Privacy Policy
Version 2.1., effective from 10 June 2024
Delfin App Services FZCO (Delfin) values you as our customer and recognizes that privacy is important to you. This Privacy Policy explains how we collect, use, and disclose personal information when you use our platform and associated services, your rights in determining what we do with the information that we collect or hold about you and tells you how to contact us.
What does this Privacy Policy cover?
This Privacy Policy is designed to describe:
What personal information do we collect and use, and how do we collect it?
We collect personal information when:
When you create an account on our Website, sign up to receive offers or information, or make a booking using our platform, you give us your personal information. We also collect such personal information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our Website or download and use our apps. We also receive personal information from our business partners and other third-parties if expressly permitted, which help us improve our platform and associated tools and services, update and maintain accurate records, potentially detect and investigate fraud, and more effectively market our services.
How is your personal information shared?
Your personal information may be shared for several purposes, including: to help you book your travel and/or vacation, assist with your travel and/or vacation stay, communicate with you (including when we send information on products and services or enable you to communicate with travel providers and/or property owners), and comply with the applicable law. The full Privacy Policy below details how personal information is shared below.
What are your rights and choices?
You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, by deletion your account as applicable, or contacting our customer service. Our Privacy Policy has more information about the options and data protection rights and choices available to you.
How to contact us
More information about our privacy practices is in our full Privacy Policy. You can also contact us as described below in the “Contact Us” section to ask questions about how we handle your personal information or make requests about your personal information.
Privacy Policy
Collection and Use of Your Personal Information
You will find in this section information about:
Lawful bases for processing:
In the tables below, you will find the lawful basis we rely on to collect and use your personal information.
In summary, we will collect personal information from you only when one of the following lawful bases applies:
Categories of Personal Information We Collect and Use
We collect personal information for the following purposes:
We collect the following categories of personal information for the following purposes:
1. Government issued identification data – including passport, driver’s license, government redress numbers, country of residence
Purposes for collection:
Sources of Personal Information:
Lawful basis:
2. Identification data – including name, username, email address, telephone number, as well as home, business, and billing addresses (including street and postal code).
Purposes for collection:
Sources of Personal Information:
Lawful basis:
3. Payment data
Purposes for collection:
Sources of Personal Information:
Lawful basis:
We are not processing your payments directly. All your payments are processed by licensed Payment Providers as defined in Terms and Conditions. To facilitate your payments, we have partnered with these licensed Payment Providers, which may transfer, process, and store your Payment Data outside the United Arab Emirates. We do not directly access your payment data. If you are using the services of our Payment Providers to pay online using Debit/Credit Card, you consent to this process and acknowledge that such data may be disclosed as required by applicable laws.
If you are using the services of our Payment Provider to pay online using Debit/Credit Card, then you are doing so with the consultation/approval of the card owner/account holder (if in case you are not the card holder/account holder yourself). If transaction is found suspicious by Payment Provider’s risk management team or by us, we are forced to identify the credit/debit card holder before we proceed with the payment in order to and to protect your payment from potential fraud. You may be asked to submit identification proof and front copy of your debit/credit card (when applicable) by email to complete your transaction. If you failed to produce the said documents on time, then your transaction/booking will be cancelled with immediate effect. All credit/debit cards details and personally identifiable information provided in order to confirm the legality of the payment will not be stored, sold, shared, rented or leased to any third parties.
4. Travel related preferences - including favorite destination and accommodation types, special dietary and accessibility needs, as available
Purposes for collection:
Sources of Personal Information:
Lawful basis:
5. Loyalty data – including loyalty program membership, loyalty points balance, points earnt and used, loyalty status
Purposes for collection:
Sources of Personal Information:
Lawful basis:
6. Geolocation data – including inferred location from IP address, country selected to use our website, and exact, real-time location (with your consent).
Purposes for collection:
Sources of Personal Information:
Lawful basis:
7. Images, videos and recordings – including facial photographs, images you upload, and videos.
Purposes for collection:
Sources of Personal Information:
Lawful basis:
8. Communications with us – including emails, chat transcripts and recordings of calls (when applicable) with customer service representatives
Purposes for collection:
Sources of Personal Information:
Lawful basis:
9. Site interaction data - including searches you conduct, transactions and other interactions with you on our platform, online services and apps
Purposes for collection:
Sources of Personal Information:
Lawful basis:
10. Device data – including device type, unique device identification numbers, operating system, mobile carrier, and how your device has interacted with our online services, including the pages accessed, links clicked, trips viewed, and features used, along with associated dates and times.
Purposes for collection:
Sources of Personal Information:
Lawful basis:
11. Friends and co-traveler data - including data you give us about other people, such as your travel companions or others for whom you are making a booking
Purposes for collection:
Sources of Personal Information:
Lawful basis:
12. Child data – including name and contact details of minor travelers provided by you as the parent/guardian of the minor as part of a trip reservation.
Purposes for collection:
Sources of Personal Information:
Lawful basis:
13. Clickstream data - In certain instances, we may use clickstream data to render an illustration of your usage of our site. Clickstream data is the collection of a sequence of events that represent visitor actions on a website. We may reconstruct your site journey modeled on the timing and location of your actions.
Purposes for collection:
Sources of Personal Information:
Lawful basis:
14. Birthdate and gender - including both your specific date of birth or an approximate age bracket you fall within, along with your gender.
Purposes for collection:
Sources of Personal Information:
Lawful basis:
15. Sensitive data – data that could reveal sensitive information, including your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, or health or disability information. We will only use your sensitive personal information for the purposes for which it was collected.
Purposes for collection:
Sources of Personal Information:
Lawful basis:
Sharing of Personal Information
We share your personal information as described below and in this Privacy Policy, and as permitted by applicable law.
Recipients of Personal Information:
1. Delfin App Services FZCO. We use your personal information as described in this Privacy Policy for the following purposes:
2. Third-party service providers. We share personal information with third-parties in connection with the delivery of services to you and the operation of our business. These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide services that are related to performance of our obligations to you. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party). The information is used for the following purposes:
• Platform Usage and Booking Purposes
• Communications and Customer Service Purposes
• Marketing Purposes (unless you have separately consented with the third-party under the terms provided by the third-party)
• Market Research, Analytics, and Training Purposes to improve our Services (unless you have separately consented with the third-party under the terms provided by the third-party)
• Security and Compliance purposes.
3. Travel suppliers. We share personal information with travel-related suppliers such as hotels, airlines, car-rental companies, insurance, vacation-rental property owners and managers, and where available, activity providers, rail, or cruise lines who fulfill your booking. Please note that travel suppliers may contact you to obtain additional personal information if and as required to facilitate your booking or to otherwise provide the travel or associated services. The information is used for the following purposes:
4. Business partners and offers. If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your personal information with that partner to assist in marketing or to provide the associated product or service. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. The information is used for the following purposes:
• Platform Usage and Booking Purposes
• Communications and Customer Service Purposes
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
5. Targeted Advertising partners. We may disclose your personal information to our third-party marketing partners for targeted advertising. View our Cookie Policy for more information on our use of tracking technology for the purposes of targeted advertising. The information is used for the following purposes:
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
6. Social media and online platforms: we share personal information with media agencies, social media, search engines and other online platforms to help us target our online marketing. These social media and other online platforms may also use personal information they hold and combine or match it against personal information received from us to create target audiences, which are audiences that we think would be interested in our online advertising. This may involve social media and other online platforms building a ‘lookalike’ profile of the type of person we are trying to target and providing specific adverts to those people when they browse the internet or use social media. The information is used for the following purposes:
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
7. Other Third-Parties. When you access certain features like a single sign-on that allows you to login with your social media credentials to our online services, you will share information with the third-party, like a social media company, such as the fact that you have visited or interacted with us. The third-party provider may combine this information with other information they have about you. The personal information shared will be governed by the third-party provider’s privacy policy (including any personal information we may access via the third-party provider). The third-party providers should inform you about how you can modify your privacy settings on their site. The information is used for the following purposes:
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
8. Recipients in relation to our legal rights and obligations. We may disclose your personal information and associated records to enforce our policies; as necessary to satisfy our tax or other regulatory reporting requirements, including the remission of certain taxes in the course of processing payments; or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a subpoena or other legal request, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests. The information is used for the Security and Compliance purposes.
9. Recipients in relations to corporate transactions. We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy. The information is used for the Security and Compliance purposes.
Your Rights and Choices
You have certain rights and choices with respect to your personal information, as described below:
Certain countries and regions provide their residents with additional rights relating to personal information. These additional rights vary by country and region and may include the ability to:
For questions about privacy, your rights and choices, and in order for you, or (where applicable) your authorized agent to make a request to amend or update your personal information, or to inquire about deletion of your information, please contact us by info@delfin.app.
In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so we can do our best to resolve your concern. You may submit your request to us using the information in the Contact Us section.
We respond to all requests we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws. Should you have the right to appeal a decision to not take action on a request under applicable law, instructions on how to make that appeal will be included in our response to you.
International Data Transfer
The personal information we process may be accessed from, processed or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country. Such cross-border transfer of your personal information is necessary for us to service your transaction with us, and for the purposes outlined in this Privacy Policy.
We have taken appropriate steps and put safeguards in place to help ensure that any access, processing and/or transfer of your personal information remains protected in accordance with this Privacy Policy and in compliance with applicable data protection law. Such measures provide your personal information with a standard of protection that is at least comparable to that under the equivalent local law in your country, no matter where your data is accessed from, processed and/or transferred to. We will comply with obligations regarding personal information cross-border transfer in accordance with application data protection laws, regulations, and conditions set by the competent authorities. This may include fulfilling obligations such as security assessments and/or certifications and signing agreements with overseas recipients in accordance with the standard contract established by the competent authorities.
We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.
Our cybersecurity team develops and deploys technical security controls and measures to ensure responsible personal information collection, storage, and sharing that is proportionate to the personal information’s level of confidentiality or sensitivity. We take efforts to continuously implement and update security measures to protect your personal information from unauthorized access, loss, destruction, or alteration. We hold our data-handling partners to equally high standards.
In the event of a personal data security incident that may affect your rights and interests, you will be notified in accordance with applicable data protection laws and regulations. We will also report the relevant incident to the competent regulatory authorities, if required by applicable laws and regulations.
Record Retention
We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Policy, unless a longer retention period is required or permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.
When we delete your personal information, we use industry standard methods to ensure that any recovery or retrieval of your information is impossible. We may keep residual copies of your personal information in backup systems to protect our systems from malicious loss. This personal information is inaccessible unless restored, and all unnecessary personal information will be deleted upon restoration.
The criteria we use to determine our retention periods include:
Updates to Privacy Policy
We may update this Policy in response to changing laws or technical or business developments. We will notify you of any amendments to the present Privacy Policy by posting the new version of the document on this webpage.
We will let you know via email and/or a prominent notice on the Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are also advised to review this Privacy Policy from time to time to be informed about any changes.
Contact Us
If you have any questions or concerns about our use of your personal information, or wish to inquire about our personal information handling practices, and exercise your rights to access, correct or inquire about deletion of personal information, please contact us via info@delfin.app.
Delfin App Services FZCO (Delfin) values you as our customer and recognizes that privacy is important to you. This Privacy Policy explains how we collect, use, and disclose personal information when you use our platform and associated services, your rights in determining what we do with the information that we collect or hold about you and tells you how to contact us.
Privacy Policy Summary
What does this Privacy Policy cover?
This Privacy Policy is designed to describe:
- How and what type of personal information we collect and use
- When and with whom we share your personal information
- What choices you can make about how we collect, use, and share your personal information
- How you can access and update your personal information.
What personal information do we collect and use, and how do we collect it?
We collect personal information when:
- You give us the personal information
- We collect it automatically
- We receive it from others (if expressly permitted)
When you create an account on our Website, sign up to receive offers or information, or make a booking using our platform, you give us your personal information. We also collect such personal information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our Website or download and use our apps. We also receive personal information from our business partners and other third-parties if expressly permitted, which help us improve our platform and associated tools and services, update and maintain accurate records, potentially detect and investigate fraud, and more effectively market our services.
How is your personal information shared?
Your personal information may be shared for several purposes, including: to help you book your travel and/or vacation, assist with your travel and/or vacation stay, communicate with you (including when we send information on products and services or enable you to communicate with travel providers and/or property owners), and comply with the applicable law. The full Privacy Policy below details how personal information is shared below.
What are your rights and choices?
You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, by deletion your account as applicable, or contacting our customer service. Our Privacy Policy has more information about the options and data protection rights and choices available to you.
How to contact us
More information about our privacy practices is in our full Privacy Policy. You can also contact us as described below in the “Contact Us” section to ask questions about how we handle your personal information or make requests about your personal information.
Privacy Policy
Collection and Use of Your Personal Information
You will find in this section information about:
- the types of personal information that we collect and use,
- how we collect and use it,
- the purposes for which we collect and use it, and
- the lawful basis we rely on to collect and use it.
Lawful bases for processing:
In the tables below, you will find the lawful basis we rely on to collect and use your personal information.
In summary, we will collect personal information from you only when one of the following lawful bases applies:
- Consent: this means that we will process your personal information where you have given your consent to do so (e.g., sending you marketing communications where consent is required).
- Legal obligation: this means that we will process your personal information where we have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.
- Performance of a contract: this means that we will process your personal information where the personal information is necessary to perform a contract with you (e.g., manage your booking, process payments, or create an account at your request),
- If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
- Legitimate interest: this means that we will process your personal information where the processing is in our legitimate interests and not overridden by your rights (as explained below),
- Certain countries and regions allow us to process personal information on the basis of legitimate interests. If we collect and use your personal information in reliance on our legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us, to respond to your queries, undertaking marketing, or for the purposes of potentially detecting or preventing illegal activities. While the concept of legitimate interest only exists in certain countries and regions, we balance our usage of your personal information against your rights globally.
Categories of Personal Information We Collect and Use
We collect personal information for the following purposes:
- Platform Usage and Booking Purposes – including to:
- Enable your booking, verify your identity, and for travel insurance purposes.
- Book the requested travel or enable vacation property booking.
- Provide services related to the booking and/or account.
- Create, maintain, and update user accounts on our platform and authenticate you as a user.
- Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of Delfin’s platform and services, and as otherwise described in this Privacy Policy.
- Enable and facilitate acceptance and processing of payments, coupons, and other transactions.
- Administer loyalty and rewards programs.
- Collect and enable booking-related reviews.
- Help you to use our services faster and easier
- Communications and Customer Service Purposes – including to:
- Respond to your questions, requests for information, and process information choices.
- Enable communication between you and the travel supplier like hotels and vacation property owners.
- Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) to provide information like travel booking confirmations and updates, emergency notifications, or for other purposes as described in this Privacy Policy.
- Marketing Purposes – including to:
- Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) for marketing purposes.
- Analyze information such as browsing and/or purchase history and use the result to optimize advertising and marketing in accordance with your interests and preferences.
- Measure and analyze the effectiveness of our marketing and promotions.
- Administer promotions like contests, sweepstakes, and similar giveaways.
- Deliver targeted advertising and advertising based on your profile. Our Cookie Policy further explains how we use cookies and similar tracking technology.
- Market Research, Analytics, and Training Purposes to improve our Services – including to:
- Conduct surveys, market research, and data analytics.
- Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services.
- Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as described in this Privacy Policy.
- Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permissible.
- Security and Compliance Purposes – including to:
- Promote security, verify identity of our customers, prevent and investigate fraud and unauthorized activities, defend against claims and other liabilities, and manage other risks.
- Comply with applicable laws, protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process.
- Comply with applicable security and anti-terrorism, anti-bribery, customs and immigration, and other such due diligence laws and requirements.
We collect the following categories of personal information for the following purposes:
1. Government issued identification data – including passport, driver’s license, government redress numbers, country of residence
Purposes for collection:
- Platform Usage and Booking Purposes
- Security and Compliance Purposes.
Sources of Personal Information:
- Directly from you
Lawful basis:
- Legal obligation
- Performance of a contract with you.
2. Identification data – including name, username, email address, telephone number, as well as home, business, and billing addresses (including street and postal code).
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legal obligation
- Performance of a contract with you (and any co-traveler)
- Legitimate interest (of you or a co-traveler)
- Consent (including consent of a parent/guardian for the use of child data)
3. Payment data
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legal obligation
- Performance of a contract with you (and any co-traveler)
- Consent
We are not processing your payments directly. All your payments are processed by licensed Payment Providers as defined in Terms and Conditions. To facilitate your payments, we have partnered with these licensed Payment Providers, which may transfer, process, and store your Payment Data outside the United Arab Emirates. We do not directly access your payment data. If you are using the services of our Payment Providers to pay online using Debit/Credit Card, you consent to this process and acknowledge that such data may be disclosed as required by applicable laws.
If you are using the services of our Payment Provider to pay online using Debit/Credit Card, then you are doing so with the consultation/approval of the card owner/account holder (if in case you are not the card holder/account holder yourself). If transaction is found suspicious by Payment Provider’s risk management team or by us, we are forced to identify the credit/debit card holder before we proceed with the payment in order to and to protect your payment from potential fraud. You may be asked to submit identification proof and front copy of your debit/credit card (when applicable) by email to complete your transaction. If you failed to produce the said documents on time, then your transaction/booking will be cancelled with immediate effect. All credit/debit cards details and personally identifiable information provided in order to confirm the legality of the payment will not be stored, sold, shared, rented or leased to any third parties.
4. Travel related preferences - including favorite destination and accommodation types, special dietary and accessibility needs, as available
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legitimate interest (of you or a co-traveler)
- Consent
5. Loyalty data – including loyalty program membership, loyalty points balance, points earnt and used, loyalty status
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legitimate interest (of you or a co-traveler)
- Performance of a contract with you
- Consent
6. Geolocation data – including inferred location from IP address, country selected to use our website, and exact, real-time location (with your consent).
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legal obligation
- Performance of a contract with you (and any co-traveler)
- Legitimate interest (of you or a co-traveler)
- Consent
7. Images, videos and recordings – including facial photographs, images you upload, and videos.
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Performance of a contract with you
- Consent
8. Communications with us – including emails, chat transcripts and recordings of calls (when applicable) with customer service representatives
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legal obligation
- Performance of a contract with you (and any co-traveler)
- Legitimate interest (of you or a co-traveler)
- Consent (including consent of a parent/guardian for the use of child data)
9. Site interaction data - including searches you conduct, transactions and other interactions with you on our platform, online services and apps
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legal obligation
- Legitimate interest
- Consent
10. Device data – including device type, unique device identification numbers, operating system, mobile carrier, and how your device has interacted with our online services, including the pages accessed, links clicked, trips viewed, and features used, along with associated dates and times.
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legal obligation
- Legitimate interest
- Consent.
11. Friends and co-traveler data - including data you give us about other people, such as your travel companions or others for whom you are making a booking
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Performance of a contract with you (and any co-traveler)
- Legitimate interest (of you or a co-traveler)
- Consent
12. Child data – including name and contact details of minor travelers provided by you as the parent/guardian of the minor as part of a trip reservation.
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Performance of a contract with you (and any co-traveler)
- Consent (including consent of a parent/guardian for the use of child
13. Clickstream data - In certain instances, we may use clickstream data to render an illustration of your usage of our site. Clickstream data is the collection of a sequence of events that represent visitor actions on a website. We may reconstruct your site journey modeled on the timing and location of your actions.
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Automatically from your device
- From third parties, such as our business and affiliate partners and authorized service providers (if expressly permitted)
Lawful basis:
- Legitimate interest
- Consent
14. Birthdate and gender - including both your specific date of birth or an approximate age bracket you fall within, along with your gender.
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
- From third parties, such as our business and affiliate partners and authorized service providers
Lawful basis:
- Legal obligation
- Performance of a contract with you (and any co-traveler)
- Legitimate interest (of you or a co-traveler)
- Consent
15. Sensitive data – data that could reveal sensitive information, including your racial or ethnic origin, religious or philosophical beliefs, sexual orientation, or health or disability information. We will only use your sensitive personal information for the purposes for which it was collected.
Purposes for collection:
- Platform Usage and Booking Purposes
- Communication and Customer Service Purposes
- Security and Compliance Purposes
Sources of Personal Information:
- Directly from you
Lawful basis:
- Legal obligations
- Consent.
Sharing of Personal Information
We share your personal information as described below and in this Privacy Policy, and as permitted by applicable law.
Recipients of Personal Information:
1. Delfin App Services FZCO. We use your personal information as described in this Privacy Policy for the following purposes:
- Platform Usage and Booking Purposes
- Communications and Customer Service Purposes
- Marketing Purposes
- Market Research, Analytics, and Training Purposes to improve our Services
- Security and Compliance purposes.
2. Third-party service providers. We share personal information with third-parties in connection with the delivery of services to you and the operation of our business. These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide services that are related to performance of our obligations to you. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party). The information is used for the following purposes:
• Platform Usage and Booking Purposes
• Communications and Customer Service Purposes
• Marketing Purposes (unless you have separately consented with the third-party under the terms provided by the third-party)
• Market Research, Analytics, and Training Purposes to improve our Services (unless you have separately consented with the third-party under the terms provided by the third-party)
• Security and Compliance purposes.
3. Travel suppliers. We share personal information with travel-related suppliers such as hotels, airlines, car-rental companies, insurance, vacation-rental property owners and managers, and where available, activity providers, rail, or cruise lines who fulfill your booking. Please note that travel suppliers may contact you to obtain additional personal information if and as required to facilitate your booking or to otherwise provide the travel or associated services. The information is used for the following purposes:
- Platform Usage and Booking Purposes
- Communications and Customer Service Purposes
- Market Research, Analytics, and Training Purposes to improve our Services.
4. Business partners and offers. If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your personal information with that partner to assist in marketing or to provide the associated product or service. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. The information is used for the following purposes:
• Platform Usage and Booking Purposes
• Communications and Customer Service Purposes
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
5. Targeted Advertising partners. We may disclose your personal information to our third-party marketing partners for targeted advertising. View our Cookie Policy for more information on our use of tracking technology for the purposes of targeted advertising. The information is used for the following purposes:
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
6. Social media and online platforms: we share personal information with media agencies, social media, search engines and other online platforms to help us target our online marketing. These social media and other online platforms may also use personal information they hold and combine or match it against personal information received from us to create target audiences, which are audiences that we think would be interested in our online advertising. This may involve social media and other online platforms building a ‘lookalike’ profile of the type of person we are trying to target and providing specific adverts to those people when they browse the internet or use social media. The information is used for the following purposes:
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
7. Other Third-Parties. When you access certain features like a single sign-on that allows you to login with your social media credentials to our online services, you will share information with the third-party, like a social media company, such as the fact that you have visited or interacted with us. The third-party provider may combine this information with other information they have about you. The personal information shared will be governed by the third-party provider’s privacy policy (including any personal information we may access via the third-party provider). The third-party providers should inform you about how you can modify your privacy settings on their site. The information is used for the following purposes:
• Marketing Purposes
• Market Research, Analytics, and Training Purposes to improve our Services.
8. Recipients in relation to our legal rights and obligations. We may disclose your personal information and associated records to enforce our policies; as necessary to satisfy our tax or other regulatory reporting requirements, including the remission of certain taxes in the course of processing payments; or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a subpoena or other legal request, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests. The information is used for the Security and Compliance purposes.
9. Recipients in relations to corporate transactions. We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy. The information is used for the Security and Compliance purposes.
Your Rights and Choices
You have certain rights and choices with respect to your personal information, as described below:
- If you have an account with us, you may change your communication preferences by either (1) logging in and updating the information in your account or (2) contacting us by info@delfin.app.
- You can control our use of certain cookies by following the guidance in our Cookie Policy.
- You can access, amend, inquire about deletion of, or update the accuracy of your personal information at any time by either logging into your account or contacting us by info@delfin.app.
- If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. You can also log into your account to change communication settings or contacting us by info@delfin.app. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe
- For our mobile apps, you can view and manage notifications and preferences in the settings menus of the app and of your operating system
- If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent
Certain countries and regions provide their residents with additional rights relating to personal information. These additional rights vary by country and region and may include the ability to:
- Request a copy of your personal information
- Request information about the purpose of the processing activities
- Delete your personal information
- Object to our use or disclosure of your personal information
- Restrict the processing of your personal information
- Opt-out of the sale of your personal information
- Port your personal information
- Request information about the logic involved in our automated decision-making, the result of such decisions,
- Object to the use of fully automated decision making, including profiling, with significant legal effect, and request a manual decision-making process instead,
- Contest a decision based solely on automated processing.
For questions about privacy, your rights and choices, and in order for you, or (where applicable) your authorized agent to make a request to amend or update your personal information, or to inquire about deletion of your information, please contact us by info@delfin.app.
In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so we can do our best to resolve your concern. You may submit your request to us using the information in the Contact Us section.
We respond to all requests we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws. Should you have the right to appeal a decision to not take action on a request under applicable law, instructions on how to make that appeal will be included in our response to you.
International Data Transfer
The personal information we process may be accessed from, processed or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country. Such cross-border transfer of your personal information is necessary for us to service your transaction with us, and for the purposes outlined in this Privacy Policy.
We have taken appropriate steps and put safeguards in place to help ensure that any access, processing and/or transfer of your personal information remains protected in accordance with this Privacy Policy and in compliance with applicable data protection law. Such measures provide your personal information with a standard of protection that is at least comparable to that under the equivalent local law in your country, no matter where your data is accessed from, processed and/or transferred to. We will comply with obligations regarding personal information cross-border transfer in accordance with application data protection laws, regulations, and conditions set by the competent authorities. This may include fulfilling obligations such as security assessments and/or certifications and signing agreements with overseas recipients in accordance with the standard contract established by the competent authorities.
We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.
Our cybersecurity team develops and deploys technical security controls and measures to ensure responsible personal information collection, storage, and sharing that is proportionate to the personal information’s level of confidentiality or sensitivity. We take efforts to continuously implement and update security measures to protect your personal information from unauthorized access, loss, destruction, or alteration. We hold our data-handling partners to equally high standards.
In the event of a personal data security incident that may affect your rights and interests, you will be notified in accordance with applicable data protection laws and regulations. We will also report the relevant incident to the competent regulatory authorities, if required by applicable laws and regulations.
Record Retention
We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Policy, unless a longer retention period is required or permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.
When we delete your personal information, we use industry standard methods to ensure that any recovery or retrieval of your information is impossible. We may keep residual copies of your personal information in backup systems to protect our systems from malicious loss. This personal information is inaccessible unless restored, and all unnecessary personal information will be deleted upon restoration.
The criteria we use to determine our retention periods include:
- The duration of our relationship with you, including any open accounts you may have with Delfin App Services, or recent bookings or other transactions you have made on our platform
- Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us
- Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations
- Whether your personal information is needed for secure backups of our systems
Updates to Privacy Policy
We may update this Policy in response to changing laws or technical or business developments. We will notify you of any amendments to the present Privacy Policy by posting the new version of the document on this webpage.
We will let you know via email and/or a prominent notice on the Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are also advised to review this Privacy Policy from time to time to be informed about any changes.
Contact Us
If you have any questions or concerns about our use of your personal information, or wish to inquire about our personal information handling practices, and exercise your rights to access, correct or inquire about deletion of personal information, please contact us via info@delfin.app.
341041, Dubai Silicon Oasis, IFZA Dubai Area, United Arab Emirates
© 2024 Delfin App Services FZCO. All Rights Reserved
