CMT travel agency, d.o.o., Ulica gledališča BTC 8, 1000 Ljubljana, Slovenia, as the manager of personal data of individuals (users or customers), is committed to use and store all personal data of individuals in accordance with the provisions of the respective law in the field of personal data protection (currently applicable Law on Personal Data Protection, Official Gazette of the Republic of Slovenia, No. 94/07, ZVOP-1) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.4.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).
In order to ensure the highest possible standard of protection of passengers’ personal data, CMT has adopted a specific personal data protection policy, which is an integral part of these General Conditions, and further regulates the collection, storage and processing of personal data collected by CMT from passengers, users of the web site www.collegium.si. Data protection is very important, therefore CMT, together with quality content, guarantees also the right of passengers to make their own decisions about the use of their data and is committed to the highest standards of ensuring the protection of individual rights.
CMT primarily processes personal data for the purpose of conclusion or performance of the contract, but also for the purposes of direct marketing purposes and to inform about the offer of CMT or its partners, market research, conducting business analysis, customer segmentation and statistical processing.
- Personal data manager
- Categories of personal data
- Purpose of data processing
- Data retention
- Legal bases
- Data protection
- User rights
- Sub-processors and retention area
- Cookies policy
- Managing cookies on Web browsers
- Legal notice
1. Personal data manager
COLLEGIUM MONDIAL TRAVEL, travel agency, d.o.o., Šmartinska c. 152, Ljubljana, Slovenia.
If you have any questions relating to the protection of personal data on www.collegium.si, the data manager can be reached at [email protected].
2. Categories of personal data
The passenger information obtained by the data manager for the purposes of the performance of the contract and kept by the personal data file manager are:
- e-mail address;
- name and surname, title or sex;
- company name;
- birth data;
- identity document information;
- information about the ordered travel arrangement and any additional ordered services;
- information on the payer of the travel arrangement, if different from the passenger information;
- payment information (type of payment, payment information);
- any passenger notes or special requirements;
- past inquiries, purchases, invoices, support claims.
The data obtained from the users of the web site and kept by the personal data file manager is:
- information about which site the user visited on the portal or how far he / she got in the process of purchasing the arrangement;
- information provided by the user’s browser or mobile device, such as the user’s IP address, location information, device identifier (IMEI number, MAC address), browser information, information about how the passenger came to the website, operating system
- data from cookies and other means of storing data in the user’s terminal equipment;
- time and duration of the visit;
- past requests, purchases, invoices, support claims.
The data obtained from newsletter subscribers, kept by the personal data file manager:
- e-mail address;
- which messages the user has opened and which links in the messages have been clicked;
- the pages visited on the portal;
- past requests, purchases, invoices, support claims;
- IP addresses of the user;
- data from cookies and other means of storing data in the user’s terminal equipment;
The data obtained on telephone calls, e-mails or chat via our website, maintained by the personal data file manager:
- your phone number, e-mail, or nickname and IP address;
- content of your message.
The data obtained on participants of prize competitions and surveys, maintained by the personal data file manager:
- e-mail address or telephone number;
- information necessary to carry out prize competitions or surveys.
3. Purpose of data processing
The data manager will use the data he obtained from passengers and website users for the following purposes:
- for the performance of the contract;
- for communication in the subscriber or. (pre) contractual relationship;
- to conduct prize competitions and surveys;
- for statistical and market analysis; tracking clicks and opening e-mails, and clicking on the website to segment and customize e-mail content;
- for notifying and sending newsletters, articles, event notifications by e-mail;
- for direct marketing and sending offers by SMS / MMS, e-mail and notification messages, conventional mail, via website and mobile applications and making phone calls;
- for segmenting, profiling and automated processing in order to create personalized messages and offers that are more relevant to the user;
- to show personalized ads on advertising platforms (Google and Facebook).
When sending e-mails, the data manager records the opening of received messages by individuals and the clicks on the links in the received messages. He also records views and campaigns on the manager’s website. For better and more targeted bidding and personalization of messages or communication, the recorded data is automatically processed, analysed and evaluated regarding the activity and measuring the interest of users.
4. Data retention
CMT holds the personal data of the passengers for ten (10) years from the conclusion of the travel arrangement, which is a limitation period for claiming compensation from the travel under the second paragraph of Article 352 of the Obligations Code. Deletion is carried out annually on 1.7. for any data that should have been deleted in the previous calendar year.
Personal data in other databases of CMT shall be stored for ten (10) years after their entry, or until the legal basis or legitimate interests for their further retention cease to exist. Deletion is carried out annually on 1.7. for any data that should have been deleted in the previous calendar year.
In case the retention is based on the consent of the individual, CMT shall effectively and permanently delete the personal data after the withdrawal of that consent within 15 days.
5. Legal bases
By signing the contract, the passenger is deemed to consent to the use of his / her personal data provided in the application form in order to fulfil the contractual obligations and rights, as well as to communicate with the passenger regarding the contractual or pre-contractual relationship. In the event that the passenger, as a payer, orders travel also for other passengers, he / she shall be deemed to have obtained the prior consent of other passengers to process their personal data for these purposes.
By signing the contract, the passenger also agrees to the use of the data in the application form for direct marketing purposes (sending information about the offer of the data manager and its business partners), customer segmentation, statistical processing and market research. The consent is valid until the cancellation, which the passenger can give personally to the data manager, by phone, by mail or by e-mail. If the passenger explicitly does not wish to have the data processed for these purposes, he / she may declare this as a note in the travel application form.
Direct marketing of the offers by the data manager via e-mail is also allowed on the basis of Article 72 of the Personal Data Protection Act (ZVOP-1) and Article 158 of the Electronic Communications Act (ZEKom-1). Notifications shall be sent periodically and clearly identified as such. The recipient shall be given a clear and explicit opportunity in each message through appropriate link to refuse further receipt of the messages free of charge and easily.
Direct marketing, segmentation of customers based on their past purchases or demonstrated interest in purchases, and implementation of statistical processing and market surveys are also permitted because they are necessary to achieve the legitimate interests pursued by the data manager. The data manager, like any other company, strives to present better and more targeted offers to its clients and potential clients, thus convincing them to order new or additional services. For this purpose, it also collects information about the use of its website, e-mails or other types of messages. The data manager notes that this practice is also common in other companies in the branch or wider, while not detecting significant restrictions or prohibitions by national supervisory authority in its work so far (at least as it appears from the annual report of the national supervisory authority or of its press releases). At the same time, the data manager points out that individuals have considerable opportunities to properly limit the possibilities of using their information for direct marketing purposes through the appropriate settings in their profiles with advertising agents (Google, Facebook). Consequently, the data manager considers that these activities do not lead to a situation where its legitimate interests offer the best possible service to outweigh the interests or fundamental rights and freedoms of the data subject.
6. Data protection
The data manager will safeguard the information obtained in accordance with the applicable legislation on personal data protection, GDPR and its internal acts. It will provide adequate organizational and technical security.
The data manager will not share or disclose the information obtained to third parties unless it is necessary for the implementation of the travel arrangement itself (e.g. to tourist accommodation providers, as mentioned below in the point on contractual processing), to comply with a court order or a similar request by the competent authorities, or for the enforcement, execution or defence of legal claims of the data manager.
It does not transmit the information to third parties, unless there is a legal basis provided for by law. Personal data may be processed on a statutory basis, on the basis of a contractual relationship, in case of personal data, necessary to fulfil contractual obligations or to exercise the rights arising from the contractual relationship, due to the legitimate interests pursued by the data manager or a third party, if it is necessary for the protection of the vital interests of the data subject or other natural person, and given the express consent of the individual to the processing of personal data, given in accordance with regulations in the field of protection and free movement of personal data. The consent given for processing by the passenger may be modified or withdrawn at any time.
7. User rights
In accordance with the provisions of the EU General Data Protection Regulation (GDPR), the personal data manager, at the request of the individual, must:
- Confirm whether or not data relating to him / her is being processed and enable access to own personal information;
- Provide an opportunity to correct or update personal information;
- Offer the possibility of partial or total erasure of personal information when personal information is no longer needed for the purposes for which they were collected or otherwise processed, and in some other cases, as well as the opportunity to object, when personal information is processed on the basis of legitimate interests of the data manager;
- Allow temporary restriction of the processing of personal information in certain cases;
- Allow partial or total withdrawal of consent to the processing of personal information.
The data manager will respect your request for cancellation and delete your personal information within 15 days at the latest, when no other legal basis for processing exists.
The rights from the list above can be claimed by an individual by writing to the address of CMT d.o.o., Šmartinska c. 152, Ljubljana, Slovenia, or by e-mail at [email protected]. The request must include the identification information, the content of the request, and the justification of the request. Replies will be submitted within one month after receipt of the request. This time limit may be extended for up to two additional months, considering the complexity and number of requests.
Any individual may, in the event that he / she considers that the data manager has in any way violated his / her rights of protection of personal information, at any time submit a written objection to the data manager at CMT d.o.o., Šmartinska c. 152, Ljubljana, Slovenia, or file a complaint with the supervisory authority (Information Commissioner, Dunajska cesta 22, 1000 Ljubljana, Slovenia, [email protected]).
Every consumer has the opportunity to unsubscribe from newsletter with one simple click in the footer of the received e-mail, or send an e-mail expressing wish to unsubscribe to [email protected], or by replying to a specific e-mail received.
8. Sub-processors and retention area
The data manager shall also transmit the collected personal information of the passengers to its contractual processors, who may process the data solely within the scope of the data manager’s instructions and authorizations, and who, by a written agreement concluded with the data manager, are obliged to ensure an adequate level of personal data protection for:
- implementation of individual services from the tourist arrangement;
- Customer Data Management (CRM),
- e-mail marketing system
- marketing automation system.
The provider keeps the databases of personal information in the EU and does not export them to third countries.
The data manager can provide personal information to digital advertising platforms (Google, Facebook, LinkedIn, and the like) and use their cookies, which allow the data manager to create more accurate segments, displaying targeted ads, and remarketing. The user gets more relevant ads on these platforms from the data manager. This may involve the transfer of information to a contracting data manager outside the EU.
9. Cookies policy
As a user of the website, you agree to have cookies uploaded to your computer to ensure function of all features of the website, web analytics and advanced advertising. The following cookies are downloaded:
– Google Analytics cookies for analytical purposes;
– Facebook remarketing and advertising cookies;
– Google Remarketing and Advertising Cookies;
– Cookies of a marketing automation tools to monitor user activity on the website.
Cookies allow certain content or features of an application to adapt to particular visitor, according to his /her choices or preferences, or according to the characteristics of the terminal equipment. Cookies for analytic purposes allow continuous improvement of the site.
10. Managing cookies on Web browsers:
11. Legal notice
All content published on CMT website is the property of the company CMT d.o.o. It may not be copied, reproduced or otherwise distributed in any form, without the permission of CMT. CMT is not responsible for any problems in the functioning of the website. CMT reserves the right of errors and changes to the content posted on the CMT websites.