GDPR

PRINCIPLES OF PERSONAL DATA PROCESSING

1 GENERAL PROVISIONS

The protection of personal data is our priority. We have developed these Principles of Personal Data Processing to inform you, as our customers, about how Mintur s.r.o. (hereinafter referred to as “we” or “the Company”) collects, stores, protects, and processes your personal data in connection with providing travel services. The processing of your personal data is necessary to properly fulfill our contractual obligations, protect our legitimate interests, and comply with our legal obligations.

Through these Principles of Personal Data Processing, we aim to provide you with information on how we process your personal data (Sections 3 to 6 below) and on your rights and how to exercise them (Section 7 below). Personal data refers to any information relating to an identified or identifiable individual, particularly our customers and other individuals whose personal data we may process in connection with providing our travel services.

We recommend that you carefully read these Principles of Personal Data Processing. If you have any questions, you can contact us at any time using the contact information provided below.

2 DATA CONTROLLER AND CONTACT DETAILS

The controller of your personal data is the travel agency Mintur s.r.o., registered at Dolné Orešany 652, 919 02 Dolné Orešany, Slovakia. Registered in the Commercial Register of the District Court Trnava, entry number: 53922/T, Company ID: 54 231 108.

  • Email address: mintur@mintur.sk

3 TRAVEL PACKAGES AND BUSINESS TRIPS

3.1 Purposes of Processing
To provide you with our services, we need to collect and process some of your personal data. We process your personal data primarily to fulfill our contractual obligations toward you, deliver the services you have purchased from us, and negotiate and conclude contracts for the selected services. The processing of data for specific purposes within the provision of services and the fulfillment of our related obligations is described in more detail below:

  • Accommodation Arrangements
    As part of organizing travel packages, corporate tours, or business trips, we ensure accommodation at your destination. For this purpose, we will process your identification and contact data, as well as data about your preferences (e.g., dietary requirements or other special requests). These data will be shared with accommodation providers such as hotels, guesthouses, or hostels.
  • Transport Arrangements
    When organizing travel packages or business trips for our customers, we also arrange transportation. In this context, we need your basic identification data and may collect information about your preferences (e.g., dietary requirements or special requests) to share with transportation providers.
  • Complaints
    If a customer believes that the services provided by our Company are defective, they are entitled to file a complaint in accordance with applicable civil law regulations. Handling complaints is part of the contractual fulfillment between the Company and you, as well as our legal obligation.

Sending Reminders

If an invoice for services provided by us is not paid on time, we may send you reminders until the invoice is settled.

Establishment, Exercise, and Defense of Legal Claims

After the termination of the contractual relationship, we may retain some of your personal data for the duration of the applicable statutory limitation periods. This processing is necessary to protect our rights and to defend or pursue legal claims, including the recovery of unpaid debts.

Accounting and Tax Documents

Some personal data may appear on accounting documents (such as invoices). Under applicable legal regulations (e.g., the Accounting Act or the Value Added Tax Act), we are required to retain these documents for up to 10 years. If we are legally obligated to archive these documents, we will store your personal data contained in the relevant tax documents along with them.

Related Processing for Travel Arrangements (e.g., Flights, Insurance, Car Rentals)

In cases where travel packages or business trips include the arrangement of flights, insurance, or car rentals, details regarding the associated data processing are outlined below.

Legal Basis for Processing

The legal basis for processing personal data for the purposes described above is the performance of a contract or compliance with legal obligations, as well as our legitimate interests. Legitimate interest is the basis for processing, especially in cases where the customer is a legal entity, and we process the personal data of its contact persons, or in cases involving family members of customers, guests of customers, or other individuals listed in the travel contract who are not direct parties to the contract with our Company.

Scope of Processed Data

For the above purposes, we process the personal data of travelers provided as part of the contractual agreement or during the use of our services. This includes, in particular, the following data of travelers or their legal representatives:

  • Identification data (name, surname, date of birth, gender, nationality, residential address);
  • Contact data (email address, phone number);
  • Data from identification documents (passport number, ID card number);
  • Travel permit data (e.g., visas, if relevant to the trip);
  • Preference data (especially dietary preferences or other specific requirements or restrictions).

Sources of Personal Data

We process personal data provided by the customer in connection with negotiating, concluding, and fulfilling a contract or other legal relationship. Some personal data may also be reasonably verified from publicly accessible registers, lists, and records (e.g., the commercial register, trade register, insolvency register, etc.).

Retention Period

Unless a longer retention period is required by law, we will retain your personal data for the duration of the contract and for the limitation periods thereafter, based on our legitimate interest in establishing, protecting, and exercising our legal claims and demonstrating compliance with our legal and other obligations (e.g., in the event of a tax audit or inspection by the trade authority).

In cases where legal disputes or other proceedings or investigations conducted by public authorities continue beyond the limitation periods, personal data may be retained until the conclusion of such proceedings.

 

4 ADDITIONAL SERVICES AND OTHER OPERATIONS

We also provide the following tourism-related services, during which personal data is processed for the purposes, durations, and legal bases outlined below:

COMMISSIONED SALES OF TOURS

When facilitating the sale of a tour organized by another travel agency, the controller of your personal data is the travel agency or company organizing the tour, identified in the tour contract as the tour provider. For any issues related to data protection in this case, you must contact the respective travel agency or company.

INCOMING SERVICES

We also provide so-called “incoming” services, which consist of delivering or arranging tourism services (such as interpreting, guiding, transportation, accommodation, etc.) for groups or individuals visiting Slovakia or other Central European countries where we provide incoming services.

  • Purpose of processing: The purpose of processing your personal data is the proper provision of the ordered incoming services. For services provided by third parties, we may share necessary personal data required for reservations or orders with the respective third parties providing those services.
  • Legal basis for processing: Processing your personal data is necessary for fulfilling our contractual obligations related to the delivery of these services.

PROVISION OF ACCOMMODATION SERVICES

We may also process your personal data to the necessary extent when providing accommodation services.

  • Purpose of processing: Your personal data is processed for the purpose of providing the accommodation services you have purchased and for fulfilling legal obligations arising from the Act on Local Taxes. If the accommodated persons are of foreign nationality, the processing also fulfills obligations under the Act on the Residence of Foreigners in Slovakia. As part of this, personal data of accommodated persons may, to the extent defined by law, be shared with the foreigner police or the local municipal office responsible for collecting local taxes.
  • Legal basis for processing: The legal basis for processing is the performance of the contract entered into with you. Additionally, processing is necessary to comply with obligations under the Act on the Residence of Foreigners in Slovakia and the Act on Local Taxes, which are applicable to us.
  • Scope of processed data: For the purposes listed above, we process personal data of accommodated persons provided during the provision of our services. This primarily includes the following data:
    • Identification data (name, surname, date of birth, gender, nationality, residential address);
    • Contact data (email address, phone number);
    • Data from identification documents (passport number, ID card number).

 

  • Visa number: For foreign nationals requiring a visa.
  • Last four digits of your payment card number.
  • Preferences: Especially related to dietary needs, special requirements, or restrictions.
  • Purpose and duration of stay.

Retention Period

  • Contractual and legal obligations: Your personal data will be stored for the duration of the contract and afterward for a period aligned with statutory limitation periods, based on our legitimate interest in defining, protecting, and exercising our legal claims.
  • Records under Slovak law: Data in the house register and evidence book must be retained for 6 years after the last entry, in compliance with the Act on the Residence of Foreigners and the Act on Local Taxes.

MEDIATION OF ACCOMMODATION SERVICES

We also process your personal data when mediating accommodation services in hotels or other facilities offered by our partners.

Purpose of Processing

  • To arrange the accommodation services you have ordered. Certain personal data may be shared with the accommodation provider to the extent necessary for reservations or bookings.

Legal Basis for Processing

  • Performance of contract: When fulfilling the contract you entered with us.
  • Legitimate interest: When processing data of other individuals being accommodated as part of the booking.

Scope of Processed Data
If you use our mediation services for accommodation, the following personal data may be processed:

  • Identification data: Name, surname, date of birth, gender, nationality, residential address.
  • Contact data: Email address, phone number.
  • Flight details.
  • Travel document number.
  • Visa number: For foreign nationals requiring a visa.
  • Last four digits of your payment card number.
  • Preferences: Dietary needs, special requirements, or restrictions.

Processing period.

Unless legal regulations require a longer processing period, we will store your personal data for the duration of the contract and for the duration of the limitation periods based on our legitimate interest in determining, protecting and exercising our legal claims and to prove compliance with our legal and other obligations, e.g. in the event of the initiation of tax proceedings or an inspection by the trade licensing office.

 

TICKET RESERVATION

The services we offer also include the ticket reservation service. If you use this service, we will transfer your personal data via the operator of the reservation system of the airline that is the operator of the flight you have selected. The airline will be an independent administrator of your personal data. In the event of a ticket complaint, we may share the data with the company handling the airline’s complaints.

Purpose of processing. We process your personal data for the purpose of booking a ticket with the airline.

Scope of processed data. If you use our flight booking service, we may process the following personal data of passengers in particular:

  • identification data (name, surname, date of birth, nationality);
  • contact data (email address, telephone number, address of residence in a foreign country);
  • data from identification documents (passport number or ID card number);
  • data on preferences (especially regarding food or other special requirements or restrictions);
  • data for flight cancellation insurance (similar to the case of insurance brokerage, see below)
  • and the last 4 digits of your payment card number.

Processing period. We will store the data we obtain from you when booking flights for a period of 5 years, unless legal regulations or our legitimate interests require a longer period.

Legal basis for processing. The legal basis for processing personal data within the framework of flight booking is the fulfillment of a contract or legal obligation, or our legitimate interest. Legitimate interest is the legal basis for processing, especially in cases where the customer is a legal entity and we process the personal data of its contact persons or in cases where the customer’s family members, guests of customers or other passengers for whom a third party makes a reservation are involved.

INSURANCE ARRANGEMENT

In connection with the sale of tours, arranging business trips and providing other services, we may offer the arrangement of travel or other insurance (e.g. cancellation of flight tickets) as an additional service. If we act on the basis of your authorization and select the most advantageous insurance for you, we act as an insurance broker. If we act on the basis of one or more insurance companies and offer their insurance products, we act as an insurance agent. We transfer your personal data to the insurance company, which is their independent administrator.

Purpose of processing. The purpose of data processing is to arrange travel or other insurance.

Legal basis for processing. The legal basis for such processing is the performance of the brokerage contract we conclude with you or a legitimate interest.

Scope of data processed. If you use our insurance brokerage service, we will process in particular the following personal data of yours:

  • identification data (name, surname, date of birth, place of residence);
  • contact data (e-mail address, telephone number);
  • data on insured activities;
  • data on your flight (in the case of flight cancellation insurance).

Processing period. Unless legal regulations require a longer processing period, we will retain the data obtained in connection with insurance brokerage for the duration of the contract and for the duration of the limitation periods on the basis of our legitimate interest in determining, protecting and exercising our legal claims and to prove compliance with our statutory obligations arising in particular from the Act on Insurance Brokers and Claims Adjusters. If any proceedings are initiated in connection with insurance brokerage, we will process your data until the complete conclusion of such proceedings.

CAR RENTAL AGENCY

Our services include car rental agency. If you use this service, we will transfer your personal data to the car rental company of your choice in the relevant country. In this case, the car rental company will be a separate controller of your personal data

Purpose of processing. The purpose of data processing is to provide you with a vehicle at your destination.

Scope of data processed. If you use our online car rental service, we will process in particular the following personal data:

  • identification data (name, surname, age);
  • contact details (e-mail address, telephone number);
  • details about your flight;
  • the last 4 digits of your credit card number.

Processing time. Unless a longer retention period is required by law, we will retain your personal data for the duration of the contract and for the duration of the limitation periods based on our legitimate interest in determining, protecting and exercising our legal claims and to prove compliance with our legal and other obligations, e.g. in the event of the initiation of tax proceedings.

CUSTOMER SUPPORT

We may also process your data for the purpose of handling your requests or inquiries sent via the contact form at http://www.mintur.com/kontakt. If your request or inquiry concerns the services we provide to you, such processing will be part of the performance of the contract. If your request or inquiry concerns other matters, we will process your data for the purpose of handling your request. Calls on the customer service line are not recorded, the relevant staff handling the request may take notes on the processing of the request or communicate your personal data to persons whose cooperation is necessary to handle the request (e.g. accommodation provider, airline, insurance company, etc.).

Purpose of processing. The purpose of this processing is to properly handle your request or inquiry.

Scope of data processed. As part of customer support, we process in particular the following data:

  • identification data (name, surname);
  • contact data (e-mail address, telephone number);
  • any other data contained in your message.

Retention period. We will store the data provided for the period necessary to handle your request or inquiry. We will then delete your data unless there is a special reason for their further processing.

SHARING AND TRANSFER OF PERSONAL DATA (PERSONAL DATA RECIPIENTS)

Recipients of personal data

Personal data that we process in the ways described above may be shared with third parties that provide certain services related to the provision of our services in the field of tourism, in particular cooperation in organizing tours, including transport and administrative support, provision of software tools, etc. These persons are in the position of processors or administrators of personal data. We may share your personal data in particular:

  • with operators of hotels, guesthouses and other accommodation facilities;
  • with airlines and other carriers;
  • with car rental companies and other means of transport;
  • with insurance companies;
  • with other travel agencies in the event that we act as a commission agent for a travel package;
  • with providers of delegation services;
  • some of your personal data may exceptionally be accessed by external auditors, tax advisors, legal representatives, if this is necessary for the recovery or accounting of receivables or to protect our legitimate interests;
  • if public authorities contact us in the exercise of their powers with a request to provide information that may include your personal data, we will be obliged to disclose your personal data to the necessary extent based on obligations arising from law or another legal act.

DATA SECURITY

We have implemented and maintain the necessary appropriate technical and organizational measures, internal controls and information security processes in accordance with best business practice corresponding to the potential risk to you as a data subject. At the same time, we take into account the state of technological development in order to protect your personal data against accidental loss, destruction, alteration, unauthorized disclosure or access. These measures may include, among others, measures to ensure physical security, taking reasonable steps to ensure the accountability of employees who have access to your data, regular backups, data recovery and incident management procedures, software protection of devices on which personal data is stored and other measures.

YOUR RIGHTS AS A DATA SUBJECT

In accordance with applicable legal regulations, you have the right to request information about the processing of your personal data and the right to correct the data that we process about you as a personal data controller. In certain cases, you have the right to request the deletion of your personal data, and you also have the right to access your personal data or to transfer it (e.g. transfer to another service provider). In certain cases, you have the right to object and also the right to request the restriction of the processing of your personal data. If you have previously provided us with consent to the processing of personal data, you can withdraw it at any time. The individual rights and the method of exercising them are described in more detail below.

How to exercise your rights

If you exercise any of your rights under this article or under applicable law, we will inform each recipient to whom the data has been disclosed pursuant to Chapter 6 of this Privacy Policy of the action taken or the erasure of personal data or the restriction of processing, in accordance with your request, if such communication is possible and/or does not involve disproportionate effort. If you wish to exercise your rights and/or obtain the relevant information, you can do so through our Data Protection Coordinator, whose details can be found in Chapter 2 of this Privacy Policy. If you exercise your rights, we may ask you to provide some additional personal data that you have previously provided to us. The provision of such data is necessary to verify whether the relevant request was actually sent by you. We will respond to you within one month of receiving your request, however, we reserve the right to extend this period by two months in complex cases.

Correction of your personal data

Under applicable law, you have the right to correct your personal data that you share with us. If you wish to correct your personal data, please contact us via our Data Protection Coordinator, whose details can be found in Chapter 2 of this Privacy Policy. We take reasonable steps to ensure that you can keep your personal data accurate and up-to-date. You can always contact us to ask whether we are still processing your personal data.

 

Erasure of your personal data

You can ask us to erase your personal data at any time by contacting our Data Protection Officer, whose details can be found in Chapter 2 of this Privacy Policy.

If you contact us with such a request, we will erase all your personal data that we hold about you without undue delay if we no longer need your personal data for the performance of our contractual or legal obligations or to protect our legitimate interests as described above. We will also erase (and ensure that our processors delete) all your personal data if you withdraw your consent to the processing of your data, if you have previously given us your consent.

Withdrawal of consent

You can withdraw your consent to the processing of your personal data that you have previously given us at any time without giving any reason. Please do so using the contact details set out in Article 2 of this Privacy Policy. If you wish to withdraw the consent you have given us, please contact us via our Data Protection Officer. In such a case, we will erase your personal data without undue delay. Please note that the withdrawal of your consent does not affect the lawfulness of any processing carried out on the basis of previously given consent before its withdrawal by you.

Access to and portability of your personal data

You have the right to request information about whether we process personal data about you and to what extent. You also have the right to request that we provide you with the personal data you have provided to us and other personal data concerning you. If you wish to confirm the extent of the data we process about you or to obtain a copy of it, please contact us via our Data Protection Coordinator, whose details can be found in Chapter 2 of this Privacy Policy. If you request the transfer of your personal data that we process on the basis of the performance of a contract and/or your consent, you may ask us to transfer them directly to a third party (another data controller) that you specify in your request, provided that such a request will not adversely affect the rights and freedoms of other persons and is technically feasible.

Right to object

If we process your personal data on the basis of our legitimate interest (e.g. if we process your data as a contact person for our customer), you have the right to object to such processing at any time on grounds relating to your particular situation. Unless we demonstrate compelling legitimate grounds for the processing that override your interests or rights and freedoms or unless we demonstrate that the data are necessary for the establishment, exercise or defence of legal claims, we will no longer process the data and will erase it without undue delay. If you object to the processing of your personal data for direct marketing purposes, we will immediately cease processing your data for this purpose.

You can object to the processing through our Data Protection Coordinator.

Restriction of processing

If you ask us to restrict the processing of your personal data, e.g. if you dispute the accuracy, lawfulness or our need to process your personal data, we will limit the processing of your personal data to the minimum necessary (storage) and, where applicable, process it only for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for other limited reasons prescribed by applicable law. If the restriction is lifted and we continue to process your personal data, we will inform you without undue delay. You can request restriction of processing through our Data Protection Coordinator.

Complaint to the Office for Personal Data Protection

You have the right to file a complaint regarding our processing of your personal data with the Office for Personal Data Protection, office: statny.dozor@pdp.gov.sk, Hraničná 12, 820 07 Bratislava 27, Slovakia. Website: https://dataprotection.gov.sk

UPDATE OF THE PRINCIPLES OF PROCESSING PERSONAL DATA

We may amend or update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective upon their publication at the following link: www.mintur.sk/gdpr. We will inform you of any significant changes via the email address you provided before their effective date.

This Privacy Policy shall become effective on 01.01-2025

 

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