Tikigo is an online platform that allows tourist professionals and travelers (collectively referred as the “User” or the “Users”) to offer, plan, book and organize tours, activities, rentals, transportations and more. Our website and its applications, referred generically as our “Website” or “Platform”, is owned and operated by Neosis LTD.
You can use our website without sharing any personal data. But in order to use specific services offered on the platform, such as advertising your company or booking a service, you may have to provide personal information. We value the trust that you put in us while doing so and that’s why it is important for us to let you know how, why and in which purpose this information is collected and used.
1. Personal Data
“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified in particular by reference to an identifier such as a name, an identification number or an online identifier.
2. Data Subject
A “Data Subject” is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
“Processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
4. Restriction of processing
“Restriction of processing” is the marking of stored personal data with the aim of limiting their processing in the future.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s preferences, interests, behaviour or location.
“Pseudonymisation” is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
7. Controller or Controller Responsible for the Processing
“Controller” or “controller responsible” for the processing is the natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data.
The “Processor” is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
The “Recipient” is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.
10. Third party
A “Third Party” is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
“Consent” of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Name and Address of the Controller
The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Yen Sheng Centre,
64 Hoi Yuen Road,
Name and Address of the Data Protection Officer
The Data Protection Officer of the controller is:
Yen Sheng Centre,
64 Hoi Yuen Road,
Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.
The data subject may at any time prevent the setting of cookies through our website by means of a corresponding setting of their Internet browser, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via their Internet browser. Note that if the user deactivates the setting of cookies in their Internet browser, some functions of our website may not be entirely usable.
Collection of General Data and Information
Tikigo collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, Tikigo does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Tikigo analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
User Registration on the Website
The data subject has the possibility to register on Tikigo platform with the indication of personal data such as the user’s email address, name, address, contact informations, company or employer name, position in the said company, profile or company pictures. The personal data entered by the data subject are collected and stored exclusively for internal use of the website and full access to the services it offers.
When registering on our website, the user’s IP address and the time of registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable our website to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the database of the company.
The registration of the data subject can be accomplished by third parties such as Google and Facebook authentication system. More details about the privacy policies of these companies are available in the next paragraphs. As a principle, Tikigo only uses the informations that these authentication systems share, under the control, settings and authorization of the user.
The company shall, at any time, provide information upon request to each data subject as to what personal data are stored about them. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.
In order to provide its services, general informations or for marketing purposes, Tikigo platform may contact its users through the mean of email notifications. The said emails may be sent to the email address provided while the user registered on the website.
The data subject may opt-out of email communications at any moment upon contacting the controller to the email provided in the hereabove section. Note that opting-out of these email notifications may hinder the user’s ability to use the whole functionalities of the website and even prevent access to his account under specific circumstances such as password reset.
Our website displays information allowing a quick electronic contact with our enterprise, such as email addresses and WhatsApp numbers. If a subject data contacts us via email, a messaging service or a contact form available on the website, the personal data that the user transmitted on a voluntary basis will be stored in order to process the given information or contact the data subject.
Tikigo users have the possibility and are even encouraged to leave reviews, photos, ratings and comments about the locations, tours, activities, companies and other essential components and actors of the platform. Wherever this functionality is available on the website, the user can create content to share their honest opinion. This reviewing system is monitored by Tikigo moderation team which can approve or unpublish a review or a picture based on the respect of company’s guidelines.
If a user leaves a review about a location, an activity or an organizer, the content shared by the data subject will be stored and published if approved by the moderation team. The review will be accessible in the reviews gallery about the said location, service or organizer. If photos were shared by the data subject, they will be accessible in the photo gallery of the said location, service or organizer.
Personal Data Routine Erasure
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
Personal Data Storage Period
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the service.
Rights of the Subject Data
In accordance with the General Data Protection Regulation (GDPR) established by the European legislator, the data subject has the following rights regarding the personal data collected about them on our website.
1. Right of Confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
2. Right of Access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- The purposes of the processing
- The categories of personal data concerned
- The recipients or categories of recipients to whom the personal data have been or will be disclosed
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
- The existence of the right to lodge a complaint with a supervisory authority
- Where the personal data are not collected from the data subject, any available information as to their source
- The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
3. Right to Rectification
Each data subject shall have the right granted by the European legislator to obtain the rectification of inaccurate personal data concerning him or her.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
4. Right to Erasure (Right to be Forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Tikigo, he or she may, at any time, contact any employee of the controller.
5. Right of Restriction of Processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by our website, he or she may at any time contact any employee of the controller to arrange the restriction of the processing.
6. Right to Data Portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of the controller.
7. Right to Object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Tikigo shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the controller processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the processing for direct marketing purposes, Tikigo will no longer process the personal data for these purposes.
In order to exercise the right to object, the data subject may contact any employee of the controller. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
8. Automated Individual Decision-Making, Including Profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by the Union or a Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the controller.
9. Right to Withdraw Data Protection Consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller.
Third Party Applications
In order to provide user-friendly services, enhanced performances, additional and complementary services and functionalities, Tikigo uses softwares, gateways and IT solutions which collects personal data about the data subject. These services include but are not limited to authentication systems, advertising and retargeting systems, website analytics and payment gateways.
The hereabove paragraphs relate to the said services and reference the way they are used by Tikigo, as well as provide information about the places where to find their own privacy policies.
Data Protection Provisions About the Use of Facebook
On Tikigo, the controller has integrated components of the social network Facebook. The operating company of this service is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Our website mainly uses Facebook for its authentication system, which allows a user to join or log into his existing account on Tikigo by using his existing Facebook account.
On pages which integrates the “like” button or another Facebook component was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject — and for the entire duration of their stay on our Internet site — which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
Data Protection Provisions About the Use of Google Analytics
On this website, the controller has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising. The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following link: https://www.google.com/analytics/.
Data Protection Provisions About the Use of Cloudflare (CDN)
On this website, the controller has integrated components of the enterprise Cloudflare. Cloudflare is a CDN (“Content Delivery Network”) provider. The operating company of Cloudflare is Cloudflare Inc., 101 Townsend St San Francisco, CA 94107.
The purpose of Cloudflare CDN is to speed up the loading times of this website by loading static components from the server closest to the user. With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a CDNJS component (cdnjs.com hosts scripts, stylesheets and images) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding cdnjs component from Cloudflare through the CDNJS component. An overview of all the CDNJS components may be accessed under https://cdnjs.com/libraries. During the course of this technical procedure, Cloudflare is made aware of what specific sub-site of our website was visited by the data subject.
The applicable data protection provisions of Cloudflare may be accessed under https://www.cloudflare.com/privacypolicy/
Data Protection Provisions About the Use of PayPal as a Payment Processor
On this website, the controller has integrated components of PayPal. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal is also able to process virtual payments through credit cards when a user does not have a PayPal account. A PayPal account is managed via an e-mail address, which is why there are no classic account numbers. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services. The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.
If the data subject chooses “PayPal” as the payment option in the online shop during the ordering process, we automatically transmit the data of the data subject to PayPal. By selecting this payment option, the data subject agrees to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which are in connection with the respective order.
The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal, in particular, if a legitimate interest in the transmission is given. The personal data exchanged between PayPal and the controller for the processing of the data will be transmitted by PayPal to economic credit agencies. This transmission is intended for identity and creditworthiness checks.
PayPal will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfill contractual obligations or for data to be processed in the order.
The data subject has the possibility to revoke consent for the handling of personal data at any time from PayPal. A revocation shall not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of PayPal may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
Data Protection Provisions About the Use of Stripe as a Payment Processor
On this website, the controller has integrated components of Stripe. Stripe is an online payment service provider. Stripe allows to pay via various other payment methods, such as credit card, giropay, SOFORT and so on. The operating company of Stripe is Stripe Payments Europe, Ltd, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin.
If the data subject chooses one of the online payment methods as the payment option on our website during the registration process, the data of the data subject will be transmitted to Stripe. By doing so, the data subject agrees to the transmission of personal data required for payment processing.
The personal data transmitted to Stripe is usually first name, last name and email address, or other data necessary for payment processing.
The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to Stripe, in particular, if a legitimate interest in the transmission is given. The personal data exchanged between Stripe and the controller for the processing of the data will be transmitted by Stripe to economic credit agencies. This transmission is intended for identity and creditworthiness checks.
Stripe provides personal data to affiliated companies and service providers or subcontractors as far as this is necessary for the fulfillment of contractual obligations or data in order to be processed.
The data subject has the possibility to revoke the consent to the handling of personal data at any time from Stripe. A revocation shall not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of Stripe may be retrieved under https://stripe.com/privacy.