This page contains information about how we collect, store and process data about you when you book with us, about the use of cookies on our page, and how we use your info if you subscribe to our email newsletter.

When you book a trip on top10potovanja.com we process your personal data according to the principles set forth on this page. Our principles follow current EU regulations (new EU regulations enter into force on 25.5.2018)

We reserve the right to amend this Notice at any time so please check back often.

By using our site and following our newsletter updates you accept our privacy policy.

We use your name and email details to send the travel documents.

If your travel group consists of several passengers, the travel documents will be sent to the email of the person booking the trip.

We need your phone number to be able to get in touch with you fast in case there are problems with the bookings, flight time changes or other communication needs.

To improve our offers and service we use feedback sent by you and other customers via our website or via email/phone.

By subscribing our newsletter you will receive the best travel offers fresh from the oven, directly to your email inbox. You subscribe to the newsletter on our website or by participating in surveys and competitions organized by our company or by us in cooperation with our partners on their sites or at local fair. When participating in a survey/competition, you have given your consent to receive our newsletter. The newsletter is free of charge. You can unsubscribe at any time by clicking the link “unsubscribe” found in the bottom of each newsletter or by contacting us via email/phone.

In order to send our newsletter, we need your email address, and often we also ask for your name (to be able to address you with your real name), postcode to better target offers that are relevant for traveling from your hometown. In some cases we also collect phone-numbers, although currently we do not send offers via text message.

When you book a trip on top10potovanja.com or subscribe to our newsletter we store the following details about you

● Booking reference, passenger names and birth dates, passport details.

● Booking date, Destination, Hotel, Travel dates

● Time when booking/subscription was made

● Possible amendment details

● Browser ip address where booking/subscription was made

● Address and email address

If you are only an email subscriber, we obviously do not store details about your booking or passport details.

We want you to be sure that your data is safe with us, and understand how we use it to offer you better and cheaper trips.. Top 10 Matkatarjoukset is part of Travel Sales Consultancy S.L. More info about us here

The data controller is Travel Sales Consultancy S.L and Top 10 Matkatarjoukset (referred to in this Notice as “we” or “us” or “Top10”). You may contact us at any time concerning your rights. Contact details found in the end of this document.

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. Your privacy is important to us, so please read our Privacy Notice which explains:

• What types of personal data we collect and why we collect it.

• When and how we may share personal data within Top10 and with other organisations.

• The choices you have, including how to access and update your personal data.

We have tried to keep this Notice as simple as possible, but if you are not familiar with terms such as data controller, special categories of personal data, then read more about these and some other terms below.

● Data controller: The data controller determines the purpose and manner in which personal data is used.

● European Economic Area (EEA): EU Member States as well as Norway, Iceland and Lichtenstein.

● Online advertising: Advertising that you may see on the internet.

● Special categories of personal data: This are categories of personal data that reveal racial or ethnic origin; political opinions; religious beliefs; trade union membership; genetic data, biometric data for the purpose of uniquely identifying a natural person; health data; and data concerning a natural person’s sexual orientation.

● Caricom API Data: Some or all of the Caricom states have entered into an agreement with the USA whereby advance passenger data, required by and provided to Caricom states for border security purposes, will be passed to the USA Department for Homeland Security for processing on behalf of those Caricom states. Please see the Caricom website for more details.

● US Secure flight Data: The Transportation Security Administration (TSA) requires you to provide your full name, date of birth and gender for the purpose of watch list screening. You may also provide your Redress Number, if available. Failure to provide details may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others under its published system of records notice. Please see the TSA website for more details.

• Email address

• Zipcode so we know which city you prefer to depart from

• In some cases we also collect phone-number, address and the your browsner’s ip address where you signed up from

• Your personal details, including your address, email address, phone number and date of birth.

• Your account login details, such as your username and the password you chose.

• Your name

• email address

• Booking reference, and trip details, if you have booked a trip from us.

• Travel preferences.

• Information about your browsing behaviour on our websites and mobile apps.

• Information about when you click on one of our adverts, including those shown on other organisations’ websites.

• Information about the way you access our services, including operating system, browser IP address, online identifiers and browser details.

• Social preferences, interests and activities.

If a child is also travelling, we also collect data on the travelling children

• Passenger information, passport details, ID document details.

• Relevant medical data and any special, dietary, religious or disability requests.

• Information about your purchases, including what you bought, when and where you bought it, how you paid for it. We do not store credit card numbers.

• Information about your browsing behaviour on our websites and mobile apps.

• Information about when you click our adverts, including those shown on other organisations’ websites.

• Information about the way you access our services, including operating system, browser IP address, online identifiers and browser details.

• Social preferences, interests and activities.

• Personal data you provide when you connect with us, including by email, post and phone or through social media, such as your name, username, contact details and the browser IP address you interacted with us from.

• Details of emails and other digital communications we send to you that you open, including any links in them that you click on.

• Your feedback and contributions to customer surveys and questionnaires.

• We may use personal data from 3rd parties, such as specialist companies that supply information, partners and public registers.

• Your insurance company, their agents and medical staff may exchange relevant personal data and special categories of personal data with us in circumstances where we/they need to act on your behalf or in the interest of other customers or in an emergency.

• We may use CCTV images, GPS location data, photo metadata, IP address and browser details collected in or in the immediate vicinity of our partners’ premises, airports, other buildings or sent to us by our users

• We use personal data about other individuals provided by you, such as other passengers in your booking.

• By providing other people’s personal details, you must be sure that you are allowed to provide it. You should also ensure that, where appropriate, they understand how their personal data may be used by us.

We use your personal data in a variety of ways, as explained below.

We need to process your personal data so that we can manage your account or booking, provide you with products and services that you want to buy and to help you with any orders and refunds you may ask for.

We use personal data to manage and improve our products, websites and other services.

We monitor how our services are used to help protect your personal data, detect and prevent fraud, crimes and the misuse of services.

We may use personal data to respond to and to manage security operations, accidents or other similar incidents, including medical and insurance purposes.

We use personal data to carry out market research and to develop and improve our producs, services, infrastructure, security and the way we communicate with you. We may use CCTV images to help maintain the safety of anyone working in or visiting our and for the prevention, detection and prosecution of criminal offences. We may also rely on the images to establish, exercise or defend our legal rights

We want to serve you better as a customer so if you contact us, for example by email, post, and phone or via social media, we may use personal data to provide clarification or to help you.

We need to process your personal data so that we can manage any promotions and competitions you choose to participate in, including those we organize in cooperation with our suppliers and retail partners. For example, if you win a prize we may need to contact you.

We may invite you to take part in customer surveys, and other market research activities carried out by ourself and by other organisations on our behalf.

To help us to better be able to provide you with services and marketing communications (including online advertising relevant to your interests), we may combine the personal data we collect when you make purchases online with personal data collected from our websites, mobile apps and other sources.

We do not sell your personal data to third parties.

We want to ensure that marketing communications relating to our products and services, and those of our suppliers, retail partners and Top10, including online advertising, are relevant to your interests.

To do this, we may use your personal data to better understand your interests so that we can try to predict what other products, services and information you might be most interested in. This enables us to tailor our communications to make them more relevant and interesting for you.

Looking at your browsing behavior and purchases helps us to better understand you as a customer and it allows us to provide you with personalised offers and services.

We may also measure your responses to marketing communications relating to products and services we offer, which enables us to offer you products and services that better meet your needs as a customer.

If you do not want to receive a personalised service from us, you can unsubscribe directly in the emails online or over the phone or by writing (e.g. email) to us at any time. We will update our records as soon as we can.

From time to time we may send you relevant offers and news about our products and services in a number of ways, including by email. We may also send you information about other companies’ products and services that we believe may be of interest to you. We will only do this if you previously agreed to receive these marketing communications.

You can change your marketing preferences over the phone, or by using the ‘unsubscribe’ link in our marketing emails, or by writing to us (e.g. email) at any time. Of course, the choice is entirely yours, but if you say you do not want to receive marketing information from us this will prevent you from receiving great offers or promotions that may be of interest to you.

You may still receive service-related communications from us. For example, confirming bookings you make with us and providing important information about the use of our products or services.

We like to hear your views to help us improve our products and services, so we may contact you for market research purposes. You always have the choice to take part or choose not to take part

In order to provide products or services to you we may share personal data with suppliers that make travelling possible, such as airlines, hotels and transport companies.

We also work with carefully selected suppliers that carry out certain functions on our behalf. For example, companies that help us with IT services, storing and combining data, marketing, market research, processing payments and delivering products and services.

We may need to share personal data to establish, exercise or defend our legal rights; this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk.

When we share personal data with other companies we require them to keep it safe, and they cannot use your personal data for their own marketing purposes.

We only share the minimum personal data to enable our suppliers and partners to provide their services to you and for us.

So that you can travel, it may be mandatory (as required by government authorities at the points of departure or in the destination) to disclose and process your personal data for immigration, border control, security and anti-terrorism purposes, or any other purposes which they require

Some countries will only permit travel if you provide your advance passenger data (for example Caricom API Data and US Secure Flight Data). These requirements may differ depending on your destination and you are advised to check. Even if not mandatory, we may assist where appropriate.

We may share the minimum personal data necessary with authorities if the law says we must, or we are legally allowed to do so.

When you order or buy products or services from us we may share your personal data with credit companies and fraud prevention agencies. That means looking into any records we hold about you and your records with credit agencies or fraud prevention agencies.

We may also do checks to confirm your identity. That is to help protect you from identity theft and other types of fraud, and to prevent and detect crime or money laundering. This information may also be shared with the police if needed.

We may send these agencies details such as your name, address, accounts and bills.

Transferring personal data

We may also transfer or share personal data with a company that we may sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the company receiving your personal data can use your data in the same way as us.

It is important to protect and manage your personal data. We take appropriate security measures to help protect your personal data from accidental loss and from un-authorised access, use, alteration and disclosure.

The security of your data also depends on you. For example, where we have given you or where you have chosen a password for access to our online services, you are responsible for keeping this password safe.

We constantly keep our staff trained on privacy related issues and our personnel have strict guidelines how to process data. Top 10 has assigned one of its employees to act as Data Protection Officer, to be in charge of all Privacy related matters. To contact our Data Protection Offcer, write to registry@travelsales.eu

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by organisations operating outside the EEA who work for us or for one of our suppliers. We put in place appropriate protections to make sure your personal data remains protected and that it is treated in line with this Privacy Notice. These protections include, but are not limited to, appropriate contract clauses, such as standard contract clauses approved by the European Commission , and appropriate security measures.

We will retain your personal data for only as long as it is necessary for the uses set out in this Privacy Notice and/or to meet legal and regulatory requirements. After this period, we will securely erase personal data. If data is needed after this period for analytical, historical or other legitimate business purposes, we will take appropriate measures to anonymise this data.

If you are an existing client or have requested information about our products, prices, or have subscribed to our newsletter, we retain your details for as long as you have an active relationship with us. You may at any time request us to remove your contact details and stop receiving any marketing communication from us by clicking the unsubscribe link in the newsletters or by contacting us and requesting to remove your address from the mailing list.

Cookies are small data files that allow our website to collect and store a range of data on your desktop computer, laptop or mobile device, so that it would be easier and more user friendly to use our service. For example, the content f the shopping basket is stored into a cookie, and without enabling cookies it would not be possible to book a trip. Please see our separate Cookie Notice

Our websites or mobile apps may contain links to websites that are operated by other organisations that have their own privacy notices. Please make sure you read the terms and conditions and privacy notice before providing any personal data on another organisation’s website. Th eresponsibility for using these other sites belongs to them and their users.

You have a right to ask for a copy of the personal data we keep about you, although you should be able to access online the personal data associated with your account or booking. You can write to us asking for a copy of other personal data we have about you.

Where we can provide data access, we will do so free of charge.

We want to make sure that the personal data we hold about you is up to date. If any of the details we hold are incorrect, please let us know.

You can also ask for your personal data to be rectified or erased, to object to the processing of your personal data and, where technically feasible, to ask for personal data you provided to be transmitted to another organisation.

We will update or erase your data, unless we have to keep it for legitimate business or legal purposes.

You can also contact us if you have a complaint about how we collect, store or use your personal data. We aim to resolve all complaints

Please submit your request or complaint in writing to the Data Protection Officer:

Travel Sales Consultancy S.L, Calle Londres 4-4, Benalmadena 29630, Spain

By email: registry@travelsales.eu

We will only collect and use your personal data if at least one of the following conditions applies:

• We have your consent;

Example: Customer account

You give us permission to process your personal data when you register for a customer account.

• It is necessary for a contract with you or to take steps at your request prior to entering into a contract;

Example: To provide the products and services you request

We need to process your personal data so that we can manage your account or booking, provide you with the products and services you want to buy and help you with any orders and refunds you may ask for.

• It is necessary for us to comply with a legal obligation;

Example: Sharing personal data with regulatory authorities

So that you can travel, it may be mandatory (as required by government authorities at the points of departure or  destination) to disclose and process your personal data for immigration, border control, security and anti-terrorism purposes, or any other purposes which they determine appropriate.

• It is necessary to protect your vital interests or those of another individual;

Example: In an emergency

Your insurance company, their agents and medical staff may exchange relevant personal data and special categories of personal data with us in circumstances where we/they need to act on your behalf or in the interest of other customers or in an emergency.

• It is in the public interest or we have official authority; or

Example: Security operations

We may use personal data to respond to and to manage security operations, accidents or other similar incidents, including medical and insurance purposes.

• It is in our or a third party’s legitimate interests and these are not overridden by your interests or rights.

Example: To personalise your experience

We may use your personal data to better understand your interests so that we can try to predict what other products, services and information you might be most interested in. This enables us to tailor our communications to make them more relevant and interesting for you.

Where we need to process special categories of personal data, for example health data for medical reasons, we will only do so if one or more additional conditions apply. For example, we have your explicit consent; it is necessary to protect the vital interests of you or another individual and you are physically or legally incapable of giving consent; it is necessary to establish, exercise or defend legal claims; it is necessary for reasons of substantial public interest.

This Notice replaces all previous versions. We may change the Notice at any time so please check this page regularly for the newest version. If the changes are significant, we will list the changes here below. If we believe it is appropriate, we will notify about the changes via email.

Last update: 24.5.2018 (original version)

Cookies are small data files that allow our website to collect and store a range of data on your desktop computer, laptop or mobile device, so that it would be easier and more user friendly to use our service. For example, the content f the shopping basket is stored into a cookie, and without enabling cookies it would not be possible to book a trip.

Cookies allow us to assess and improve the way our websites and mobile apps work so that we can personalise your experience and allow you to use many of their useful features. For example, cookies help us to keep track of what you are booking as you move through each stage of the booking process; they help us to remember your preferences such as recent searches or shortlisted holidays, and the contents of your online shopping basket.

Cookies can help us to understand how our websites and mobile apps are being used, for example, by telling us if you get an error messages as you browse, to test different designs of our website and mobile app pages. Website analytics, including Google Analytics, provides information about the number of visitors to our website and mobile apps, which parts of our website and mobile apps are most popular and if there are any trends such as one specific page being viewed mostly by people in a particular country. These cookies help us to improve your experience.

 We use cookies to help us deliver online advertising that we believe is most relevant to you on our websites, mobile apps and other organisations’ websites. For example, these cookies help us to suggest flights from your nearest airport, holidays in destinations you have shown interest in or products you might like.

 These cookies may collect data about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket.

 This means that you may see our adverts on our websites, mobile apps and on other organisations’ websites. You may also see adverts for other organisations on our websites and mobile apps.

To help us to deliver online advertising that is relevant to you, we may also combine data we collect through cookies in the browser of your devices with other data that we have collected.

To measure the effectiveness of our marketing communications, including online advertising

 Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert so it does not become too repetitive. We also use cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you.

 You can use your browser settings to accept or reject new cookies and to delete existing cookies. You can also set your browser to notify you each time new cookies are placed on your computer or other device. You can find more detailed information about how you can manage cookies at the All About Cookies  and Your Online Choices websites.

 If you choose to disable some or all cookies, you may not be able to make full use of our websites or mobile apps. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

Where we display personalised adverts on other organisations’ websites, the AdChoices icon will usually be displayed. Clicking on this icon will provide you with specific guidance on how to control your online advertising preferences. More information is available on the YourAdChoices website.

This Notice replaces all previous versions. We may change the Notice at any time so please check it regularly on our website(s) for any updates. If the changes are significant, we will provide a prominent notice on our websites including, if we believe it is appropriate, electronic notification of Cookie Notice changes.

Last update: 24.5.2018