Privacy Policy

Effective 24 May 2018


Transfer NV (“Transfer”, “we”, “our” or “us”) want to inform you about the way we process your data. This Privacy Policy describes the processing of information we collect from and about you when you visit the website (the “Website”). Our Privacy Policy also describes other sources we use to obtain information about you; tells you how we use, share and protect your information; and what choices you have about how your information is used.

A list of our affiliated companies (“Our Affiliates”) is available at

We do not knowingly collect, use or disclose personal information about users under age 16, except as permitted by law.

For the purposes of this Privacy Policy, “personal information” means information that identifies a specific person, such as contact details including your name, IP address, email address or newsletter choices.


Information You Provide Directly to Us

If you are interested in obtaining information, products or services from us, or participating in certain activities through the Website, you may provide us with information about yourself when you use the ‘contact us’ facility or subscribe to our newsletter. Registration information may include name, email, company and phone number.

Information We May Collect Automatically

In addition to information you choose to provide to us, we also use standard technologies to automatically collect certain additional information. For example:

  • Activity Information. When you access and interact with our Website, we may collect information about your visits in order to permit you to connect to and obtain the Website. For example, we may collect your Internet Protocol (IP”) address, which identifies the computer or service provider that you use to access the Website, or information about your browser type, authentication identifiers, and other software and hardware information. If you access the Website through a mobile or other device we may collect your mobile device identifier, geolocation data (including your precise location), or other transactional information for that device. Social Media Information and Content. If you access or log into this Website through a social media service or connect the Website to a social media service, the information we collect may also include your user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service.


  1. to provide you with access to and use of the Website; or
  2. to communicate with you about the content and Website or other products, content or services in which you may be interested, or to respond to your inquiries or comments;
  3. Protect the rights of Transfer and others. For example, there may be instances when Transfer may use your personal data, including situations where Transfer has a good faith belief that such processing is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of the Transfer, Our Affiliates or their employees, agents, contractors, licensors and suppliers (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Website or members of the public; (iii) protect Transfer, as well as other third parties involved, such as Transfer suppliers, against fraud or for risk management purposes; or
  4. Comply with applicable laws or legal process and/or respond to requests from public and government authorities; or
  5. Complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Transfer business, assets or stock (including in connection with any bankruptcy or similar proceedings). For example, if Transfer is  involved in a merger or transfer of all or a material part of its business, Transfer may disclose and transfer your personal data to the party or parties involved in the transaction as part of that transaction; or
  6. To allow social sharing functionality. If you log in with or connect a social media service account with the Website, we may share your user name, picture, and likes, as well as your activities and comments with other Website users and with your friends associated with your social media service. We may also share the same information with the social media service provider. The social media service’s use of the shared information will be governed by their own privacy policy so please read it carefully. If you do not want your personal information shared in this way, please do not connect your social media service account with your account and do not participate in social sharing on Website.

We will use and share your personal information as described in this Privacy Policy, including:

  • with entities that help us to manage and provide the Website, including development of our websites and applications, maintenance and support, personalization, fulfilment, and operation of travel services and products, and promotions management, only to the extent that these entities need the information to perform their services or as required by law;
  • with our Affiliates for the purposes described in this Privacy Policy. A link to a website that lists Our Affiliates can be found at the beginning of this policy. Users who visit websites of Our Affiliates’, or make use of their services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy.


The processing of your personal data for the purposes of:

  • Section 3, letters from a) to c) of this Privacy Policy is necessary for the provision of the requested services and therefore it is mandatory since otherwise the services could not be provided;
  • Section 3, letter d) of this Privacy Policy is requested under applicable laws and therefore it is also mandatory; and
  • Section 3, letter e) of this Privacy Policy is performed based on the legitimate interest of Transfer and of its counterparties to perform such economic activities, which is adequately balanced with your interest since the data processing, is performed within the limits strictly necessary to perform such economic activities. This data processing activity is not mandatory and you can object at any time as described in Section 7 of this Privacy Policy.

On the contrary, the processing of your personal data for the other purposes of:

  • Section 3, letter f), is discretionary, but, without your consent, it is impossible to connect a social media service account with the Website so that you will have to log to the Website using a different mechanism.


We take a number of adequate administrative, technical, personnel and physical measures to safeguard information in our possession from loss, theft and unauthorized use, disclosure or modification.


Your personal data may be transferred to countries within and outside the European Economic Area, in particular in the United States. Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available at For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place appropriate and suitable safeguards designed to protect your personal data and the transfer of your personal data in compliance with applicable data protection laws, such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the EU General Data Protection Regulation 2016/679 (the “Privacy Regulation”).

You have the right to request a copy of the above measures and further information on your personal data by contacting Transfer at the address indicated in Section 9 of this Privacy Policy.


You have the right, in any given time, to:

  • Obtain confirmation as to whether or not your personal data exists and to be informed of its content and source, verify its accuracy and request its rectification, update or amendment;
  • Request the deletion, anonymization or restriction of the processing of your personal data processed in breach of applicable law;
  • Object to the processing, in all cases, of your personal data for legitimate reasons.

You may send your request at the address indicated under Section 9 below. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress, or delete.

On May 25, 2018, the Privacy Regulation will become effective and the following provisions will apply:

A. Retention periods applying to your personal data 

We will retain your data only for the period necessary to fulfill the purposes for which the data was collected as outlined in this Privacy Policy. In any case, the following retention periods will apply to the processing of your personal data for the purposes indicated below:

  • Data collected for the purposes as per Section 3, letter from a) to g) of this Privacy Policy is retained during the provision of the Websites and related features and services, plus the duration of the statute of limitation period under applicable laws, following the termination of such services; Data collected for the purposes as per Section 3, letter h) of this privacy policy is retained for the time necessary to log to the Website through a social network.
  • At the end of the retention period your personal data will be either cancelled, anonymized or aggregated.

B. Additional rights

In addition to the rights as indicated in this Section 7 of this Privacy Policy when the Privacy Regulation becomes effective, you will have the right, in any given moment, to:

a. Request Transfer to limit the processing of your personal data where:

  • You contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
  • The processing is unlawful but you do not want us to erase your personal data;
  • We no longer need your personal data for the purposes of the processing, but you require the personal data for the establishment, exercise or defense of legal claims; or
  • You have objected to processing justified on legitimate interests, pending verification as to whether Transfer has compelling legitimate grounds to continue processing.

b.Object to the processing of your personal data;

c. Request the erasure of your personal data without undue delay;

Receive an electronic copy of your personal data, if you would like to port your personal data, that you have provided to us, to yourself or to a different provider (“data portability”), when the personal data is processed by automatic means and the processing is either (i) based upon your consent or (ii) necessary for the provision of the Website and related services and features; and

d. Lodge a complaint with the relevant data protection supervisory authority.


Third Party Sites

If you click on or interact with a hyperlink or advertisement that you find on the Website, you may leave our Website or send information to a different website or application. Our Privacy Policy does not apply to your interactions with third-party websites or mobile apps, even if you find a link to them on or access them through our Website, and so you should read the privacy policy of the third-party provider to see how your personal information will be treated on its site. We have no control over such third parties, their Internet sites, or their products or services. In particular:

External Websites

 If you click on or interact with any hyperlink on the Website, you will leave our Website and be redirected to the external websites (“External Websites“). Our Privacy Policy does not apply to your interactions with the External Websites, even if you access it through our Website, and so you should read the privacy policy of the External Websites to see how your personal information will be treated on it.

Changes in this Privacy Policy

We may amend this Privacy Policy at any time by posting the most recent version of the Policy on the Website, along with an indication of the date on which the Policy was amended most recently. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website. If we make any material changes to this Privacy Policy in the way we collect, use, and/or share personally identifiable information through the Website in a manner that expand our rights to use the personal information we have already collected from you, we will provide details of such material changes on the Website and provide you with a choice about our future use of that information.


If you want to access and correct your personal information and/or exercise rights in accordance with the law (including as set out in Section 7 above), or if you have questions or wish to send us comments about this Privacy Policy, please write us at –