隐私政策 | Holicay

We collect information and data that is automatically transmitted or generated by your browser each time you visit our website. The information includes:

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:

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 Holicay 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.

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.

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.

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.

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.

When you choose to sync your trip itineraries with Google Calendar through our Export to Google Calendar feature, our application accesses the following Google user data:

• Your Google Calendar information and events
• Permission to create, edit, and manage calendar events in your Google Calendar
• Basic Google account information (email address and name) for authentication purposes

We use your Google user data exclusively for the following purposes:

• To create calendar events in your Google Calendar based on your trip itinerary created in Holicay
• To help you better organize and manage your travel plans by syncing them with your personal calendar
• To verify your identity when connecting to Google Calendar services
• To maintain the connection between your Holicay trip plans and your Google Calendar

We do not use your Google user data for any other purposes, including advertising, marketing to third parties, or any activities unrelated to the calendar synchronization feature.

We implement the following security measures to protect your Google user data:

• All data transmitted between Holicay and Google services is encrypted using industry-standard HTTPS/TLS protocols
• Google authentication tokens are securely stored and encrypted
• Only authorized personnel have access to systems handling Google user data

Retention Policy:

• Google authentication tokens are retained only as long as you maintain an active connection between Holicay and your Google Calendar
• Calendar event data is not stored on our servers after synchronization is complete

Data Deletion:

• You can revoke Google Calendar access at any time through your Google Account settings under “Apps with account access”
• If you delete your Google Calendar account, we will delete all Google user data associated with your account

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

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.

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.

a) Transportation providers When you make a booking on our service sites, we will transmit any personal data needed to execute the booking to the respective service providers. The service providers will need your personal information to process your bookings and generate personalised tickets for you. Data processed by other transportation providers and third-party services, is regulated seperately from our privacy policy. Please refer to the privacy policy of other transportation provider and third-party services to learn more about their data regulation policies.

b) Payment providers Payment details like the credit card information used for bookings made on our service sites or App are processed by Stripe. These third party payment processers will then transmit your card details to the respective credit card companies. Your details are transferred using secured SSL protocols to the payment processor.

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.

Google Services Integration: We integrate with Google Calendar API services to provide trip synchronization functionality. When you choose to connect your Google Calendar, we transmit your trip itinerary data to Google's servers to create calendar events. This integration is governed by Google's privacy policy and our data handling practices described in the "Google User Data and Calendar Integration" section above.

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.

We will only process personal information in ways that are compatible with the purposes outlined in this privacy policy (or those you later authorize). We process your personal data for the following purposes and on the following legal basis:

a) Pursuant to Art. 6(1)(b) GDPR to enter into, perform, modify or terminate a contractual relationship with you, in particular:

• To enable your access and use of the Service Sites
• To facilitate your search queries and bookings
• To indicate dates that you wish to travel
• The days and dates you will spend in different places for your booking
• To personalise the ticket or booking that you have made and to deliver them to you
• To facilitate your account login on the Service Sites by remembering your user login details

b) Pursuant to Art. 6(1)(f) GDPR or corporate interest:

• To improve the Service Sites and our other services and to improve services offered
• To perform internal upgrades and quality control
• To ensure network and information security
• To create statistics about the on the Service Sites and App
• For internal accounting and invoicing purposes
• To personalize the Service Sites and our offers
• To show promotions that would interest you on our platforms
• To collect information on marketing material and strategy
• For partnerships with other companies and/ or affiliates Accounting and record keeping

c) Pursuant to Art. 6(1)(a) GDPR based on your consent if you sign up for the following services:

• To send you newsletter emails or other marketing push messages based on your interest (see above)
• To transfer data for certain bookings to our partner Distribution and to transfer Facebook Data (see above)

d) Pursuant to Art. 6(1)(a) GDPR based on your explicit consent for Google Services integration:

• To access your Google Calendar for trip synchronization purposes
• To create, edit, and manage calendar events based on your Holicay trip itineraries
• To maintain the connection between your Holicay account and Google Calendar services
• To provide ongoing synchronization between your trip plans and calendar events