Europe in Click Ltd
A private company registered in Israel · Company no. 517395828
Privacy and Cookie Policy
An annex forming an integral part of the Terms of Engagement
This is a translation provided for convenience. The binding text is the Hebrew original, published at clickincorfu.co.il/privacy-policy. Where the two differ, the Hebrew governs. Nothing here limits any right you may have under the data-protection law of your own country of residence.
Recitals
Whereas the Company collects and processes personal information about its customers and the users of its websites, in the course of acting as an intermediary for tourism services;
And whereas fulfilling a booking necessarily involves passing passenger details to the supplier in the destination;
And whereas the Company wishes to tell people plainly what is collected, what it is used for, who receives it, how long it is kept and what rights they have;
The following is declared and made known:
To fulfil a booking, the Company passes passenger details to the supplier in the destination, including to countries outside Israel. That transfer is necessary to perform the contract; without it the service cannot be provided.
The supplier is an independent controller who decides for itself how it uses the information it receives, under its own privacy policy and the law of its own country. The Company does not sell, rent or trade personal information, and does not pass it to third parties for their own marketing.
Chapter OneWho holds the data and how to reach us
Database owner and controller: Europe in Click Ltd, company no. 517395828 (the "Company").
Address: 9 HaHermon St, Snir, Israel · Telephone: +972-55-720-0440 · Email: info@clickincorfu.co.il
This policy is written under the Israeli Protection of Privacy Law, 1981, including Amendment 13, the Protection of Privacy (Data Security) Regulations, 2017, and the Protection of Privacy (Transfer of Data to Databases Abroad) Regulations, 2001.
Any question, request or complaint about privacy should go to info@clickincorfu.co.il, and the Company will answer within a reasonable time and in any event within the time the law allows.
Chapter TwoWhat we collect
The Company collects the categories below, and no others:
| Category | Detail | When it is collected |
|---|---|---|
| Identity and contact | Full name as it appears in the passport, telephone number, email address, country of residence | When booking, or on signing up for mail |
| Booking details | Destination, dates, number of passengers, type of service, special requests, booking number | When booking |
| Travel document details | Passport number and expiry, date of birth, and driving licence number for a vehicle rental | Only where the supplier makes the service conditional on it |
| Payment details | Last four digits, card type, amount and date. The full card number is never stored | On payment |
| Correspondence | Contacts by email, telephone, SMS and messaging apps, including complaints | When you contact us |
| Technical data | IP address, browser and device type, pages viewed, referral source, cookie identifiers | While browsing, subject to cookie consent |
| Record of consent | When the terms were accepted, which version, the IP address, and consent to marketing | When booking |
The Company does not ask for, and does not knowingly collect, health information. If you tell us about a medical condition so that the service can be adapted, it is used for that purpose alone, passed to the relevant supplier, and deleted when the service ends.
Chapter ThreeWhether you have to give it, and what happens if you do not
There is no legal obligation to give the Company any information. That said, identity and booking details are a necessary condition of making a booking: without them the Company cannot place the booking with the supplier.
Travel document details are required only where the supplier makes the service conditional on them, and the Company will say so expressly when it asks.
Giving details for marketing is entirely voluntary, and neither withholding them nor unsubscribing has any effect on your ability to book or on the terms of a booking.
Chapter FourWhat we use it for
The Company uses the information only for the purposes below, and will not use it for another purpose without telling you and, where required, obtaining your consent:
placing the booking and passing it to the supplier;
operational messages: confirmations, vouchers, notice of changes, reminders and arrival instructions;
customer service, investigating problems and handling complaints, including with suppliers and airlines;
charging, collection, refunds and invoicing;
meeting legal obligations, including tax and record-keeping;
preventing fraud and securing the Company's systems;
improving the site and the service, on the basis of aggregated statistics;
sending marketing messages, subject to express consent as set out in Chapter Eight below;
defending legal rights and conducting proceedings.
In line with the principle of purpose limitation in the law, the information is not used beyond the purposes for which it was collected.
Chapter FiveWho else receives it
Suppliers in the destination. This is the main transfer and it is necessary to fulfil the booking. Only the details the supplier needs in order to provide the service are passed. The supplier is an independent controller, not a processor acting for the Company.
Service providers acting for the Company, on its instructions and under obligations of confidentiality and security: the payment processor, hosting and cloud providers, the customer relationship system, the mailing system and the analytics provider.
Competent authorities, where the Company is required to do so by law or by court order.
Professional advisers, including lawyers and accountants, to the extent needed and subject to the duty of confidence that binds them.
On a corporate change, including a merger or a transfer of the business, provided the recipient takes on the obligations in this policy.
Chapter SixTransfers outside Israel
Given the nature of the Company's business, information is transferred outside Israel, mainly to European countries where its suppliers operate, and to infrastructure and software providers based abroad.
Transfers are made under the Protection of Privacy (Transfer of Data to Databases Abroad) Regulations, 2001, on one of these bases: the transfer is necessary to perform the contract with the person concerned; the receiving country maintains an adequate level of protection; or the recipient has given a written undertaking to meet the conditions of transfer and to keep the information safe.
The countries of the European Union, where most of the Company's suppliers operate, are subject to a comprehensive data-protection regime.
Chapter SevenCookies and tracking
The site uses cookies and similar technologies. Cookies that are not strictly necessary are loaded only after consent, given through the consent banner on the site.
| Type | Purpose | Consent needed |
|---|---|---|
| Strictly necessary | Running the site, keeping your basket, security and load balancing | No |
| Preferences | Remembering language, currency and display settings | Yes |
| Statistics | Measuring traffic and improving the site | Yes |
| Marketing | Measuring campaigns and showing relevant advertising | Yes |
The banner lets you accept everything or reject everything that is not strictly necessary. It is stated here that refusing is available in the same first layer as accepting, in one click and with no extra step.
You may change or withdraw consent at any time, through the "Cookie settings" link at the foot of every page and through your browser settings. Withdrawing consent does not affect the lawfulness of what was done beforehand.
Some of these tools process information in the United States. They run only with your consent.
Chapter EightMarketing messages
Marketing messages are sent only after express consent, under section 30A of the Israeli Communications (Telecommunications and Broadcasting) Law, 1982.
The marketing consent box on the site is never ticked in advance, and ticking it is never a condition of making a booking.
Every marketing message carries the word "advertisement" prominently at its start, the Company's name and address, and how to unsubscribe.
You may unsubscribe at any time, through the link in the message, by replying on the same channel it arrived on, or by writing to info@clickincorfu.co.il. It is done without delay and without conditions.
Service messages are not advertising. A booking confirmation, a voucher, notice of a change and an arrival reminder are sent even to someone who has unsubscribed, because they are needed to perform the contract. The Company undertakes not to put marketing content inside a service message.
Chapter NineHow long we keep it
| Category | Retention | Why |
|---|---|---|
| Booking documents, invoices and payment records | 7 years | Tax record-keeping obligations |
| Record of acceptance of the terms | 7 years | Evidence in answer to a later claim |
| Correspondence and complaints | 7 years | The civil limitation period |
| Passport and travel document details | Up to 90 days after the service | Deleted at the earliest point possible |
| Health information volunteered by the customer | Until the service ends | Deleted immediately afterwards |
| Mailing list | Until you unsubscribe | Unsubscribing is acted on without delay |
| Technical data and cookies | Up to 24 months | Or until consent is withdrawn, whichever is sooner |
At the end of the retention period the information is deleted or irreversibly anonymised, except where the law requires it to be kept or it is needed for pending legal proceedings.
Chapter TenSecurity
The Company takes reasonable technical and organisational security measures under the Protection of Privacy (Data Security) Regulations, 2017, including encryption in transit, access control on a need-to-know basis, password management, backups and logging of access to data.
Payments are handled by a licensed payment processor certified to PCI-DSS, and the full card number is never stored on the Company's systems.
In the event of a serious security incident, the Company will report it to the Israeli Privacy Protection Authority as the law requires, and will notify those affected where notification is required.
No online system is completely secure. The Company works continuously to improve its defences, and invites you to report any suspected security problem to info@clickincorfu.co.il.
Chapter ElevenYour rights
Access. You may inspect the information the Company holds about you. The Company will answer within the time the law allows.
Correction. If the information is inaccurate, incomplete, unclear or out of date, you may ask for it to be corrected or deleted.
Removal from the marketing database. You may require at any time that your information be removed from any database used to send commercial offers. This is done without delay and without conditions.
Information about use. You may ask what purposes your information has been used for and to whom it has been passed.
To exercise these rights, write to info@clickincorfu.co.il. The Company will verify your identity before disclosing information, which is a protection for you.
If the Company refuses a request, it will say so in writing with its reasons, and you may then apply to the Israeli Privacy Protection Authority or to the court as the law provides.
Chapter TwelveChildren
The service is intended for people aged eighteen (18) and over. The Company does not knowingly collect information from children. Details of children travelling on a booking are given by the responsible adult, who is also responsible for their content and accuracy.
If the Company learns that information has been collected from a child without the permission of the adult responsible for them, it will delete it.
Chapter ThirteenChanges to this policy
The Company may amend this policy from time to time. The current text is published on this page, with a version number and a date it takes effect.
A material change, in particular to the purposes of use or to who receives the information, is brought to people's attention actively before it takes effect.
This document was drafted in Hebrew. The English edition is published for the reader's convenience. The Hebrew is the binding text, and where the two differ the Hebrew governs.