Privacy Policy of Rapsody Travel Agency Ltd.

Rapsody Travel respects your privacy.

You have the right to protection of personal data: name, address, phone number, email address, and other data such as IP address, geolocation data, etc.

In the General Privacy and Personal Data Protection Policy of Rapsody Travel („this policy“), the process of collecting your personal data and the purposes for which they are collected, the way your personal data are used, with whom your personal data are shared, how they are protected, and what your options are in terms of personal data protection are described.

This policy applies to the processing of your personal data within various services, tools, applications, websites, portals, (internet) promotions, marketing campaigns, sponsored social media platforms, etc., provided or managed by us or a third party on our behalf.

This policy contains general rules and explanations. For certain services, tools, applications, websites, portals, (internet) promotions, marketing campaigns, sponsored social media platforms, etc., offered by Rapsody Travel or managed by a third party on behalf of Rapsody Travel, this policy may be supplemented by specific, separate privacy notices. We will inform you about these specific privacy notices in an appropriate manner each time we collect your personal data in the activities mentioned above (for example, on websites, portals, individual communication services, newsletters, reminders, surveys, offers, events, etc.).

This policy applies to all your personal data collected by Rapsody Travel Ltd., Vojvode Šupljikca br.19 Belgrade, and/or Rapsody Travel’s authorized sellers, complaint handlers, etc., collectively referred to in this policy as „Rapsody Travel“, „we“, „us“, and „our“.

At the end of this policy, you can find some definitions of key terms used in this policy (such as personal data, processing, data controller, etc.).

Who is responsible for processing your personal data?

Organizations responsible for processing your personal data are:

„Rapsody Travel“ Ltd., Belgrade, Vojvode Šupljikca br.19;

Whom can you contact if you have questions or requests regarding personal data?

We have appointed a person and specified a special contact address for personal data protection, which handles your questions or requests regarding this policy or special privacy notices, your personal data, and their processing. For any questions, requests, or complaints regarding the implementation of this policy or the exercise of your rights under this policy, you can contact the data protection officer:

Email: sasa@rapsodytravel.com

Rapsody Travel Ltd., Vojvode Šupljikca br.19, 11000 Belgrade, with a note „Contact person for personal data protection“.

Basic principles:

We appreciate the trust you place in us by entrusting us with your personal data and commit to always processing them in a fair, transparent, and secure manner. The key principles that Rapsody Travel respects in the processing of personal data are as follows:

Legality: We will collect personal data in a fair, lawful, and transparent manner.

Minimal personal data scope (minimization): We will limit the collection of personal data to those that are appropriate and necessary for the purpose for which they are collected.

Purpose limitation: We will collect personal data only for specific, explicit, and legitimate purposes and will not process them in a manner incompatible with those purposes.

Accuracy: We will ensure the accuracy and timeliness of personal data.

Security and protection of personal data: We will implement technical and organizational measures to ensure appropriate levels of data protection, taking into account, among other things, the nature of your personal data to be protected. These measures include preventing any unauthorized disclosure or access, accidental or intentional destruction or loss, alteration, and other unlawful forms of processing.

Access and corrections: We will process your personal data respecting your rights to request access, correction, or deletion of personal data, the right to restrict processing, the right to object, the right to complain to the Commissioner, and the right to data portability, all in accordance with the Law.

Storage limitation: Your personal data will be kept in accordance with applicable legal regulations on personal data protection and only for as long as necessary to achieve the purpose for which they were collected, unless you request deletion or withdraw consent earlier. Providing personal data in this case is neither a legal nor a contractual obligation nor a necessary condition for concluding a contract.

Protection during international transfers: We will ensure that your personal data, if transferred to countries outside the European Economic Area, are transferred in accordance with legal regulations and adequately protected during the transfer.

Protection of personal data in mediation with third parties: We will ensure the transmission of personal data to third parties and processing by third parties in accordance with applicable legislation and with appropriate contractual measures for protection.

Legality of direct marketing and cookies: Sending promotional materials and setting cookies will be done in accordance with applicable legislation.

Processing of your personal data: what data do we collect and on what legal basis:

You will always be clearly informed about the personal data we collect. We will provide you with this information with a separate privacy notice included in certain services.

In accordance with applicable personal data protection regulations, we may process your personal data if:

you have given consent for specific processing purposes (as stated in the privacy notice related to a specific processing and purchase terms). You have the right to withdraw your consent at any time without stating reasons; or the processing of your personal data is necessary to fulfill the conditions of a contract of which you are a party; or we follow legitimate interests, e.g., Rapsody Travel may process certain personal data for the purpose of preventing abuse or fraud, or, in certain cases, to check your satisfaction with its services. We will inform you about legitimate interests in the privacy notice related to that specific processing; or it is necessary to fulfill our legal obligations, e.g., when making a purchase (e.g., payment), complaint. For what purposes do we process your personal data and profiling

We process personal data only for specific, explicitly confirmed, and legitimate purposes and will not process them in a manner inconsistent with those purposes.

Care for the accuracy and timeliness of your personal data

It is important to us that your data are always accurate and up-to-date. Inform us of any changes or errors in our records of your personal data by contacting us through the contact person for personal data protection. We will take reasonable measures to delete or correct all inaccurate or outdated personal data.

5.1 Access to your personal data

You have the right to access your personal data that we process, and if your personal data are incorrect or incomplete, you can request correction or deletion of personal data.

5.2 How long do we keep your personal data

We keep your personal data in accordance with applicable personal data protection regulations.

We keep your personal data only for as long as necessary to achieve the purpose for which we process your personal data, the period determined by law, or the period necessary to fulfill contractual conditions.

Personal data processed based on your personal consent will be kept permanently until you withdraw it, unless the purpose for which the personal data were collected has already been achieved.

Protection of Your Personal Data

We implement technical and organizational security measures to protect your personal data from illegal or unauthorized access or use, as well as from accidental loss or destruction. These measures are implemented considering our IT infrastructure, potential impact on your privacy, and the costs of implementation, in accordance with current standards and practices in the field of data protection.

We will only entrust the processing of your personal data to authorized persons (third parties) who adhere to the aforementioned technical and organizational measures for the protection of personal data.

Data protection means ensuring the confidentiality, integrity, and availability of your personal data.

(a) Confidentiality: We will protect your personal data from unauthorized disclosure to third parties.

(b) Integrity: We will protect your personal data from changes by unauthorized third parties.

Our security procedures include access control, backup systems, monitoring, audits and maintenance, incident management, and continuous operation, etc.

Forwarding of Personal Data

Regarding the purpose of collecting your personal data, we may forward, disclose, or grant access to categories of users listed below, who process this data in accordance with the stated purpose. We require them to always comply with applicable legal regulations, personal data protection rules, and to pay exceptional attention to the confidentiality of your personal data.

7.1 Social Media Usage

If you log in to Rapsody Travel tools (website, portal, etc.) from social media (for example, using your Facebook or Instagram account), Rapsody Travel will record your personal data available on those social media platforms, and your use of those platforms means that you explicitly consent to the forwarding of your personal data recorded by Rapsody Travel using its tools. These social media platforms have their own terms of use that you must comply with while using them.

Your Options and Rights

We want to be as transparent as possible, so we offer you the opportunity to choose how you want us to use your personal data.

8.1 Your Contact Preferences

You have various options for choosing how you want us to contact you or through which channel (for example, email, mail, social media, phone, etc.). You can select this by leaving your contact information on the appropriate form, adjusting privacy settings on the relevant device, or updating your user profile or account following the unsubscribe instructions provided in the notification. If you have provided multiple contact details without explicitly selecting a method or channel of contact, you will receive our promotional and other messages in the usual manner of publication, all within permissible legal frameworks.

8.2 Your Personal Data

You can always contact us through the data protection officer (see section „Whom can you contact if you have questions or requests?“) if you want to find out which of your personal data we process and the source of that data. Under certain conditions, you have the right to receive the personal data you provided to us in the most commonly used structured, machine-readable format, as well as the right to transmit that personal data to any third party of your choice.

8.3 Corrections

If you find an error in your personal data or believe that the data is incomplete or inaccurate, you can request correction or supplementation.

8.4 Restriction of Processing

You have the right to request the restriction of processing of your personal data.

8.5 Your Objections

You can object to the processing of your personal data for the purpose of direct marketing (if you wish, you can inform us through which channel and how often you want us to contact you) or for your personal data to be forwarded to third parties for that purpose. You can withdraw your consent in writing, or by sending a notice to us via email to the data protection officer or through other means published on www.rapsodytravel.rs. Refusing consent for the processing of personal data does not entail any negative consequences or sanctions and is entirely voluntary. However, there is a possibility that after withdrawing consent for the processing of personal data, Rapsody Travel may not be able to provide the user with individual or more of its services that cannot be provided without the use of personal data. You also have the right to lodge a complaint with the Commissioner in accordance with the law.

8.6 Deletion

Additionally, you can request that we delete all your personal data (except in certain cases, e.g., for the purpose of proving a transaction or if required for compliance with legal regulations).

Cookie Usage

When you browse the pages at www.rapsodytravel.rs, we do not collect your personal information, such as name, address, phone number, or email address. However, our software uses so-called cookies to collect information about how its websites are used.

On a group basis, information is collected and tracked about the server your computer is connected to, the type of internet browser you use (e.g., Chrome or Internet Explorer), and whether you have participated in a survey. This information is used to limit voting once from the same IP address, or for statistical data about internet browsers.

Legal Information:

The provisions of these rules supplement and do not override the legislative provisions in the field of personal data protection. In case of inconsistency between the provisions of these rules and legislative provisions in the field of personal data protection, the legislative provisions shall prevail.

Rapsody Travel may change these rules at any time. You can check these rules on our website to learn more about the changes.