1. 1. Name: Golden Light Travel Services Llc
      

1. Headquarters: Sharjah Media City, Sharjah, UAE
   
2. Email address: info@goldenlighttravelservices.com
3. Tax number: 104094284700001

(2) The purpose of this privacy notice is to define the scope of the personal data processed, the manner of data processing, ensure the enforcement of constitutional principles of data protection, data security requirements, and prevent unauthorized access, alteration, or disclosure of the data, in order to respect the privacy of individuals.
(3) For the purpose stated in paragraph (2), we will process your personal data confidentially, in compliance with applicable legal requirements, ensuring its security, taking the necessary technical and organizational measures, and establishing procedures required to enforce relevant legal provisions and other recommendations.

2. Legal Background

The data processing we perform is primarily governed by the following laws:

• Act V of 2013 on the Civil Code, Section 2:43(e) (“Civil Code”)
• Act CXII of 2011 on informational self-determination and freedom of information (“Data Protection Act”)
• Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”)
• Act CVIII of 2001 on certain issues of electronic commerce services and information society services (“E-Commerce Act”)
• Act XLVIII of 2008 on the basic conditions and certain restrictions of economic advertising activities (“Advertising Act”)
• Act VI of 1998 on the proclamation of the Convention for the protection of individuals with regard to automatic processing of personal data, Strasbourg, January 28, 1981
• Act CXIX of 1995 on the handling of name and address data for research and direct marketing purposes (“Data Act”)

3. Legal Basis for Data Processing

We process your personal data under the following legal grounds in accordance with applicable data protection laws:

• Article 6(1)(a) GDPR: Your voluntary consent based on appropriate information.
• Article 6(1)(b) GDPR: Data processing necessary for the performance of a contract in which the data subject is one of the parties (performance of the contract)
• Article 6(1)(c) GDPR: Data processing required for compliance with a legal obligation of the data controller (such as fulfilling accounting or bookkeeping obligations (legal obligation))
• Under Section 13/A of the E-Commerce Act of 2001, data about the user’s identity (name, birth name, mother’s birth name, place and date of birth) and address can be processed without the user’s consent for the creation, modification, monitoring of the contract related to the provision of information society services, invoicing the related fees, and enforcing claims.
• Under Section 6(1) of the Advertising Act, the personal data of a natural person may only be used for direct marketing (via electronic mail or equivalent personal communication) if the recipient has explicitly consented to it in advance.

4. Scope of Data Processed, Purpose of Data Processing, and Duration

4.1 Newsletter Service

The Portal provides an option for subscribing to newsletters. We will only send you newsletters if you have given your explicit consent by checking the appropriate box on the Portal.

For the newsletter service, we process the following data:

• Full name
• Email address
• Address
• Phone number

Purpose of data processing: To continuously inform you, as a subscriber, about the latest news and updates regarding the services we offer.

You may unsubscribe from the newsletter service at any time, without restriction or justification, free of charge. In this case, we will immediately delete your data from our records.

You can withdraw your consent by:

• Clicking the unsubscribe link in the newsletter
• Sending a letter to our mailing address

Please note that the withdrawal of consent does not affect the lawfulness of data processing carried out based on your consent prior to its withdrawal.

Legal basis for data processing: Article 6(1)(a) GDPR, and Section 6(1) of the Advertising Act – Your prior, voluntary consent.

Duration of data processing: Until you withdraw your consent.

4.7 Use of Cookies

What cookies do we use?

There are cookies that we must store because without them the Portal would not work. These are called technically necessary cookies. We are allowed to use these cookies without your consent.

• Cookies that store the data you have entered: These cookies are automatically deleted from your computer when you close your browser. These cookies only serve to identify your computer and do not store personal information.
• Authentication session cookies: These are used to identify users after logging in, ensuring that users can access personal pages and do not need to log in again for each click during navigation.
• User-centered security cookies: These cookies are designed to enhance the security of the service explicitly requested by the user, such as detecting repeated unsuccessful login attempts or other similar mechanisms to protect the login system against abuse. While authentication cookies typically expire at the end of the session (when exiting the browser), security cookies have a longer expected expiration time to fulfill their security purpose.
• Cookies that help customize the user interface: These cookies are used to store preferences related to the service, which do not relate to permanent identifiers like a username (e.g., language preference, desired display format for query results).

There are cookies that we can only use if you have given prior consent. These are as follows:

• Cookies for performance enhancement: These cookies collect data about how you use the Portal. We use Google Analytics cookies to better understand our users’ behavior, characteristics: which subpages, how often, and for how long they visited. These cookies only identify your computer, and the data collected is anonymous.
• Functional cookies: These allow the Portal to remember your previous settings, thus providing you with a higher quality experience.

• Google Adwords: It is used to remember your recent searches, interactions with ads from individual advertisers or search results, and visits to advertisers’ websites. The AdWords conversion tracking feature uses cookies. When a user clicks on an ad, cookies are saved on their computer to track sales and other conversions resulting from the ad.
• Google Analytics: Google Analytics is Google’s analytical tool that helps website and app owners get a more accurate picture of their visitors’ activities. The service may use cookies to collect and report statistical data about website usage without identifying visitors individually to Google. In addition to the website usage statistical reports, Google Analytics – together with some of the advertising cookies mentioned earlier – can also be used to display more relevant ads on Google products (e.g., Google Search) and across the web. More details http://www.google.com/analytics/
• Facebook Pixel, also known as Facebook Pixel: This is a code placed in the Portal’s source code that allows us to display personalized ads to Portal visitors on Facebook.

More details https://www.facebook.com/business/help/651294705016616

Legal basis for data processing: Your prior, voluntary consent

Duration of data processing: Until you withdraw your consent.

Please note that withdrawing your consent does not affect the lawfulness of the data processing performed before your withdrawal.

4.9 Log files

To provide the services, the system automatically logs the following data:

• Your computer’s dynamic IP address
• Your browser and operating system type, depending on your computer’s settings
• Your activity related to the website
• The time of the activity

Purpose of data processing: These data are used for technical purposes, such as analyzing the secure operation of servers, post-checking, and for generating website usage statistics and analyzing user needs in order to improve the quality of the services.

The above data cannot be used to identify you and are not linked with other personal data.

Data retention period: 180 days from creation

4.10 Data processing for purposes other than those listed above

Your personal data can only be processed for purposes other than those defined above – including enhancing the effectiveness of the service or for market research purposes – with prior determination of the data processing purpose and based on your consent.
These data cannot be linked to your identification data and cannot be shared with third parties without your consent.

We are obliged to delete this data if the purpose of data processing has ceased or if you request it.

5. Data processors’ details, contact information:

• For extracting independent traffic and other web analytics data of the Portal, we use the Google Analytics software, so in relation to this data, Google Inc. acts as the data processor. Google’s Privacy Policy can be found at http://www.google.com/intl/hu ALL/privacypolicy.html.

By using the Portal, you consent to the processing of your data by Google.

• Newsletter service providers who are involved in sending newsletters. In this process, the name and email address of the data subject are processed to the extent necessary for the sending of the newsletter. Name: Bithuszárok Számítástechnikai és Szolgáltató BT. Registered address: 2051 Biatorbágy, Damjanich utca 8.
  Email: info@listamester.hu

1. We reserve the right to use additional data processors beyond those listed above, and we will publish the names and addresses of these data processors in an accessible manner no later than at the time the data processing begins.

6. Individuals entitled to access your personal data:

Our own employees, contractors, and other collaborators who need to access the processed data to perform their duties or tasks. We are obliged to ensure that those entitled to access the data we process always comply with the provisions of this data processing notice and the relevant laws.

The data you provide during the use of the Portal is stored on our own server, protected by SSL encryption, and only those authorized by the Data Controller can access this data through the Portal’s password-protected Admin Panel.

7. Your rights regarding data processing

7.1 Right to request information

(1) Upon your request, we will inform you, without undue delay but no later than 25 days from the submission of your request, in writing – including electronically – about the data we process, the source of the data, the purpose, legal basis, duration of processing, the name and address of the data processor, and the related activities. If your personal data is transferred, we will also inform you about the legal basis and the recipient of the data transfer.

(2) The information is free of charge. However, if the request is clearly unfounded or – particularly due to its repetitive nature – excessive, considering the administrative costs related to providing the requested information or taking the requested action:

1. a) we may charge a reasonable fee, or
2. b) we may refuse to act on the request.

It is our responsibility to prove the clearly unfounded or excessive nature of the request.

7.2 Right to erasure

(1) We are obliged to delete the personal data if:

1. a) its processing is unlawful;
2. b) You withdraw the consent on which the processing is based, or request the deletion of your data and there is no other legal basis for processing;
3. c) it is incomplete or inaccurate – and this condition cannot be lawfully rectified – provided that deletion is not excluded by law;
4. d) the purpose of the data processing has ceased, or the legal retention period for the data has expired;
5. e) the data deletion has been ordered by a court or authority.

(4) Instead of deletion, we will block the personal data if the data subject requests it, or if it is presumed based on available information that deletion would violate your legitimate interests. The blocked personal data can only be processed as long as the data processing purpose that excludes deletion persists.

7.3 Right of access

(1) You have the right to receive feedback from us on whether your personal data is being processed and, if such processing is occurring, to access the following information about your personal data:

1. the purpose of processing
2. the categories of personal data concerned
3. the recipients with whom/which your personal data has been or will be shared, particularly third-country recipients and international organizations
4. the duration for which the personal data will be stored, or if that is not possible, the criteria used to determine that period
5. your right to request the rectification, deletion, or restriction of processing of your personal data, and to object to the processing of such data;
6. the right to lodge a complaint with a supervisory authority;
7. if the data was not collected from you, any available information on the source of the data

(2) We will provide a copy of the personal data subject to processing. For any additional copies requested by you, the data controller may charge a reasonable fee based on administrative costs. If the request was submitted electronically, we will provide the information in a widely used electronic format, unless you request otherwise.

7.4 Right to Rectification
(1) Upon your request, we will rectify any inaccurate personal data concerning you without undue delay.
(2) If the correct or supplementary data is not available, we will perform the rectification and supplementation via a supplementary statement.
7.5 Right to Object
(1) You have the right to object to the processing of your personal data if:

1. the processing or transfer of personal data is necessary solely for the fulfillment of a legal obligation or for the legitimate interest of us or a third party, except in cases of mandatory data processing;
2. the use or transfer of personal data is for direct marketing, public opinion polling, or scientific research purposes; and
3. in other cases defined by law.

(2) We will examine the objection and inform you of the outcome in writing, within the shortest time possible, but no later than 15 days from the submission of the request.
If the objection is justified, we are obliged to cease the data processing – including further data collection and transfer – and to block the data, as well as notify those to whom we have previously transferred the personal data affected by the objection, and who are required to act to enforce the objection.
If you disagree with our decision or if we fail to meet the 15-day deadline, you may appeal to the court within 30 days from the communication of the decision or the last day of the deadline.
7.6 Right to Restrict Processing
(1) We will restrict the processing of data if any of the following apply:

1. You dispute the accuracy of the personal data;
2. the data processing is unlawful, and you oppose the deletion of data, requesting instead the restriction of its use;
3. we no longer need the personal data for processing purposes, but you require it for the submission, enforcement, or defense of legal claims; or
4. You have objected to the data processing.

(2) If the processing is restricted, the personal data will only be processed with your consent, or for the submission, enforcement, or defense of legal claims, for the protection of another individual’s or legal entity’s rights, or for important public interests of the Union or any member state, except for storage.
7.7 Right to Data Portability
You have the right to receive the personal data you have provided to us, in a structured, commonly used, machine-readable format – if technically feasible – if the processing is based on your consent or contract, and the processing is carried out automatically.
If your request for rectification, restriction, or deletion cannot be fulfilled, we will inform you in writing of the refusal, including the factual and legal reasons, within 25 days of receiving the request.
The rights outlined in this section may be restricted by law in cases related to national and internal security, such as defense, national security, crime prevention or prosecution, the safety of the penitentiary system, as well as state or municipal financial or economic interests, the significant economic or financial interests of the European Union, and the prevention and investigation of disciplinary and ethical violations related to professional activities, labor law and occupational safety obligations – including supervision and control – as well as the protection of the rights of the data subject or others.

8. Legal Remedies

If you believe your rights have been violated, you can seek legal remedies from:
The Office of Data Protection Authorities Building ADGM Square Al Maryah Island Abu Dhabi UAE
The data processing notice is valid from May 24, 2024, until further notice>