Privacy policy
Draft document. The text below is a working draft and is not the binding version — the final wording is being prepared by legal counsel.
Last updated: September 11, 2026
1. Who controls your data
Your personal data is controlled by AVENTOUR Sp. z o.o., registered in Warsaw (00-682), ul. Hoża 86 lok. 410, NIP 7011290672, KRS 0001210793.
Office and postal address: Warszawa, al. Jana Pawła II 11. Contact: info@hottour.pl, phone +48 69 009 13 31.
We have not appointed a data protection officer. For anything about your personal data, write to the address above.
2. What we collect and why
a) Trip enquiry (form and chat). We collect your name, phone number and what you tell us about the trip — destination, dates, how many people, budget, preferences. Why: to put together an offer and get back to you. Legal basis: art. 6 ust. 1 lit. b RODO (GDPR) — steps taken at your request before entering into a contract.
b) Continuing the conversation in a messenger. If you move from the chat on this site to Telegram, we pass your earlier answers across so you do not have to repeat them. Legal basis: art. 6 ust. 1 lit. b RODO (GDPR) and your own action — clicking the link.
c) Statistics and marketing. We collect your IP address, browser type, where you came from and how you use the site. Why: to see how the site is used, improve it and target ads. Legal basis: art. 6 ust. 1 lit. a RODO (GDPR) — your consent in the cookie banner. Without consent no analytics or marketing tool runs at all.
d) Defending and pursuing claims. Legal basis: art. 6 ust. 1 lit. f RODO (GDPR) — our legitimate interest.
⚠️ We do not collect passport details or dates of birth through this site. Anything needed for a booking you give to the consultant directly, off the site.
3. Who receives your data
| Recipient | Role | Location |
|---|---|---|
| Tour operators (including Anex/Orex Travel, JoinUp, TUI Poland, Itaka, Rainbow) | booking the trip you choose | EU / [TO BE VERIFIED BY LEGAL COUNSEL] |
| Otpusk (TAT) | tour search engine | Ukraine |
| Iterios | CRM — handling your enquiry | Ukraine |
| Anthropic PBC | AI assistant that runs the chat | USA |
| Google Ireland Ltd. | Google Analytics 4 — statistics; Google Maps — map on the hotel card (only with consent) | EU |
| Meta Platforms Ireland Ltd. | Meta Pixel — advertising (only with consent) | EU |
| Telegram | messenger, if you choose it to carry on the conversation | [TO BE VERIFIED BY LEGAL COUNSEL] |
4. Transfers outside the EEA
Some of our providers operate outside the European Economic Area:
- Ukraine — Otpusk (TAT), Iterios. The European Commission has recognised an adequate level of data protection for Ukraine [TO BE VERIFIED BY LEGAL COUNSEL] — check the current status of the adequacy decision.
- USA — Anthropic PBC. The transfer relies on Standard Contractual Clauses (SCC) approved by the European Commission [TO BE VERIFIED BY LEGAL COUNSEL] — confirm the basis in the provider agreement.
You can ask for a copy of the safeguards in place by writing to info@hottour.pl.
5. How long we keep it
| Type of data | Retention |
|---|---|
| Chat transcript | 45 days |
| Enquiry details (name, phone, preferences) | [TO BE COMPLETED] — retention period in the CRM |
| Completed booking records | for as long as tax and accounting rules require [TO BE VERIFIED BY LEGAL COUNSEL] |
| Analytics data (cookies) | up to 14 months, or until you withdraw consent |
6. Your rights
You have the right to:
- access your data and get a copy of it,
- have it corrected,
- have it deleted,
- restrict how it is processed,
- move it to another provider,
- object to processing based on legitimate interest,
- withdraw consent at any time — this does not affect processing that happened before you withdrew it (cookie settings are in the site footer).
You can also complain to the supervisory authority: Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, Poland.
7. Is it optional?
Giving us your data is voluntary, but we cannot prepare an offer without it. With no phone number or other way to reach you, we have no way to show you what is available.
8. Automated decision-making
The chat on this site is run by an AI assistant: it gathers your preferences and puts together a first shortlist. It does not make decisions with legal consequences — the final offer is prepared and presented by a consultant. You can ask to speak to a person at any point.
⚠️ [TO BE VERIFIED BY LEGAL COUNSEL] — assess whether this amounts to profiling within the meaning of art. 22 RODO (GDPR).
9. Cookies
Details about cookies, including how to change your consent, are in the settings available in the site footer.