17 Harrier Way, London, England
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Privacy policy

GLOBAL LUX TRAVEL S.R.L.

PRIVACY AND PERSONAL DATA PROTECTION POLICY

Version 1.0 | Approval date: 10 September 2026

Personal data controller: Limited Liability Company “GLOBAL LUX TRAVEL” (GLOBAL LUX TRAVEL S.R.L.), IDNO , 17 Harrier Way, London, England. Website: globalluxtravel.co.uk. Telephone: +44 7474 318381.

This Policy establishes the rules for the collection, use, storage, disclosure and protection of personal data processed by GLOBAL LUX TRAVEL S.R.L. in the course of its activities, including through the website, applications and IT systems used to provide travel services.

Note: This document has been developed for the legislative framework of the Republic of Moldova and must, in practice, be aligned with internal processing records, contracts with data processors, the Security Policy, the Cookie Policy and internal procedures concerning data subjects' rights.

1. PURPOSE AND SCOPE

This Policy applies to all operations through which GLOBAL LUX TRAVEL S.R.L. processes the personal data of customers, prospective customers, website and application users, partners, their representatives, employees and other individuals, to the extent that GLOBAL LUX TRAVEL acts as a controller.

The Policy applies to data collected online and offline, including through forms, requests for offers, bookings, correspondence, calls, applications, user accounts, booking systems, cookies and similar technologies.

2. LEGAL FRAMEWORK

Data is processed in accordance with Law No. 195/2024 on personal data protection, in force in the Republic of Moldova, and with applicable legislation and regulations, including the requirements and recommendations of the competent supervisory authority.

For operations to which European data protection requirements apply directly or indirectly, GLOBAL LUX TRAVEL will also take into account the principles and standards of Regulation (EU) 2016/679 (GDPR), to the extent applicable.

3. PROCESSING PRINCIPLES

GLOBAL LUX TRAVEL applies the following principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; data accuracy; storage limitation; integrity and confidentiality; accountability of the controller.

Data will not be collected or used for purposes incompatible with the purpose for which it was obtained, except where permitted by applicable legislation.

4. CATEGORIES OF DATA PROCESSED

  • Identification data: surname, first name, date of birth and, where necessary, other identification details.
  • Contact details: telephone number, email address, postal address and other details provided for communication purposes.
  • Travel data: destination, departure/arrival dates, flight and accommodation preferences, number of passengers, information about individuals travelling with the customer and other information necessary for the booking.
  • Technical data: IP address, browser type and version, operating system, technical identifiers, access logs, device information and data collected through cookies, in accordance with the Cookie Policy.
  • Business relationship data: requests, bookings, contracts, payments, invoices, communications, complaints and service history.
  • Special categories of data: where exceptionally necessary for carrying out a trip or providing a service, such data will be processed only on an appropriate legal basis and with the safeguards required by law.

5. SOURCES OF DATA

Data may be obtained directly from the data subject, from an individual making a booking for other travellers, through communications with GLOBAL LUX TRAVEL, from booking systems and partners involved in providing the service, and automatically through the use of the website and applications.

An individual providing other travellers' data must have the necessary right or authorisation to disclose it and must inform those travellers about the processing, where applicable.

6. PURPOSES OF PROCESSING

  • Providing the requested travel offers and services.
  • Creating, managing and fulfilling bookings and contracts.
  • Communicating with customers about requests, bookings, changes, cancellations and support.
  • Providing travel documents and disclosing the necessary data to travel service providers.
  • Fulfilling accounting, tax, legal and record-keeping obligations. Preventing fraud, securing systems and investigating incidents. Improving the website, applications, services and user experience.
  • Sending marketing communications and offers where an appropriate legal basis exists and, where applicable, the individual has given consent.
  • Statistical analysis and measurement of service and campaign performance, including through analytics technologies and cookies, under the conditions set out in the Cookie Policy.

7. LEGAL BASES

Processing is carried out, where applicable, for the performance of a contract or to take steps at the individual's request before entering into a contract.

Processing may be necessary for compliance with a legal obligation of GLOBAL LUX TRAVEL.

In certain circumstances, processing may be based on the legitimate interests of GLOBAL LUX TRAVEL or a third party, with due regard for the data subject's rights and freedoms.

Where the law requires consent, it will be requested in a form that makes it possible to demonstrate that it was freely given, specific, informed and unambiguous. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before its withdrawal.

8. RECIPIENTS AND DATA PROCESSORS

Depending on the service requested, data may be disclosed to suppliers and partners involved in carrying out the trip: tour operators, hotels, airlines, transport operators, transfer providers, insurers, booking systems, payment processors and other suppliers necessary for providing the service.

GLOBAL LUX TRAVEL may use IT, hosting, email, CRM, technical support, analytics and security providers that process data on behalf of the company. Where applicable, these providers will be subject to contractual obligations concerning data protection and confidentiality.

Personal data is not sold as a data product.

9. CROSS-BORDER TRANSFERS

Travel services may involve disclosing data to recipients in other countries, including outside the Republic of Moldova or the European Economic Area.

Before a transfer, GLOBAL LUX TRAVEL will assess the applicable legal framework and use, where appropriate, an adequacy decision, appropriate safeguards, standard contractual clauses or another mechanism permitted by applicable legislation.

Data subjects will be informed, to the extent required by law, about relevant transfers and the applicable safeguards.

10. RETENTION PERIOD

Data is retained only for the period necessary for the purpose for which it was collected, in compliance with legal obligations and the periods applicable to accounting, tax and contractual records and the resolution of disputes.

Data used for user accounts is retained for as long as the account exists and, after deactivation, only for as long as necessary for legitimate purposes or to fulfil legal obligations.

Data collected through cookies is retained according to the periods specified in the Cookie Policy and the actual configuration of the tools used.

11. DATA SUBJECTS' RIGHTS

Under the conditions laid down by law, data subjects may have the right to be informed, the right of access, rectification, erasure, restriction of processing, objection, data portability, withdrawal of consent and the right not to be subject to a decision based solely on automated processing, where applicable.

The exercise of a right is not absolute and may be restricted in cases provided for by legislation. GLOBAL LUX TRAVEL may request additional information to verify the requester's identity where necessary and proportionate.

12. EXERCISING RIGHTS

Requests concerning personal data may be submitted to GLOBAL LUX TRAVEL using the official contact details published on globalluxtravel.co.uk or through other channels made available to data subjects.

Requests are reviewed and addressed within the time limits established by applicable legislation. If a request cannot be fulfilled in full, the individual will be informed of the reason and, where applicable, of the right to lodge a complaint with the supervisory authority.

13. CHILDREN AND MINORS' DATA

Bookings may require data about children travelling with the customer. The individual providing this data is responsible for ensuring that they have the right to disclose it and comply with applicable legal requirements.

GLOBAL LUX TRAVEL does not seek to collect minors' data unnecessarily and limits processing to what is necessary for the requested service and legal obligations.

14. COOKIES AND SIMILAR TECHNOLOGIES

The globalluxtravel.co.uk website may use cookies and similar technologies for functionality, security, analytics, personalisation and marketing.

Strictly necessary cookies may be used for the operation of the service in accordance with the law. Cookies requiring consent will be activated only after a valid consent choice has been made through the consent management mechanism.

Details concerning cookie categories, providers, purposes, duration and how to withdraw consent are set out in the Cookie Policy.

15. DATA SECURITY

GLOBAL LUX TRAVEL implements technical and organisational measures appropriate to the risks, including measures concerning access control, authentication, communications security, infrastructure protection, backups, logging and incident management, where applicable.

Access to data is restricted to individuals who need it to perform their duties.

Operational details concerning security measures are set out in the Security Policy on the processing of personal data and in internal procedures.

16. SECURITY INCIDENTS AND PERSONAL DATA BREACHES

Any suspected incident that may affect the confidentiality, integrity or availability of data must be reported and investigated in accordance with internal procedures.

GLOBAL LUX TRAVEL will assess the incident and, where required by legislation, notify the competent authority and/or affected individuals within the time limits established by law.

17. AUTOMATED DECISION-MAKING AND PROFILING

If GLOBAL LUX TRAVEL uses profiling or automated processes to personalise offers, these will be implemented in accordance with the principles of transparency and proportionality and with respect for data subjects' rights.

No decision based solely on automated processing that produces legal effects or similarly significant effects will be made except under the conditions permitted by applicable legislation and with the necessary safeguards.

18. THIRD-PARTY LINKS AND SERVICES

The website may contain links to websites, applications or services operated by third parties. Once these are accessed, data processing is governed by the policies of the respective controllers.

GLOBAL LUX TRAVEL recommends reviewing third parties' privacy policies before providing personal data.

19. POLICY UPDATES

GLOBAL LUX TRAVEL may update this Policy to reflect legislative, technological, organisational or service changes.

The current version is published on the company's website. In the event of significant changes, GLOBAL LUX TRAVEL may use reasonable means to inform data subjects, depending on the nature of the change.

20. SUPERVISORY AUTHORITY

Data subjects have the right to lodge a complaint with the competent personal data protection authority in the Republic of Moldova under the conditions laid down by law.

The national authority is the National Centre for Personal Data Protection (CNPDCP). Official information and up-to-date contact details are available on the authority's website: datepersonale.md.

21. FINAL PROVISIONS

This Policy enters into force on the date of approval and applies to all processing within its scope.

This document must be applied together with the Security Policy, the Cookie Policy, the record of processing activities, procedures concerning data subjects' rights and contracts with data processors.

In the event of a conflict between this Policy and a mandatory legal provision, applicable legislation shall prevail.

CONTROLLER IDENTIFICATION DETAILS

Name: Limited Liability Company “GLOBAL LUX TRAVEL”

IDNO: 

Legal form: S.R.L.

Registered address: 17 Harrier Way, London, England

Website: globalluxtravel.co.uk

Telephone: · +44 7474 318381

Administrator: As recorded in the company's details and applicable registers

Document version: 1.0 / 10.09.2026

Official internal document. For publication on the website, the text must be aligned with the actual cookie configuration, the providers actually used, the actual retention periods and the mechanisms in place for exercising rights.