upenta Privacy
Privacy Statement
First things first – your privacy is important to us. That might be the kind of thing all these notices say, but we mean it. You place your trust in us by using Upenta.com services and we value that trust. That means we’re committed to protecting and safeguarding your personal data. We act in our customers’ best interest and we are transparent about the processing of your personal data.
This document (‘this Privacy Statement’ or ‘our Privacy Statement’) describes how we use and process your personal data, provided in a readable and transparent manner. It also tells you what rights you can exercise in relation to your personal data and how you can contact us. Please also read our Cookie Statement, which tells you how Upenta.com uses cookies and other similar tracking technologies.
If you’ve used us before, you know that Upenta.com offers online travel-related services through our own websites and mobile apps, as well as other online platforms such as partners’ websites and social media. We’d like to point out that all the information you are about to read, generally applies to not one, not two, but all of these platforms.
In fact, this single privacy statement applies to any kind of customer information we collect through all of the above platforms or by any other means connected to these platforms (such as when you contact our customer service team by email).
If you are one of our business partners, make sure to also check out our Privacy Statement for Business Partners to understand how personal data is further processed as part of the business relationship.
We might amend this Privacy Statement from time to time, so we recommend you visit this page occasionally to make sure you know where you stand. If we make any updates to this Privacy Statement that will impact you significantly, we’ll notify you about the changes before any new activities begin.
Terms we use in this Privacy Statement
'Trip' means the various different travel products and services that can be ordered, acquired, purchased, bought, paid, rented, provided, reserved, combined, or consummated by you from the Trip Provider.
'Trip Provider' means the provider of accommodation (e.g. hotel, motel, apartment, bed & breakfast, landlord), attractions (e.g. (theme) parks, museums, sightseeing tours), transportation provider (e.g. car rentals, cruises, rail, airport rides, coach tours, transfers), tour operators, travel insurances and any other travel or related product or service as from time to time available for Trip Reservation on the platform.
'Trip Service' means the online purchase, order, (facilitated) payment or reservation service as offered or enabled by Upenta.com in respect of various products and services as from time to time made available by Trip Providers on the platform.
'Trip Reservation' means the order, purchase, payment, booking, or reservation of a Trip.
What kind of personal data does Upenta.com collect?
We can’t help you book the perfect Trip without information, so when you use our services there are certain things we ask for. This is typically routine information – your name, preferred contact details, the names of the people travelling with you and your payment information. You might also decide to submit additional information related to your upcoming Trip (for example, your anticipated arrival time).
In addition to this, we also collect information from the computer, phone, tablet or other device you use to access our services. This includes the IP address, the browser you’re using and your language settings. There are also situations in which we receive information about you from others or when we automatically collect other information.
This is the general overview but if you’d like to know more about the information we collect, we go into more detail below.
Read more about the personal data we collect
Why does Upenta.com collect and use your personal data?
The main reason we ask you for personal details is to help you organise your online Trip Reservations and ensure you get the best service possible.
We also use your personal data to contact you about the latest deals, special offers and other products or services we think you might be interested in. There are other uses, too. If you’d like to find out what they are, read on for a more detailed explanation.
Read more about why Upenta.com collects your data
How does Upenta.com share your data with third parties?
There are different parties integrated into Upenta.com’s services, in various ways and for various reasons. The primary reason we share your data is to supply the Trip Provider with the relevant information to complete your Trip Reservation.
We also involve other parties to provide you with Upenta.com services. This includes, for example, financial institutions, advertisers, subsidiaries of the Upenta.com corporate group, and the other companies that form the Upenta Holdings Inc. corporate group. Or, in some cases, if we’re required to by law, we might share your data with governmental or other authorities
Below, we go into more detail about how the information you share with us is used and exchanged with these parties.
Read more about how data is shared with third parties
How is your personal data shared within the Upenta Holdings Inc. corporate group?
Upenta.com is part of the Upenta Holdings Inc. corporate group. Read on to find out more about how your data may be shared within the Upenta Holdings Inc. corporate group.
How is your personal data shared and further processed for ground transport services?
Upenta.com and Tripfloric.com – also part of the Upenta Holdings Inc. group of companies – jointly use your data to offer you ground transport services via the Upenta.com websites. Read more to understand the scope and limited nature of our joint responsibility.
Read more about data and our ground transport services
How is your personal data shared and further processed for insurance services?
We work with different parties when offering insurance services. Follow the link below to understand how your data is used and shared for insurance purposes and learn about the responsibilities of the parties involved.
Read more about data and insurance products and services
How does Upenta.com process communications that you and your Trip Provider may send via Upenta.com?
Upenta.com can help you and Trip Providers exchange information or requests about services and existing Trip Reservations, through the Upenta.com platform. If you want to find out more about how Upenta.com receives and handles these communications, read on here.
Read more about how these communications are processed
How does Upenta.com make use of mobile devices?
We offer free apps, through which we also collect and process personal data. This works in much the same way as our website, but they also allow you to benefit from the location services available on your mobile device(s).
Read more about how we use data from mobile devices
How does Upenta.com make use of social media?
The use of social media may be integrated into Upenta.com services in various ways. These will involve us collecting some of your personal data or the social media provider receiving some of your information. If you’d like to learn more about how this information is used and exchanged, read on.
Read more about how we use social media data
What security and retention procedures does Upenta.com put in place to safeguard your personal data?
We have implemented a range of procedures to prevent unauthorised access to, and the misuse of, personal data that we process.
Read more about security and retention procedures
How does Upenta.com treat personal data belonging to children?
Unless indicated otherwise, Upenta.com is a service you are only allowed to use if you are over 16 years of age. We only process information about children with the consent of their parents or legal guardians, or when the information is shared with us by the parents or legal guardians themselves.
Read more about the personal data of under 16s
How can you control the personal data you’ve given to Upenta.com?
Among others, you have the right to review the personal data we keep about you at any time and request access to or deletion of your personal data by submitting this form. If you want to find out more about your rights to control your personal data, read on.
Read more about how you can control your personal data
Who is responsible for the processing of personal data on the Upenta.com website and apps?
Upenta.com B.V., located in Amsterdam, The Netherlands, controls the processing of personal data for the provision of its services. That includes its websites and mobile apps, except for some exceptions that are clarified in this privacy statement.
Read more about Upenta.com B.V.'s responsibility for personal data
Country-specific provisions
Depending on the law that applies to you, we may be required to provide some additional information. If applicable, you will find additional information for your country or region below.
Read more about country-specific provisions
What kind of personal data does Upenta.com collect?
OK, so you’re looking for some more in-depth information. Here’s a closer look at what we collect.
Personal data you give to us.
Upenta.com collects and uses information you provide to us. When you make a Trip Reservation, you are (at a minimum) asked for your name and email address.
Depending on the Trip Reservation, we may also ask for your home address, telephone number, payment information, date of birth, current location (in the case of on-demand services), the names of the people travelling with you and any preferences you might have for your Trip (such as dietary or accessibility requirements). In some cases you may also be able to check-in online with the Trip Provider, for which we will ask you to share passport information or a driving licence and signatures.
If you need to get in touch with our customer service team, contact your Trip Provider through us, or reach out to us in a different way (such as social media or via a chatbot) we’ll collect information from you there, too. This applies whether you are contacting us with feedback or asking for help using our services.
You might also be invited to write reviews to help inform others about the experiences you had on your Trip. When you write a review on the Upenta.com platform, we’ll collect any information you’ve included, along with your display name and avatar (if you choose one).
There are other instances where you’ll provide us with information, as well. For example, if you’re browsing with your mobile device, you can decide to allow Upenta.com to see your current location or grant us access to some contact details. This helps us to give you the best possible service and experience by, for example, showing you our city guides, suggesting the nearest restaurants or attractions to your location or making other recommendations.
If you create a user account, we’ll also store your personal settings, uploaded photos, and reviews of previous bookings there. This saved data can be used to help you plan and manage future Trip Reservations or benefit from other features only available to account holders (such as incentives or other benefits).
You can also choose to add details from your identification documents to your user accounts, so that you don’t have to submit this information for each individual Trip Reservation.
We may offer you referral programs or sweepstakes, and participating in these will mean providing us with relevant personal data.
Personal data you give us about others.
If you have a Upenta.com for Business account, you can keep an address book there to make it easier to plan and manage business travel arrangements for others.
In some cases, you might use Upenta.com to share information with others. This can take the form of sharing a wishlist, taking part in a travel community or participating in a referral programme, as described when you use the relevant feature.
At this point, we have to make it clear that it’s your responsibility to ensure that the person or people you have provided personal data about are aware that you’ve done so, and that they have understood and accepted how Upenta.com uses their information (as described in this Privacy Statement).
Personal data we collect automatically.
Whether or not you end up making a Trip Reservation, when you visit our websites or apps we automatically collect certain information. This includes your IP address, the date and time you accessed our services, and information about your computer’s hardware and software (such as the operating system, the internet browser used, software/application version data and your language settings). We also collect information about clicks and which pages have been shown to you.
If you’re using a mobile device, we collect data that identifies the device, as well as data about your device-specific settings and characteristics, app crashes and other system activity. When you make a Trip Reservation using this kind of device, our system registers how you made your reservation (on which website), and/or which site you came from when you entered the Upenta.com website or app.
Personal data we receive from other sources.
It’s not just the things you tell us, though – we may also receive information about you from other sources. These include business partners, such as affiliate partners, subsidiaries of the Upenta.com corporate group, other companies in the Upenta Holdings Inc. corporate group and other independent third parties.
Anything we receive from these partners may be combined with information provided by you. For example, Upenta.com Trip Reservation services are not only made available via Upenta.com and the Upenta.com apps, but are also integrated into services of affiliate partners you can find online. When you use any of these services, you provide the reservation details to our business partners who then forward your details to us.
We also integrate with third party service providers to facilitate payments between you and Trip Providers. These service providers share payment information so we can administer and handle your Trip Reservation, making sure everything goes as smoothly as possible for you.
Additionally, we collect information in the regrettable case that we receive a complaint about you from a Trip Provider, for example in the case of misconduct.
Another way we might receive data about you, is through the communication services integrated into our platforms. These communication services offer you a way to contact theTrip Provider you’ve booked with to discuss your stay. In some cases, we receive metadata about these communication activities (such as who you are, where you called from, and the date and length of the call).
We may also receive information about you in order to show you more relevant ads, such as the additional cookie data Upenta.com social media partners make available to us. Please read the section Why does Upenta.com collect and use your personal data? for more information.
When you link your Upenta.com user account to your social media account, you might trigger exchanges of data between Upenta.com and that social media provider. You can always choose not to share that data.
Trip Providers may share information about you with Upenta.com, too. This could happen if you have support questions about a pending Trip Reservation, or if disputes or other issues arise about a Trip Reservation.
Why does Upenta.com collect and use your personal data?
We use the information collected about you for a variety of purposes. Your personal data may be used in the following ways:
A. Trip Reservations: First and foremost, we use your personal data to complete and administer your online Trip Reservation – which is essential for us to provide this service for you. This includes sending you communications that relate to your Trip Reservation, such as confirmations (including, where applicable, providing you with a proof of purchase and/or payment), modifications and reminders. In some cases, this may also include processing your personal data to enable online check-in with the Trip Provider or processing personal data in relation to possible damage deposits.
B. Customer service: We provide international customer service from our local offices in more than 20 languages, and we’re here to help 24 hours a day, 7 days a week. Sharing relevant details, such as reservation information or information about your user account with our global customer service staff allows us to respond when you need us. This includes helping you to contact the right Trip Provider and responding to any questions you might have about your Trip Reservation (or any other queries, for that matter).
C. Account facilities: Upenta.com users can create an account on our website or apps. We use the information you give us to administer this account, allowing you to do a number of useful things. You can manage your Trip Reservations, take advantage of special offers, make future Trip Reservations easily and manage your personal settings.
Managing personal settings gives you the ability to keep and share lists, share photos, easily see Trip Services you’ve searched for and check travel-related information you’ve provided. You can also see any reviews you’ve written.
If you want to, you can share certain information as part of your user account, by creating a public profile under your own first name or a screen name you choose.
If you’re a Upenta.com for Business account holder, you can also save contact details under that account, manage business reservations and link other account holders to the same Upenta.com for Business account.
D. Online groups: We give account holders the chance to connect and interact with each other through online groups or forums, such as travel communities.
E. Marketing activities: We use your information for marketing activities. These activities include:
1. Using your contact information to send you regular news about travel-related products and services. You can unsubscribe from email marketing communications quickly, easily and at any time. All you need to do is click on the ‘Unsubscribe’ link included in each newsletter or other communication, or manage your preferences via your account settings.
2. Based on your information, individualised offers might be shown to you on the Upenta.com website, in mobile apps or on third-party websites/apps (including social media sites) and the content of the site displayed to you might be personalised. These could be offers that you can book directly on the Upenta.com website, on co-branded sites, or other third-party offers or products we think you might find interesting.
3. When you participate in other promotional activities (such as sweepstakes, referral programmes or competitions), only relevant information will be used to administer these promotions.
F. Communicating with you: There might be other times when we get in touch, including by email, by chatbot, by post, by phone or by texting you. Which method we choose depends on the contact information you’ve previously shared.
We process the communications you send to us. There could be a number of reasons for this, including:
1. Responding to and handling any requests you or your booked Trip Provider have made. Upenta.com also offers customers and Trip Providers various ways to exchange information, requests and comments about Trip Providers and existing Trip Reservations via Upenta.com. For more information, read the section titled ‘How does Upenta.com process communications that you and your Trip Provider send through Upenta.com?’.
2. If you have started but not finished a Trip Reservation online, we might contact you to invite you to continue with your reservation. We believe that this additional service benefits you as it allows you to pick up the process where you left off without having to search for a Trip Provider or fill in your reservation details again.
3. When you use our services, we might send you a questionnaire or invite you to provide a review about your experience with Upenta.com or the Trip Provider.
4. We also send you other material related to your Trip Reservations, such as how to contact Upenta.com if you need assistance while you’re away, and information that we feel might be useful to you in planning or getting the best out of your Trip. We might also send you material related to upcoming Trip Reservations or a summary of previous Trip Reservations you made through Upenta.com.
5. Even if you don’t have an upcoming Trip Reservation, we may still need to send you other administrative messages, which could include security alerts.
6. In case of misconduct, we may send you a notice and/or warning.
G. Market research: We sometimes invite our customers to take part in market research. Please see the information that accompanies this kind of invitation to understand what personal data will be collected and how that data is used.
H. Improving our services: We also use personal data for analytical purposes and product improvement. This is part of our commitment to making our services better and enhancing the user experience.
In this case, we use data for testing and troubleshooting purposes, as well as to generate statistics about our business. The main goal here is to get insights into how our services perform, how they are used, and ultimately to optimise and customise our website and apps, making them easier and more meaningful to use. As much as possible, we strive to use anonymised and de-identified personal data for this analytical work.
I. Providing the best price applicable to you, depending on where you are based: When you search our apps or website, for example to find an accommodation, a rental car or a flight, we process your IP address to confirm whether you are in the European Economic Area (EEA) or in another country. We do this to offer you the best price for the region (EEA) or country (non-EEA) where you are based.
J. Customer reviews and other destination-related information: During and after your Trip, we might invite you to submit a review. We can also make it possible for the people you’re travelling with or whom you’ve booked a reservation for to do this instead. This invite asks for information about the Trip Provider or the destination.
If you have a Upenta.com account, you can choose to display a screen name next to your review, instead of your real name. If you’d like to set a screen name, you can do that in your account settings. Adding an avatar is also possible.
By completing a review, you’re agreeing that it can be displayed (as described in detail in our Terms and Conditions) on, for example, the relevant Trip Provider information page on our websites, on our mobile apps, on our social media accounts and social media apps, or on the online platform of the relevant Trip Provider or business partner’s website. This is to inform other travellers about the quality of the Trip Service you used, the destination you have chosen or any other experiences you choose to share.
K. Call monitoring: When you make calls to our customer service team, Upenta.com uses an automated telephone number detection system to match your telephone number to your existing reservations. This can help save time for both you and our customer service staff. However, our customer service staff may still ask for authentication, which helps to keep your reservation details confidential.
During calls with our customer service team, live listening might be carried out or calls might be recorded for quality control and training purposes. This includes the usage of the recordings for the handling of complaints, legal claims and for fraud detection.
We do not record all calls. In the case that a call is recorded, each recording is kept for a limited amount of time before being automatically deleted. This is unless we have determined that it’s necessary to keep the recording for fraud investigation or legal purposes. You can read more about this below.
L. Promotion of a safe and trustworthy service: To create a trustworthy environment for you, the people you bring with you on your Trip, Upenta.com’s business partners and our Trip Providers, we continuously analyse and use certain personal data to detect and prevent fraud and other illegal or unwanted activities.
Similarly, we use personal data for risk assessment and security purposes, including when you report a safety concern, or for the authentication of users and reservations. When we do this we may have to stop or put certain Trip Reservations on hold until we’ve finished our assessment.
M. Legal purposes: Finally, in certain cases, we may need to use your information to handle and resolve legal claims and disputes, for regulatory investigations and compliance, to enforce the Upenta.com online reservation service terms of use or to comply with lawful requests from law enforcement.
Providing your personal data to Upenta.com is voluntary. However, we may only be able to provide you with certain services if we can collect some personal data. For instance, we can’t process your Trip Reservation if we don’t collect your name and contact details.
If we use automation to process personal data which produces legal effects or similarly significantly affects you, we’ll always implement the necessary measures to safeguard your rights and freedoms. This includes the right to obtain human intervention.
To process your personal data as described above, we rely on the following legal bases:
As applicable, for purpose A and B, Upenta.com relies on the legal basis that the processing of personal data is necessary for the performance of a contract, specifically to finalise and administer your Trip Reservation.
If the required personal data is not provided, Upenta.com cannot finalise the Trip Reservation, nor can we provide customer service. In view of purposes C to L, Upenta.com relies on its (or third parties’) legitimate interest, to provide and improve services and to prevent fraud and other illegal acts (as set out more specifically under C to L).
When using personal data to serve Upenta.com’s or a third party's legitimate interest, Upenta.com will always balance your rights and interests in the protection of your personal data against Upenta.com’s rights and interests or those of the third party. For purposes M, Upenta.com also relies, where applicable, on compliance with legal obligations (such as lawful law enforcement requests).
Finally, where needed under applicable law, Upenta.com will obtain your consent prior to processing your personal data, including for email marketing purposes or as otherwise required by law.
If you wish to object to the processing set out under C to L and no opt-out mechanism is available to you directly (for example, in your account settings), please contact us at [email protected].
ow does Upenta.com share your data with third parties?
In certain circumstances, we’ll share your personal data with third parties. These third parties include:
1. The Trip Provider you booked: In order to complete your Trip Reservation, we transfer relevant reservation details to the Trip Provider you have booked. This is one of the most essential things we do for you.
Depending on the Trip Reservation and the Trip Provider, the details we share can include your name, contact and payment details, the names of the people accompanying you and any other information or preferences you specified when you made your Trip Reservation.
In certain cases, we also provide some additional historical information about you to the Trip Provider. This includes whether you’ve already booked with them in the past, the number of completed bookings you’ve made with Upenta.com, a confirmation that no misconduct has been reported about you, the percentage of bookings you’ve cancelled in the past or whether you’ve given reviews about past bookings.
If you have a query about your Trip, we may contact the Trip Provider to handle your request. Unless payment is made during the booking process, via the Upenta.com website, we will forward your credit card details to the booked Trip Provider for further handling (assuming you’ve provided us with those details).
In cases of Trip Reservation-related claims or disputes, we may provide the Trip Provider with your contact details and other information about the booking process, as needed to resolve the situation. This can include, but might not be limited to, your email address and a copy of your reservation confirmation as proof that a Trip Reservation was made or to confirm reasons for cancellation.
For completeness, Trip Providers will further process your personal data outside of the control of Upenta.com. Trip Providers may also ask for additional personal data, for instance to provide additional services, or to comply with local restrictions. If available, please read the Privacy Statement of the Trip Provider to understand how they process your personal data.
2. Connectivity Providers: Please note that certain Trip Providers may need us to share your personal data with a contracted Connectivity Provider in order to be able to finalise and administer your reservation. Connectivity providers act on behalf of Trip Providers and help them to manage their reservations.
3. Your local Upenta.com office: To support the use of Upenta.com services, your details may be shared with subsidiaries of the Upenta.com corporate group, including for customer service. To find out more about the Upenta.com corporate group, visit About Upenta.com.
4. Third-party service providers: We use service providers from outside of the Upenta.com corporate group to support us in providing our services. These include:
o Customer support
o Market research
o Fraud detection and prevention (including anti-fraud screening)
o Insurance claims
o Payment
We use third parties to process payments, handle chargebacks or provide billing collection services. When a chargeback is requested for your Trip Reservation, either by you or by the holder of the credit card used to make your reservation, we need to share certain reservation details with the payment service provider and the relevant financial institution so they can handle the chargeback. This may also include a copy of your reservation confirmation or the IP address used to make your reservation. We may share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.
When a chargeback is requested for your Trip Reservation, either by you or by the holder of the credit card used to make your reservation, we need to share certain reservation details with the payment service provider and the relevant financial institution so they can handle the chargeback. This may also include a copy of your reservation confirmation or the IP address used to make your reservation.
We may also share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.
o Marketing services
We share personal data with advertising partners, including your email address, IP address and telephone number, as part of marketing Upenta.com services via third parties (to ensure that relevant advertisements are shown to the right audience). We use techniques such as hashing to enable the matching of your email address, IP address and/or telephone number with an existing customer database, to prevent this data from being used for other purposes. For information on other personalised advertisements and your choices, please read our Cookie Statement.
o Advertising partners
We use advertising partners, such as metasearch providers, to allow you to compare our offers with offers from other Online Travel Agencies (OTAs). When you make a reservation on Upenta.com after using an advertising partner, we will send the details of the reservation that you made on Upenta.com to that partner.
5. Other professional third parties: In certain cases (such as disputes or legal claims or as part of auditing activities), we may need to share your personal data with professional advisors. These advisors include parties such as law firms or auditors. We only share your personal data to the extent that is necessary and such third parties process this data in line with their own professional obligations.
6. Competent authorities: We disclose personal data to law enforcement to the extent that it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud, or if we are otherwise legally obligated to do so. We may need to further disclose personal data to competent authorities to comply with a legal obligation (for instance, under short term rental laws), to protect and defend our rights or properties, or the rights and properties of our business partners.
7. Business partners: We work with many business partners around the world. These business partners distribute and advertise Upenta.com services, including the services and products of our Trip Providers.
When you make a reservation on one of our business partners’ websites or apps, certain personal data that you give them, such as your name and email address, your address, payment details and other relevant information, will be forwarded to us to finalise and manage your Trip Reservation.
If customer service is provided by the business partner, Upenta.com will share relevant reservation details with them (as and when needed) in order to provide you with appropriate and efficient support.
When you make a reservation through one of our business partners’ websites, the business partners can receive certain parts of your personal data related to the specific reservation and your interactions on these partner websites. This is for their commercial purposes.
When you make a reservation on a business partners’ website, please also take the time to read their privacy notice if you’d like to understand how they process your personal data.
For fraud detection and prevention purposes, we may also exchange information about our users with business partners – but only when strictly necessary.
If an insurance claim is made, concerning you and a Trip Provider, we may provide the necessary data (including personal data) to the insurance company for further processing.
o Partner Offer: We may present you with a ‘Partner Offer’. When you book a stay marked ‘Partner Offer’, your reservation will be facilitated by a Trip Provider who is separate from the accommodation you’re booking. As part of the reservation process, we’ll need to share some relevant personal data with this business partner.
If you book a Partner Offer, please review the information provided in the booking process or check your reservation confirmation for more information about the Trip Provider and how they will further process your personal data.
8. The Upenta Holdings Inc. corporate group: Read about how we share your personal data with the Upenta Holdings Inc. corporate group.
Upenta.com is a global business. The data that we collect from you, as described in this Privacy Statement, could be made accessible from, transferred to or stored in countries which may not have the same data protection laws as the country in which you initially provided the information. In such cases, we will protect your data as described in this Privacy Statement.
This may also be applicable if you are in the European Economic Area (EEA). Countries your data may be transferred to may not have laws that provide the same level of protection for your personal data as laws within the EEA. Where this is the case, we will put appropriate safeguards in place to make sure that these transfers comply with European privacy law.
In particular, when your data is transferred to third-party service providers, we establish and implement appropriate contractual, organisational and technical measures with them. This is done by putting in place Standard Contractual Clauses as approved by the European Commission, by examining the countries to which the data may be transferred, and by imposing specific technical and organisational security measures.
In certain specific cases, we transfer your data outside the EEA because it is in your interest or is necessary to conclude or perform the contract we have with you. For instance, when you make a reservation on Upenta.com or through a business partner, we might need to transfer your data to a Trip Provider or business partner who is located outside the EEA.
How is your personal data shared within the Upenta Holdings Inc. corporate group?
Upenta.com is part of the Upenta Holdings Inc. corporate group. More information is available at Upentaholdings.com.
We may receive personal data about you from other companies in the Upenta Holdings Inc. corporate group, or share your personal data with them, for the following purposes:
A. To provide services (including to make, administer and manage reservations or handle payments)
B. To provide customer service
C. To detect, prevent and investigate fraudulent, other illegal activities and data breaches
D. For analytical and product improvement purposes
E. To provide personalised offers or send you marketing with your consent or as otherwise permitted by applicable law
F. For hosting, technical support, overall maintenance and maintaining security of such shared data
G. To ensure compliance with applicable laws
As applicable and unless indicated otherwise, for purposes A to F, Upenta.com relies on its legitimate interests to share and receive personal data. For purpose G, Upenta.com relies, where applicable, on compliance with legal obligations (such as lawful law enforcement requests).
For example, Upenta.com works closely with Rentalcars.com to offer ground transport services to customers. Please read How is your personal data shared and further processed for ground transport services? for more information.
All companies within the Upenta Holdings Inc. group of companies may need to exchange personal customer data to ensure all users are protected from fraudulent activities on its online platforms.
How is your personal data shared and further processed for ground transport services?
Upenta.com Transport Limited, trading as Rentalcars.com, is a private limited liability company, incorporated under the laws of the United Kingdom with offices at 6 Goods Yard Street, Manchester, M3 3BG, United Kingdom.
Upenta.com and Tripfloric.com (both part of the Upenta Holdings Inc. group of companies) work together closely to offer you ground transport services via tripfloric.com websites.
The ground transportation services offered by Upenta.com websites and apps are operated by Rentalcars.com, under the Upenta.com brand. This means that when you're booking or browsing for ground transport services via the app or website, Upenta.com and Rentalcars.com are collectively responsible for the collection and use of your personal data.
In addition to the data we process to allow you to search for ground transport services and make your booking, Upenta.com and Rentalcars.com can also use your personal data independently. This is in line with the purposes set out in this Privacy Statement and the Rentalcars.com Privacy Notice.
For further information about the relationship between Upenta.com and Tripfloric.com, and to exercise your rights regarding your personal data that is collected via the Upenta.com websites and apps, please feel free to contact Upenta.com at any time. You can do this via the email address under 'Who is responsible for the processing of personal data via Upenta.com and how to contact us?'.
How is your personal data shared and further processed for insurance services?
Upenta.com Distribution B.V. is a sister company of Upenta.com with registered offices at 597 Herengracht, 1017 CE Amsterdam, The Netherlands. Upenta.com and Upenta.com Distribution B.V. work closely together to offer customers different insurance products and services for Trip Reservations, for example room cancellation insurance.
The offering of insurance can involve multiple parties, such as intermediaries, underwriters, and other agents. Where Upenta.com Distribution B.V. is involved, it will act as the intermediary and authorised agent or appointed representative (depending on the jurisdiction) on behalf of the insurer, by offering insurance products and services to Upenta.com customers.
Please review the information provided during the booking process for more information about Upenta.com Distribution B.V and the parties who work together with Upenta.com to offer you these products and services. The details of the insurer will be visible in the insurance policy and related documentation provided to you.
When offering insurance, Upenta.com and Upenta.com Distribution B.V. may have to use and share personal data that is relevant to the insurance product. This data relates to you as a potential or actual policyholder, the beneficiaries under a policy, family members, claimants and other parties involved in a claim:
• To provide offers, arrange insurance cover and handle insurance claims, some personal data, provided to us during the booking process, (‘General Order Data’) may have to be shared with Upenta.com Distribution B.V.. You may also be asked to provide additional information, such as names of family members or other beneficiaries or details about a claim (‘Insurance-Specific Data’).
• If you make a claim under an insurance policy, this claim may be directly handled by the insurer. This means that you may be asked to provide personal data in order to submit the claim directly to them. The insurer will inform you accordingly at the point of collection of your information. When your claim is handled by the insurer, Upenta.com may receive information about the status of your claim in order to provide you with customer support services.
When Upenta.com Distribution B.V. acts as an intermediary for insurance products and services via Upenta.com, the two companies are jointly responsible for the collection of Insurance-Specific Data and its transmission from Upenta.com to Upenta.com Distribution B.V. However, Upenta.com Distribution B.V. acts as the sole controller for any processing outside of the Upenta.com B.V. systems. Any personal data collected by Upenta.com for insurance purposes will be processed as set out in this Privacy Statement.
For further information about the relationship between Upenta.com and Upenta.com Distribution B.V., and to exercise your rights regarding personal data that is collected via the Upenta.com website and apps, please contact us.
How does Upenta.com process communications that you and your booked Trip Provider may send via Upenta.com?
Upenta.com can offer you and Trip Providers various ways to communicate about the Trip Services and existing Trip Reservations, directing the communications via Upenta.com. This also allows you and your Trip Provider to contact Upenta.com with questions about your Trip Reservation through the website, our apps and the other channels that we make available.
Upenta.com accesses communications and may use automated systems to review, scan, and analyse communications for the following reasons:
• Security purposes
• Fraud prevention
• Compliance with legal and regulatory requirements
• Investigations of potential misconduct
• Product development and improvement
• Research
• Customer engagement (including to provide you with information and offers that we believe may be of interest to you)
• Customer or technical support
We reserve the right to review or block the delivery of communications that we, in our sole discretion, believe might contain malicious content or spam, or pose a risk to you, Trip Providers, Upenta.com or others.
All communications sent or received using Upenta.com communication tools will be received and stored by Upenta.com. Trip Providers and Business partners you’ve booked a Trip Reservation through might also choose to communicate with you directly by email or through other channels that Upenta.com does not control.
How does Upenta.com make use of mobile devices?
We offer free apps for a range of different mobile devices, as well as versions of our regular website that have been optimised for browsing on a mobile and tablet.
These apps and mobile websites process the personal details you give us in much the same way as our website does. They also allow you to use location services to find Trip Services nearby, if you want to.
With your consent, we may send you push notifications with information about your Trip Reservation. You can also choose to grant us access to your location data or contact details in order to provide services you’ve requested. If you upload pictures to our platform, these pictures may include location information (known as metadata) as well. Please read your mobile device’s instructions to understand how to change your settings and control the sharing of this category of data.
When you choose to use our ‘Voice Assistant’ to search our services or manage your bookings, your speech will be anonymously translated into text by a third-party service provider. You will need to give us access to your device's microphone to use this feature.
In order to optimise our services and marketing activities, and to make sure we give you a consistent user experience, we use something known as ‘cross-device tracking’. This can be done with or without the use of cookies. For more general information about cookies and other similar technologies, please see our Cookie statement.
With cross-device tracking, Upenta.com is able to track user activity across multiple devices. As part of cross-device tracking, we may combine data collected from a particular browser or mobile device with data from another computer or device used by the same customer.
In order to optimise the content of the Upenta.com newsletter, we combine searches and reservations made from different computers and devices. You can unsubscribe from the Upenta.com newsletter at any time.
Personalised ads shown to you on other websites or in apps, can be offered based on your activities on linked computers and devices. By changing the cookie settings on your device (see our Cookie statement under ‘What are your choices?’), you can change your cross-device tracking settings for advertisement purposes. You should know that logging out of your Upenta.com account doesn’t mean that you will no longer receive personalised ads.
How does Upenta.com make use of social media?
At Upenta.com, we use social media in different ways. We use it to facilitate the use of online reservation services, but also to promote our Trip Providers’ travel-related products and services and to advertise, improve and facilitate our own services.
Note that the use of social media features can result in the exchange of personal data between Upenta.com and the social media service provider, as we describe below. You are free not to use any of the social media features available to you.
1. Sign in with your social media account. We offer you the opportunity to sign in to a Upenta.com user account with one of your social media accounts. We do this to reduce the need for you to remember different usernames and passwords for different online services.
After you’ve signed in once, you’ll be able to use your social media account to sign into your Upenta.com account. You can decouple your Upenta.com user account from your chosen social media account any time you want to.
2. Integration of social media plugins. We have also integrated social media plugins into the Upenta.com website and apps. This means that when you click or tap on one of the buttons (such as Facebook’s ‘Like’ button), certain information is shared with these social media providers.
If you’re logged into your social media account when you click or tap one of these buttons, your social media provider may relate this information to your social media account. Depending on your settings, they might also display these actions on your social media profile, to be seen by others in your network.
3. Other social media services and features. We may integrate other social media services (like social media messaging) for you to interact with Upenta.com or with your contacts about our services.
We may maintain social media accounts and offer apps on several social media sites. Whenever you connect with Upenta.com through social media, your social media service provider may allow you to share information with us.
If you choose to share, your social media provider will generally inform you about which information will be shared. For example, when you sign into a Upenta.com user account using your social media account, certain information from that account may be shared with Upenta.com. This includes your email address, your age and the profile pictures you’ve saved – depending on what you authorise in your social media account.
When you register with a Upenta.com social media app or connect to a social media messaging service without a Upenta.com user account, the information you choose to share with us may include the basic information available in your social media profile (including your email address, status updates and a list of your contacts).
We’ll use this information to help provide you with the service you requested – for example, to forward a message you want to send to your contacts, or to create a personalised user experience in the app or on our websites. It means that if you want us to, we can tailor our services to suit your needs, connecting you and your friends with the best travel destinations and analysing and improving our travel-related services.
Your social media provider will be able to tell you more about how they use and process your data when you connect to Upenta.com through them. This can include combining the personal data they collect when you use Upenta.com through them with information they collect when you use other online platforms you have also linked to your social media account.
If you decide to connect using your Facebook or Google account, please review the following links for information about how these parties use data they receive: Facebook and Google.
What security and retention procedures does Upenta.com put in place to safeguard your personal data?
We have procedures in place to prevent unauthorised access to, and the misuse of, personal data.
We use appropriate business systems and procedures to protect and safeguard your personal data. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorised personnel are permitted to access personal data in the course of their work.
We’ll keep your personal data for as long as is necessary to enable you to use our services or to provide our services to you (including maintaining any Upenta.com user accounts you may have), to comply with applicable laws, resolve any disputes and otherwise to allow us to conduct our business, including to detect and prevent fraud and/or other illegal activities. All personal data we keep about you as a Upenta.com customer is covered by this Privacy Statement.
For added protection, we strongly recommend that you set up two-factor authentication for your Upenta.com user account. This adds an extra authentication step, to make sure that anyone who gets hold of your username and password (e.g. through phishing or social engineering) won’t be able to get into your account. You can set this up in the Security section of your account settings.
How does Upenta.com treat personal data belonging to children?
Our services aren’t intended for children under 16 years old, and we’ll never collect their data unless it’s provided by (and with the consent of) a parent or guardian. The limited circumstances we might need to collect the personal data of children under 16 years old include: as part of a reservation, the purchase of other travel-related services, or in other exceptional circumstances (such as features addressed to families). Again, this will only be used and collected as provided by a parent or guardian and with their consent.
If we become aware that we’ve processed the information of a child under 16 years old without the valid consent of a parent or guardian, we will delete it.
How can you control the personal data you’ve given to Upenta.com?
We want you to be in control of how your personal data is used by us. You can do this in the following ways:
1. We want you to be in control of how your personal data is used by us. You can do this in the following ways:
2. You can ask us for a copy of the personal data we hold about you,
3. You can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you. As explained below, you can make some of these changes yourself, online, when you have a user account,
4. In certain situations, you can ask us to erase, block, or restrict the processing of the personal data we hold about you, or object to particular ways in which we are using your personal data,
5. In certain situations, you can also ask us to send the personal data you have given us to a third party,
6. Where we are using your personal data on the basis of your consent, you are entitled to withdraw that consent at any time subject to applicable law, and
7. Where we process your personal data based on legitimate interest or the public interest, you have the right to object to that use of your personal data at any time, subject to applicable law.
We rely on you to make sure that your personal information is complete, accurate and current. Please do let us know about any changes to, or inaccuracies in, your personal information as soon as possible.
If you have a Upenta.com user account, you can access a lot of your personal data through our website or apps. You’ll generally find the option to add, update or remove information we have about you in your account settings.
Users with a Upenta.com account can also request that we delete your account through the Upenta.com app. Note that app features can vary between operating systems and their third-party software providers.
If any of the personal data we have about you isn’t accessible through our website or apps, you can send us a request.
If you want to exercise your right of access or erasure, all you need to do is complete and submit the Data Subject Request for Upenta.com Customers form. For any requests relating to this Privacy Statement, to exercise any of your other rights, or if you have a complaint, please contact our Data Protection Officer at [email protected]. You can also contact your local data protection authority.
If you’d like to object to your personal data being processed on the basis of legitimate interest and there’s no way to opt out directly, please contact us at [email protected].
If you’d like to contact us by post, please address it to the Data Protection Officer and use the following postal address: Herengracht 597, 1017 CE, Amsterdam, the Netherlands.
Who is responsible for the processing of personal data via Upenta.com and how to contact us?
Upenta.com B.V. controls the processing of personal data, as described in this Privacy Statement, except where explicitly stated otherwise. Upenta.com B.V. is a private limited liability company, incorporated under the laws of the Netherlands and has its offices at Herengracht 597, 1017 CE Amsterdam, the Netherlands.
If you have any questions about this Privacy Statement, or about our processing of your personal data, please contact our Data Protection Officer at dataprotectionoffice@ Upenta.com and we’ll get back to you as soon as possible.
For questions about a reservation, please contact our customer service team through the customer service contact page.
Requests from law enforcement should be submitted using the Law Enforcement process.
Country-specific provisions
Depending on the law that applies to you, we may be required to provide some additional information. If applicable, you will find additional information for your country or region below.
Turkey
Customers from Turkey may also use the contact details set out below for requests related to this privacy statement:
The local representative for Upenta.com B.V. in Turkey is Ozdagistanli Ekici Avukatlık Ortaklığı, located at Al Zambak Sok No: 2 Varyap Meridian Grand Tower A Blok K: 32 D: 270 Ataşehir-İstanbul.
Cookie statement
Whenever you use our online services or apps, we use cookies and other online tracking technologies (which we’ll also refer to as 'cookies' for the purpose of this Cookie Statement).
Cookies can be used in various ways, including to make the Upenta.com website work, to analyse traffic, or for advertising purposes.
Read on below to learn more about what a ‘cookie’ is, how they’re used and what your choices are.
What are cookies and other online tracking technologies?
How are cookies used?
What are your choices?
What are cookies and online tracking technologies?
A web browser cookie is a small text file that websites place on your computer’s or mobile device’s web browser.
These cookies store information about the content you view and interact with, in order to remember your preferences and settings or analyse how you use online services.
Cookies are divided into ‘first party’ and ‘third party’:
• First party cookies are the cookies served by the owner of the domain – in our case that’s Upenta.com. Any cookie we place ourselves is a ‘first party cookie’.
• Third party cookies are cookies placed on our domains by trusted partners that we’ve chosen to allow to do so. These can be social media partners, advertising partners, security providers and more.
And they can be either ‘session cookies’ or ‘permanent cookies’:
• Session cookies only exist until you close your browser, ending what is called your ‘session’. They are then deleted.
• Permanent cookies have a range of different lifespans and stay on your device after the browser is closed. On the Upenta.com platform, we try to only serve permanent cookies (or allow permanent cookies to be served by third parties) that have a limited lifespan. However, for security reasons, or in other exceptional circumstances, we might sometimes need to give a cookie a longer lifespan.
Web browser cookies may store information such as your IP address or another identifier, your browser type, and information about the content you view and interact with on digital services. By storing this information, web browser cookies can remember your preferences and settings for online services and analyse how you use them.
Alongside cookies, we also use tracking technologies that are very similar. Our website, emails and mobile apps may contain small transparent image files or lines of code that record how you interact with them. These include ‘web beacons’, ‘scripts’, ‘tracking URLs’ or ‘software development kits’ (known as SDKs):
• Web beacons have a lot of different names. They might also be known as web bugs, tracking bugs, tags, web tags, page tags, tracking pixels, pixel tags, 1x1 GIFs or clear GIFs.
In short, these beacons are a tiny graphic image of just one pixel that can be delivered to your device as part of a web page request, in an app, an advertisement or an HTML email message.
They can be used to retrieve information from your device, such as your device type or operating system, your IP address, and the time of your visit. They are also used to serve and read cookies in your browser or to trigger the placement of a cookie.
• Scripts are small computer programs embedded within our web pages that give those pages a wide variety of extra functionality. Scripts make it possible for the website to function properly. For example, scripts power certain security features and enable basic interactive features on our website.
Scripts can also be used for analytical or advertising purposes. For example, a script can collect information about how you use our website, such as which pages you visit or what you search for.
• Tracking URLs are links with a unique identifier in them. These are used to track which website brought you to the Upenta.com website or app you’re using. An example would be if you click through from a social media page, search engine or one of our affiliate partners’ websites.
• Software Development Kits (SDKs) are part of our apps’ source code and unlike browser cookies, SDK data is stored in the app storage.
They’re used to analyse how the apps are being used or to send personalised push notifications. To do this, they record unique identifiers associated with your device, like device ID and IP address, as well as your in-app activity and your network location.
All these tracking technologies are referred to as ‘cookies’ here in this Cookie Statement.
How are cookies used?
Cookies are used to collect information, including:
• IP address
• Device ID
• Viewed pages
• Browser type
• Browsing information
• Operating system
• Internet service provider
• Timestamp
• Whether you have responded to an advertisement
• A referring URL
• Features used or activities engaged in on the website/apps
They allow you to be recognised as the same user across the pages of a website, across devices, between websites or when you use our apps. When it comes to purpose, they are divided into three categories – functional cookies, analytical cookies and marketing cookies.
Functional cookies
These are cookies required for our websites and apps to function and they must be enabled in order for you to use our services.
Functional cookies are used to create technologically advanced, user-friendly websites and apps that adapt automatically to your needs and preferences, so you can browse and book easily. This also includes enabling essential security and accessibility features.
More specifically, these cookies:
• Enable our website and apps to work properly, so you can create an account, sign in, and manage your bookings.
• Remember your selected currency and language settings, your past searches and other preferences to help you use our website and apps efficiently and effectively.
• Remember your registration information, so that you don’t have to retype your login credentials each time you visit our website or app. (Don’t worry, passwords will always be encrypted.)
Analytical cookies
These cookies measure and track how our website and apps are used. We use this information to improve our website, apps and services.
More specifically, these cookies:
• Help us understand how visitors and customers like you use Upenta.com and our apps.
• Help improve our website, apps, and communications to make sure we're interesting and relevant.
• Allow us to find out what works and what doesn't on our website and apps.
• Help us understand the effectiveness of advertisements and communications.
• Teach us how users interact with our website or apps after they have been shown an online advertisement, including advertisements on third-party websites.
• Enable our business partners to learn whether or not their customers make use of any accommodation offers integrated into their websites.
The data we gather through these cookies can include which web pages you have viewed, which referring/exit pages you have entered and left from, which platform type you have used, which emails you have opened and acted upon, and date and time stamp information. It also means we can use details about how you’ve interacted with the site or app, such as the number of clicks you make on a given screen, your mouse movements and scrolling activity, the search
