PRIVACY POLICY
We take the protection of your data very seriously and want you to feel safe when you use our online service. This privacy policy provides details about the personal information (hereinafter “Data”) that we collect and how we use it. The term “User” includes all users of our website and apps (“Website”) regardless of whether they have a registered account or not. Terms used such as “User” are gender neutral.
Reach the Sea d.o.o., a corporation organized under the laws of the Republic of Croatia, with registration number 081520924 and its registered office at Mlinovi 27, Zagreb, Croatia (“Reach the Sea”) is the owner and operator of the Website and a contractual partner to the User.
DESCRIPTION OF OUR SERVICES AND GOALS
Our mission is to improve online travel-related services and help User save more by searching less. To do that, we show you personalized content and ads we think you’ll be interested in based on information we collect from you and third parties. We only use that information where we have a proper legal basis for doing so.
1. DEFINITIONS
1. ‘Data’ means any information relating to an identified or identifiable natural person (‘data subject’), such as a name, an identification number, an online identifier etc. and it includes any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person;
2. ‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
3. “Processing controller” means a natural or legal person, public body, agency or other body which, alone or together with others, determines the purposes and means of the processing of personal data.
4. “Processor” means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the Processing controller.
5. ‘Company‘ just like ‘we‘ and other such pronouns means Reach the Sea d.o.o., Zagreb (Grad Zagreb), Mlinovi 27, OIB: 23182591050, that is responsible for your information under this Privacy Policy based on the country you are based;
6. ‘Cookie‘ means a small piece of data stored on your computer by your web browser used to identify your browser, provide analytics, remember information about you such as your language preference;
7. ‘Data protection officer‘ refers to a designated person in the Company who is in charge of the procedures related to the personal data processing;
8. ‘End customer‘ refers to a person that, due to the recommendation of our users, books tickets (“Travel Products”) provided by third party (“Service Provider”) advertised at our site;
9. ‘Our site‘ refers to reachthesea.com;
10. ‘Service‘ means a service provided by Reach the Sea;
11. ‘Supervisory authority’ means an independent public authority;
12. ‘User‘ means a person who visits our Website (registered account is not needed).
2. RELEVANT LEGAL BASIS FOR PROCESSING
In accordance with Art. 13 of the GDPR, we inform you about the legal basis of data processing. If the legal basis is not explicitly stated in the Privacy Policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 a and art. 7 of the GDPR, the legal basis for processing for the performance of our services and the execution of contractual measures, as well as for answering inquiries, is Art. 6 (1) b of the GDPR, the legal basis for processing to meet our legal obligations is Art. 6 (1) c of the GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 (1) f. GDPR. In the event that the vital interests of the Data Subject or other natural persons require the processing of personal data, Article 6 (1d) of the GDPR serves as the legal basis.
3. HOW AND WHEN WE COLLECT DATA
3.1. When you give it to us or give us permission to obtain it
When you sign up for or use our site you voluntarily share certain data including your name, email address, phone number, photos, recommendations, and any other information you give us. You can also choose to share your precise location using your device settings or through photos. We will still use your IP address, which is used to approximate your location, even if you don't choose to share your precise location. You will also have the option to share other information about yourself such as your gender, age, and preferred language.
If you connect your Facebook, Google, or other third-party accounts to our site, we use information from those accounts (such as your friends or contacts) to improve your Reach the Sea experience. This is dependent on the privacy policies or settings for those accounts.
3.2. We also get technical information when you use Reach the Sea
When you use a website, mobile application or other internet service, certain internet and electronic network activity information gets created and logged automatically. This is also true when you use our site. Here are some of the types of data we collect:
● Log data. When you use our site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit a website, or that your mobile app automatically sends when you’re using it. This log data includes your Internet Protocol address (which we use to infer your approximate location), the address of and activity on websites you visit that incorporate Reach the Sea features (like the “Save” button—more details below), searches, browser type and settings, the date and time of your request, how you used Reach the Sea, cookie data and device data.
● Cookie data. We also use “cookies” (small text files sent by your computer each time you visit our website, unique to your Reach the Sea account or your browser) or similar technologies to get log data. When we use cookies or other similar technologies, we use session cookies (that last until you close your browser) or persistent cookies (that last until you or your browser delete them). For example, we use cookies to store your language preferences or other settings so you don‘t have to set them up every time you visit our site. Some of the cookies we use are associated with your Reach the Sea account (including information about you, such as the email address you gave us) and other cookies are not. For more detailed information about how we use cookies, please review our
Cookies Policy.
● Device information. In addition to log data, we collect information about the device you’re using Reach the Sea on, including the type of device, operating system, settings, unique device identifiers and crash data that helps us understand when something breaks.
● Clickstream data and inferences. When you’re on our site, we use your activity—such as which products you click on, boards you create, and product links that you generated from Reach the Sea—along with information you provided when you first signed up and information from our partners and advertisers to make inferences about you and your preferences.
3.3. Our partners and advertisers share information with us
We also get information about you and your activity outside our site from our affiliates, advertisers, partners and other third parties we work with. For example:
● Some websites or apps use Reach the Sea features such as our “Save” button, or you may install our “Save” button for your browser. If so, we collect log data from those sites or apps.
● Online advertisers or third parties share information with us to measure, report on or improve the performance of ads on Reach the Sea, or to figure out what kinds of ads to show you on or off Reach the Sea. This includes information about your visits to an advertiser's site or purchases you made from them, or information about your interests from a third-party service, which we might use to help show you ads.
You can control how we use this information to personalize your experience and the ads you see on our site in your Privacy and Data Settings.
4. WHAT WE DO WITH THE DATA WE COLLECT
We’re committed to showing you content that’s relevant, interesting and personal to you. To do that, we use your information to provide and improve your experience, including:
● Identify you when you use our site.
● Recommendation of products, boards, blogs or categories you might like based on your activity on our site.
● Provide you with the most up-to-date products relevant to your interests.
We have a legitimate interest for using your info in these ways. It's fundamental to what we do at Reach the Sea and necessary to make our Website and its features relevant and personalized to you.
We also have a legitimate interest in making our site safe and improving our product features, so you keep finding the products you love in less time and at the best price. We all benefit when we use your information to:
● Suggest other people who have similar interests.
● Work with law enforcement and keep Reach the Sea safe. We may get requests for account information from law enforcement authorities like the police or courts.
● Conduct analytics and research on who is using our Webiste and what they are doing. For example, by logging how often people use two different versions of a feature on our site, we can understand which version is better.
● Improve our Webiste and offer new features.
● Advertise Reach the Sea products and services to you on other sites. You can choose for us not to share your information with other sites to personalize those ads.
● Send you updates (such as when certain activity, like saves or price decreases, happens on our Website) and news by email or push notification, depending on your settings. For example, we send weekly updates that include recommendations you may like. You can decide to stop getting these notifications by updating your settings.
We have a legitimate interest in delivering ads that are relevant, interesting and personal to you in order to generate revenue. To further these interests we use the information we collect to:
● Decide which ads to show you. We customize the ad content we show you by identifying your interests based on your onsite and offsite activities, as well as by using information we receive from ad partners or other third parties. Where we use cookies to identify your offsite interests, we’ll get your consent where we need to. Where ad partners or other third parties share information with us about you, we rely on the consent they already obtained.
● Tell our ad partners how their Reach the Sea ads are doing, and how to make them better. Some of this information is aggregated. For example, we would report to an advertiser that a certain percentage of people who viewed a Promoted Recommendation went on to visit that advertiser's site. Depending upon where you live and your settings, we may also disclose this information at an individual level; this information isn’t aggregated. For example, we would let an advertiser know that a particular Promoted Recommendation has been saved by certain people.
We have a legitimate interest in using information we collect to customize your Reach the Sea experience based on your offsite behavior. When we identify your interests based on your offsite behavior with cookies, we (or our partners) will obtain any consent that we may need. To find out more about how we use cookies, please see our Cookie Policy.
In addition to the specific circumstances above, we’ll only use your data with your consent in order to:
● Send you marketing materials by email, text, push notification or phone call depending on your account or operating system settings. Each time we send you marketing materials, we give you the option to unsubscribe.
● Identify your precise location and customize the recommendations and ads we show you.
Where required, we’ll also rely on your consent where we use cookies to show you ads you might be interested in. We use cookies to identify your interests based on your offsite activity.
5. YOUR RIGHTS OVER THE DATA THAT WE COLLECT
5.1. You have the right to obtain from the Processing controller a confirmation of whether personal data relating to you are being processed and, if so, access to personal data and further information and a copy of the data in accordance with Art. 15 of the GDPR.
5.2. You also have the right to obtain from the Processing controller the correction of inaccurate personal data concerning you or the completion of data concerning you, in accordance with Art. 16 GDPR.
5.3. In accordance with Art. 17. GDPR, you have the right to request that the relevant data be deleted without undue delay or, alternatively, to request a restriction on data processing in accordance with Art. 18 of the GDPR.
5.4. In accordance with Art. 20 of the GDPR the right to receive personal data relating to you, which you have provided to us, in a structured, frequently used, and machine-readable format and the right to transfer this data to another Processing controller.
5.5. In accordance with Art. 77 GDPR, you also have the right to appeal to the supervisory authority.
6. RIGHT OF WITHDRAWAL
You have the right to withdraw consents given in accordance with Art. 7 (3) of the GDPR with effect in the future.
7. RIGHT TO OBJECT
You may object to future processing of data concerning you in accordance with Art. 21 of the GDPR at any time. An objection may be filed specifically against processing for direct marketing purposes.
8. DELETION OF DATA AND ARCHIVING OBLIGATIONS
The data we process will be deleted or their processing will be restricted in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated in this Privacy Policy, the data we have stored will be deleted as soon as it is no longer needed for the intended purpose and there are no legal obligations to retain it. If the data is not deleted because it is needed for other and legally permitted purposes, their processing is limited. This means that the data is excluded and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
9. CHOICES YOU HAVE ABOUT YOUR DATA
Our goal is to give you simple and meaningful choices regarding your information. If you have a Reach the Sea account, many of these controls are built directly into our Website or your settings. For example, you can:
● Edit information in your profile at any time
● Link or unlink your Reach the Sea account from other services (like Facebook, Google or Twitter).
● Edit unpublished board settings. Unpublished boards are visible to you only.
● Choose whether Reach the Sea ads delivered to you on other platforms, sites or apps are customized using information about your account activities. You can control this by visiting your settings and updating your “Personalization” preferences.
● Choose whether Reach the Sea shares information about your activity on Website for ads performance reporting. You can control this by visiting your settings and updating your “Data Personalization” preferences.
● Close your account at any time. When you close your account, we’ll deactivate it, and delete your account data. Please note that there may be legal reasons for us to keep your data, such as if we receive a law enforcement request asking us to preserve data. We may also retain certain information in our backup systems for a limited period of time, or as required by law.
You also have choices available to you through the device or software you use to access Reach the Sea. For example:
● The browser you use lets you control cookies or other types of local data storage.
● Your mobile device lets you choose how and whether your precise location, photos, contacts and other data is shared with us.
To learn more about these choices, please see the information provided by your device or software provider.
10. TRANSFERRING YOUR INFORMATION
Reach the Sea is a worldwide service. By using our products or services, you authorize us to transfer and store your information outside your home country, for the purposes described in this policy. The privacy protections and the rights of authorities to access your personal information in such countries may not be equivalent to those of your home country.
11. HOW AND WHEN WE SHARE INFORMATION
Anyone can see the public boards and recommendations you create and profile information you give us.
We also share your information with:
● Other services, at your direction, to enable you to sign up for or log in to our site, or when you decide to link your Reach the Sea account to those services, like Facebook or Google.
● Third-party companies, service providers or individuals that we employ to process information on our behalf based on our instructions and for the purposes described in this Privacy Policy. For example, we share data with security consultants to help us get better at identifying spam. Some information we acquire may be collected by third-party providers on our behalf.
● Law enforcement agencies or government agencies. We only share information if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or Reach the Sea; or to detect, prevent, or otherwise address fraud, security or technical issues.
● Our wholly-owned subsidiaries and affiliates. If we were to engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy, we would share your information with a party involved in such a process (for example, a potential purchaser).
● To enhance our services, we may send your personal information outside of Croatia and European Union, including to the United States. This data may be subject to the laws of the countries where we send it. We try to only send your information to countries that have strong data protection laws. As mentioned, while we do what we can to protect your information, we may at times be legally required to disclose your personal information (for example, if we receive a valid court order) so in those cases, we might disclose your personal data to persons other than those mentioned in this section.
12. OUR POLICY ON CHILDREN’S INFORMATION
Children under 13 are not allowed to use our Website. If you are based in the EEA you may only use our Webiste if you are over the age at which you can provide consent to data processing under the laws of your country.
13. RESIDENTS OF THE EEA
If you have any questions about our data processing activities, the data Processing controller you should contact is Reach the Sea d.o.o., Zagreb (Grad Zagreb), Mlinovi 27, OIB: 23182591050. You can also contact our Data Protection Officer.
If you think that we haven't complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Croatia or with your local supervisory authority.
14. AMENDMENTS TO THIS PRIVACY POLICY
Please keep yourself informed of the contents of our Privacy Policy. We will adjust the Privacy Policy as soon as they make any changes to the data processing we have made. We will notify you as soon as the changes require your cooperation (e.g., Consent) or other individual notice.
15. CONTACT US
The best way to get in touch with us or to exercise your options described above is through the Help Center.