This Policy sets out how the personal data you provide to us is collected, used, processed or disclosed by us in accordance with the European Union General Data Protection Regulation (“GDPR”) and the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”). We may amend this Policy at any time and without prior notice. Such amendments will be effective immediately and shall apply to any information you provide, or your use of the Services. Your use and access of Betravelo after the amendments to this Policy will constitute your acceptance to the terms and conditions, as modified.
1. Who We Are
Betravelo Group Limited is operating as Betravelo (“Betravelo”, “we”, “our” or “us”) is the controller (for the purposes GDPR) responsible for the processing of personal data through our Services. Our address is 8F, King Place Plaza, 55, King Yip St, Kwun Tong, Hong Kong. Our Data Protection Officer can be contacted directly at email@example.com
2. Information We Collect
We collect specific data from you directly, like the information you enter yourself. We may also receive some data automatically, like information about your device and the aspects of our Services you interact with or spend time using. Examples of information we collect include:
2.1 Personal Data
a. When you create a Betravelo Account (“Account”), you provide us with personal information that may include your username, email address, first and last name, contact details, account password, company information and payment information. We may collect additional information when you are using our Services such as passenger information (necessary for travel reservations), travel preferences (for example, meal requests, seat preferences, membership numbers), travel itinerary (flight and accommodation details), travel budget, and expense data. If you choose to use our invitation service, we will ask you for an email address and automatically send an email invitation. We store this information to send the invitation and track the success of our invitation service.
b. In some cases, your employer may have set up an account with us. Your employer’s service administrator may provide your email address to us, which we use to send you an email invitation, in which case your use of the Services shall be deemed as authorisation of and consent to your employer’s disclosure of your personal information in the manner described in this Policy. All employer service administrators further warrant, represent, and undertake that they have obtained the consent of all parties of the personal information provided in the manner described in this Policy.
c. If you provide to us any personal data relating to a third party, you warrant, represent and undertake that, by submitting such information to us, you have obtained the consent of the third party to provide us with their personal data.
2.2 Technical, Usage, and Location Information
2.3 Third Party Platforms
We may collect information when you interact with our advertisements and other content on third-party platforms or sites, such as social networking sites. Information may include your social profile from the social networking sites or the fact that you viewed or interacted with the content.
2.3 Other Information
We may collect additional information from you that is not explicitly listed here. We may use any such information under this Policy or as otherwise permitted by you.
3. Information We Collect
a. Essential cookies: These are strictly necessary to provide you with our Services. Without these cookies, we would not be able to provide you with our Services.
b. Functionality cookies: These cookies allow us to remember your preferences when you use our Services.
c. Analytics cookies: These cookies allow us to gather statistical data and analyse how our users use our Services.
d. Advertising cookies: These cookies are used to make advertising messages more relevant to you.
e. Social media cookies: These cookies are used to enable you to share content that you find interesting through third-party social networking and other websites. These may also be used for advertising purposes.
4. How We Use Your Information
We may use the information that we collect to provide, improve, personalise, analyse, diagnose, measure and protect our Services. Examples of how we may use your information include:
a. Providing our Services to you;
b. To verify your bookings and reservations via our Betravelo platform;
c. To provide media announcement and responses;
d. Maintain and improve our Services;
e. Customizing existing and future product offerings to our users;
f. Processing payments, refunds, fee adjustments and waivers;
g. Processing insurance and administrative claims arising from the Services;
h. Research and development;
i. Providing customer support or technical assistance;
j. Responding to inquiries from you;
k. Contacting you to provide product updates, information about products you have requested or purchased;
l. Creating or administrating your Account, including verifying you with your Account;
m. Marketing and promoting our products, services and features that you may be interested in, and monitoring the performance of our marketing efforts;
n. Generate aggregate, non-identifying information about how people use our Services;
o. Fight spam, fraud and other form of abuse and all related investigations thereto;
p. Enhancing security of our Services and protecting your information;
q. To monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
r. Sharing with third parties for the purposes discussed in Clause 5 below;
s. Facilitating business asset transactions involving Betravelo Group Limited.;
t. To comply with applicable law, legal process and regulation and protect legitimate business interests; and
u. Purposes which are reasonably related to the aforesaid.
5. How We Share Your Information
At times we may share specific personal information with our strategic partners that work for us to provide services. Examples of some of these third parties include:
5.1 Service Provider
We share personal information with companies who provide services such as payment processing, data storage, hosting, order fulfilment, customer service, travel related services, insurance related services, information processing, analytics, marketing, research, and other service providers who enable specific features and functionalities of the Services you have requested.
5.2 Travel Suppliers
When you use our travel related Services, we will share relevant personal information with travel suppliers ("Suppliers") such as airlines, hotel, property owners, insurance, car rental, ground transportation, activities, online travel agencies, intermediaries, and resellers who will fulfil your travel reservations.
5.3 Professional Advisors
Our lawyers, accountants, auditors, financial institutions, advisors may need to review specific personal information to provide legal, accounting, compliance, banking and similar services.
5.4 Service Administrators
If you work for an organisation that uses our Services, your employer's service administrator and others within your organisation may have the ability to access and control specific personal information. As set out above, your employer’s service administrator’s use of the Services shall be deemed as authorisation of and consent to your employer’s access and control of the said personal information in accordance with their internal policy. Please refer to your organisation’s internal policy if you have questions about this.
All employers warrant, represent, and undertake that all internal policies and usage of employee personal information shall be in material compliance with all applicable laws.
5.5 Legal Authorities
We may disclose your personal information if we believe it is reasonably necessary to comply with applicable law, including government requests, law enforcement requests, and otherwise to protect rights, property and safety of ourselves or others.
In the event of a reorganisation, merger, or sale we may transfer any personal information we collect to the relevant third party.
6. How We Protect Your Information
We implement appropriate technical and organisational security safeguards to protect the information we collect and store. However, due to inherent open nature of the Internet, no security measures are entirely foolproof. In the event that any information gets compromised, we will take reasonable steps to investigate and notify the affected users and take other actions in accordance with any applicable laws and regulations.
7. How Long We Store Your Information
We will retain your information for as long as your Account is active or as needed to provide you Services. We may also keep some of your personal information for as long as reasonably necessary for our legitimate business interests, including fraud detection, and to comply with our legal obligations including tax, statutory reporting, and auditing.
8. Minors Under 18 Years of Age
Our Services are not intended for children under the age of 18, and we do not knowingly collect personally identifiable information from children under the age of 18. In the event that we learn that we have collected personal information from a child under age 18, we will take the necessary steps to remove that information. If you believe that a child under the age of 18 has under any circumstances provided us with personal information, please contact us at firstname.lastname@example.org.
9. Links To Other Websites
Our Services may contain links to and from third party websites. If you follow a link to any of these websites, please note that we are not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information, we recommend that you carefully review the privacy policies of other websites and services that you access.
10. Your Rights
You have the following rights in relation to your personal information:
10.1 Communication Preferences
You may unsubscribe from our marketing communications at any time by following the opt-out links on any marketing message sent to you, updating your communication preferences through your Account settings, or by contacting us at any time. Please note that you may be unable to opt-out of certain Services-related communications including but not limited to the confirmation of your reservations, security and verification alerts, billings and expense approvals.
10.2 Blocking Cookies
You may remove or block certain cookies using the settings in your browser. If you do not accept our cookies, you may not be able to use our Services properly. Also, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com
10.3 Access and Correction
If you wish to access, correct or update your personal information, you may do so at any time by accessing Account settings through our website. Alternatively, you can contact us at email@example.com with your name and information requested to be accessed, corrected, or removed. You are responsible for providing us with current and updated information. We may decline to process requests that jeopardise the privacy of others. We may also charge a reasonable fee if your request if repetitive, excessive or require disproportionate technical effort, or, we may refuse to comply with your request in these circumstances. Please note that we may retain your information as necessary to support our Services, comply with legal obligations or resolve disputes.
10.4 Data Subject Rights for EU Citizens and/or Organisations within the EU
The GDPR provides relevant individuals with additional rights including the right to access personal information, right to rectify personal information, right to delete personal information, right to object to processing of personal information, right to restrict processing of personal information, the right to transfer personal information, the right to object to the processing of personal information and the right not to be subject to automated decision-making. To exercise these rights, please contact us at firstname.lastname@example.org. Please note that we will require you to provide us with proof of identity before responding to any requests to exercise your rights. We will respond to your request within the applicable statutory term.
Please note that if you withdraw your consent to any or all use of your personal data, depending on the nature of your request, we may not be in a position to continue to provide the Services to you.
11. How to Contact Us
If you have any questions or need to contact us about this Policy, please contact us by email at email@example.com.
12. Changes to Our Policy
We reserve the right to make changes to this Policy at any time. We will notify you of any significant changes to this Policy on our website or through appropriate communication channels. All changes shall be effective immediately upon posting to this page unless otherwise mentioned in the notification. Your continued use of our Services constitutes your agreement to this Policy and any updates.
13. Governing Law and Jurisdiction
This Policy shall be governed by the laws of Hong Kong. You agree to submit to exclusive jurisdiction of the Hong Kong courts.