1. Introduction

Welcome to the web site (the “Site”) of Seagull Group Ltd (“Seagull Group”, “we”, “us” and/or “our”), a company incorporated in Lithuania. This Privacy Notice (“Notice”) sets out how we protect the privacy of your Personal Information. The registration and mailing address for Seagull Group is J. Savickio str. 8, LT-01108, Vilnius, Lithuania. Registration number of our company is 300618042 and tour operator licence number is 13664 (issued by the Lithuanian State Department of Tourism).

We will be a “data controller” for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) for any personal information you provide to us in connection with our relationship.

Seagull Group, doing business as Seagull Group and Seagull Travel, is a Full-Service Baltic Sea Region Destination and Corporate Event Management Company, founded in 2006. We need to collect, use, and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. GDPR does not apply to information already in the public domain. We will be a “data controller” for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) for any personal information you provide to us in connection with our relationship.

2. Personal Information we collect and use

We collect Personal Data from you when you voluntarily provide such information such as when you register for access to the Services (for example, name, email address, and payment information), use certain Services, contact us with inquiries or respond to one of our surveys. Wherever Seagull Group collects Personal Data we make an effort to provide a link to this Privacy Policy. 

We usually process the following information you submit with the course of your relationship with us. We will collect this information directly from you:

• Contact information (name, surname, email, phone number);
• Payment information (credit/debit card details, including card type, card number, security number, and expiry date);
• Copy of the identity card;
• Information about your dietary requirements and health issues (if any);
• Other details relevant to your travel arrangements or requested by the relevant service providers (e.g. accommodation).

Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.

In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveler on the booking.

Where you make a travel booking on behalf of another person (e.g. a family or group booking or a travel booking made for an employee), you agree you have obtained the consent of the other person for Seagull Group to collect, use and disclose the other person’s personal information in accordance with this Notice and that you have otherwise made the other person aware of this Notice. 

You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person’s personal information to us.

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include but is not limited to your name (“Personal Information”). 

Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, and the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this. 

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information. 

3. Security 

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security, so you should take special care in deciding what information you send to us in this way. 

4. Linked Sites

Our websites may contain links to third party websites over which we have no control. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy policies of any linked third party websites you visit as their privacy policy and practices may differ from ours.

5. Your Rights

You have a right to update, modify, delete or obtain a copy of personal information that we hold on you. Also, restrict or stop us from using your Personal Information. You can request this by emailing us at the address you find contact us section.

Please note that, if you request that we restrict or stop using personal information we hold on you, or withdraw a consent you have previously given to the processing of such information, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveler’s full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information. You must always provide accurate information and you agree to update it whenever necessary. 

You also agree that, in the absence of any update, we can assume that the information submitted to us is correct unless we subsequently become aware that it is not correct. 

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us.

You have the right to raise any issues or concerns directly by contacting us or your National Data Protection Authority.

6. Changes to our Notice

We reserve the right to update or change our Notice at any time and you should check this Notice periodically. Your continued use of the Service after we post any modifications to the Notice on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Notice. If we make any material changes to this Privacy Notice, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website. 

If you have any questions about this Privacy Policy, please contact us.