1. Who we are
Traveloptix is developing distinct Personal Travel, Business Travel and Travel Partners experiences. The precise registered legal entity, company number, registered office and privacy contact must be confirmed and published before this notice becomes final. Contact us through the Contact page.
Depending on the service and arrangement, Traveloptix may act as a controller or processor. For Corporate and Partner services, the relevant organisation's role and instructions must be established contractually; they must not be assumed to be identical to Personal Travel.
2. Applicable data protection law
Our Isle of Man starting framework is the Data Protection Act 2018, the Data Protection (Application of GDPR) Order 2018 and associated implementing regulations. The Isle of Man's adapted GDPR framework is often called the Applied GDPR. The EU GDPR and UK GDPR may also apply directly to particular activities depending on their territorial scope. Their applicability must be assessed rather than presumed.
The Isle of Man supervisory authority is the Information Commissioner.
3. Information we may process
Depending on the features used, information may include names, contact details, account credentials, traveller profiles, trip requirements, search history, booking references, itineraries, travel documents, preferences, customer support communications, billing records, security logs and device or website usage information.
Some travel arrangements may require sensitive information, such as accessibility or health-related assistance requirements. Such information needs an additional lawful condition where required, access restrictions and minimisation.
4. Purposes and lawful bases
Potential purposes include operating accounts and travel services, searching and arranging bookings, managing itineraries, providing disruption support, preventing fraud, securing the platform, administering payments and meeting legal obligations. Lawful bases may include contract necessity, legal obligation, legitimate interests and consent, depending on the processing activity. We must document the actual purpose and lawful basis for each processing operation before launch; consent is not a blanket basis for all travel processing.
5. How information is collected and shared
Information may be supplied by travellers, authorised corporate or agency representatives, suppliers and travel-related service providers. Where needed to fulfil an authorised arrangement, relevant details may be shared with airlines, accommodation providers, transport operators, booking intermediaries, payment processors, technology providers and authorised servicing partners. Actual recipients and processor agreements require verification.
Personal, Corporate and Third-Party environments must retain separate identities and access permissions. Acting for a traveller does not imply ownership of their identity or unrestricted access to their information.
6. International transfers
Travel inherently involves cross-border disclosures. Transfers outside the Isle of Man or other applicable protected jurisdictions must be assessed against applicable adequacy rules and safeguards, such as recognised contractual mechanisms, with additional measures where necessary. No particular transfer safeguard is claimed here until the real supplier and hosting arrangements have been assessed.
7. Retention and security
We intend to retain information only for justified periods linked to travel servicing, contractual duties, statutory record-keeping, security and dispute handling. Exact retention periods must be documented and published by data category before launch. Appropriate technical and organisational measures should include access controls, encryption where suitable, logging, supplier due diligence and incident response. No system can guarantee absolute security.
8. Your rights
Subject to the applicable legislation and exemptions, rights may include access, rectification, erasure, restriction, objection, portability and rights concerning qualifying automated decisions. Individuals may also withdraw consent where processing relies on consent, without affecting prior lawful processing. Requests will be assessed under the applicable framework and verified appropriately.
9. Cookies, marketing and choices
Our separate Cookie Policy explains website storage and preferences. Optional analytics or marketing technologies must not be activated before any required consent. Marketing communications require their own applicable legal assessment and opt-out arrangements.
10. Questions and complaints
For privacy enquiries, email contact@traveloptix.com. A designated privacy contact, if required, will be confirmed before final publication. Individuals may complain to the Isle of Man Information Commissioner, and in some circumstances another competent supervisory authority. This draft will be updated when the service's verified operational practices are available.