Introduction
This Privacy Policy outlines G2 Travel Ltd (“we“, “our” or “the Company“) practices with respect to information collected from users who access our website (the “Site“) or communicate with us in any other way (collectively: “Users“).
We encourage Users to carefully read the Privacy Policy and use it to make informed decisions. In this Privacy Policy you can read about:

What information we collect
We collect two types of data and information from Users who access our Site.
The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your access to the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. browser type, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. clicks, actions, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information includes:

• Contact information: The Site may provide you with the option to fill in contact information. If you choose to contact us through our Site or by any other means, you will be asked to provide us with your name, email address and phone number.
• Device Information: We may also collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

If we associate Non-personal Information with Personal Information, we will treat such information as Personal Information.

How the information is used and with whom we share the information
We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.
We may use the information for the following:

• Communicating with you – If you have contacted us, for any reason, we will use your information in order to further communicate with you.
• Conducting statistical and analytical purposes, intended to improve the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors. In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes:

• Providing you with our Service, including providing a personalized display of our Site;
• Storing and processing such information on our behalf;
• Performing research, technical diagnostics or analytics;

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

In any case we will conclude that disclosure of Personal Information is necessary, we will only disclose that portion of the Personal Information that is required in order to satisfy the basis for disclosure. We will share the Personal Information under appropriate safeguards.

User rights
You may request to:

a. Receive confirmation as to whether personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
b. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
c. Request rectification of your personal information that is in our control.
d. Request erasure of your personal information.
e. Object to the processing of personal information by us.
f. Request to restrict processing of your personal information by us.
g. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us at web.support@g2-travel.com

How long we retain the information

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is col-lected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, un-used information at the earliest reasonable time. Under applicable regulations, we will keep records con-taining client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies
When you use our site, we may store cookies on your computer (as well as other tracking technologies like web beacons, pixels etc.) in order to facilitate and customize your use of our Site. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your web browser permits) that can later be retrieved to identify you to us. Our cookies may store information regarding your registration to our newsletter of demo services. You are always free to decline our cookies if your browser permits, but such disabling may cause some of the features of our Site to not operate properly and your online experience may be limited. Please see our Cookie Policy for more information.
We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.
This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

Transfer of data outside the EEA
Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

How we safeguard your information
We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Corporate transaction
We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors
The Site is intended to the use of individuals over the age of 18. In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If have any reason to believe that a child under 18 has shared any information with us, please contact us at web.support@g2-travel.com

Updates or amendments to this Privacy Policy
We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the “Last modified” section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at web.support@g2-travel.com or write to:
Global Compass RO Srl
City Offices (2nd Floor)
2 Oltenitei Road
Sector 4
Bucharest 041312
Romania

As part of your interaction with the G2 Travel group, we may be required to process certain aspects of information that can lead to an identified individual (“Personal Data“).
We are committed to ensure that our Personal Data privacy and security practices are in strict compliance with the provisions of applicable data protection and privacy legislation, including without limitation, the GDPR. As part of our commitment to the rights of individuals whose Personal Data we process, we provide below the relevant information on the purpose, the legal basis and the duration for which we process your Personal Data, who we share it with, as well as on the rights you are entitled to and how you can exercise those rights.
Nothing in this Privacy Notice will serve as an obligation to enter into a binding agreement between the parties.

What Personal Data do we process?

In order to determine the nature of the contractual engagement between G2 and you (if any), and in order to ensure the performance of any agreement with you, we may be obliged to process the following types of data (the information below is meant to provide you with general examples of the types of information. Not all types of Personal Data may be required. Also, additional types may be collected, if the need arises):

– Identification data (name, surname, photograph, series and number of identity documents, civil status certificate, driving license);
– Contact details (phone number, e-mail address, home, residence);
– Financial data (bank account information);
– Data about your education and previous employment history;
– Information collected as part of reviewing possible future engagements (copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process, such as past employment records, job titles, training records, professional certifications).

How do we collect your Personal Data?

Prior to entering into an engagement – we collect Personal Data through the application and review process, either directly from suppliers or sometimes from a background check provider. We may also collect additional information from third parties including former employers, credit reference agencies or other background check agencies or publicly available resources (such as social networks).
During an ongoing engagement – we will collect Personal Data in the course of the performance of your obligations throughout the period of the engagement.

Why do we process your Personal Data?

We must process your Personal Data in order to comply with our contractual obligations when we enter into an engagement with you. We may also have a legal obligation to process such data to comply with various regulations, such as payment of taxes and compliance with anti-money laundering and bribery regulations.
Additionally, processing is necessary for conducting negotiations relating to any future engagement between the parties. Processing may also be necessary for our or your legitimate interests.
We may also process Personal Data when it is needed in the public interest or in protection of our rights, such as dealing with legal disputes, including incidents which occur during the provision of your services.

How long do we retain your Personal Data?

In general, your Personal Data is processed for the duration necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example, if you are engaged as a supplier to provide a certain service, we may retain your data for the duration of your service agreement and store it for an additional period, in accordance with our general retention policy. Additional periods may be necessary to enable us to protect the rights conferred to us by the law for the period fiscal statute of limitation. However, we do not undertake to keep these data for the entire period mentioned above and we may delete or anonymise your Personal Data earlier if we do not have a legal
obligation to keep them.

To whom do we disclose your Personal Data?

We do not sell, transfer, disclose or allow access to your Personal Data to third parties not related to its activity.
Where required by law, necessary to administer the contractual relationship with you or where we have another legitimate interest in doing so, we may have to share your Personal Data with third parties, including third-party service providers and other entities in the Company group.
We require third parties to respect the security of your Personal Data and to treat it in accordance with the law. We may transfer your Personal Data outside the EU. If we do, you can expect a similar degree of protection in respect of your Personal Data.
In order to achieve the goals described above, we may disclose your Personal Data to our suppliers of products and services, namely:
– providers of services and products involved in managing the contractual relationship between you and us – such as legal, tax or financial advisors, payment service providers, banks, suppliers of telecommunication services, travel agencies etc.
– IT service providers assisting us or other entities in our group for the operation maintenance of our systems and equipment;
We may also provide your contact details to any contractual partner to enable them to contact you in connection with the performance of the contract concluded by them with us.
In all the cases described above, the disclosure of your Personal Data is limited to the Personal Data strictly necessary for the achievement of each purpose and is performed on the basis of a contract with the recipients of the data whereby they commit themselves to use the data solely for the purpose for which they were entrusted, to observe the obligation of confidentiality and to ensure the security of data, as well as to comply with all the provisions of the legislation in force regarding the protection of personal data.

Transferring Personal Data outside the EU

In cases where the entities in the group or the contractual partners to whom we disclose your Personal Data in the situations described above are located outside the European Economic Area, the disclosure shall be done only when the European Commission has confirmed an adequate level of protection for the respective country or if adequate protection measures have been implemented (for instance the application of standard EU contractual clauses).
We may also disclose your Personal Data to public authorities, on the basis and within the limits of the legal provisions and as a result of requests expressly made by them.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data. We do not allow our third-party service providers to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

What rights do you have and how can you exercise them?

You may request to:

– be informed whether we process your Personal Data and what data is processed;
– request correction of processed data, if it is incorrect or incomplete;
– oppose to processing and to restrict the processing of your Personal Data for justified and legitimate reasons relating to your situation and only if the processing of such data is not a legal obligation for us or is not essential for the performance of our agreement;
– ask for the deletion of your Personal Data, except where the law forbids deletion or if the data is essential for the performance of the agreement;
– ask to receive your Personal Data in a structured commonly used and machine-readable format and to transmit such data to another party.

As noted above, the exercising of these rights may be subject to regulatory requirements or our legitimate interests.
You may exercise the above rights by contacting us at gdpr.team@g2-travel.com. The contact details of the Data Protection Officer at group level, who is also acting on our behalf, is Florin Marcu. To protect your personal data and your interests, we may request additional information to identify you.

Protecting the privacy of your Personal Data

When processing your Personal Data, we use technical and organisational measures to ensure the confidentiality, availability and accuracy of your data. However, no information security system is infallible.
That is why we are working continuously to ensure that our security measures are kept at the highest level and we commit ourselves to inform you on time of any security incidents that could pose a significant risk to your rights.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.

“If you disclose and share Personal Data with G2, the following will apply”

http://www.g2-travel.com/dpaclients/