Version: 2.0., Effective date: Jan. 21, 2021
- Data Collection
SOMABAY HOLIDAYS as data processor
SOMABAY HOLIDAYS as data controller
When using SOMABAY HOLIDAYS Services or contacting SOMABAY HOLIDAYS whether it is:
- using SOMABAY HOLIDAYS platforms and applications such as SOMABAY HOLIDAYS
- signing up for events/webinars organized by SOMABAY HOLIDAYS
- signing up for a newsletter
- booking a demo with SOMABAY HOLIDAYS
- signing up for a research paper
- applying for a job position or contacting SOMABAY HOLIDAYS
- contacting SOMABAY HOLIDAYS via forms on our websites or via any other contact center
- Data Processing
SOMABAY HOLIDAYS Services
For the provision of SOMABAY HOLIDAYS Services, SOMABAY HOLIDAYS may process the following data categories:
- Identification details (name, surname)
- Contact details, such as address, phone number, e-mail address
- Booking and accommodation details
- Credit/debit card information
- Payment information
- Information about the company you work for and your work position
- Information about any additional services you order through SOMABAY HOLIDAYS Services
- Information about your subscriptions to marketing communication
- Any other information you decide to share with SOMABAY HOLIDAYS through SOMABAY HOLIDAYS Services
By accessing and using SOMABAY HOLIDAYS Services, you enter into an agreement for provision of such services with SOMABAY HOLIDAYS. The legal ground for processing of your personal data is performance of contract or pre-contractual relations. The purpose of processing your personal data is provision of relevant SOMABAY HOLIDAYS Services to you.
SOMABAY HOLIDAYS Services and website personalization
We can process data for the purpose of evaluation and analyzing of the market, monitoring, evaluation, improving and personalization of SOMABAY HOLIDAYS Services, customizing the content of websites according to your preferences, and as well for protection of our legal rights. The legal ground for processing this data is legitimate interests of SOMABAY HOLIDAYS. When data is processed based on the legitimate interest, we always evaluate whether such processing does not constitute an inadequate interference to your rights.
SOMABAY HOLIDAYS processing of job applications
If you apply for any of our job positions at SOMABAY HOLIDAYS through SOMABAY HOLIDAYS website or other means, we will process the personal data you provide us with for the purposes of evaluating your application and information contained therein to assess whether you are a suitable candidate for any of our positions. We may as well conduct pre-employment screening of job applicants to verify inter alia the truthfulness of the information contained in your CV and other documents you provide us with. For particular positions, you may be asked to provide us with your criminal record as well. The pre-employment screening is always done in such a way that its proportionality, adequacy, and compliance with applicable law is assured. The legal ground for processing this data is performance of contract or pre-contractual relations or your consent (where applicable). Respective SOMABAY HOLIDAYS affiliate to which you applied for a job position shall be considered as data controller.
We may keep your CV in our internal database in order to consider you for future positions at SOMABAY HOLIDAYS subject to your consent. You can withdraw your consent at any time in your User account or by sending a message to email@example.com
SOMABAY HOLIDAYS records calls with its clients and processes associated personal data based on SOMABAY HOLIDAYS legitimate interest for the purposes of evidence of proper provision of services and defense against any client claims.
We notify our clients about the recording at the beginning of every call. By continuing the phone call you agree with the recording taking place and capturing expressions of personal nature. If you wish to get in touch with us in a different way, please contact us at firstname.lastname@example.org
In some instances, legal regulations impose obligations on us under which we are obliged to process personal data, such cases are for instance tax and accounting laws and provision of some data to public authorities based on law. Thus, we can process your data for the purpose of fulfilling our legal obligations and archiving our internal records. Legal ground for processing of such data is compliance with legal obligations.
III. Cookies on our website
Additionally, cookies help us deliver online advertising that we believe is most relevant to you. Cookies are also used for profiling. Cookies can help us to understand how our website is being used, for example, by telling us if you get an error message as you browse. For more information about cookies please visit http://www.allaboutcookies.org.
We use the following types of cookies: (i) essential cookies, which are essential for the provision of access to our websites and for the provision of services explicitly requested by you; (if these cookies are disabled, our website may not work properly); (ii) analytical cookies, which do not identify you individually (until you enter your identification details in any of our forms) but help us to personalize your content in accordance with your actions on our websites and analyses how you navigate our websites and what content is relevant to our users; (iii) functional cookies that enable the website to provide enhanced functionalities and personalization; and (iv) advertising cookies, which help make advertisements more relevant to visitors of our website.
When you visit our websites, you shall be informed through a cookie banner placed at the bottom of the website that we collect cookies. The banner allows you to manage what kind of cookies can be collected by Somabay Holidays. You can change the settings and withdraw your consent at any time through Cookie management provided on the bottom of our websites.
When we collect essential cookies the legal ground for processing of this data is legitimate interest. It is not possible to disable these cookies through the Cookie management as our websites might not function properly when you disable this type of cookies however if you still wish to do so you may follow the instructions below in the section Disabling cookies.
When we store data or gain access to data already stored in your terminal equipment such as your PC or mobile device for analytical, functional or advertising purposes we only do so once you have given us your consent.
Apart from cookies we also use other technologies that allow us to analyze your behavior on our websites and alert us if any feature of the website does not operate properly. The current tools we use are Sentry (error monitoring system) and Hotjar (analytical tool).
If you wish cookies not to be collected, you may restrict, block or delete the cookies at any time by modifying your browser configuration. Although each browser is parameterized differently, cookie configuration is normally located on the “Preferences” or “Tools” menu. If you turn off cookies, the functionality of our website may be limited (in the case of essential cookies you may not be able to access our website).
If you wish to prevent new cookies from being installed or if you wish to delete existing cookies you can find the instructions on the links below. The exact procedure depends on which browser you are using:
- Internet Explorer
- Google chrome
For mobile devices you can limit tracking via the privacy setting on your device (disabling the advertising identifier), for instructions please see https://www.networkadvertising.org/mobile-choice/
Furthermore you can use a third party tool to opt out from targeted advertising, available third-party opt-out tools include the Digital Advertising Alliance, the Network Advertising Initiative, and the European Interactive Digital Advertising Alliance (Europe only).
To opt out from receiving cross-device site advertising (i.e. tracking a user across devices) you can access your device settings or visit and employ the controls described on the NAI’s Mobile Choices page.
- Direct Marketing
SOMABAY HOLIDAYS may use your data for marketing purposes, i.e. in order to inform you of its services which may, according to your past preferences, be of interest to you. These communications shall strictly adhere to applicable legal regulations.
Advertising and marketing materials of other parties shall be sent to you only if you opted in for these communications during the registration process, via e-mail or otherwise.
Your decision about direct marketing may be withheld in accordance with the opt-out rules described in each marketing-mail or other form of communication via the unsubscribe option in the footer of every email. Opting out can be done as well via changing the settings of your User account or by directly contacting SOMABAY HOLIDAYS. If you opt out, SOMABAY HOLIDAYS shall retain only such data necessary that is necessary for provision of services to you in accordance with the rules set out in this policy.
- Data Retention
SOMABAY HOLIDAYS Services
SOMABAY HOLIDAYS shall not store your personal data for a longer period than what is necessary, given the purposes for which they were provided or collected. If you create a User account, we will process your data for the period of your registration with SOMABAY HOLIDAYS. Subject to situations set out below, your personal data will be deleted once you inform SOMABAY HOLIDAYS that you do not wish to use SOMABAY HOLIDAYS’ Services anymore. SOMABAY HOLIDAYS shall retain only that of your data serving legitimate purposes (e.g., some data is required to be retained by legal regulations, some data is necessary to maintain the mutual relationship with you – for instance billing purposes, etc.) SOMABAY HOLIDAYS shall neither collect an excessive amount of personal data nor other information which is not relevant for the purposes for which the personal data is collected.
SOMABAY HOLIDAYS processing of job applications
SOMABAY HOLIDAYS shall not store data provided by you or collected automatically during the phone calls for a longer period than what is necessary, given the purposes for which they were provided or collected. Moreover, you can withdraw your consent to process your data at any time by sending the message to email@example.com, in which case we will remove your data from our system.
- Data Sharing and transfer to third countries
SOMABAY HOLIDAYS Services
Your personal data shall not be shared with any third party except for the following situations: (a) data is necessary for provision of SOMABAY HOLIDAYS services, (b) based on your consent, (c) entrusting of personal data to processors who process personal data on behalf of SOMABAY HOLIDAYS (d) SOMABAY HOLIDAYS is obliged to provide the personal data on the basis of law or upon order by a public authority, or (e) it is specifically allowed by applicable legal regulations. Should the applicable legal regulations prohibit that, your personal data shall never be shared with any third party.
In order to allow you to manage various reservations made with hotels, SOMABAY HOLIDAYS may share your personal data with hotels for the sole purpose of making and managing your reservation as well as other services of the hotels available to you through Somabay Holidays Services. Sharing of any other personal data or information may be shared with hotels based on your consent only.
SOMABAY HOLIDAYS processing of job applications
Your personal data shall not be shared or provided to any third party except for when (a) we use services and applications of third parties to manage HR processes, whereas these third parties are processors of your personal data and act upon instructions of SOMABAY HOLIDAYS as the data controller (b)we obtain your consent for sharing of your personal data b) SOMABAY HOLIDAYS is obliged to provide the personal data on the basis of law or upon order by a public authority, or (c) it is specifically allowed by applicable legal regulations. Should the applicable legal regulations prohibit that, your personal data shall never be shared with any third party.
Categories of Processors
SOMABAY HOLIDAYS uses trusted third parties that in some instances process personal data on behalf of SOMABAY HOLIDAYS and based on instructions provided by SOMABAY HOLIDAYS. SOMABAY HOLIDAYS uses the following categories of Processors:
- data center, hosting
- marketing tools
- tools for analytics and recording
- tools for running polls or surveys
- business management tools
- task management and communication tools
- information security tools
- Data Security
SOMABAY HOLIDAYS shall ensure that your personal data is stored securely. Therefore, SOMABAY HOLIDAYS has introduced adequate physical, technical, and organizational measures and plans to protect and secure all information collected via SOMABAY HOLIDAYS Services.
The aim is to eliminate unauthorized or unlawful processing of your personal data, or accidental, unauthorized, or unlawful access, use, transferring, processing, copying, transmitting, alteration, loss or damage of your personal data. Despite all efforts and meeting all rules set out by applicable legal regulations, it is not possible to guarantee the security of your data if it is transferred or transmitted in an unsecured way.
SOMABAY HOLIDAYS protects your data in particular in the following ways:
- Using cryptography, where necessary
- Using password protection, where necessary
- Restricting access to your personal data (i.e. access to your personal data is granted only to those employees or personnel of SOMABAY HOLIDAYS for whom the access is indispensable for the purposes described herein).
These measures do not deprive you from your duties to undertake proper steps in order to secure your own personal data. You should, inter alia, regularly change your passwords. On the other hand, you should not, inter alia, use predictable usernames and/or passwords, share your password with other persons, or grant access to your user account and/or disclose your personal data to other persons. SOMABAY HOLIDAYS will never ask you for your password in any unsolicited communication. Please notify our data protection officer immediately of any unauthorized use of your account credentials or any other suspected breach of security.
- Your rights
Where EU General Data Protection Regulation 2016/679 (“GDPR”) applies to the processing of your personal data you are entitled under the GDPR to the following rights:
Right of access
You are entitled to be informed inter alia about what personal data SOMABAY HOLIDAYS processes about you, for what purposes, who are the recipients of your personal data.
Right to rectification
You have a right for any of your incomplete, inaccurate, or out-of-date personal data to be rectified.
Right to erasure (‘right to be forgotten’)
You are entitled to erasure of certain personal data that we have collected and processed about you. Please be aware that SOMABAY HOLIDAYS might be allowed or even obliged to keep some of the personal data despite your deletion request.
Right to restriction of processing
In given cases such as when we process inaccurate personal data about you, or you deem the processing as no longer necessary you may ask for a restriction of the processing.
Right to data portability
You have a right to receive personal data you provide us with in a structured, commonly used, and machine-readable format and have it transmitted to another controller where technically feasible.
Right to object
You are entitled to object, on grounds relating to your particular situation, at any time to processing of personal data that concerns you and is carried out in public interest or for the purposes of legitimate interests pursued by SOMABAY HOLIDAYS, including profiling.
The exercise of your rights may be limited shall SOMABAY HOLIDAYS be obliged to keep any of your personal data for the purpose of compliance with legal obligations, for the establishment, exercise or defense of legal claims or any other compelling reasons as provided by the relevant data protection law.
Right to not be subject to automated decision making
Should you wish to exercise any of your rights you may contact us at firstname.lastname@example.org
Right to file a complaint
If you wish to file a complaint in regard to processing of your personal data by SOMABAY HOLIDAYS you may contact our DPO at email@example.com who will undertake to resolve the issue. You also have a right to lodge a complaint with our supervisory authority seated in Netherlands Autoriteit Persoonsgegevens (https://autoriteitpersoonsgegevens.nl/nl), or with the supervisory authority of the particular affiliate (for contact details please see: https://edpb.europa.eu/about-edpb/board/members_en).
- California Consumer Privacy Act of 2018 (“CCPA”) Notice
Consumers residing in California have some additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”). If you are a California resident, this section applies to you and supplements the above policy.
Your Californian Consumer Rights
Where the California Consumer Privacy Act of 2018 Assembly Bill No. 375 (“CCPA”) applies to the processing of your data you are entitled to the following rights:
Right to notice
Right of access
You are entitled to be informed about what personal data SOMABAY HOLIDAYS processes about you, for what purposes and who are the recipients of your personal data.
Right to request deletion
You are entitled to the erasure of certain personal data that we have collected and processed about you. Please be aware that SOMABAY HOLIDAYS might be allowed or even obliged to keep some of the personal data despite your deletion request.
Right to receive equal services
You have a right to not be discriminated against even if you exercise any of your CCPA rights.
XIII. Contact Details
Please help SOMABAY HOLIDAYS ensure that your data is up to date. If you believe that some of the data processed by SOMABAY HOLIDAYS is incorrect, please contact SOMABAY HOLIDAYS at firstname.lastname@example.org