Privacy Policy

PARU AG ("We") is the data controller responsible for the collection and processing of your personal data in connection with its activities. Our mission is to provide our customers with a comprehensive range of travel services.

In this Privacy Policy, we explain how we process your personal data and how you can control and manage it. Our data processing may be covered by other data protection notices, such as those contained in the General (Travel) Terms and Conditions in particular, or may arise from the circumstances or be regulated by law.

This privacy policy complies with the requirements of Swiss data protection law and - if and insofar as applicable - the General Data Protection Regulation (GDPR) of the European Union.

1. Are you affected by this notice?

This Privacy Policy applies to you if you:

• are one of our customers or have a contractual relationship with us;
• are a fellow traveler of one of our customers.
• are interested in our products or services and therefore provide us with your personal data (e.g. in an agency, on our websites and apps or at events) so that we can contact you.

If you provide us with personal data of other people, please ensure that you inform them about the disclosure of their personal data and ask them to read this privacy policy. We will ensure that we do the same whenever possible (e.g. if we have the contact details of the person concerned).

2. How can you control our processing of your personal data?

You have rights that allow you to effectively control your personal data and the way we process it. We explain your rights in relation to your personal data below.

If you wish to exercise the rights listed below, please submit a request by e-mail to hello@paru.travel or by post to the following address: PARU AG, P.O. Box, 3097 Liebefeld.

If you have any questions about the use of your personal data in the context of this privacy policy, please send them to the following address: hello@paru.travel

2.1. You can request information about your personal data

If you would like information about your personal data, we will provide you with a copy of the personal data you have requested and information about its processing.

Your right to information may be limited in cases provided for by law.

2.2. You can request the rectification of your personal data

If you believe that your personal data is incorrect or incomplete, you can request that this personal data be amended or completed accordingly. In some cases, the submission of supporting documents may be required.

2.3. You can request the erasure of your personal data

If you wish, you can request the erasure of your personal data to the extent permitted by law.

2.4. You can object to the processing of your personal data on the basis of legitimate interests

If you do not consent to processing based on a legitimate interest, you can object to this on grounds relating to your particular situation. In this case, please inform us in detail about the relevant processing and the reasons for your objection. We will stop processing your personal data unless there are compelling legitimate grounds for doing so or the processing serves the establishment, exercise or defense of legal claims.

2.5. You can object to the processing of your personal data for the purpose of direct marketing

You have the right to object to the processing of your personal data for direct marketing purposes at any time. This also applies to profiling insofar as it is associated with such direct advertising.

2.6. You can request the restriction of the processing of your personal data

If you contest the accuracy of the personal data we use or object to the processing of your personal data, we will review or revise your request. You can request that we restrict the processing of your personal data while we review your request.

2.7. You have rights against an automated individual decision

In principle, you have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. However, we may automate such a decision if it is necessary for the conclusion or fulfillment of a contract with us, if it is permitted by law or if you have given your consent.

In any case, you have the right to contest the decision, to express your point of view and to request the intervention of a competent person to review the decision.

2.8. You can withdraw your consent

In cases where processing is based on your consent, you can withdraw this consent at any time.

2.9. You can request the portability of part of your personal data

You may request a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format. If technically feasible, you can request that we transfer this copy to a third party.

2.10. Complaint to the Federal Data Protection and Information Commissioner

In addition to the rights mentioned above, you can lodge a complaint with the competent supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern.

3. For what purpose and on which legal basis do we use your personal data?

3.1. Contract fulfillment and legitimate interest

In this section, we explain the purpose for which we process your personal data and the legal basis for doing so. First and foremost, we use your personal data to fulfill a contract to which you are a party or to carry out pre-contractual measures at your request. However, we may also process your personal data in order to fulfill our legitimate interest or that of third parties.

In particular, your personal data will be processed if this is necessary for the conclusion or fulfillment of a contract in order to:

• enter into a (travel) contract with you. We may process personal data in order to register you as a new customer, conclude a contract and fulfill this contract with you;
• provide you with products and services that you have purchased under the relevant contract;
• carry out billing, invoicing and debt collection;
• to provide you with services in connection with the preparation and realisation of a trip;
• for insurance purposes;
• to provide counseling services;
• to be able to provide assistance in the event of difficulties during the trip;
• to provide you with access to our digital platforms. We may process personal data when you use our digital platforms for various purposes (e.g. to manage your personal information or to access travel information);
• to provide access to our premises and facilities. We may process personal data when you visit our premises in order to carry out appropriate access and security checks;
• to communicate with you. We may process personal data if you wish to contact us, if you ask us for information about our company or our services or if the contract needs to be updated;
• to respond to your enquiries and support you;
• manage the cancellation of the contract.

Where we base a processing activity on a legitimate interest, we will balance that interest against your interests or fundamental rights and freedoms to ensure that they are proportionate. As part of our business activities as a travel provider, we also use your personal data to:

• Further develop our products and services;
• improve cyber security, manage our platforms and websites and ensure business continuity
• Implement the introduction of IT solutions;
• carry out maintenance of IT systems during operation;
• Improve the automation and efficiency of our operations and customer services (e.g., automatically filling complaints, tracking your requests and improving your satisfaction based on personal data collected during our interactions with you, such as phone records, emails or chats);
• enable the assertion of legal claims and defence in connection with legal disputes and official proceedings;
• organise competitions, promotions and conduct opinion polls and customer satisfaction surveys.

3.2. Advertising and marketing

If you are a customer and unless you object, we may send you offers for our products and services. We will ensure that these commercial offers relate to products or services that are relevant to your needs and complement the offers you have already taken advantage of. You can object to this at any time.

3.3. Consent

For certain processing of personal data, we will inform you specifically and ask for your consent. You can of course withdraw your consent at any time.

In particular, we ask for your consent for:

• The transfer of particularly sensitive personal data to third parties;
• Tailoring our offers and products or services on the basis of a complex profile in order to predict your needs and behavior;
• any electronic offers for products and services that are not similar to those you have purchased or for products and services from our trusted partners.

If necessary, we may ask you for further consent to process your personal data, but this will not affect any data processing that has already taken place.

4. What types of personal data do we collect?

We collect and use your personal data, i.e. any information that identifies you or makes it possible to identify you.

Depending on the type of product or service we provide to you and the interactions we have with you, we collect different types of personal data about you:

• Contact information, (private or professional) postal address, e-mail address, telephone number;
• Personal details, e.g. gender, birthday and age, marital status, nationality, passport details, etc.
• Lifestyle, e.g. hobbies and interests, traveling;
• Travel details, such as travel dates, itinerary/destination, airline, hotel, price, customer preferences, information about your fellow travelers, frequent flyer programmes, etc;
• Health data, e.g. information about health-related special needs or illnesses and accidents while traveling;
• Financial data, e.g. payment information, credit card number, account details;
• Data about your habits and preferences in relation to the use of our products and services (e.g. food preferences);
• Data from our interactions with you, e.g. your comments, suggestions, needs collected during our exchanges with you in person at our locations and during telephone communication (call note or call recording), communication by email, chat, chatbot, exchanges on our social media and any complaints you may have. Your connection and tracking data (e.g. collected via cookies for non-advertising or analytical purposes on our websites), online services, other applications;
• Data about your devices (mobile phone, computer, tablet, etc.), such as IP address, technical data and unique identification data;
• Personalised login data or security features that are used to connect you to our website and apps.

5. From who do we collect personal data?

We usually collect personal data directly from you. However, we may also collect it from other sources.

Sometimes we collect data from public sources:

• publications/databases provided by official authorities or third parties (e.g. the Swiss Official Gazette of Commerce or the commercial register);
• websites/social media sites of legal entities or corporate clients that contain information you have disclosed (e.g. your own website or social media site);
• public information, e.g. information from the media.

We also collect personal data from third parties:

• from our customers (e.g. as fellow travelers);
• our business partners (e.g. tour operators, service providers abroad);
• third parties such as credit reference agencies and fraud prevention agencies;
• address research service providers who are responsible for ensuring that they collect the relevant information by lawful means.

6. Who do we share your personal data with and why?

In order to fulfill some of the purposes described in this data protection declaration, in particular the execution of a trip, we may pass on your personal data to others if necessary. These may be the following:

• Our service providers in the destination country (e.g. agencies, tour guides, hotel reservations, transfer and excursion services), transport service providers (airlines, trains, car rental, etc.) and accommodation providers (hotels, hostels, etc.);
• processors who provide services on our behalf (e.g. IT services, logistics, printing services, telecommunications, debt collection, consulting and sales and marketing);
• certain regulated professional groups such as lawyers, notaries or auditors, if this is necessary under certain circumstances (legal disputes, auditing, etc.) as well as to our insurers;
• partners for the purpose of advertising, market research and opinion polling;
• partners for the purpose of assisting in the investigation of criminal offences (e.g. fraud), the assertion, exercise or defence of legal claims;
• public authorities and official bodies (e.g. tax authorities, embassies of the destination country) in the event of a legal or official obligation (e.g. retention obligations, visa acquisition, acquisition of entry requirements).

7. International transfer of personal data

In the case of international transfers from Switzerland and the European Economic Area (EEA) to a non-EEA country (third country), your personal data may be transferred across borders. In particular, you should expect your data to be transferred to your travel destinations. But also to other countries in Europe, the USA and worldwide, where the service providers and service providers we use are located. If the FDPIC or the European Commission has recognised that a third country offers an adequate level of data protection, your personal data can be transferred on this basis.
 
For transfers to a third country whose level of protection has not been recognised as adequate by the FDPIC and the European Commission, we either rely on an applicable exemption (e.g. if the transfer is necessary to fulfil our contract with you) or apply one of the following appropriate safeguards to ensure the protection of your personal information:

• standard contractual clauses approved by the FDPIC and the European Commission;
• binding corporate rules.

To obtain a copy of these safeguards, or information on where they can be obtained, you may make a written request in accordance with section 2.

8. How long do we store your personal data?

We will store your personal data for as long as is necessary to fulfil our contractual obligations and to comply with the applicable laws and regulations, or for another period with regard to our legitimate business interests, such as proper accounting and responding to legal claims or official requests.

9. Data security

We use appropriate technical and organisational security measures to protect your personal data stored by us against manipulation, partial or complete loss and against unauthorised access by third parties (e.g. encryption of data transmission, access controls, etc.). Our security measures are continuously improved in line with technological developments.

We take appropriate precautions to protect your data. However, the transmission of information via the internet and other electronic means always entails certain security risks and we cannot guarantee the security of information transmitted in this way.

10. Cookies and tracking when using the website

We typically use "cookies" and similar techniques on our websites and apps that can be used to identify your browser or device. A cookie is a small file that is sent to your computer or automatically stored by the web browser you are using on your computer or mobile device when you visit our website or install our app. If you visit this website again or use our app, we can recognise you again, even if we do not know who you are. In addition to cookies that are only used during a session and deleted after your visit to the website ("session cookies"), cookies can also be used to store user settings and other information over a certain period of time (e.g. two years) ("permanent cookies"). However, you can set your browser to reject cookies, to only store them for one session or to delete them prematurely. Most browsers are set to accept cookies by default. We use permanent cookies so that you can save user settings (e.g. language, auto-login), so that we can better understand how you use our offers and content, and so that we can display offers and advertising tailored to you (which can also happen on the websites of other companies; however, they do not find out from us who you are, if we even know, because they only see that the same user who was on a certain page of our website is on their website). Some of the cookies are set by us, some by contractual partners with whom we work. If you block cookies, certain functionalities (such as language selection or booking processes) may no longer work.

We may use third-party tools or services on our website to improve the functionality or content of our website (e.g. by integrating videos or maps), to compile statistics or to place advertising. In doing so, we use the third-party service providers listed below. You can find the contact details and further information about their data processing in the providers' respective data protection declarations.

Cookies currently used on paru.travel:

• Google Tag Manager: Google Tag Manager sets cookies to test the advertising effectiveness of websites that use its services; to calculate visitor, session and campaign data and track website usage for the website's analytics report; to present users with ads that match their profile. The cookie stores information anonymously and assigns a randomly generated number to recognize individual visitors.
• Google Ads, Provider: Google Ireland Ltd., Ireland, Privacy Policy: policies.google.com/privacy
• Google Analytics
  provider: Google Ireland Ltd., Ireland
  Privacy policy: policies.google.com/privacy
• Google Maps, Provider: Google LLC, USA, privacy policy: policies.google.com/privacy

In a world where technology is constantly evolving, we regularly review this privacy policy and update it as necessary.

The current version published on our website applies. We encourage you to view the latest version of this document online. We will notify you of any changes via our website or through our usual communication channels.