- Which kind of personal data we process and why;
- when and in what way certain data is shared within De Drait group and third parties;
- the protection of your personal data;
- how to get access, and make changes to your personal data, how to file complaints and the legal grounds for processing your personal information;
- changes to our policy.
The responsible authority for deciding on the grounds for processing your personal data is the De Drait group, which in turn consists of:
De Drait b.v. establishment De Wilgen: Biskopswei 27, 9213 VM De Wilgen (Holland)
Yachtcharter Brandenburg GmbH.: Grosse Mühlenstrasse 10, 14774 Brandenburg(Germany)
1: What kind of personal data do we process, what for, how long is the data stored and how do we do it?
When you sign up for one of our services, you get to provide us with the following information:
Personal data: Address, e-mail address, phone number and date of birth.
When visiting our website or using one of our mobile apps, the following information will be shared:
- Travel preference;
- Surfing behavior: this includes the duration of your online stay, the total number of website visitors, and the requested pages in chronological order;
- Information about the specific instance of when you click one of our ads, even when it is displayed on third party websites;
- Information concerning the way you connect to our digital services, which includes the browser and operating system used, IP-address and other means of online identification;
- Social preferences, personal interests and activities.
When performing a booking, buying a product, or requesting a service, we get to process the following information:
- traveling data, passport data, and in specific cases banking details;
- information related to the time of the requested booking, what the booking entails, and where the booking was requested, in addition to payment details.
When visiting our website or participating in one of our campaigns, contests, surveys or questionnaires regarding our services, in addition to us getting into contact with you and you contacting us, we get to keep a record of the following data:
- Personal data you provide us through e-mail, conversing by phone, or through written forms of communication (which includes letters as well as getting in contact through social media). This can include, but is not limited to personal information like your name, address, phone number, place of residence and e-mail address;
- Information concerning received e-mails and other digital announcements we provide you with e.g. using links in e-mail messages, providing you opened them;
- Your feedback and participation in questionnaires and customer surveys.
Other possible sources of personal data:
- personal data originating from third parties like traveling agencies or public databanks;
- requesting access to our online services through social networks including Facebook, Google+ or Twitter or sharing any data by means of contact by phone grants us permission to use said data. This again can include name, e-mail, location data, banking information and additional information you voluntarily share with us;
- security camera imagery, IP-addresses, browser details and other information collected in one of our establishments.
Personal data of travelling companions:
Grounds for processing personal data:
To provide you with the Products and services you ask of us
- We require customer information to provide our booking service, supply you with products and services and help you with possible orders or refunds when requested. These refunds include the return of deposits.
Products, services and managing and improving management.
- To provide you with the best possible experience using our digital offerings and services we make use of data supplied by you, the customer.
Personalizing user data
- Personal data is used for researchand development as well as performing market research. This allows us to improve the way we provide our services, gain relevant knowledge and improve ways of communications within De Drait Group.
- Security cameras are deployed to safeguard security for anyone visiting any of our establishments. Provided imagery is used to prevent any transgressions, and allow us to track down and prosecute those responsible.
- We may use personal information in cases of national security operations, accidents and similar incidents as well as insurance purposes.
Getting into contact with you
- We get to provide personalized services when it comes to delivering advertisements and digital communication by monitoring online behavior, keep track of responses to online marketing campaigns and purchased products, and collecting data provided to us by a variety of sources within De Drait Group. This supplies us with means of improving marketing relevancy and customer satisfaction.
Marketing communication and service notifications
- We reserve the rights to send you newslettters, market research, e-mail social media messages and others when we think it is of interest to you. Keep in mind we will only use any of these if you have given us explicit permission to do so. If you choose to revoke this permission, you will still be able to receive service messages, like booking confirmation and important info regarding the use of our products and services.
2: When and in what way we are allowed to share personal data within De Drait Group and with third parties
Sharing personal data with suppliers and partners
To provide you with the requested products and services we only share the most vital data to suppliers and third parties like traveling arrangements and companies taxed with transportation.
- When thoughtfully selecting IT-specialists to aid us in combining user data, marketing, marketing research, processing payments and providing products and services, we make sure to only provide the most vital data.
- At times we share personal data to establish, act upon, or defend our legal rights. In these specific cases we may provide personal data to third parties to prevent fraud and minimise the risk of credit loss.
- When sharing personal data to third parties, you are assured we make clear arrangements on how this data is saved and will clarify that this data is not to be used for marketing purposes.
Sharing personal data with government agencies:
- We may provide vital personal data with government agencies in cases where we are either lawfully obliged to do so, when pressed the concerning agencies, or voluntarily, in the case of traveling data.
- We will, in cases of being pressured by concerning agencies or when obliged to assist in international travel, share personal data with customs, border patrols and/or other government agencies taxed with security, immigration, terrorism and so on.
Sharing personal data within De Drait Group
- When needed, we share only the most vital personal data with other companies within De Drait Group. For example to provide you certain services or products, to improve said services an products, improve and personalize user experience, or to get in contact with when needed. Reasons to get in to contact include some marketing purposes and market research.
Sharing personal data by obligation
- We may, justified by one or more arrangement with you, share personal data with any company to which we sell or transfer any of our companies, rights or obligations, or with which we are negotiating the selling or transfer thereof. The recipient of said data in turn gets to use the data for the same goals as we do.
International transfer of data outside of the European Union (from now on abbreviated to EU)
- Because of technical reasons the necessity for sharing personal data to De Drait Group affiliated companies can arise that require that particular data to be sent to companies outside of the EU. Because regulations of these country concerning privacy differ from those within the EU, the same protection of data can not be guaranteed. For this reason, De Drait Group will make use of standard contractual clauses to protect your digital privacy as much as possible. In cases where the aforementioned cannot be guaranteed, De Drait Group will ask for your explicit permission to send the data in question to countries without a fitting security policy. You can revoke these permissions at any time.
3: Protection of your personal data
Securing your personal data:
- We want you to safely be able to use our services, and will continue to monitor their usage. We do this by protecting personal data and prevent fraud and other transgressions. We take fitting security measures to protect your data from deliberate loss and unauthorized access, use, changes and publication
- In cases where you don’t want to receive personalized information from us, you can always inform us of your preferences. We will take action on it as soon as we are able.
- Afterwards you may still receive service notifications, like booking confirmations and important information concerning the use of our products or services.
Storing your personal data and store duration thereof
- We store personal data for as long as the goals mentioned in this privacy statement necessitate, and to comply with rules and regulations. When this necessity no longer exists, the data will be deleted. All data is stored in compliance with legal guidelines. If we would wish to use this data for analysis, historical or other business purposes, the data will be made anonymous before further processing.
Links to other websites and social media functionality
4: Cookie statement
- This cookie statement describes the cookies in use by websites of De Drait Group, and the functions they fulfill.
What are cookies?
- A cookie is a small file or part of a file stored on a World Wide Web user’s computer, created and subsequently read by a website server, and containing personal information (such as a user identification code, customized preferences, or a record of pages visited)
The cookies in use by De Drait Group
- For the most part De Drait Group makes use of functional cookies. These cookies are necessary to supply you with the services and functionalities you have requested. For example, functional cookies remember the fact that you have been logged in (so called session-cookies), so you don’t have to re-login when moving on to the next web page.
- To gather statistics on the use and purpose of visits of our website, De Drait Group deploys analytical services. The collected data is analyzed by the provider of these analytical services, after which the results are returned to De Drait Group. This provides De Drait Group with insight into how their websites are used, and gives it the ability to alter the way it deploys its services to best be of service to its customers. When legally required to do so, the analytical service provider can supply this information to third parties.
- Through some of our websites, the ability to access a variety of social media platforms, like Facebook, Twitter, LinkedIn, Instagram, Pinterest, YouTube and Google+. By making use of these so-called social plugins information originating from these website can be shared with others. Through these social plugins, third parties are able to store data on your device by using cookies. These cookies can be used to improve your user experience, as well as track your surfing behavior across multiple websites and building up a profile of your online presence.
- De Drait Group employs third party cookies on some of its websites, that can provide you with personalized offerings based on your online behavior.
- Some of these websites place a uniquely identifiable cookie, which enables the website to recognize your device and make other websites within the same advertisement network aware who you are. This also makes it possible for De Drait Group to provide personalized advertisements.
- Data gathered in this way will only be used by De Drait Group to display our advertisements on other websites, and will in no way be used for any other purpose.
Deletion of cookies
- Any permission you provided to De Drait Group for placing cookies on your device can be revoked at any time, by changing your browsers way of handling those cookies, or by removing any already stored cookies. Use your browsers built-in help feature to figure out how to perform these actions in your browser.
- Keep in mind that removing cookies or revoking permissions to place them might cause certain parts of our websites to not function as intended.
- Refusing to accept and deleting cookies only affects the system and browser that is used to perform the deletion and refusal of cookies, when you make use of multiple computers or browsers, make sure to perform those action for every computer and browser seperately.
5: Access to your personal data, modifying it, and filing complaints
Gaining access to, Modifying and deletion of you personal data:
- You may, at all times, request any piece of personal information concerning you we have in possession. When you wish to gain access to, delete, correct or in any other way alter this information, you can send us a request for it, after which we will identify and locate the requested data. When any of your personal data turns out to be out of date or not as they should be, we would like to receive your request to either alter or delete said data. You can also object to our processing your personal data.
- We will edit or delete your data, unless we are legally obliged to keep them as-is.
- We try our hardest to manage your data as best we can. If you feel you want to file a complaint for whatever reason regarding the way we manage, collect, store or use any of your data, please let us know in a written complaint addressed to De Drait, Biskopswei 27, NL-9213VM, De Wilgen, or reach us at firstname.lastname@example.org
- if you feel our response was unsatisfactory, you can file a complaint with autoriteitpersoonsgegevens.nl
- before we will process your request or complaint, we may request additional information from you, to confirm your identity. This is done to ensure you are authorized to file the specific complaint or make the specific request.
Legal grounds for processing personal data (GDPR)
We will only process your personal data in one of the following cases:
- We have received your explicit permission;
- The agreement we have with you or a request by you requires that we have to;
- we have to comply with some legal obligation;
- It is necessary to protect your own vital interest or those of other affiliated people
- out of common interest or when we have an official warrant for a task relating to the carrying out of public authority;
- If it is in our or a third parties justified interest, and these interests outweigh your interests and/or rights.
6: Legal basis for the processing of personal data
(General data protection regulation)
We only process your data in the following situations:
- We have your permission;
- It is necessary in connection with an agreement we have with you or to take action at your request before we enter into an agreement;
- We have to comply with the legal obligation;
- It is necessary to protect your own vital interests or those of other natural persons;
- It is the general interest whether we have an official authorization for a task in the exercise of public authority;
- It is in the legitimate interest of us or third parties and these interests outweigh your interests or rights.
7: Changes to our policy:
This policy will be in effect from May 2018 onward. We are allowed to make changes to this policy at any moment, so be sure to check for updates on our website regularly. We will clearly post information on our website regarding any notable changes.