FAQ

1. The Privacy Policy on Personal Data Protection developed by the Agency (hereinafter referred to as “the Policy”) is integral part of the General Terms of Service which is accessible at the following: https://corporate.ttnbtm.com/en/content/agreement-bookings-creation-and-cancellation.html

3. Regarding additional information related to the processing, place of storage and use of the personal data of Travelers and your representatives, please contact the Customer Care Service or send your requests to the Agency’s email address.

4. Processing of personal data by the Agency as the data controller

4.1. Before you obtain the Traveler’s consent to the collection and processing of his/her personal data required for rendering the services selected and booked in his/her name, or prior to notifying the Traveler of any other lawful ground of processing of the personal data, you shall notify to the Traveler the full name of and the contact details of the Agency as well as the following information:

4.2. What is personal data: Personal data — information related to an individual who is identified or can be identified, regardless of the form and format of such data (e.g., first name and last name, email address, number and series of a passport, etc.).
4.3. What type of data about Travelers the Agency collects and processes: Te Agency receives and stores all the information you leave on the Website, provide to the Customer Care Service or the Agency in any other way, and to the extent necessary to provide the services or execute the contractual relationship with you. Further, personal data may be collected and processed automatically when you are using this Website (e.g., through cookies).
4.4. Through your use of the Website, the Agency collects, receives, stores and processes the following personal data on Travelers and your representatives (if such data are required for the rendering of services and specified at the moment of the Order/Booking placement):

• last name, first name, patronymic, date of birth, gender, citizenship, mobile phone number, postal address and email address;
• data of the documents necessary for identification purposes (e.g., number and series of a passport, its validity date);
• Customer’s/Traveler’s bank payment card data (bank payment card number, expiration date, CVC/CVV code and the name of a cardholder);
• Logfiles (IP address, browser type, referring/exit pages on the Website and URLs, the number of clicks and methods of interaction with the Website, domain names, landing pages/content, pages/content viewed, device ID and device location);
• profile information (preferences, details of your historical searches, historic booking details, travel plans and other information);
• your behavior and content (feedback and comments and files that you upload to the Website and any other information you voluntarily leave on the Website).

These personal data may be collected via cookies (see below).
4.5. Sensitive information on Travelers information about Travelers that may include “sensitive” personal data may be required in order to provide you with the highest-possible-level services. Such data may be related to Travelers’ preferences with respect to the choice of a seat in the vehicle or hotel, meals, necessity additional support or use of additional equipment when using the services. Such “sensitive” information shall be provided by you, in particular on the Traveler’s own initiative and upon his/her explicit consent, and only if the provision of services are impossible without such “sensitive” information.
4.6. Automated data collection and cookies. As most websites and mobile applications, we use automated collection of information on Website users, cookies, provided that you have granted consent to their use (e.g., through the banner on the Website) in order to optimize our services and the Website, unless cookies are required for strictly technical functioning of the Website.
When using this Website, there is the automated collection of information on the device you use to visit the Website, e.g. software, operating system, IP address, the source of links, webpages clicked on by you, links you have used to access the Website, etc. Such automated data collection takes place with the purpose to adjust the use of services of the Website and offers intended for you, as well as to prevent possible fraud.
The automated collection of some data and the use of the technologies “cookie” and “web beacon” improve the functions of the Website and development of the most convenient use of Website services, as well as helps us assess the implementation of advertising and marketing campaigns, offer information which may be of interest and useful for you and building usage profiles for market research.
Cookies are small text files that can be stored on your computer (or any other device) during your first visit of the Website and allow us to recognize your computer during your visit (for example, in order to remember data for logging into the “My Account” section). We mainly use: (i) functional cookies that do not collect personal data and (ii) cookies that help us compile aggregate data about user traffic and interaction with the Website so that we can offer better Website experiences and personalized advertisement. We may also use third party services that track this information on our behalf. You can choose to have your device warn you each time a cookie is being set on your Website or you can choose to turn off all cookies. However, if you disable cookies some features may be disabled and some of our services may not function properly.
4.7. Google Analytics. We use Google Analytics, which is a web analytics tool that helps us understand Wbsite users engage with the Website. The following information is collected by Google Analytics: browser, type of a gadget, model of a gadget, location, country, city, service provider, screen resolution (on a mobile phone), time on the Website, language, operating system, visited pages on the Website. The information generated by cookies about the use of the Website (including the user's IP address) may be transmitted to and stored by Google on servers outside of the country of your company registration and Europe (e.g., in the USA). Google uses the information to examine the Website’s usage, prepare reports on the Website activities and to offer other optional services. Google may supply this information to third parties if Google is legally required to, or if the information is processed on behalf of Google. The Google Analytics cookies expire in 730 days (default value) and will be kept on your device for that period of time, unless of course you remove them manually. You can at any time disable collection of your data by Google Analytics, as described here — https://tools.google.com/dlpage/gaoptout/.
4.8. How do we use data about Travelers? We use personal data of Travelers to:

• ensure the provision of services and execution of contractual relationships with Suppliers/Carriers with respect to the ordered services;
• communication with you concerning the ordered services and to send you confirmation of your Booking;
• perform, process and edit your Booking;
• provide information on existing and future services and offers;
• improve the performance and quality of the Website;
• provide answers to your requests and comments;
• encourage you to participate in our surveys and provide feedback;
• find out the services which may be of interest to you;
• satisfy your claims;
• file claims to the Suppliers;
• notify you of possible illegal or unlawful acts;
• solve any issues which may arise under or in respect of the fulfillment of the conditions of the Terms;
• for any other purposes about which we will notify you prior to the new processing takes place. If required, we will seek your consent before commencing the new data processing activity.

Bank payment card data shall be used to confirm the payment for the Booking created by you on the Website.

Please note that the provision of services might be impossible if some personal data of Travelers have not been provided by you.
Based on your explicit or our legitimate interest, we will also process your personal data (name, email address and preferences) in order to send you periodic emails (newsletters) as well as push notifications regarding our services, special offers, promotions and ancillary services, in particular the services you have used before. The Agency strives to provide you with the highest possible level of service. Thus, we may send you information with the list of offers on our Website which may be of interest to you and which may be related to the Services selected by you, upon your consent. If you do not wish to receive such emails, you may opt-out the relevant dialog box on the website or opt out of receiving them.
4.9. Profiling. Based on your and Travelers’ consent we may collate and analyze your consumption and usage behavior data to perform profiling in order to provide you with offers tailored to your needs, preferences and interests. Offers may include inter alia discounts on services. Offers means offers of the Agency or our business partners.
Profiling is any form of automated processing of your and Travelers’ personal data consisting of the use of personal data to evaluate certain personal aspects relating to you/Travelers, in particular to analyze or predict aspects concerning economic situation, health, personal preferences, interests, reliability, behavior, location or movements of Travelers.
4.10. Legal basis for data processing. Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect such data. However, we usually will process the personal data only (i) where we need the personal data to provide the services or perform the contract, to which the Traveler is subject, (ii) where we have your/Travelers consent to do so, or (iii) where the processing is in our legitimate interests and not overridden by your/Travelers rights. In some cases, we may also have a legal obligation to collect personal data from you and Traveler.
4.11. Data Storage. We store personal data you provide us with where we have an ongoing legitimate need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements) or for the period of limitation prescribed in the relevant laws. When we have no ongoing legitimate need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible. In the case of consent-based data processing, personal data will be processed until the consent is withdrawn.
4.12. Transfer of Travelers’ data. To the extent it is necessary for the proper provision of the booked services, we transfer Travelers’ personal data to recipients as indicated below since the services could not be provided without such transfer:

• Suppliers/operators, e.g. hotels, airline carriers, GDS, etc. which render the services you booked. All the services on this Website, which are offered by third parties, are marked as such on our Website. We do not give your email address to Suppliers, unless it is required for the performance of the services, which you booked through the Agency. The Suppliers may use personal data for the purposes of rendering booked (or similar) services to the Travelers and other purposes, defined by the Suppliers. We do not impose any other restrictions on Suppliers with respect to the use or disclose of other types of personal data. However, we recommend that you get acquainted yourself and the Travelers with the personal data protection policy of each Supplier that performs the services you booked on this Website. The Suppliers may contact you or Travelers in order to obtain additional information on Travelers, help you with the booking of services, or answer your requests. Please note that we do not supervise the data protection policy of the Suppliers;
• Independent operators (service providers), which offer services and act on our behalf, as well as operators, which process bank payment card data, business analytics, customer service managers, marketing consultants, experts, who distribute questionnaires or other offers and are in charge of prevention of payment fraud. We may as well allow independent operators to use personal data on our behalf if it is required for the proper functioning of our Website or sending of online messages, which may be of interest to you. Independent operators obtain access and collect information, which is required for their work. They are not allowed to share such data or use them for any other or their own purposes. They must, in the same manner as we, abide by the same data protection terms;
• Business partners, with whom we jointly offer products and services or their products and services we offer on our Website. You may see whether the services you requested belong to a certain independent company. In that case, only the business partner name is given or is accompanied by our name. If you accept their services, there is a possibility that we share your and Traveler information, namely your personal data, with such business partner. Please note that we do not supervise the data protection policy of such business partners;
• We may also share personal data to the Agency Affiliates, representatives, officers, agents, employees, or partners of the Agency in order to implement the terms and conditions set forth in the General Terms of Service and the Agreement concluded between you and the Agency, as far as it is required to render ordered services.

If applicable, you agree that in order to render the services you are contracting, Travelers’ personal data will be included in a data file whose data controller is the Spanish company Amadeus IT Group, S.A. The Traveler may exercise his/her rights of access and rectification by notice (preferably in English) to [email protected].

4.13. Cross-border data transfer. You ensure us that the Traveler confirms and agrees that in order to provide the services that you have requested, the Agency may transfer the personal data of the Traveler, including the sensitive personal data to recipients located outside of the country of your company registration and Europe in order to obtain the proper level of the services ordered. Thus, Travelers’ personal data may be accessed by the Agency Affiliates and data processors and recipients from countries that do not provide the same level of data protection as provided in the European Economic Area. The storage and processing of Travelers’ personal data may be carried out on the servers and media owned/leased by the Agency, suppliers or independent contractors that may be located in any country of the world (including, but not limited to, the countries of the European Union or European Economic Area, the USA, Canada).
Therefore, the Agency, where applicable, will take all reasonable measures which are necessary to ensure an adequate level of protection as defined by the applicable data protection law, in particular through the application of the Standard Contractual Clauses issued by the European Commission or by a decision of the European Commission which states that the country in which the recipient of the transferred data is provides an adequate level of data protection. You ensures the Traveler is aware, confirms and agrees that based on his/her chosen travel destination, his/her personal data may be transferred to the third countries (Suppliers’ country of registration/operation, airports, etc.), which do not have an adequate level of protection of personal data cannot be ensured.
If the Traveler thinks his/her privacy rights have been breached, he/she may lodge a complaint with an authority of the European Union country of his/her habitual residence, place of work or of an alleged infringement. Contact information for these authorities can be accessed at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.