1. Who Is Responsible for Your Data
The data controller for personal data collected through this website is:
[Business legal name — sole proprietorship / CEIDG entry]
[Registered business address, Krakow, Poland]
NIP: [NIP xxx-xxx-xx-xx]
Email: info@eltours.com
2. What Data We Collect
We collect personal data that you provide directly to us:
- Enquiry form: name, email address, phone number, number of travellers, preferred tour, preferred dates, and any details you choose to share in your message (which, for genealogy enquiries, may include family names or ancestral towns).
- Direct communication: any information you share by email, phone or WhatsApp.
- Review form: the name and country you choose to show, the tour you took, your rating and review text, and your email address (used only to verify the review and never published). A review is published on this website only if you tick the consent box, and you can ask us to remove it at any time.
We do not knowingly collect any special category data (Article 9 GDPR) unless you choose to share it voluntarily (for example, historical or family details relevant to a genealogy tour), in which case we treat it with particular care and only for the purpose of preparing your tour.
3. How We Use Your Data, and Our Legal Basis
| Purpose | Legal Basis (GDPR) |
|---|---|
| Responding to your enquiry | Art. 6(1)(b) — steps taken at your request prior to a contract |
| Planning and delivering a booked tour | Art. 6(1)(b) — performance of a contract |
| Keeping booking & financial records | Art. 6(1)(c) — compliance with a legal obligation |
| Responding to complaints | Art. 6(1)(f) — our legitimate interest in resolving disputes fairly |
We do not use your data for automated decision-making or profiling, and we do not send marketing communications unless you separately opt in to receive them.
4. Who We Share Data With
We do not sell your personal data. We share it only with the following categories of recipients, each acting as our processor or as an independent controller of their own service:
- FormSubmit (or equivalent form-processing service) — delivers enquiry-form and review-form submissions to our email inbox.
- Google — if you choose to load the embedded map, Google processes data as described in Google's Privacy Policy.
- European Legacy Tours (Eltours) — only if you ask us to introduce you for a multi-day itinerary; in that case, relevant contact details are shared with your consent so they can contact you directly.
- Professional advisers or authorities, where required by law.
5. International Data Transfers
Google's services may process data on servers located outside the European Economic Area. Where this occurs, Google relies on recognised safeguards such as the EU Standard Contractual Clauses. We do not otherwise transfer your data outside the EEA.
6. How Long We Keep Your Data
Enquiries that do not lead to a booking are kept for up to 12 months, then deleted. Data relating to confirmed bookings is kept for the period required by Polish tax and accounting law (generally 5 years from the end of the relevant tax year). You can ask us to delete data sooner, subject to Section 8 below.
7. Cookies & This Website
This website does not use first-party analytics, advertising or tracking cookies. The Google Map on our Contact page is loaded only if you actively click to reveal it, at which point Google may set its own cookies in line with its Privacy Policy. If a live Google Calendar booking widget is enabled on this site in future, the same applies to that widget while you are using it.
8. Your Rights
Under GDPR, you have the right to: access the personal data we hold about you; request correction of inaccurate data; request erasure ("right to be forgotten"); restrict or object to certain processing; and request data portability. You also have the right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.
To exercise any of these rights, contact us at info@eltours.com. You also have the right to lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (Urząd Ochrony Danych Osobowych, UODO), or with the supervisory authority in your own EU country of residence.
9. Providing Your Data
Providing your data via our enquiry form is voluntary, but necessary if you would like us to respond to your enquiry or arrange a tour — without it, we cannot process your request.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes to this website or to data protection law. The current version is always available on this page.
Questions about this policy can be sent to info@eltours.com.