Privacy Policy

This Privacy Policy has been written by Ruby Rejser ApS, CVR No. 18422298, as Ruby Travel is part of Ruby Rejser ApS (collectively referred to as "Ruby Rejser ApS", "Ruby Rejser", "Ruby Travel", "we", "us" or "our" in this Privacy Policy) and applies to all our customers, guests, suppliers and cooperation partners.

 

1. About Ruby Travel

Ruby Travel is located in Aarhus but has guests and customers from all over the world. Read more about Ruby Travel here.

As part of its business, Ruby Travel collects and processes personal information for the purposes described in this Privacy Policy. Ruby Travel is data controller in regard to the processing of personal information for these purposes.

If you have questions about this Privacy Policy or our processing of your personal information, please contact us here:

 

Ruby Rejser

Mejlgade 46B

8000 Aarhus C

Denmark

Email: ruby@ruby-rejser.dk

 

2. Data security is important to us

For us, responsible handling of the personal information we've collected as part of our business operations is crucial to our goals and reputation as a business. This Privacy Policy explains the types of information we collect, how your personal information is collected and used when you are a customer, supplier or cooperation partner at Ruby Travel, and how you can get insight into your personal information.

 

3. What is personal information?

Personal information is any information about an identified or identifiable natural person. An identifiable natural person is a person who can be directly or indirectly identified, e.g. by an identification number or one or more elements specific to a given person's identity.

4. What kind of personal information do we process about you and why?

The information we collect about you will be used for various purposes in connection with your customer relationship and the operation of Ruby Travel's business. The information collected may vary depending on whether you are a customer, supplier or cooperation partner, but generally it will be information about customer administration, supplier management and information about Ruby Travel's rights and obligations.

Failure to provide personal information on your part may result in Ruby Travel being unable to meet its obligations regarding your customer or supplier relationship.

As a rule, Ruby Travel collects and processes only general personal information. However, in some cases when booking a trip, it may be necessary for us, to a limited extent, to process sensitive personal information (e.g. information about special menus on your flight or information about the need for special assistance on your journey), as well as information about your personal identification number or social security number (e.g. in connection with obtaining a copy of your passport for use in a visa application) in order to provide you with your desired trip.

The information we collect depends on how you interact with us. For example, when booking a holiday or tour with us, we are likely to ask for more information than if you’re only requesting a brochure, sending us a contact request or browsing our website. We may collect, use, store and transfer different kinds of personal information about you, as summarised in the box below.

Details about you: Your first and last name, marital status, title, gender, email address, phone number, date of birth, loyalty membership details, your reasons for travel, meal and other travel preferences or dietary requirements.

 

Payment details: Your bank details and payment card details when making a booking with us. Details about payments to and from you and other details of products and services you have purchased from us.

 

Identification documents: If you are travelling on a route requiring advance passenger information (API), your passport or identity card details including your passport number, the country in which your passport was issued and expiry date.

 

Details about your booking with us: Details such as where you are flying from and to, your booking information (including anyone else on the booking), any onward travel details if relevant, details of experiences or excursions booked through us, baggage requirements, upgrade information, lounge visits, seat preferences, meal preferences or requirements, details of any special assistance required and any other relevant information so that we can provide you with the holiday or other service you have arranged with us.

 

Details from your interactions with us: Information about interactions or conversations with us and our staff, including when you make enquiries, comments, complaints or submit feedback to us. This could also include username and password and your interests, marketing preferences and responses to surveys.

 

Your use of our systems and services: This includes how you use our website, app, retails stores, call centres and/or social media pages, IP addresses and information you may post on social media.

 

Job applications: If you apply for a job with us, your CV, work history, educational details and the role you are applying for.

 

Special types of data: In some circumstances we may need to collect information from you that is deemed sensitive. For example, we might collect:

 

Information about your health. Knowing your dietary requirements and any medical conditions you have, will ensure that the trip is suitable for you and that any necessary adjustments are made.

 

Information about your religion (for example, if you specify a meal preference that indicates a particular religion, such as a kosher or halal meal).

 

We try to limit any sensitive personal information we collect to the minimum possible. Unless we have a specific lawful reason to use this information, we will ask for your consent to collect it.  


Read the following for a further elaboration of which information we collect from our customers and suppliers, respectively:

4.1    Information about our customers

Information you provide us when you book a trip, e.g. online via the website or by contacting one of our holiday consultants, including contact details (first name, middle name(s), last name, address, phone number, email address and possibly your occupation), personal identification number og social security number (for use in visa applications, etc.), passport number, bank details, credit card information, information you provide us in regards to your special preferences (e.g. information about special meals or dietary requirements, the need for special assistance in case of disabilities or other illnesses etc.), health information (when travelling for treatment trips, sports trips, etc.), information about height, weight, clothing and shoe size (for use when renting/booking equipment for skiing holidays, bike holidays etc.), the purpose of the trip, information about which languages you speak, citizenship, your membership status with our cooperation partners' associations, contact information on your next of kin, information that you give us about your preferences in relation to marketing or communications, as well as information you provide us if you contact us with a question, to report a problem or when you contact us in connection with your customer relationship with us.

4.2    Information about our suppliers and cooperation partners

Information you provide in connection with the conclusion of a delivery or cooperation agreement, including contact information (occupation, job title, first name, middle name(s), last name, address, phone number and email address), information you provide us about your preferences in relation to marketing or communications, as well as information that you provide us if you contact us with a question, to report a problem, or in any other regard when you contact us as part of our cooperation.

 

5. How do we collect your information?

Depending upon your interactions with us, we might collect information in the following ways:

Direct interactions: You may give us information about your identity, contact and financial information by filling in forms or by corresponding with us by post, phone and email or otherwise. This includes personal information you provide when you:

  • book or search for a holiday or other service (such as flight, cruise, hotel lounge access, transportation or special assistance, etc.) via one of our websites, any apps we use, retail stores, our call centre, etc.
  • fill in part of the booking information on our website but do not complete the booking.
  • request a brochure, sign up to receive email updates, participate in any of our competitions, promotions (for example via any social media channels, email or our website), surveys or market research.
  • create an account on our website and enter information into online forms.
  • provide us with information about an accident, illness or incident that occurred or some other feedback.
  • apply for a job with us by email or via the website.
  • contact us via our call centre, press office, social media, post, email or instant messenger. Our interactions with you may be recorded and monitored for the purposes of improving customer service, quality assurance, training, security and general business purposes.
  • attend any of our events.

Automated technologies or interactions

When you interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources

We may receive personal information about you from various third parties as set out below:

a) airlines, hotel providers or other parties we work with if you make a complaint to them

b) analytics providers

 

6. What do we use your personal information for?

Ruby Travel processes your personal information for the purposes listed below. Please note that not all of the stated purposes, categories of information, recipients of information or types of information being processed apply to you in all instances.

Ruby Travel only processes your personal information to the extent necessary for your customer, supplier or cooperative relationship (in each case taking into account any interests), or according to applicable law.

At any time, you may withdraw your consent for processing your personal information for any of the following purposes, except for any processing determined by applicable laws and regulations. Please note, that your withdrawal of consent may cause Ruby Travel to no longer be able to fulfil its obligations in relation to your customer or supplier relationship. Therefore, in some cases, your withdrawal of consent may result in the cancellation on your part of your purchased products or services upon withdrawal.

6.1    Customer management

Ruby Travel processes your personal information in connection with the establishment and ongoing administration of your customer relationship with Ruby Travel as part of the operation of our business, including booking of travel and delivery of our other products (such as visa applications, travel insurance, transfer services, etc.), maintenance of our customer records, billing, debt collection, marketing, statistics, etc.

6.2    Administration of supplier and cooperative relationships

Ruby Travel processes your personal information in connection with the management of supplier and/or cooperative relationships where you are the supplier or cooperation partner, or the contact person at a supplier or cooperation partner, with whom Ruby Travel works in the operation of our business, including maintaining our CRM registry with information about our contacts at our suppliers and cooperation partners.

6.3   Prize draws, competitions or questionnaire and customer surveys

Ruby Travel processes and uses your personal information when fulfilling our contract with you or in our legitimate study of how customers use our services, to develop our products and services and to grow our business.

6.4    Marketing communications

Ruby Travel will use your personal information to contact you in order to keep you up to date with the latest news, offers, events, sales, brochures, promotions and competitions that we consider may be of interest or relevance to you. We will usually only contact you when we have your consent to do so, or on the basis of our legitimate interest in providing you with customer service. Please see the section "Marketing" below for more information.

6.5    Personalisation of your customer experience and improvement of our service

Ruby Travel uses your personal information to provide you with a more personalised service. This might include personalising the communications we send to you based on your preferences, sending you only advertising that we think you might like and/or that will enhance your holiday experience (on the basis of our legitimate interest in presenting you with the right and relevant products and services). We may also record and/or monitor calls in order to improve our customer service.

6.6    Processing of job applications

Ruby Travel uses your personal information to process any job applications that you send to us, whether directly or through an agent or recruiter (unsolicited or in response to any add) (on the basis of our legitimate interest in recruiting new employees or suppliers).

6.7    Optimising our websites

If you use our websites, we will use your personal information to ensure that the content from our websites is presented in an effective manner for you and your device, for the purpose of providing you with access to our websites in a manner that is effective, convenient and optimal, and to provide you with content that is relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interest in operating and presenting effective and convenient websites to our website users).

6.8    Data analytics with the purpose of improving our websites, products/services, marketing, customer relations and experiences

The processing of your personal information is necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy).

6.9    Research

Ruby Travel uses your personal information to carry out aggregated and anonymised research about general engagement with our services and systems, or if you choose to participate in customer surveys, consumer focus groups and research (on the basis of our legitimate interest in improving our products, services and customer service).  

6.10    Compliance with applicable laws and regulations

Ruby Travel processes your personal information in compliance with laws and regulations that Ruby Travel is subject to in connection with the operation of the company, or to fulfil various reporting or disclosure obligations in accordance with applicable laws and regulations.

Ruby Travel aims to ensure that all the personal information we process is accurate and up-to-date. We therefore ask you to always notify us of any changes in your personal circumstances (e.g. change of address or payment information) so that we can ensure that your personal information is always accurate and up-to-date. If you have created a travel profile with us, we ask you to sign in to your profile and update it, in case of any changes.

 

7. Marketing

One of the other reasons why we sometimes collect your personal information is so that we can form an idea of what we think you might want or need, or what may be of interest to you. With this information, we decide which products, services and offers may be relevant for you, and what marketing you may be interested in.

We keep you up to date with our latest offers, partnerships, sales, promotions, competitions (or those of our partners) that we think might be of interest/relevance to you.

We will only contact you in this way if:

  • You have signed up to receive marketing communications from us and have not later told us that you don't want to hear from us.
  • You have made a booking with us and have not told us that you do not want to hear from us.

7.1    What if I don't want to receive marketing?

We never want to send our marketing to anyone who isn't interested in receiving this content. If you have decided that you no longer wish to hear from us, you can unsubscribe from our marketing by clicking the "unsubscribe" link included in all our emails or by contacting us.

7.2    Third parties and marketing

We will not pass your information to other parties for marketing purposes unless you have agreed to us doing so. We will obtain your express opt-in consent before we share your personal information with any company for marketing purposes.

In the marketing material we send you, we may also occasionally include information about selected business partners who provide services closely related to our own product.

 

8. Legal basis for processing your personal information

As a rule, Ruby Travel processes your personal information based on one of the following: (1) Your consent, (2) the conclusion or fulfilment of your contract with Ruby Travel, (3) the consideration of the legitimate interests of Ruby Travel, i.e. the purposes described above, (4) fulfilment of any legal obligations imposed upon Ruby Travel, (5) the protection of your or any other natural person's vital interests; (6) the processing is necessary in order for a legal claim to be established, exercised or defended, and (7) the processing is required to comply with Ruby Travel's or your legal labour, health and social obligations in accordance with national or EU law. In addition, there may be situations where we process your personal information in consideration of third parties' legitimate interests with regard to the purposes described above, unless the consideration for your interests outweighs them.

 

9. Sharing of personal information

Ruby Travel only shares the information to the extent necessary for the operation of our business, including to be able to provide you your holiday and any other products or services you have purchased from us in connection with it.

Ruby Travel will typically transfer personal information to the following recipients when booking a trip and any related products:

9.1    Global Distribution Systems (GDSs)

A GDS is an IT network system owned or operated by a company that enables transactions between suppliers in the travel industry, primarily airlines, hotels, car rental companies and travel agencies. A GDS connects services, prices and bookings by combining products across the three travel sectors, i.e. flight reservations, hotel reservations and car rental.

Ruby Travel uses various GDSs in the running of our company - contact us if you wish to know which.

9.2    Airlines

Ruby Travel transfers personal information to airlines when booking your trip. In order to book your flight, we typically have to provide the chosen airline with information about first name, middle name(s), last name, departure airport, destination, departure and return dates, bonus card number and any special requests for your trip, including the booking of special meals during the flight and any need for special assistance on the plane or at the airport.

In connection with travel to certain destinations, we may also provide the airline with information about your passport number or other necessary passport information. 

9.3    Hotels

Ruby Travel transfers personal information to the hotels that you will stay at during your trip. In order to book your hotel accommodation, we typically have to provide the hotel(s) with information about first name, middle name(s), last name, destination, date of arrival and departure, room category, bonus card number, special requests for your trip, including the booking of special meals and dietary requests during your hotel stay and any need for special assistance during your hotel stay in connection with a disability or illness.

9.4     Car rental

Ruby Travel transfers personal information to car rental companies if your booking includes having a vehicle available during your trip. In order to book your rental car, we typically have to provide information about first name, middle name(s), last name, pick-up location, rental period, car type and category, special requests in connection with the car rental, including special measures in case of disability or illness, child seats, etc.

Ruby Rejser uses various car rental companies in the running of our company - contact us if you wish to know which.

9.5    Bus companies

Ruby Travel transfers personal information to bus companies if travel by bus is part of your trip (e.g. on day trips to famous tourist attractions, etc.). In order to book your bus travel, we typically have to provide information about first name, middle name(s), last name, pick-up location, date and time of the bus travel, destination and special requests for the bus travel, including the booking of special meals during the bus travel and any need for special assistance during the bus travel due to disability or illness.

9.6    Passenger ship companies

Ruby Travel transfers personal information to ship companies if you are travelling by ferry as part of your trip (e.g. on day trips to famous tourist attractions, cruises, etc.). In order to book your travel by ferry, we typically have to provide information about first name, middle name(s), last name, destination, itinerary, date and time of departure and return trip, as well as special requests in connection with your travel by ferry, including the booking of special meals during the sailing and any need for special assistance during sailing due to disability or illness.

9.7    Bed banks

A bed bank is an IT network system owned or operated by a company that enables transactions between suppliers in the travel industry, mainly hotels and travel agencies, or the end-customer. Ruby Travel transfers personal information to bed banks when booking the hotels that you will stay at during your trip. In order to book your hotel accommodation through a bed bank, we typically have to provide information about first name, middle name(s), last name, destination, date of arrival and departure, room category, special requests for your trip, including the booking of special meals and dietary requests during your hotel stay and any need for special assistance during your hotel stay in connection with a disability or illness.

Ruby Travel uses various bed banks in the running of our company - contact us if you wish to know which.

9.8    Travel agents

If, as part of your trip, you will participate in excursions or need a transfer, Ruby Travel may transfer personal information to travel agents. The travel agent is responsible for arranging the excursion or transfer in question when booking the desired service(s) with local suppliers at the destination. In order to book your excursions, transfers, etc., we typically have to provide information about first name, middle name(s), last name, date and time of arrival and/or departure, type of vehicle, destination and special requests in connection with the transfer or excursion, including the booking of special meals and any need for special assistance due to disability or illness.

9.9    Insurance companies

When booking your holiday or trip with us, you have the opportunity to purchase a travel and/or cancellation insurance. If you wish to purchase such insurance, we will disclose your personal information to the insurance company in order for them to register the insurance. In order to purchase a travel and/or cancellation insurance, we typically have to provide information to the insurance company about first name, middle name(s), last name, email address, destination, departure and return dates, and travel type.

Ruby Travel cooperates with the following insurance companies in the running of our company: Europæiske (ERV), Gouda.

9.10    Equipment rental companies

When booking your holiday or trip with us, you have the opportunity to rent equipment that you may need on your trip, e.g. ski equipment, bicycle equipment, diving equipment, or the like. If you wish to rent such equipment, we will disclose the information to the company at your destination from whom you will be renting the equipment. In order to book your equipment rental, we typically have to provide the rental company with information about first name, middle name(s), last name, type of equipment, pick-up location, rental period and information about height, weight, clothes and shoe size.

9.11    Particularities of qualified offers

When you choose Ruby Travel, you have the opportunity to get a qualified offer on a trip. A qualified offer is a form of offer, in which a preliminary booking of the desired trip is made for you at the time of making you the offer. This allows you to reserve a spot on the desired departures for up to three days, before deciding whether to make a final booking on the preliminary reservation or whether it should be cancelled.

In order to make a qualified offer, we disclose the information about you and your desired reservation to a GDS (as mentioned above), which makes the preliminary booking with the airline, hotel, etc.

When requesting the qualified offer, information about you is sent to several new independent data controllers (GDS, airlines, hotels, etc.). As a result, your information may be stored by these recipients after the expiry of the offer – also in the event of the offer being cancelled.

In addition, Ruby Travel may disclose and/or transfer your personal information to other suppliers and/or service providers in connection with the general operation of our business, e.g. in connection with remote administration of our IT systems, analytical tasks, marketing tasks, debt collection, credit rating, auditing, legal assistance, etc.

For further information about our suppliers' and cooperation partners' processing and protection of your personal information, please refer to their privacy policies and terms. Contact us if you want this information.

Ruby Travel seeks to limit the disclosure of personal information in personally identifiable format to the extent possible, with the purpose of limiting the instances where the disclosed information can be attributed to you personally.

Ruby Travel does not share your personal information unless this is required in order to conduct our business or meet your needs.

10. International transfer of your personal information

Due to the nature of Ruby Travel's business, your personal information may be transferred to countries outside the EU/EEA when booking a trip with us. In order to be able to deliver our services to you, in certain cases we need to use partners and suppliers outside the EU/EEA.

Without the possibility of transferring your information to recipients outside the EU/EEA, Ruby Travel will be unable to deliver the desired trip to you. This applies if booking your trip requires that information is sent to recipients outside the EU/EEA, e.g. to book flights, hotels, etc. at your travel destination.

The data protection legislation in these countries may be less strict than it is in Denmark and in the rest of the EU/EEA, as in most cases the European Commission has assessed that the level of data protection in these countries is not as high as the data protection level within the EU/EEA.

To the extent that it is practically possible for us, the transfer of your personal information will be done according to the standard data protection contract clauses adopted by the European Commission, and which have been specifically prepared for this purpose. For transfers to the United States, these will, to the extent possible, be made under the Privacy Shield. Privacy Shield is an agreement between the EU and the United States. Among other things, Privacy Shield establishes a strong set of data protection rules and security measures that US companies registered under the Privacy Shield must comply with when processing personal information.

In certain cases, however, it will not be practically possible for Ruby Travel to enter into a contract based on the standard data protection clauses or use Privacy Shield as a legal framework for transfer. In such cases, the transfer of information will be carried out pursuant to Article 49(1)(b) of the Data Protection Directive, as the transfer of your personal information to the country(s) concerned is necessary for the fulfilment of the contract between you and Ruby Travel (your travel booking) or for the implementation of measures taken at your request prior to the conclusion of such a contract (e.g. in connection with the making and giving of a qualified offer as mentioned above in the section "Particularities of qualified offers").

It is therefore important that you are aware that the transfer of your personal information to countries outside the EU/EEA, when making a booking with Ruby Travel, means that your personal information will not benefit from the same protection as under the Danish or European Union's legal rules.

In connection with the transfer of information, there is a potential risk that the country in question has no clear, precise and available rules regarding the authorities of the country's access to use your personal information; that there are no rules regarding the authorities of the country's access to your personal information must be necessary and proportional; that the country does not have an independent and effective supervisory authority; and that the country has no accessible and effective remedies for the data subjects.

If you do not want Ruby Travel to transfer your personal information to recipients outside of the EU/EEA when booking your travel(s), you should inform us of this no later than when making your travel booking with us.

Ruby Travel does not, in any case, transfer your personal information to recipients outside of the EU/EEA unless this is necessary in order to conduct our business and meet your needs, e.g. to deliver the desired trip to you.

 

11. Data integrity and security

Personal information is not stored any longer than is necessary for the purposes for which is was collected, provided we are not required to store the information in order to comply with national law, including statutory storage periods in connection with accounting, etc.

It is Ruby Travel's policy to protect personal information by taking the appropriate technical and organisational security measures. When your personal information is no longer needed, we will ensure that it is deleted in a secure manner.

 

12. Your rights

At any time, you have the right to exercise your rights under the data protection legislation applicable at any given moment. You may, for example, request insight into the personal information that Ruby Travel has stored about you, or object to the processing of the information, including objecting to automated technologies or interactions (cf. sections 5 and 6) or to the use of your personal information for direct marketing. Additionally, you may request correction or deletion of any incorrect information about you, withdraw your consent to the processing of your personal information, and exercise your right to data portability.

If you wish to exercise one or more of your rights, please contact us by email at ruby@ruby-rejser.dk. Your request will be processed in accordance with the, at any given moment, applicable data protection legislation.

Complaints about Ruby Travel's processing of your personal information can be made at:

Datatilsynet

Borgergade 28, 5.

1300 Copenhagen K

Email: dt@datatilsynet.dk

 

13. Updates

Ruby Travel regularly evaluates and updates this Privacy Policy. You should therefore regularly check this Privacy Policy for any changes that may affect our processing of your personal information.

This Privacy Policy was last updated 24th of May 2018.