Privacy Policy

1. Introduction and Scope

Elit Travel Club respects the privacy of its users, members, guests, business partners, suppliers and website visitors. This Privacy Policy explains what personal data we collect, why we process it, how we share it, how long we retain it and what rights individuals may have.

This Policy applies to our website, mobile-compatible pages, membership area, Elite Member card program, hotel reservations, timeshare or vacation-period packages, quotation forms, call center, WhatsApp, e-mail, social media, payment, invoicing, customer support and marketing processes.

2. Data Controller

Depending on the relevant service, your personal data may be processed by Elit Travel Club and/or Tiffany Hotels & Resorts International Ltd. as data controller.

Contact: info@elittravelclub.com | Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom | Website: www.elittravelclub.com

In some cases, hotels, payment institutions, travel suppliers, transfer companies, insurance providers or technology vendors may act as independent controllers or processors.

3. Who This Policy Applies To

This Policy applies to website visitors, registered members, Elite Member users, customers making reservations, guests, payers, applicants, agents, suppliers, hotel representatives and all individuals who communicate with us.

For corporate customers, personal data relating to company representatives, authorized persons and contact persons is protected under this Policy.

4. Categories of Personal Data We Collect

Identity Data

• Name, surname, date of birth, nationality, gender, passport or ID information, tax identification number, signature and membership number.

Contact Data

• E-mail address, telephone number, WhatsApp number, address, country, city, postal code, billing address and emergency contact details.

Membership and Account Data

• Username, password, membership type, Elite Member card details, points/benefit records, account activity, preferences and favorites.

Reservation and Travel Data

• Destination, hotel, room type, season, week, check-in/check-out dates, number of guests, child guest information, transfer/tour requests and cancellation/change history.

Financial and Payment Data

• Payment amount, currency, payment date, payment method, invoice details, transaction reference, refund and chargeback records. Full card numbers and CVV codes are not stored by Elit Travel Club.

Call Center and Communication Records

• Call recordings, call date/duration, e-mail and WhatsApp correspondence, live chat records, complaint and request notes.

Marketing and Preference Data

• Marketing consents, e-mail/SMS/WhatsApp preferences, open and click records, interests and promotional usage history.

Technical and Digital Data

• IP address, device information, browser, operating system, language setting, session records, security logs, cookie identifiers and error logs.

Location and Route Data

• Approximate location, country/city information, pickup and drop-off points for transfers, map and route data.

Sensitive Data

Accessibility requests, health or mobility information, allergies or dietary requirements are processed only where requested by the user, based on explicit consent or where necessary to provide the service.

5. Sources of Personal Data

Personal data may be collected from forms completed directly by users, membership screens, reservation and purchase transactions, call center conversations, WhatsApp/e-mail/social media messages, hotels, agents, payment providers, technology vendors and legally available sources.

Technical and analytics data may also be collected through cookies, pixel tags, local storage, session storage and similar digital technologies.

6. Purposes of Processing

Service Delivery

• Creating membership accounts, making reservations, managing room/week/season selections, providing Elite Member benefits and customer support.

Contracts and Sales

• Preparing quotations, issuing sales contracts, managing distance sales and pre-information processes, collecting payment, issuing invoices and managing refunds and cancellations.

Finance and Legal Compliance

• Maintaining accounting records, meeting tax obligations, conducting audits, preserving evidence in disputes and making legal notifications.

Security and Risk Management

• Protecting account security, preventing fake reservations and payment fraud, conducting chargeback and suspicious transaction controls.

Marketing and Analytics

• Offering campaigns, showing personalized travel recommendations, managing loyalty programs, conducting surveys, measuring website performance and improving services.

7. Legal Bases

We process personal data based on consent, performance of a contract, compliance with legal obligations, legitimate interests, establishment/exercise/defense of legal claims, pre-contractual steps requested by the user and emergency requirements.

For users in the European Union/European Economic Area and the United Kingdom, GDPR and UK GDPR principles apply. For users in Türkiye, Law No. 6698 on the Protection of Personal Data applies. Other local privacy laws may apply depending on location.

8. Sharing of Personal Data

Personal data may be shared, where necessary, with hotels, resorts, local operation teams, transfer companies, tour and activity providers, car rental companies, insurance/assistance providers, banks, virtual POS and payment institutions, CRM and technology providers, cloud/hosting providers, accounting and legal advisors, group companies, public authorities and courts.

Data sharing is carried out in line with data minimization, purpose limitation, contractual confidentiality and security principles.

9. International Data Transfers

Because Elit Travel Club provides global tourism and accommodation services, your personal data may be transferred to hotels, suppliers, technology systems, payment providers or group companies outside your country.

Countries of transfer may include the United Kingdom, Türkiye, EU/EEA countries, the United States, Cuba, Canada, Singapore, the United Arab Emirates and other countries where services are provided or supported.

International transfers may rely on standard contractual clauses, data processing agreements, explicit consent, transfers necessary for contract performance, technical and organizational safeguards, encryption and access restrictions.

10. Cookies and Tracking Technologies

Our website may use strictly necessary cookies, performance/analytics cookies, functional cookies and marketing cookies. Strictly necessary cookies are required for site security, session, basket, reservation and payment processes.

Where required, consent is obtained for non-essential cookies. Users can manage cookie preferences through browser settings or the cookie preference center on our website.

11. Marketing Communications

Users may receive campaigns, offers and announcements by e-mail, SMS, telephone, WhatsApp, push notifications and digital advertising channels in accordance with applicable law.

Marketing consent may be withdrawn at any time. Reservation confirmations, payment notices, security alerts, cancellation information and contractual notices are not marketing communications.

12. Profiling, Automation and Artificial Intelligence

Travel preferences, previous reservations, destinations viewed, membership level and campaign interactions may be analyzed to provide more relevant offers and a better user experience.

AI-supported tools may be used for customer support, request classification, translation, fraud detection, reservation assistance and operational reporting. Decisions that may produce significant legal effects are subject to human review where required.

13. Payment Security

Credit card transactions are processed through banks, card schemes and PCI-DSS compliant payment infrastructures. Elit Travel Club does not store full card numbers or CVV codes in its own systems.

3D Secure, fraud checks, transaction references, IP/device analysis and chargeback monitoring may be used for payment security.

14. Children's Data

For family reservations, we may process child guest name, age, date of birth, passport information, accommodation and ticket data. Such data must be provided by a parent or legal guardian and used only for travel/accommodation services.

We do not direct marketing to children.

15. Retention Periods

Personal data is retained for as long as necessary for the processing purpose and for statutory retention periods. Membership data is kept while the account is active; reservation and contract records are generally retained for limitation periods; invoice and accounting records are retained under applicable tax/commercial laws; marketing consents are retained until withdrawn and during proof periods.

When retention periods expire, data is deleted, destroyed or anonymized.

16. Data Security

Security measures may include SSL/TLS encryption, secure server infrastructure, access authorization, strong password policies, multi-factor authentication, logs, firewalls, backups, data masking, staff confidentiality undertakings and data processing agreements.

No digital system can be guaranteed as absolutely secure; however, Elit Travel Club aims to implement reasonable and industry-standard security measures.

17. Data Breach Notification

If personal data is subject to unauthorized access, loss, disclosure, alteration or unlawful use, we take necessary technical, organizational and legal measures. Where required by applicable law, notifications are made to competent authorities and affected individuals.

18. User Rights

Depending on applicable law, users may have rights of access, rectification, erasure, restriction, objection, data portability, withdrawal of consent, objection to automated decision-making and lodging a complaint with a supervisory authority.

Rights requests may be submitted to info@elittravelclub.com. Reasonable additional information may be requested to verify identity.

19. Regional Rights and Additional Notices

EU/EEA and UK users may exercise rights under GDPR/UK GDPR. Users in Türkiye have rights under Article 11 of Law No. 6698. California users may have rights under CCPA/CPRA to know, delete, correct, opt out of sale/sharing and not be discriminated against. Users in Canada, Australia, Singapore and Brazil may exercise rights under applicable local privacy laws.

California users may submit "Do Not Sell or Share My Personal Information" requests where targeted advertising technologies are involved.

20. Third-Party Links and Social Media

Our website may contain links to hotels, payment pages, map services, social media platforms and business partners. When users click those links, the privacy policy of the relevant third party applies.

If you communicate with us through social media, profile information, message content and interaction data may be processed under the rules of the relevant platform.

21. Applicants, Agents and Business Partners

For agency, supplier, franchise, management, investor, business partner or employment applications, we may process name, company, role, contact details, trade registry/tax data, financial capability, references, CVs, authorization documents, licenses and evaluation notes.

This data is used for application assessment, contract negotiations, due diligence, risk analysis and legal compliance.

22. Complaints, Disputes and Fraud Controls

Complaints, requests, objections, payment disputes or legal notices may be recorded. Controls may be carried out for fake payments, card fraud, chargeback risk, high-value transactions, suspicious activity and sanctions screening.

These processes are conducted for secure contract performance, legitimate interests, legal obligations and legal defense.

23. Account Security and Data Accuracy

Users are responsible for securing their account credentials and ensuring that the information they provide is accurate and up to date. Incorrect information may cause reservation, payment, invoicing or travel document issues.

If suspicious activity is detected, users should contact Elit Travel Club immediately.

24. Withdrawal of Consent and Deletion Requests

Where processing is based on consent, users may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Deletion requests are assessed by considering ongoing contracts, tax/accounting obligations, disputes, fraud investigations and statutory retention requirements.

25. Changes to This Policy and Contact

Elit Travel Club may update this Privacy Policy from time to time. The current version will be published on the website and significant changes may be notified where required.

Privacy contact: info@elittravelclub.com | 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom

Appendix 1 — Short Website Privacy Notice

Elit Travel Club processes personal data for membership, reservations, payments, customer support, marketing, security, legal compliance and service improvement. Data may be shared with hotels, payment providers, technology vendors, business partners and competent authorities where necessary. For your rights, contact info@elittravelclub.com.

Appendix 2 — Short Form Notice

Your personal data will be processed to receive your request, contact you, manage reservation/membership/quotation processes, provide services, process payments and meet legal obligations. Please review our Privacy Policy for details.

Appendix 3 — Marketing Consent Text

I consent to be contacted by Elit Travel Club via e-mail, SMS, telephone, WhatsApp and digital notification channels regarding campaigns, discounts, special offers, membership benefits, travel recommendations and announcements. I understand that I can withdraw this consent at any time.

Appendix 4 — Cookie Consent Text

Our website uses strictly necessary cookies as well as performance, analytics, functional and marketing cookies. Strictly necessary cookies are required for the website to work. You may accept, reject or manage non-essential cookies.

Appendix 5 — California Do Not Sell or Share Notice

California users may have the right to opt out of the sale or sharing of personal information for targeted advertising. To exercise this right, contact info@elittravelclub.com with the subject "Do Not Sell or Share My Personal Information".