1. Object

This Policy is established by the company Explorogist SRL, located at Voie du Chêne 4, 4650 HERVE – BELGIUM – EU – company number BE0726.407.462

Explorogist SRL (in the text, “we”, “us” or possibly “ours”) is the owner of this website (www.explorogist.com) to offer customized travel on the Internet to solo travellers. In the course of our activities, we are required to process personal data about our customers, natural persons, or any natural person in contact with us, including the potential customer (hereinafter referred to as “the prospect”).

The purpose of this Policy is to explain how we collect, use, and store your personal data.

By “personal data” we mean all data about you; that is any information that identifies you directly or indirectly as a natural person.

This Policy is part of our desire to act in a transparent manner, in accordance with the law of 8 December 1992 on the protection of privacy with regard to the processing of personal data (hereinafter referred to the “Law on the protection of privacy”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data repealing Directive 95/46 / EC (hereinafter referred to as the “General Data Protection Regulation”).

2. What are the categories of personal data that we process and how do we get them?

  • Personal identification data: When you subscribe to our newsletter 
  • Electronic identification data: Some of this information is collected via the online forms that you find on our website. Others via cookies allowing us to ensure you better user experience.
  • Personal characteristics: When you subscribe to our newsletter
  • Life habits: we want to be able to inform you of the offers which interest you.
  • Lifestyle: we have access when you fill the form to the information relating to the type of trip that you want to organize. Also, depending on your research and requests, we can establish how you intend to travel.

We may collect non-personal data. These data are qualified as non-personal data because they do not identify you directly or indirectly.

These can then be used for any purpose, for example, to improve our website, our products, target our advertising or improve the services offered.

3. For what purposes do we collect your data?

We have determined these purposes and ensure that only the necessary and relevant personal data – while respecting the data minimization principle – are processed.

In general, we base the processing of your personal data on the following legal bases:

  • To comply with our legal obligations;
  • In order to take the prior steps and execute the contract that binds us when you confirm a trip;
  • In order to realize our legitimate interest (in this case we always pay attention to respect a balance between our interest and your rights and freedoms).

If we are required to perform treatments that are not yet covered by this Policy, we will contact you before using your personal data. 

A. Compliance with our legal obligations

In some cases, we are obliged to process your personal data in the context of legal obligations or when we collaborate with the competent authorities. In these cases, we transmit your personal data to fulfill our commitments.

B. As part of our contractual relationship

When you confirm a trip through our site, a contract exists between you and us. In this context, we are required to process personal data to meet our contractual obligations and to fulfill the mission you have set for us.

In order to fulfill our contract, we process your personal data for the following purposes:

  • Ensure an answer to your requests;
  • Ensure the smooth running of the trip;
  • Ensure communication and marketing actions;
  • Contacting you to evaluate our services;
  • Keep you informed about news and information from the tourism sector via our newsletter.

C. As part of our legitimate interests

In some cases, it is in our legitimate interest to process your personal data.

To this end, we always strive to maintain the right balance between the need to process your personal data and respect for your rights and freedoms, including the protection of your privacy.

Your personal data are thus processed for:

  • Identification on the website;
  • The personalization of our services;
  • Management of people registered on the site;
  • Business prospecting and prospect management;
  • The preparation of studies, models (of risk, marketing, and others) and statistics, using techniques of anonymization and/or pseudonymization whenever possible;
  • Preservation of the security of property and persons, the fight against fraud or attempted intrusion, abuse or other offenses;
  • The analysis of your previous research in order to better customize our service offerings so that they correspond to you;
  • Improving the quality of service for non-contracted website registrants;
  • Retention of a list of customers no longer wishing to be contacted;
  • Improvement of existing services and user experience (registered or not) of the site;
  • Organization of games, competitions;
  • The management of your requests related to the application of your rights;
  • The recognition, exercise, defense, and preservation of our rights.

D. Consent

When you register on our website following forms or a newsletter or when you ask us to contact you, we ask you to acknowledge and accept that we process your personal data in accordance with this Policy.

We will, therefore, process your personal data based on your consent for:

  • Send you a specialized editorial newsletter;
  • Send you messages containing personalized ads based on your preferences;
  • To inform you about new trips corresponding to your needs that are available on the site;
  • To contact you to inform you about the news of the trip;
  • Transmit your contact data to our third party partners so that they contact you to offer you commercial offers;
  • Contact you to let you know about our new services.

Once you have given us your agreement to send a newsletter via our site, we consider that you continue to accept that we contact you for this purpose. Please note that you have the right to withdraw your consent to the processing of personal data at any time.

E. Profiling and automated processing

To ensure better user experience, we use the profiling technique to associate you with your different preferences.

As soon as possible, we will only use anonymized or pseudonymized data.

In cases where we use your personal data to conduct profiling, we make sure that no decision having legal effects or significantly affecting you in a similar way is taken.

4. How long do we keep your personal data?

In general, we take care not to keep your personal data beyond the time necessary for the purposes for which they were collected.

More specifically, it is necessary to distinguish several situations to determine the retention period of your personal data. 

For instance: 

  • You are registered on the website: We keep your personal data for the duration of your registration in order to offer you the best possible service.
  • You are registered on the website and our newsletters: We keep your personal data for the duration of your registration in order to offer you the best possible service and to inform you about the latest developments in travel.
  • You have unsubscribed from the website, our newsletters: In this case, we will keep your data for one year from your unsubscription. Then, these will be destroyed.
  • We have a contract following your confirmation of the trip via the website: Following the end of our contract, we archive your contract and your personal data for a period of ten years.
  • You are applying to subscribe to our newsletters: We keep your personal data for the duration of your registration in order to offer you the best possible service and to inform you about the journeys corresponding to your criteria.

At the end of the retention period, we make every effort to ensure that the personal data has been made unavailable and inaccessible.

5. Access, withdrawal, rectification, deletion, portability, limitation and opposition

Your rights under the regulations allow you to maintain control over what we do with your personal data.

A. Right of access and copy

This right of access to the data that we have about you applies for all the purposes we have listed above.

This right enables you, among other things, to ask us if we process your personal data, for which purposes, the categories of data concerned, as well as the recipients of your data.

You can also ask us for a copy of all the personal data that we process, and that concerns you.

B. Right to withdraw your consent

As long as we process your personal data on the legal basis of consent, you can always withdraw your consent.

C. Right of rectification

You also have a right of rectification, allowing you to request, at any time, to modify the information that is inaccurate, incomplete, or obsolete.

D. Right to be forgotten

You may obtain the deletion of your personal data when one of the following reasons applies:

  • The data are no longer necessary for the purposes of the treatment;
  • You withdraw your consent to the processing of your data, and we base this treatment only on the legal basis of your consent;
  • You oppose the treatment;
  • We have treated your personal data unlawfully;
  • If the data we possess is incomplete, inaccurate or obsolete;
  • We must erase your personal data in order to comply with a legal obligation (of EU law or the law of the Member State) to which we are subject.

E. The right to portability

If we process your personal data on the basis of a contract or your consent, you may ask us to transfer all of your personal data to you or to transfer it to another controller.

F. Right to limitation of treatment

In some cases, you may also ask us to limit the processing of your personal data.

The situations in which you can ask us to limit the processing of your personal data are as follows:

  • If you dispute the accuracy of a personal data the time we can verify the accuracy of this data;
  • If we treat your personal data unlawfully and you prefer that we limit this treatment rather than the erasure of your personal data.

Of course, if the limitation of treatment is no longer applicable, we will inform you.

G. Right of opposition

As we have explained, we ask for your agreement to send you commercial information, advertising, or personalized proposals (through direct marketing actions or electronic newsletters).

You have the right if you do not wish or more than we send you such communications, to oppose the processing of your personal data for these purposes.

6. How to exerce your rights

A. Identification

In order to help you to enforce your rights, we must verify that your request relates to your personal data.

With this in mind, we will conduct a verification of your identity by sending a unique link by email, allowing us to ensure your identity.

B. How soon do we respond to you?

We promise to return to you as soon as possible and, at the latest, in the month of your request.

We may have to extend this period to two months if your request is complex, and we are faced with an excess of demands. Should such a situation occur, we will inform you of the reasons for the delay

7. Transfer to third parties

Depending on your choices and the necessities of fulfilling our contract, we may transfer your personal data to our subcontractors.

A. Our subcontractors

One of our goals is to offer trips around the world. In this context, we work with professionals.

This transfer to these third parties, mainly hoteliers, local correspondents, will be done either in the context of our contractual relationship or when you decide to transmit your personal data via our website.

We also work with IT service providers who help us set up our website and, more generally, our services.

Like us, we ask them to ensure compliance with the legal and regulatory provisions in force. We also ensure that they comply with this Policy.

B. To our business partners, third parties

We do not transmit your data to business partners or third parties. We do only transmit your data to our subcontractors so that they can carry out their mission.

C. Transmission for a legal obligation or by order of a competent authority

As already explained, in some cases, we will have to transmit your personal data to comply with a legal obligation, a judicial decision, or a request from any competent authority.

8. Data security

We implement appropriate technical and organizational measures to ensure an adequate level of security in the processing of your personal data. This level of security is established based on the risks presented by the processing and the nature of the data to be protected.

We have implemented appropriate security measures to protect your personal data, including against loss, theft, misuse, or alteration of information received, disclosure, or unauthorized use of your data. 

In the unlikely and unfortunate event that your personal data that we control were to be compromised due to a breach of information security, we commit ourselves to act promptly to identify the cause of the breach and to take appropriate action. 

If necessary, in accordance with the law in force, we will inform you of this incident.

9. Complaint and complaint

If you wish to respond to any of the practices described in this Policy, we advise you to contact us directly to see how we can help you.

You can also lodge a complaint with the Data Protection Authority at the following address:

Data Protection Authority
Rue de la Presse, 35
1000 Brussels

Phone: + 32 2 274 48 00
commission@privacycommission.be

In addition, you always have the possibility to file a complaint before the Brussels Court of First Instance.

For further information on possible complaints and remedies, we invite you to consult the information available on the website of the Data Protection Authority: https://www.privacycommission.be/

10. How to contact us?

Please, send us an email to hello@explorogist.com

11. Change in this Policy

We reserve the right to change the terms of this Policy at any time. We will post the changes directly on our website.

12. Applicable law and competent jurisdiction

This Policy is governed by Belgian law.

Any dispute relating to the interpretation or execution of this Policy will be subject to Belgian law and will fall under the exclusive jurisdiction of the French-speaking courts of the judicial district of Brussels.

This version of the Policy is effective and has been updated as of November 21, 2019.