privacy policy pertains to the collection of personal data by Holicay Private Limited. Holicay Private Limited, Holicay Pte Ltd or Holicay (“us”, “we”, or “our”) operates the https://www.holicay.com website (the “Service”). This declaration informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. The controllers of your personal data in the meaning of the General Data Protection Regulation (GDPR) is Holicay Pte Ltd with whom you have a business relationship or whose products/services you are using.

By using the service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible from https://www.holicay.com
A. What kinds of data do we collect?
Holicay collects the following data:
1. Website visitor information and browsing patterns
We collect information and data that is automatically transmitted or generated by your browser each time you visit our website. The information includes:

∙ Your IP address
∙ The URLs of the site you visited before accessing our Service Sites (“referrer”)

∙ The browser used by you and the browser language
∙ The operating system and user interface

∙ The access device used
∙ The date and time of your access
∙ The pages viewed on our website
∙ The time you spend on our Service Sites
∙ The engagement in terms of clicks on our Service Sites

The data mentioned above is stored for a period of 5 years and deleted automatically thereafter. We may use this information to investigate errors, to improve the stability and functionality of the Service Sites, and to assist you in completing any interrupted bookings. We may also use the information collected to improve our future offerings and services.
2. Data provided voluntarily by you / user accounts
In addition to the data above, we also collect and use the information given to us about yourself, the people you travel with and about the planning process of your trip by using the service site.

When you use our service site to book a product, we may need the provision of the following data from you which includes:

∙ Name
∙ Email address
∙ Phone number
∙ Government-issued identification numbers
∙ Passport number
∙ Emergency contact information
∙ Billing address
Payment method and/or credit card information
∙ Preferred travel connections
∙ Travel interests and bookings
∙ Feedback on our products and services
∙ If applicable – information about loyalty, bonus or discount cards (railcards or mileage point systems)

In order to complete your bookings with us, you will be asked to provide the data that the respective service provider requires. Our forms show what kind of data is required for each respective booking and we only collect data from you which are essential to the booking process.

a) If you or your companion(s) may need to amend or delete their information, please reach out to us at [email protected]. We store booking-related data for a period of 5 years after you have made your booking. However, if the information is needed for other investigations or research purposes, it may be stored for a longer duration.

b) Should you opt to additionally register for a personal profile with Holicay by creating a user account, this data will be stored with us for your future bookings. We keep your account data as long as you do not delete the account. If you decide to delete your account, we delete the associated data. However, other information like the potential booking data and related basic data (e.g. your name and address) will be kept as described above.

However, if your account shall remain inactive for a period longer than 5 years, we may notify you of our intention to delete your account by mail. If you would like to retain your account with us, you may do so by informing us by following the instructions in the mail that will be sent by us prior to deleting your account.

c) Should you contact us or our customer support (e.g. by email, telephone or contact form on the Service Sites), the information you used to reach us such as your contact information or name, will be used to respond to you. The data will also be saved for processing your inquiries and to improve internal quality controls in the future. We keep your results and data of your inquiries for a period of five years after responding except unless stipulated otherwise.

d) When contacting us by voice call to reach our customer service team, your call may be recorded for quality assurance and for training purposes. The recordings may also be used to process claims, refunds or for fraud detection purposes. While not every call is recorded, recordings are usually kept for a minimum of (3) months unless stated otherwise for legal proceedings or investigations.

e) To improve our overall customer service and product, we may invite you to participate in feedback sessions or surveys. These surveys may help us understand how to improve your overall experience when using our product via the service site. The surveys are also used as a means of conducting market research. The data you provide in these instances will be collected, stored and used to improve our overall offering.

You can withdraw your consent to share your personal data with us at any given time at [email protected]
3. Newsletter and marketing emails
In the event that you opted to receive our newsletter subscription either by signing up for the newsletter on our service site or when creating an user account, we will by default send you newsletter and marketing emails including information about Voyley and/ or partnered third party providers. The information may also include promotions, offers, or general updates about our company products and services.

You can also “unsubscribe” from our newsletter by clicking on the link included in any of our newsletter and marketing emails.

When you have successfully unsubscribed from our mailing list, we will delete your contact information unless the information remains is stored for other reasons described in our privacy policy in this page.
4. Cookies and similar technology
Like many other website operators, we use cookies, web beacons, and similar technology (collectively “Tracking Facilities”) when you visit or use our Service Sites.

Cookies are small text files that are stored by your browser on your computer or mobile device which allows re-identification of your computer or mobile device, potentially across numerous websites, including the Service Sites for the following purposes:

∙ To help us recognize your browser as a previous visitor and save any preferences that may have been set while your browser was visiting our website. We also automatically log you in if you check the “remember me” option on the login page

∙ To help us customize the content and advertisements shown to you on our website or on third party sites and advertisements
To help us measure the effectiveness of the features and offerings, advertisements, and email communications (by determining which emails you open and act upon) shown to you on our service site.
∙ To save and load your preferred currency and language while on our service sites
∙ To allow for website analysis, retargeting and conversion tracking
∙ To allow revisits in between different pages and to remember popular recent search queries

In the event where you are redirected to another website for other services from our service site, the storage of cookies on those websites are not tracked by us. We have no control over cookies from other third-party sites.
5. Targeted advertisements based on your interests
Our Service Sites may use what are known as retargeting ads for presentation of interest-related advertising on third-party websites. We use retargeting ads from Google and Facebook to understand your interests by placing a cookie to gather data from other third-party sites. The retargeting ad provider may then display interests-based ads on other third party sites that you visit. In the entire process, no personal data is stored or transmitted and thus, prevents us from being able to identify you from the data collected. That being said, the retargeting ad provider could associate the data collected with you if you have registered an account with them.
6. Conversion tracking using analytics tools
We use advertising partners to advertise our offers on third-party websites in order to show you relevant products and services you may be interested in from us.

Similarly, our ad partners use cookies that cannot be used to personally identify you but can do the following:∙ Identify your clicks on an ad
∙ Redirection of your browser to specific landing pages

As such, our advertising partners can show the number of users that clicked on ads that we create and eventually determine the number of people redirected to various pages. In the entire advertising process, we will not collect any personal data of consumers and can only obtain statistical data which are general and non-identifying.
7. Web analytics and statistics / Facebook Pixel and Google analytics
The Service Sites use Google Analytics and Facebook pixel, which are web analytics tools provided by Google LLC and Facebook respectively. These companies use cookies stored on the user’s computer when accessing our service sites or App. This allows us to analyze the use of the Service Sites.

Google is subjected to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
8. Data breaches
In the unlikely event of any unauthorized access or acquisition of your personal data, or if we experience a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data, where such breach poses a significant risk of harm to your rights and freedoms, we will promptly notify you without undue delay and, where feasible, not later than 72 hours after having become aware of it. In such a case, we will also inform governmental authorities of such breaches as required by applicable law.
B. With whom do we share your data?
1. Data processing with Voyley AB
Holicay is a online marketplace company that uses online service sites to operate computer systems, handle order processing and perform customer service. We may share your information with, and among, our affiliates in order to enhance the products and services that we provide.

Holicay will process your data solely in compliance with this privacy policy and only for the purpose of performing product services.

Our data processing is in compliance with the GDPR set out in the EU and Impressum laws because we operate in Asia and in Singapore.
3. Other service providers
We may use third party service providers, in particular for technical and business services, tax advisors and legal counsel. This may include hosting providers, including a content delivery network to cache and provide content, statistics and analytics, providers to handle service desk and support data, provision of CRM systems, sending of newsletters/mailings, spam and fraud prevention, IT service and development providers.

These service providers receive personal data solely for the performance of their services for us on our behalf. They are contractually obliged not to use personal data for other purposes.