privacy statement

General Information

GTM- Global Travel Management is committed to respecting your privacy and protecting your personal data.

In this Privacy Policy, “GTM”, “we”, “us” or “our” means GTM- Global Travel Management SRL, registered in Romania, Iasi, Sos. Stefan cel Mare 4/ A17/ 4 under 38269678 registration nr; “you” or “your” means you, the person who provides us with personal data; and “personal data” shall have the meaning assigned to it in Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council.

All personal data is obtained, held, and processed by GTM, in compliance with, this Policy, any and all data protection related laws and regulations that are applicable to GTM (including without limitation, Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”)), and any and all data protection related terms in any agreement or contract in force between you and GTM in relation to the supply by us to you of services and/or products.

The main establishment of GTM for purposes of the GDPR shall be Romania (Europe).
When we ask you to provide certain personal data, then you can be assured that it will only be used in accordance with this Policy. This Policy applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as a client or potential client, including when you book travel arrangements with us, use our website, service agents and book to use services of third parties providers (such as agents, airlines and other carriers, hotels, rent a car companies).

This Policy applies to you whether you use our services or products on a casual basis, or have registered to use any of our services or products, or have entered into a contract with us in relation to the supply by us to you of services and/or products. Any products and/or services acquired by you from us will be subject to their own terms and conditions which you must also read and accept. In the event of any conflict between this Policy and the terms and conditions of any such products or services (such as, without limitation, those terms and conditions in, any flight tickets, accommodation bookings, transfers, and auxiliary services), then the terms and conditions of those products or services shall prevail.

This Policy is effective as of the “Effective Date” which appears at the bottom of this Policy. Use the “Last Revised Date” appearing at the bottom of this Policy to determine when this Policy was last updated. This Policy is current as of the “Last Revised Date”. We reserve the right, at our sole and absolute discretion, to change or modify this Policy at any time. Any such changes or modifications will become effective when posted on this page. Please check this page periodically to ensure that you are happy with any such changes or modifications. It is in your own interest to access this page regularly to view the latest version of this Policy. If we make a change or modification to this Policy, we may, where appropriate and where possible in our sole discretion, alert you with a notice on our website or with any other means of notification we deem fit. Your continued access to or use of any of our services or products or your purchase of any of our products or services or your continued provision of personal data to us following any change or modification to this Policy shall be deemed your acceptance to be bound by any such changes or modifications.

Your access to or use of any our services or products and your purchase of any of our products or services is entirely voluntary. Please read this Policy carefully, as your access to or use of any our services or products and your purchase of any of our products or services constitutes your acceptance of all of the terms and practices described in this Policy, including without limitation, the collection, use, processing, and disclosure of your personal data as described in this Policy. Please do not access or use any of our services or products or purchase any of our services or products if you disagree with any part of this Policy.

What types of personal data do we collect?

We collect personal data about you, about your travel arrangements, about how you use our services and products, and about how you use our websites, call centres and mobile applications, and such personal data so collected includes without limitation:

  • Your name and surname;
    Contact information including address of residence and/or business address, email address, telephone number, and fax number;
    Your date of birth, nationality, and passport information when you book a flight with us;
  • Personal tastes (e.g food and beverages) and dietary requirements;
    Medical condition (e.g. allergies for catering purposes, and disabilities);
    Information about your travel arrangements, such as details of your bookings, travel itinerary, details of any additional assistance you require and other information related to your travel arrangements with us.
  • Information about the services we have provided to you in the past, including your previous travel arrangements, such as flights and other bookings, and related matters, such as upgrades, etc.
  • Your geographical position;
  • Information about your use of our websites, including information about which pages you view;
  • Information about interactions you have with us and our staff;
  • Your financial and credit card information (including such information as received from third party banks and other credit institutions and credit rating institutions) which are necessary for us to provide you with the requested product or service; and,
  • Other information that may be required by us, to carry out obligations arising from any contracts entered between you and us, and/or to carry out client surveys and/or offers.

This personal data may include information that you provide to us directly as well as information which we collect when you use our products or services.

When, and why, do we collect ‘sensitive personal data’?

Certain categories of personal data, such as that about race, ethnicity, religion or health, are considered “sensitive personal data” in terms of applicable law. Sensitive personal data will only be processed where:
you have requested specific medical assistance from an operator, such as the provision of wheelchair assistance or oxygen, or,
you have sought clearance from to fly with a medical condition or because you are pregnant, or,
you have otherwise chosen to provide such information to us (or a service provider like air carriers, accommodation providers, rent a car companies, or any other applicable).
By providing any personal data that is, or could be considered to be “sensitive personal data”, you explicitly agree that we may collect, use, share with third parties and transfer such data, within and outside of the European Economic Area, in accordance with this Policy.

What do we use your personal data for?

We store, handle, send and generally process personal data to provide you with the best service, and in particular for the following reasons:

  • We will need to use the personal data to fulfil your request and provide your:
    flights; and, other travel related arrangements if you choose to book them with us.
    To deal with the general enquiries you raise from time to time on our services;
  • For the purposes of accounting and billing
  • To carry out obligations and/or enforce rights arising from any contracts entered between you and us;
  • To carry out due diligence or other background checks on you (thru’ sanction and enforcement list data) so as to protect our rights, interests, property and safety and the interests, rights, property and safety of our clients, or others;
  • For internal record keeping and the general administration of your records by us which may include for example, accounting and billing, auditing, credit or other payment card verification, anti-fraud screening (including the use of credit reference agency searches and payment card validation checks.
  • For security purposes to protect your personal data held and/or processed by us;
  • For training our employees in respect of providing our service and products to you;
  • For statistical analysis;
  • To improve our products and services;
  • For our general marketing purposes where you have notified us that you consent to receive information about us and our services, products and offers;
  • From time to time, we may also use your personal data to contact you for feedback on our services and third-party supplier services so as to assist us in their improvement and development, and to provide services tailored to your requirements and treat you more personally, for example:
    • to deliver messages and information that we think is relevant and may be of interest to you, prior to, during, and after your travel with us
    • to personalise and tailor your travel experience.

Who do we share your personal data with?

We may disclose your personal data (and any third party personal data provided by you to us) to:

  • air operators, the actual carrier and other third parties in order to give effect to our obligations under any contact entered into between you and us for the provision of services;
  • companies which work with us based on a legal and transparent partnership
  • our authorised representatives;
  • third parties:
    • if we are under a duty to disclose such personal data in order to comply with any legal or regulatory obligation or request (whether in Romania, Malta, or elsewhere);
    • in order to give effect to and/or enforce the terms and conditions of any contract entered into between you and us;
    • so as to protect our rights and safety (including by way of exchange of information with third parties for the purposes of fraud protection);
    • to facilitate your travel arrangements, including air carriers and airport operators, agents or brokers involved in making your travel arrangements, and global distribution systems service providers; and,
    • who deliver services either to you or to us, such as companies that provide airport assistance, ground handling, catering, transportation.
    • All carriers are required by laws in several countries to give border control agencies and other public authorities access to booking and travel information and other personal data. Therefore, any information we hold about you and your travel arrangements may be disclosed to the customs, immigration and public authorities of any country in your itinerary.
    • In addition, laws in several countries require carriers to collect passport and associated information for all passengers prior to travel to or from those countries. When required, GTM will provide this information to air carriers with acceptance and understanding of the immigration authority procedures and requirements.

When do we collect personal data about you?

We collect personal data about you when you use our services or products (whether directly provided by us or by another provider or carrier), when you travel with us, and when you use our website, contact our agents or mobile applications. The following are examples of when we collect personal data about you:

  • when you book or search for a flight or other products or services on our website
  • when you book or search for a flight or other products or services through our other sales channels, such as through an agent
  • when you contact our service agents or sales representatives
  • if you complete a client survey or provide us with feedback
  • if you choose to interact with us via social media

How we use cookies

Cookies are a small amount of data sent from the server, which is then stored on your computer’s hard disc drive. We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies help us to improve our services and to deliver a better and more personalised service.

You can delete all cookies that are already on your computer and you may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our services, unless the cookies to be issued require your informed consent.

Security, storage, and transfer

We are committed to ensuring that your personal data is secure at all times. We have in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect.

All of our employees and suppliers with access to your personal data and/or who are associated with the processing of that data are contractually obliged to respect the confidentiality of your personal data.

Your personal data will be stored on and processed by our systems and may also be stored on and processed by systems of a third-party data processor(s) appointed by us.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by employees operating outside the EEA who work for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy, the GDPR, and any data protection related laws that are applicable to GTM.

Withdrawal of Consent

If you withdraw your consent to the processing of your personal data at any time, it may mean we will not be able to provide all or parts of the products or services you have requested from us (example: if you book a flight with us and prior to the flight you withdraw your consent to the processing of certain of your personal data which is necessary for the performance of that flight, then we will not be able to provide you with the flight ticket). Please be aware that in these circumstances you will not be able to obtain a refund of any fees or monies you would have paid, unless air carrier fare conditions entitle you to a partial refund.

On the other hand, if for example you withdraw your consent to us sending you marketing communications, then such withdrawal should not have any affects.

Transmission of information over the internet

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Links to third party websites

Our websites, online services and mobile applications may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. You are advised to please check these policies before submitting any personal data to these websites or using these services.

Providing information about someone else

If you are providing personal data to us about someone else you confirm that they have appointed you to act for them, to consent to the processing of their personal data, and that you have informed them of our identity, of this Policy, and of the purposes (as set out in this Policy) for which their personal data will be processed.

How to access, review, transfer and delete your personal data

We will make your personal data available to you for review pursuant to a simple request from you. If you tell us that the personal data which we hold about you is incorrect or is used inappropriately, we will correct, update or delete such person data as appropriate. You also have other rights such as the right to request from us erasure of personal data or restriction of processing or to object to processing and the right to data portability. For information about how to get access to your personal data and for exercising your rights, please contact [email protected]

Complaint, applicable law, Jurisdiction and Severability

If this Policy is incorporated by reference into a contract having its own choice of law and jurisdiction, then any dispute arising from or related to the acceptance, interpretation or observance of this Policy shall be subject to the governing law, of that contract.
You also have the right to lodge a complaint with a supervisory authority established within the EEA. List of contact details of supervisory authorities within the EEA is available here.

Further details

Further details about your rights under the GDPR can be accessed here.