Privacy Policy
Last updated: June 2021
1. Who are we and what do we do?
We are Origin B.V. (hereinafter, Origin). We are specialised in designing tailor-made trips for our Clients. Our travel specialists compose a trip that completely suits Clients’ personal needs, so that our Clients do not have the hassle of planning (our Service). In order to access our Service, our Clients (and potential Clients) can visit our Website (www.origin.me) or App (Origin - Curated Travel), and request an invitation within our online environment (the Website, App and online environment together, the Online Services).
This Privacy Policy applies to the Personal Data that is processed via our Online Services. This Privacy Policy is not applicable to any (Personal) Data collected offline or via channels other than our Online Services.
2. What is this?
This is our Privacy Policy. In this document we explain what kind of Personal Data we collect in relation to our Clients’ use of the Online Services. We also explain what role we have in the processing of Personal Data, how we protect and use the Personal Data and what rights you have as a data subject.
If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us. You can find our contact details below.
3. Privacy and the Privacy Legislation
At Origin, the privacy of our Clients is one of our top priorities. We process Personal Data. Personal Data means all information by which a person can be directly or indirectly identified – in line with the definitions of the General Data Protection Regulation (GDPR) and other relevant legislation on the protection of Personal Data (collectively referred to as the Privacy Legislation).
4. Our role as Controller
We collect and process the Personal Data in the context of our Service. We determine the purposes and means of these processing activities. This means we act as Controller within the meaning of the Privacy Legislation.
5. Personal Data we collect
• When you use our Online Services, we may process information on the device used to access our Online Services, IP-address and information on the used browser.
• When you request an invite via our Online Services, we may process the Personal Data you are asked to provide, such as: your first and last name, email address, and – if you choose to get higher on the invitation list (optional) – we may ask additional information on your travel behaviour, for example information about how often you travel, your travel expenses, whether you want to find out more about exclusive travel Services and options like, which kind of phone you use (iPhone, Android, otherwise) and which means of communication you do prefer.
• When you contact us directly, we may receive additional information about you, such as: your name, email address, phone number, the contents of the message and/or attachments you may send us and any other information you may choose to provide us with.
• When you register for an account, we may ask for your contact information, including items such as: name, company name, address, email address, and telephone number.
• When you use our Online Services, we may collect information about you and your use of our Service, your interactions with us and our advertising. This information includes: your activity on the Origin service, such as interactions with our published trips and inspiration items; your interactions with our emails and texts, and with our messages through push and online messaging channels; details of your interactions with our customer service or curators, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings
6. How we use your Personal Data
• When you use our Online Services, we process your (personal) data to provide, operate and maintain our Online Services. Next to that, we use the technical information to communicate with you in the same language of your browser and to adapt our Online Services to the device used. We also process these data to understand and analyse how you use our Online Services, and to further improve, personalize and expand our Online Services. This way we can develop and improve new products, services, features, and functionalities. We may process these data because we have a legitimate interest to do so, i.e. to provide you with good functioning Online Services and to improve our Services for our users.
• When you request an invite via our Online Services, we process your Personal Data in order to draw up a personal, tailor-made travel plan for you. We may process these Personal Data in order to perform a contract with you and/or take steps prior to entering into such contract. We may process the Personal Data you provide us in order to get higher on the invitation list based on your consent.
• When you contact us directly, we process your Personal Data to communicate with you and/or help you with your request submitted. We may process these Personal Data because we have a legitimate interest to contact and assist (potential) Clients based on their request.
• When you register an account, we process your Personal Data to enable you access to your account and provide you with our Online Services via your account. We may process these data, because this is necessary to perform our contract with you (i.e. give you access to an account, including all services related thereto).
• The Personal Data collected may also be used to detect and prevent fraud. We may process these Personal Data because we have a legitimate interest to detect and prevent fraud.
• We may use your personal data to communicate with you concerning our service so that we can send you news about Origin, details about new features and content available on Origin, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels.
• We may use your Personal Data we collect, including in combination with data from third parties for the purpose of personalizing and improving marketing communications (including ads). For that purpose, we may share Personal Data with third parties. We perform these activities on the basis that these are necessary for the purpose of our legitimate interests or on the basis of your consent. See the section titled "Your rights" for information on how to withdraw any consent you may have given.
7. Cookies and similar techniques
Our Website uses 'cookies'. A cookie is a simple small text file that can be stored in your computer when visiting the Online Services. This text file identifies your browser and/or device, so when you visit our Online Services again, the cookie ensures that we recognize your browser or device.
These cookies are used to allow our Online Services to function properly (functional cookies), to review the quality and effectiveness of the Online Services (analytical cookies), and to track click behaviour and the visited pages to optimize your experience on our Online Services by customizing our content based on this information (tracking cookies).
The information collected by these cookies include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. The purpose of the information is for analysing trends, administering the site, tracking users' movement on the website, and gathering demographic information.
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites. Bear in mind that some functions of our Online Services may not function, or not so well, without cookies.
For more general information on cookies, please visit:https://www.cookieconsent.com/what-are-cookies/.
8. How long do we keep the Personal Data?
We will delete the Personal Data if they are no longer necessary for the purposes as mentioned above. In any case, we use the following retention periods:
• Personal Data regarding potential Clients | These data are stored as long as necessary to determine whether we enter into an agreement with a potential Client and for a maximum period of 24 months after our last contact.
• Personal Data regarding Clients | This data is stored as long as our legal relation with our Clients’ endures. After our Client terminates the legal relationship (or the legal relationship is terminated automatically), we will delete the data related to this Client at the latest two (2) year after the termination of the legal relationship.
• Personal Data in our records for the tax authorities | These data are stored for seven (7) years, unless we are legally obliged to retain the data for a longer period.
• Other information | We store other Personal Data only for as long as necessary for the purposes. This means that other Personal Data will be deleted as soon as it is no longer necessary for the purposes for which we processed it.
9. Who do we share the Personal Data of our Client with?
We use processors to assist us in our Online Services provided. Within this context these processors receive Personal Data from us which they process by our order. We use, for instance, processors for hosting our data, managing our internal processes, and send service updates. We enter into a data processing agreement with all of our processors. Our use of processors is in accordance with the Privacy Legislation.
In addition, we may share some of the Personal Data processed as Controller with other controllers. For example, we share our financial administration with the national tax authorities, because we are legally obliged to do so.
Apart from the above, we will not share your Personal Data with third parties, unless we are legally obliged to do so.
10. Export of data outside the European Union
We may transmit Personal Data to parties outside the European Union, if one of our processors is established outside the European Union. The Personal Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with the European standards.
The transmission of data outside the EU will always happen in conformity with the Privacy Regulation (chapter 5 of the GDPR).
11. Changes of this Privacy Policy
We may update our Privacy Policy from time to time. When we change this Privacy Policy in a significant way, we will notify you via e-mail and post a notification on our Website along with the updated Privacy Policy.
12. Your rights
As laid down in the Privacy Legislation, you have the right to:
• Ask the Controller to rectify or update your Personal Data;
• Ask the Controller to remove your Personal Data from its systems;
• Ask the Controller for a copy of the Personal Data processed of you. Such copy may also be transferred to another data controller at your request. We may charge you a small fee for this copy;
• Withdraw your consent to process your Personal Data. This only affects the processing activities that are based on your consent and does not affect the validity of such processing activities before you have withdrawn your consent;
• Object to the processing of your Personal Data;
• File a complaint with the Dutch Data Protection Authority, if you believe that your Personal Data is processed unlawfully.
If you have any questions, comments or concerns regarding the way we handle your Personal Data, please contact us through the contact information below:
Origin B.V.
Singel 542
1017 AZ Amsterdam
Trade register number: 78463629