Privacy Policy

Data protection and data security

Travel agency LEONI LUXURY TRAVEL, (Luxury Travel, G. Leoni and Co., represented by Giorgio Leoni, Obere Strasse 43 A, CH-7270 Davos Platz) ("We") is the data controller responsible for the collection and processing of your personal data in connection with its activities. Our mission is to provide our customers with a comprehensive range of travel services.

In this Privacy Policy, we explain how we process your personal data and how you can control and manage it. Our data processing may be covered by further data protection notices, such as those contained in particular in the General (Travel) Terms and Conditions, or may arise from the circumstances or be regulated by law.

This Privacy Policy complies with the requirements of Swiss data protection law and, if and to the extent applicable, the General Data Protection Regulation (GDPR) of the European Union.

1. ARE YOU AFFECTED BY THIS COMMUNICATION?

This Privacy Policy applies to you if you:

  • are one of our customers or have a contractual relationship with us;
  • a fellow traveler is one of our customers.
  • are interested in our products or services and therefore provide us with your personal data (e.g. in an agency, on our websites and apps or at events) so that we can contact you.

If you provide us with other people's personal information, please ensure that you inform them about the sharing of their personal information and request that they read this Privacy Policy. We will ensure that we do the same whenever possible (e.g. if the contact details of the person concerned are available).

2. HOW CAN YOU CONTROL OUR PROCESSING OF YOUR PERSONAL DATA?

You have rights that allow you to effectively control your personal data and the way we process it. Below we explain your rights in connection with your personal data.

If you wish to exercise the rights listed below, please submit a request by email to info@ll-travel.ch or by post to the following address: Obere Strasse 43 A, 7270 Davos Platz.

If you have any questions about the use of your personal data under this Privacy Policy, please address them to the following address: info@ll-travel.ch

You can request access to your personal data

If you would like access to your personal data, we will provide you with a copy of the personal data you have requested, as well as information about how it is processed.

Your right to information may be limited in the cases provided for by law.

You can request the correction of your personal data

If you believe that your personal data is inaccurate or incomplete, you can request that such personal data be amended or completed accordingly. In some cases, the submission of supporting documents may be required.

You can request the deletion of your personal data

If you wish, you can request the deletion of your personal data to the extent permitted by law.

You can object to the processing of your personal data on the basis of legitimate interests

If you do not agree to processing based on a legitimate interest, you may object on grounds relating to your individual situation. In this case, please inform us in detail about the corresponding processing and the reasons for your objection. We will stop processing your personal data unless there are compelling legitimate grounds or the processing serves to assert, exercise or defend legal claims.

You can object to the processing of your personal data for direct marketing purposes

You have the right to object to the processing of your personal data for direct marketing purposes at any time. This also applies to profiling, insofar as it is related to such direct advertising.

You can request the restriction of the processing of your personal data

If you contest the accuracy of the personal data we use or object to the processing of your personal data, we will review or revise your request. You can request that we restrict the processing of your personal data while we consider your request.

You have rights against an automated individual decision

In principle, you have the right not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning you or similarly significantly affects you. However, we may automate such a decision if it is necessary for the conclusion or performance of a contract with us, is permitted by law or if you have given your consent.

In any case, you have the right to challenge the decision, to express your point of view and to request the intervention of a competent person with the review of the decision.

You can withdraw your consent

In those cases where processing is based on consent you have given, you can withdraw this consent at any time.

You can request the portability of part of your personal data

You may request a copy of the personal data provided by you in a structured, commonly used and machine-readable format. Where technically feasible, you may request that we transmit this copy to a third party.

Complaint to the Federal Data Protection and Information Commissioner

In addition to the above rights, you can file a complaint with the relevant supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern.

3. FOR WHAT PURPOSE AND ON WHAT LEGAL BASIS DO WE USE YOUR PERSONAL DATA?

Contract execution and legitimate interest

In this section, we explain the purpose for which we process your personal data and the legal basis for doing so. First and foremost, we use your personal data to execute a contract to which you are a party or to take pre-contractual measures at your request. However, we may also process your personal data in order to fulfil our legitimate interest or those of a third party.                     

In particular, your personal data will be processed if it is necessary for the conclusion or performance of a contract in order to:

  • conclude a (travel) contract with you. We may process personal data in order to register you
  • as a new customer, enter into a contract and perform it with you;
  • Provide you with products and services that you have purchased under the applicable
  • Agreement;
  • carry out invoicing, invoicing and collection;
  • To provide you with services related to the preparation and implementation of a trip;
  • for insurance purposes;
  • Provide consulting services;
  • to be able to provide assistance in case of difficulties during the trip if necessary;
  • Provide you with access to our digital platforms. We may process personal data when you use
  • our Digital Platforms for various purposes (e.g. to manage your personal information or to
  • gain access to travel information);
  • To provide access to our premises and facilities. We may process personal data when you visit
  • us at our premises to carry out appropriate access and security checks;
  • To communicate with you. We may process personal data if you wish to contact us, if you ask
  • us for information about our company or services, or if the contract needs to be updated;
  • To respond to your inquiries and assist you;
  • Manage the termination of the contract.

Where we base a processing activity on a legitimate interest, we balance that interest against your interests or fundamental rights and freedoms to ensure that they are proportionate. As part of our business as a travel provider, we also use your personal data to:

  • Develop our products and services;
  • Improve cybersecurity, manage our platforms and websites, and ensure business continuity;
  • Implement IT solutions;
  • To carry out maintenance of IT systems during operation;
  • Improve the automation and efficiency of our operations and customer services (e.g., auto-
  • populating complaints, tracking your inquiries, and improving your satisfaction based on
  • personal information collected during our interactions with you, e.g., phone recordings,
  • emails, or chats);
  • enable the assertion of legal claims and defense in connection with legal disputes and official
  • proceedings;
  • Organize contests, promotions and conduct opinion polls and customer satisfaction surveys.

Advertising and Marketing

If you are a customer and unless you object, we may send you offers for our products and services. We ensure that these commercial offers relate to products or services that are relevant to your needs and complement your already availed offers. You can object to this at any time.

Consent

For certain processing of personal data, we will inform you specifically and ask for your consent. Of course, you can revoke your consent at any time.

In particular, we ask for your consent for:

  • the transfer of particularly sensitive personal data to third parties;
  • tailoring our offers and products or services based on a complex profile to predict your needs and behavior;
  • any electronic offers for products and services that are not similar to those you have purchased or for products and services from our trusted partners.

If necessary, we may ask you for further consent to the processing of your personal data, but this will not affect any data processing that has already taken place.

4. WHAT TYPES OF PERSONAL DATA DO WE COLLECT?

We collect and use your personal information, which is any information that identifies you or that allows you to be identified.

Depending on the type of product or service we offer you and the interactions we have with you, we collect different types of personal data about you:

  • Contact information, (personal or professional) postal address, e-mail address, telephone number;
  • Personal details, e.g. gender, birthday and age, marital status, nationality, passport details, etc.
  • Lifestyle, e.g. hobbies and interests, travel;
  • Travel details, such as travel dates, itinerary/destination, airline, hotel, price, customer preferences, information about your travel companions, frequent flyer programs, etc.;
  • Health data, e.g. information about health-related special needs or illnesses and accidents during a trip;
  • Financial information, e.g., payment information, credit card number, bank account information;
  • Data about your habits and preferences, in relation to the use of our products and services
  • (e.g. food requests);
  • Data from our interactions with you, e.g. Your comments, suggestions, needs that may arise during our exchanges with you personally in our locations and during the telephone communication (call note or call recording), communication via email, chat, chatbot, sharing on our social media and your possible complaints. Your connection and tracking data (e.g. collected via cookies for non-advertising or analytical purposes on our websites), online services, other applications;
  • Data about your devices (mobile phone, computer, tablet, etc.), such as IP address, technical data and unique identification data;
  • Personalized login credentials or security features used to connect you to our website and apps.

5. FROM WHOM DO WE COLLECT PERSONAL DATA?

We usually collect personal data directly from you. But we can also collect it from other sources.

Sometimes we collect data from public sources:

  • Publications/databases provided by official authorities or third parties (e.g. the Swiss Official Gazette of Commerce or the Commercial Register);
  • Social media websites/appearances of legal entities or corporate clients that contain information that you have disclosed (e.g. your own website or social media presence);
  • public information, e.g. information from the media.

We also collect personal information from third parties:

  • from our customers (e.g. as fellow travelers);
  • from our business partners (e.g. tour operators, service providers abroad);
  • from third parties such as credit reference agencies and anti-fraud agencies;
  • Address search service providers, who are responsible for collecting the relevant information in a lawful manner.

6. WHO DO WE SHARE YOUR PERSONAL DATA WITH AND WHY?

In order to fulfill some of the purposes described in this Privacy Policy, in particular to carry out a trip, we may share your personal information with others. These can be the following:

  • Our service providers in the destination country (e.g. agencies, tour guides, hotel reservations, transfer and excursion services), transport service providers (airline, train, car rental, etc.) and accommodation providers (hotel, hostels, etc.);
  • Processors who provide services on our behalf (e.g. IT services, logistics, printing services, telecommunications, debt collection, consulting and sales, and marketing);
  • certain regulated professions, such as lawyers, notaries or accountants, where this is necessary in certain circumstances (litigation, auditing, etc.), and to our insurers;
  • Partners to carry out advertising, market and opinion research;
  • Partners to assist in the investigation of criminal offences (e.g. fraud), the assertion, exercise or defense of legal claims;
  • Authorities and official bodies (e.g. tax authorities, embassies of the destination country) in the event of a legal or official obligation (e.g. retention obligations, obtaining visas, obtaining entry requirements).

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

International transfers from Switzerland and the European Economic Area (EEA) to a non-EEA country (third country) may result in cross-border transfers of your personal data. In particular, you must expect your data to be transmitted to your countries of travel. But also to countries in Europe, the USA and worldwide, where the service providers and service providers we use are located. If the FDPIC or the European Commission has recognized that a third country provides an adequate level of data protection, your personal data may be transferred on this basis.

For transfers to a third country whose level of protection has not been recognized as adequate by the FDPIC and the European Commission, we will either rely on an exception applicable to the situation in question (e.g. if the transfer is necessary for the performance of our contract with you) or apply one of the following appropriate safeguards to ensure the protection of your personal data:

  • Standard contractual clauses approved by the FDPIC and the European Commission;
  • Binding Corporate Rules.

To obtain a copy of these warranties or information on where they are available, you may submit a written request in accordance with Section 2.

8. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will retain your personal information for as long as necessary to fulfill our contractual obligations and to comply with applicable laws and regulations, or for another period in light of our legitimate business interests, such as proper accounting and responding to legal claims or regulatory requests.

9. DATA SECURITY

We use suitable technical and organizational security measures to protect your personal data stored by us against manipulation, partial or complete loss and against unauthorized access by third parties (e.g. encryption of data transmission, access controls, etc.). Our security measures are continuously improved in line with technological developments.

We take reasonable precautions to protect your information. The transmission of information via the Internet and other electronic means always involves certain security risks and we cannot guarantee the security of any information transmitted in this way.

10. HOW YOU CAN FOLLOW THE DEVELOPMENT OF THIS PRIVACY POLICY

In a world where technologies are constantly evolving, we regularly review this Privacy Policy and update it as necessary.

The current version published on our website applies. We recommend that you consult the latest version of this document online. We will notify you of any changes through our website or through our usual communication channels.