Date: 9 January 2023
At Distinctly Deutschland, we take the personal privacy, data security, and the trust of our clients very seriously. As a luxury bespoke Travel Company, we really get to know a lot about you as we make all your travel arrangements. Therefore, Distinctly Deutschland takes every step to make sure the information we receive about everyone in your travel party is handled with integrity and in a secure, lawful manner in order to protect your privacy.
1. What is the scope of this policy?
By personal data we are referring to any information that can easily be used, directly or with some research, to identify a distinct individual. This includes information such as name, address, age, sex, phone number, email, financial information, and more. For more information on what constitutes personal data please see the EU General Data Protection Regulation (GDPR) https://gdpr-info.eu/art-4-gdpr/.
As well, in conducting various aspects of our business operation, we share your information with third-party service providers such as hotels, tour guides, tour operators and transport companies through whom we are requesting services for our clients. While we work hard to only have trust worthy partners, the ways in which these services process personal data falls outside the scope of this policy.
2. What information we collect and how we do it
Distinctly Deutschland is committed to the principles of trust and transparency. Here are the ways in which we collect your personal data and what information we get through each channel.
2.1 Through the Website:
Through our website, we collect personal information from you in two ways:
A) The first is when you actively provide us with your information in order to receive a service from us. One way we collect your data is when you make a travel inquiry through our website. In this process, you will give your name, email, phone number, how you heard about Distinctly Deutschland, and any other information you chose to provide in the optional text field provided. In addition, if you elect to sign up to our company newsletter or to comment on our blog you will also give us some personal information. In these cases, you will be asked to provide us with your name and email address.
B) The second way we collect your personal information when you visit our website is through Internet cookies and log files. Cookies are common to almost all websites and are in place to improve the functionality of the website’s user experience and provide us with metrics of website performance. Distinctlydeutschland.com uses both internally based and third party based cookies.
Data these methods collect can include: your internet protocol (IP) address, the country from which you are accessing the website, what type of device you are using to access the site, what internet browser you are using, which pages you visit, and how long you spend on our page. Personal data collected in this method collected and stored in a way that protects anonymity.
In using our website you are consenting to our collection of information through cookies. If you wish, you can always change your personal settings to block or delete cookies. For more information please see our Cookies Statement (->3.7).
2.2 Other Methods:
Distinctly Deutschland also collects our guests’ data directly through communication by phone, email, or in person. It is also possible, with your consent, for third parties such as travel agents, to provide information to us about you and your travel intent via these direct channels.
We will collect all personal information that is needed to respond to your inquiries, provide vacation quotes, book all parts of your travels, and provide in vacation concierge services.
In fulfilling these services we may require information such as (but not limited to) name, age, nationality, phone number, email address, home address, passport and drivers license details, personal interests, preferences and limitations, and banking/payment information.
If you wish to not disclose any information, that is your right, but unfortunately this may make it impossible for Distinctly Deutschland to offer some of our services.
In providing our in-vacation travel concierge service, we provide guests with the option of using a fully connected iPhone owned by Distinctly Deutschland. Because this phone is registered to Distinctly Deutschland, we may have access to the personal information you chose to enter into our device, including your phone call record (which is printed on the monthly phone bill). In addition, to prevent loss or theft, the phone is traceable via GPS and thus could be used to identify your location. By choosing to use our cell-phone service, clients are consenting to our collection of this information.
2.3 Information about other people
When providing personal data to Distinctly Deutschland, guests must have the permission of everyone in the travel party of whom they are giving the personal information. This is also true for third-party bookers such as travel agents; one must have the consent of all members of a travel party before providing Distinctly Deutschland with their personal data. In the case of children, consent of transferring personal data will be required of the holder of parental responsibility.
2.4 Sensitive Data
In providing travel services, Distinctly Deutschland may ask for what is considered sensitive data about you or a member of your travel party. Sensitive data is defined as information such as one’s religion, political affiliations, medical information, ethnicity or race, sexuality, or information that could be used to infer this type of sensitive personal information.
Sensitive personal information may be needed in order for us and third-party travel service provides to fulfil your travel requests and make sure travel is comfortable and enjoyable and adequate. An example of this could be the arranging for specific lodging to accommodate a health-related issue or booking appropriate dinning arrangements in accordance with a your health related or religious dietary requirements.
You may decline to provide this type of information but unfortunately without it Distinctly Deutschland may be unable to provide our normal level of personalized service.
Distinctly Deutschland is particularly careful when collecting and storing this type of information. By freely communicating this information to Distinctly Deutschland you are providing explicit consent for our collection and use of it in order to provide the best travel service possible.
3. How we use personal information
We are committed to the principle of Data minimization. This means we collect only the data needed for carrying out our normal business operations. Here are the ways that Distinctly Deutschland uses personal information of our clients:
3.1 To provide travel services
We will use your personal information to provide you and your party with the travel services that you and Distinctly Deutschland have agreed upon. This includes, but is not limited to, planning itineraries that match your interests and desires, making bookings on your behalf, providing our in vacation concierge service and processing your payment for services.
3.2 To send newsletters
If clients choose, they can receive our company newsletter. At any time, clients can opt out of receiving communications if they so chose (see section 6).
3.3 To customize future experiences
Distinctly Deutschland uses our client’s personal information in order to personalized future service. This means if you book for a second time with Distinctly Deutschland, we will use the information of your first booking along with any new information in order to plan an even more perfect and personalized vacation.
3.4 Sharing with third-party services
In order to book your vacation Distinctly Deutschland will have to share your personal information with third-party travel-service providers such as hotels, transportation companies, restaurants, tour guides, and any other operator needed to arrange the vacation you have requested. In addition, we will need to share relevant personal information with the bank in order to process payments.
Distinctly Deutschland uses third-party data-storage services to help us store and organize the data we process more securely and efficiently. Under relevant legislation, this is also considered sharing your personal information with a third party. For more information on third-party storage services see section 4.2.
3.5 Internal organization and business analysis
We use personal data for internal administrative, research, and other purposes in order to organize and improve Distinctly Deutschland’s business operations and offerings. For example, we may aggregate some types of personal information of our guests, such as age, to better understand who travels with us in order to provide better future travel offerings.
3.6 Legal purposes
Distinctly Deutschland uses and stores client personal information in order to comply with legal responsibilities such as tax and other regulatory requirements. We reserve the right to use personal information in order to comply with any legal investigation or process. As well, we reserve the right to use the information we collect for the purpose of protection against liability, litigation, and fraud.
Distinctly Deutschland employs internally based Interment cookies as well as third-party cookies on our website. These cookies collect some information from website visitors that is considered personal information to help us understand who visits our website, how they use it, and how we can improve the website user experience.
3.8 What we do not do with your data
Distinctly Deutschland under no circumstances will sell or lease our client’s personal information for advertising or any other reason.
4. How is data stored?
Protecting our clients’ personal information is of great importance to us. No data system connected to the Internet can be perfectly secure and free of human error. This is why at Distinctly Deutschland we use several internal and external data storage protection services and measures to help ensure the confidentiality of our client data.
With the goal of security in mind, we urge caution to our clients about what personal information they chose to share with us by email, as this can be a particularly vulnerable method of communication. For this reason, Distinctly Deutschland prefers to collect important information from our guests by phone or via encrypted files and uses secure file-sharing technologies to communicate internally.
If you are concerned about the security of your email communication with Distinctly Deutschland, we can set up encrypted email communication. Upon request, we would be more than happy to provide you with our Public Key PGP, GnuPG, or OpenPGP, in order to set up secure encrypted correspondence.
4.1 Internal Storage
We store the data we process internally on a secure in-house server that is protected by a strong firewall which we keep updated regularly with state of the art IT technology.
4.2 External Storage
To complement the security of our in-house server and to help with many business tasks, Distinctly Deutschland also uses third-party services.
Some of these third-party services operate their data servers and businesses outside the European Union. This means that they are subject to different rules and regulations than within the European Union. However, many of these companies have voluntarily complied with the GDPR and all are operating under the US-EU Privacy Shield framework that permits GDPR compliant companies to share data with them.
Third party data services Distinctly Deutschland uses:
4.3 Duration of Storage
Below outlines our data retention policy as it applies to general categories of personal data under normal circumstances. We will continue to store your personal data only as long as required to complete the tasks outlined in section 3 above.
Credit Card and Payment Information: Distinctly Deutschland stores client payment information with 1Password’s encrypted storage only until full payment has been processed, in accordance with the travel agreement. After payment has been received this data is deleted. Payment data is only accessible to the sales and accounting staff and is only ever shared with our trusted banking institutions.
Passport and Drivers License Data: Distinctly Deutschland stores this information up until one month after a guest has travelled with us, after which point we will delete it. This information is accessible to our sales and travel planning staff and is only disclosed to rental car or other travel service providers who legally require this information for bookings (e.g. Hotels who may need your passport number to register with the local authorieties, government protected buildings who will make a security checks before granting admission to our guests,…)
Personal Information: In general, Distinctly Deutschland stores personal client information on our internal server for up to 10 years in compliance with tax law and commercial regulations. We also hold onto this data in case a client decides to travel again with us as well as other internal business processes outlined in section 4.
Sensitive Information: Distinctly Deutschland stores sensitive information on our internal server for up to 5 years in case clients decide to travel again with us. After 5 years we will delete this sensitive data.
5. Tour Guides
At Distinctly Deutschland we have on-going business relations with free-lance tour guides who lead our guests on our behalf while on vacation. We work hard to select only the very best guides in terms of their skills as guides but also their business professionalism.
In line with the travel agreement contract between Distinctly Deutschland and our clients, we will need to share personal information of our clients with tour guides. We trust our free-lance guides to process client data with integrity and a respect for the data privacy of all clients, in accordance with the GDPR.
6. Unsubscribing from Emails and Newsletter
If you receive Distinctly Deutschland’s email newsletter, you can choose to unsubscribe from receiving it. Should you wish to do this, you simply can click the unsubscribe button at the bottom of all newsletters. Email- store your address and make sure only those intended have access to your emails- protected by state of the art technology.
If you wish to suspend all email communications simply email email@example.com and communicate your desire.
7. Access, Change and Delete information
In accordance with the GDPR, you have the right to correct/change, find out what we have, take with you, and request the deletion of the personal information that Distinctly Deutschland has about you. You can do this by email by contacting firstname.lastname@example.org.
You could also reach us by telephone at +49 721 61909040.
You can also contact us by writing to:
Distinctly Deutschland Germany Luxury Travel GmbH
76135 Karlsruhe Deutschland
We will be happy to assist you with any of your data related concerns. However, it should be noted that your rights regarding your data could be limited by our obligations to comply with other laws and regulations like German general tax code (AO) and German Commercial Code (HGB).
8. The site is not for those under 16
This website is not intended for anyone under sixteen years of age. Any information given about someone under sixteen-years-old must be done with the consent of the minor’s parent or legal guardian.
9. Changes to the policy in the future
10. Security Information:
Distinctly Deutschland’s data processing and storing procedure are designed to comply with the European Union Data Protection Regulation (GDPR).
For more information on the GDPR the full regulation can be found here: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ENG&toc=OJ:L:2016:119:TOC
The Data Controller of this website is:
Distinctly Deutschland German Luxury Travel GmbH
76135 Karlsruhe Germany
Telephone: +49 721 61909032
In accordance with the GDPR, Distinctly Deutschland is obligated to inform our clients within 72 hours of a breach of our data security.