Privacy Statement

Holiday Clippers respects your privacy and processes personal data in accordance with the General Data Protection Regulation (GDPR).

1. Who is responsible?

Controller: [legal company name], [address], Chamber of Commerce (KvK) [Chamber of Commerce number], email holidayclippers@proton.me. Hereinafter: "Holiday Clippers" or "we".

2. What data do we process?

Account data

• name
• email address
• phone number, if provided
• password data in secured/hashed form
• profile photo
• country

Business data

• company name
• website
• job title
• user type
• business contact details
• Chamber of Commerce, VAT or similar registration data, where needed

Platform data

• accommodations
• photos, videos and other content
• saved accommodations
• tracking links and clicks
• campaigns
• booking and attribution data
• commissions
• platform activity

Technical data

• IP address
• browser and device information
• log data
• security information
• cookies and similar technologies

Communication

• support requests
• complaints
• other communication with us

3. Why do we process data?

We process personal data for:

• creating and managing accounts
• performing our agreement
• connecting Accommodation Partners and Distribution Partners
• tracking and attribution of bookings
• calculating and administering commissions
• platform analysis and improvement
• security and fraud prevention
• customer service
• compliance with legal obligations
• communication about the Platform

Depending on the processing, the legal basis is: performance of a contract, a legal obligation, our legitimate interest in security/fraud prevention/improvement, or consent where required by law.

4. Tracking and attribution

The Platform uses tracking technology to determine whether a visit or booking originates from a Distribution Partner. This may involve processing unique tracking codes, clicks, timestamps, referrer information and booking data.

This information is used for attribution, fraud prevention, analytics and commission calculation. Where cookies or similar technologies require consent, they are only placed after the required consent has been obtained.

5. With whom do we share data?

We do not sell personal data. We may share data with service providers necessary for hosting/database, cloud storage, email, analytics, security, authentication, payments (if added) and technical support.

These parties may only process data in accordance with our instructions and applicable privacy law. Data may also be shared where required by law or necessary to protect our rights.

6. Data between platform users

For the Platform to work, business profile data and relevant accommodation or distribution data may be visible to other registered users. We limit this data to what is reasonably necessary for collaboration and distribution.

Users may not use personal data obtained through the Platform for purposes other than those for which it was made available.

7. International transfers

When personal data is processed outside the European Economic Area, we ensure a valid transfer mechanism, such as an adequacy decision or Standard Contractual Clauses approved by the European Commission, where required by law.

8. Retention periods

We do not keep personal data longer than necessary for the purpose for which it was collected. Account data is in principle kept for as long as the account is active.

After termination, data may be kept longer where necessary for legal administrative and tax obligations, commissions and transactions, fraud prevention, legal claims or disputes. After that, data is deleted or anonymised when further retention is no longer necessary.

9. Security

We take appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, alteration and disclosure. No digital system can guarantee absolute security.

10. Your rights

Under the GDPR you may, where applicable, request:

• access
• rectification
• erasure
• restriction of processing
• data portability
• objection to processing
• withdrawal of consent

A request can be sent to holidayclippers@proton.me. We may ask for additional information to verify your identity. You also have the right to lodge a complaint with the competent data protection authority; in the Netherlands this is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority).

11. Cookies

We use necessary cookies and similar technologies for, among other things, login, security and the operation of the Platform. For non-essential analytics, marketing or tracking cookies, we ask for consent where required by law.

More information will be included in our cookie policy/cookie preference centre.

12. Automated matching and AI

The Platform may use automated systems and AI to match accommodations and Distribution Partners, improve search results and show relevant recommendations.

Where such systems use personal data, this is done in accordance with this Privacy Statement and applicable privacy law. We do not make decisions based solely on automated processing that have legal or similarly significant effects, unless there is a valid legal basis and the required safeguards are in place.

13. Minors

The Platform is intended exclusively for professional users aged 18 and over and does not direct its services at children.

14. Changes

We may amend this Privacy Statement when our services, technology or legal obligations change. The current version is published on the Platform. In the event of material changes, we inform users where required by law.

15. Contact

Questions about privacy can be sent to: [legal company name], [address], holidayclippers@proton.me, https://travelclipper.vercel.app.