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Privacy Policy

Privacy Policy

Last Updated: March 2022

  1. 1.
    General 1.1 This website is operated by DIGILYO TRAVEL LTD (“LYOTRAVEL”). We recognize the importance of your privacy and are committed to protecting your personal data. This privacy notice (hereinafter - “Notice”) explains how LYOTRAVEL collects and uses information when you provide us with your personal data on our website: www.lyotravel.com. 1.2 LYOTRAVEL processes your personal data under this Notice and in accordance with applicable legislation, including the European Union General Data Protection Regulation (2016/679) and the applicable national data protection laws of the jurisdiction in which we provide services to you, our user, as applicable towards the personal data controller stated in Section 2 of this Notice.
  2. 2.
    Personal Data Controller 2.1 For the purposes of personal data processing provided in Section 5 of this Notice, the controller of your personal data is: DIGILYO TRAVEL LTD (LYOTRAVEL) Address: Room 1104, Crawford House, 70 Queen's Road Central, HONG KONG E-mail: [email protected]
  3. 3.
    Data Protection Officer 3.1 You shall have the right to communicate with LYOTRAVEL’s data protection officer in order to obtain information on the processing of your personal data. LYOTRAVEL’s data protection officer’s contact references are: E-mail: [email protected]
  4. 4.
    Categories and Sources Of Personal Data Processed By LYOTRAVEL 4.1 Personal data is information that can be used to directly or indirectly uniquely identify, contact, or locate you as a private individual (“Personal Data”). The source of the collected Personal Data depends on how you interact with us. 4.2 Communications data. LYOTRAVEL processes the following Personal Data for the purpose of communicating with you via e-mail or otherwise: name, surname, e-mail address or social media profile, phone number. 4.3 Authentication data. LYOTRAVEL processes the following Personal Data for the purpose of verifying your identity when you try to access or purchase the services we provide: name, surname, billing information, billing address, digital wallet address, residence address, IP address. 4.4 Registration data. LYOTRAVEL processes the following information in order to retain you as a registered user of our website and platform if such a registration request is made by you: name, surname, email, billing information, billing address, digital wallet address, residence address, username, log in location. 4.5. Marketing data. LYOTRAVEL shall from time to time process the following data for advertising services on the website and bookings that may be applicable based on your location and preferences when using our services and website: log in location, email address, cookies, IP address. 4.6. Cookies. Cookies are small pieces of text sent as files to your computer or mobile device when you visit most websites. Cookies may be delivered by us (first party cookies) or delivered by a third-party partner or supplier (third-party cookies). Cookies are either session cookies or persistent cookies. Session cookies enable sites to recognize and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognize you as an existing user and these cookies are stored on your system or device until they expire, although you can delete them before the expiration date.
  5. 5.
    Legal Basis and Purposes For Processing Personal Data 5.1. LYOTRAVEL’s legal basis to process your Personal Data is LYOTRAVEL’s legitimate interest, fulfilment of a legal obligation, and your consent. 5.2. We may process your Personal Data for other purposes, provided that LYOTRAVEL discloses the purposes and use to you at the relevant time, and that you either consent to the proposed use of the Personal Data, other legal grounds exist for the new processing purposes, or the new purpose is compatible with the original purpose brought out above.
  6. 6.
    Personal Data Retention Period 6.1 Your Personal Data shall be stored insofar as reasonably necessary to attain the purposes stated in Section 4 and 5 of this Notice, or if a legal obligation stipulates that we do so. If legal enactments do not provide a retention period for relevant categories of Personal data, then the retention period of such data shall be 1 year as of the collection of relevant Personal data. 6.2 After the retention period mentioned in Section 6.1 of this Privacy Notice, we may retain your Personal Data for a longer period if it is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes and enforce the contract between you and LYOTRAVEL or we may anonymize your Personal Data and retain this anonymized information indefinitely.
  7. 7.
    Rights as a Data Subject 7.1 We have a legal obligation to ensure that your Personal Data is kept accurate and up to date. We kindly ask you to assist us to comply with this obligation by ensuring that you inform us of any changes that must be made to any of your Personal Data that we are processing. This is applicable to registered users of LYOTRAVEL. 7.2 You may, at any time, exercise the following rights with respect to our processing of your Personal Data by contacting us via contact information referred to in this Notice: 7.2.1 Right to access: you have the right to request access to any data that can be considered your Personal Data. This includes the right to be informed on whether we process your Personal Data, what Personal Data categories are being processed by us, and the purpose of our data processing; 7.2.2 Right to rectification: you have the right to request that we correct any of your Personal Data if it is inaccurate or incomplete; 7.2.3 Right to object: you are entitled to object to certain processing of the Personal Data, including for example, making automated decisions based on your Personal Data or when we otherwise base the processing of your Personal Data on our legitimate interest; 7.2.4 Right to restrict Personal Data processing: you have the right to request that we restrict the processing of your Personal Data if you wish to: (i) object the lawfulness of the processing; (ii) fix unlawful processing of the Personal Data; (iii) receive or avoid deletion of the Personal Data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of LYOTRAVEL’s legitimate interest in the specific processing activity; 7.2.5 Right to erasure: you may also request your Personal Data to be erased if the Personal Data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the Personal Data has to be erased to enable us to comply with a legal requirement; 7.2.6 Right to data portability: if your Personal Data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that Personal Data in a structured, commonly used and machine-readable format. Moreover, you may request that the Personal Data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible; 7.2.7 Right to withdraw your consent: in cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time; 7.3 Please note that you will need to provide sufficient information for us to handle your request regarding your rights brought out in Section 7.2 of the Notice. Prior to answering your request, we may ask you to provide additional information for the purposes of identifying you and evaluating your request.
  8. 8.
    Sharing Your Personal Data and Data Transfers 8.1 LYOTRAVEL discloses your Personal Data to third parties only in accordance with the Notice and to persons authorized to process Personal Data, who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality. In specific cases, LYOTRAVEL may share your Personal Data with a third party if you have given consent to such disclosure. 8.2 Only if necessary for fulfilling its statutory or contractual obligations, LYOTRAVEL may disclose your Personal Data to the following recipients (including data processors) in its data processing activities (as necessary): 8.2.1 Law enforcement and data protection authorities, only if LYOTRAVEL has the duty to disclose or share this data in order to comply with any legal obligation (for example, if required to do so under applicable law, by a court order or for the purposes of preventing criminal activities); 8.2.2 Operational and professional service providers (legal advisors, accounting etc. bound to confidentiality); 8.2.3 Information technology service providers with the aim of providing IT solutions for operating the website; 8.2.4. Marketing and advertising agencies for analysis and selection of preferences so we can better advertise our services and products, promotional offers to you, if such consent is given by you. 8.3 In some cases, we may transfer your Personal Data outside the jurisdiction of our registered office or your residence for purposes of providing the Personal Data to service providers that you have entered into agreements with through our website and services or to services providers that facilitate our services.
  9. 9.
    Amendments to This Notice 9.1 This Notice may be amended or modified from time to time to reflect changes in the way we process Personal Data and, in such case, the most recent version of the Notice will appear on this page. Please check back periodically, and especially before you provide any new personally identifiable information. How to contact us If you have any general questions about the website or the information we collect about you and how we use it, you can contact us at [email protected]