Privacy policy
Draft for legal review. Last updated: [date].
1. Who we are
This privacy policy explains how [Veetek legal entity name] ("Veetek", "we", "us" or "our") collects and uses personal data through the website at veetek.io and through the Veetek platform, including Vee Travel, Vee Connect, Vee Operations and Vee Money.
For personal data collected through the website, such as contact form messages, newsletter sign-ups, demo requests and job applications, Veetek is the controller. Our registered address is [registered address]. [If applicable: our data protection officer or representative is [DPO or representative name and contact details].]
When our customers use the platform to process data about their own clients and travellers, such as passenger names and booking details, the customer is usually the controller and Veetek acts as a processor on the customer's behalf under a data processing agreement. In that case, the customer's own privacy notice applies, and questions should go to the customer first.
2. What we collect
Contact form
Your name, email address, company name, phone number if you provide it, and the content of your message.
Newsletter
Your email address, your subscription preferences and basic information about whether emails are opened or links are clicked.
Demo requests
Your name, job title, company, business email, phone number, country, the type of travel business you work for, the products you are interested in and any notes you add.
Job applications
Your name, contact details, CV, cover letter, work history, qualifications, the role you are applying for, links you choose to share such as a portfolio or profile, and notes from the recruitment process.
Platform account data
For users of the platform: name, business email, phone number, agency or organisation, role and permissions, login and security information, and records of actions taken in the platform, such as bookings created, settings changed and log-in times, together with technical data such as IP address and browser type.
Cookies and analytics
Information about how you use the website, such as pages visited, referring site, approximate location derived from IP address, device and browser type. See section 9 for more on cookies.
3. Why we use your data and our legal bases
- Responding to enquiries and demo requests: to reply to you and arrange demos. Legal basis: our legitimate interests in responding to business enquiries, or steps taken at your request before entering into a contract.
- Sending our newsletter: to send product news and articles. Legal basis: your consent, which you can withdraw at any time using the unsubscribe link.
- Recruitment: to assess applications and communicate with candidates. Legal basis: steps taken at your request before entering into an employment contract, and our legitimate interests in recruiting.
- Providing the platform: to create and manage user accounts, provide support, keep the platform secure and maintain audit records. Legal basis: performance of our contract with the customer, and our legitimate interests in operating a secure service.
- Improving the website and products: using analytics and usage data. Legal basis: your consent where required for non-essential cookies, otherwise our legitimate interests.
- Legal and compliance: to meet tax, accounting and other legal obligations, and to establish or defend legal claims. Legal basis: legal obligation and legitimate interests.
We do not sell personal data, and we do not use it for automated decisions that have legal or similarly significant effects on you.
4. Sharing and processors
We share personal data only where needed for the purposes above, with:
- service providers that process data for us, such as cloud hosting [hosting provider, for example Amazon Web Services], email delivery, customer relationship management, analytics, recruitment software and support tools;
- travel suppliers and payment providers, where needed to carry out bookings and payments that platform users request;
- professional advisers, such as lawyers, accountants and auditors;
- authorities, regulators or courts, where required by law;
- a buyer or successor, if Veetek is involved in a merger, acquisition or sale of assets, under appropriate confidentiality terms.
Our processors may only use personal data on our instructions and must protect it appropriately. A list of our main processors is available on request at [privacy contact email].
5. International transfers
Some of our service providers, and some travel suppliers, are located outside the country where you are based, including outside [the European Economic Area and the United Kingdom]. Where we transfer personal data to a country that does not provide an adequate level of protection under applicable law, we use appropriate safeguards, such as standard contractual clauses approved by the relevant authority. You can ask us for more information about these safeguards.
6. How long we keep data
- Contact form messages and demo requests: up to [retention period] after our last contact with you, unless you become a customer.
- Newsletter data: until you unsubscribe, after which we keep only what is needed to respect your choice.
- Job applications: up to [retention period] after the recruitment process ends, or longer with your consent so we can consider you for future roles.
- Platform account data: for the duration of the customer's subscription and then for [retention period], unless the subscription agreement or law requires otherwise.
- Financial and accounting records: as long as required by law, typically [statutory retention period].
7. Security
We use technical and organisational measures appropriate to the risk, including encryption in transit, access controls based on role, logging of access to systems, regular backups and staff confidentiality obligations. No system is completely secure, so we also keep procedures for detecting and responding to security incidents, including notifying authorities and affected people where the law requires.
8. Your rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have your data deleted in certain circumstances;
- restrict or object to certain processing, including processing based on legitimate interests and direct marketing;
- receive your data in a portable format;
- withdraw consent at any time, without affecting processing carried out before withdrawal.
To use these rights, contact us at [privacy contact email] or through our contact page. We may need to confirm your identity first. If you are a traveller or client of one of our customers, we may refer your request to that customer. You also have the right to complain to a data protection authority, such as [supervisory authority name].
9. Cookies
We use a small number of cookies and similar technologies on the website:
- Strictly necessary cookies that make the website and platform work, such as session and security cookies. These do not require consent.
- Analytics cookies that help us understand how the website is used, provided by [analytics provider]. We use these only with your consent where the law requires it.
You can change your choices at any time through [cookie settings link or mechanism] and can also block or delete cookies in your browser settings. Blocking strictly necessary cookies may stop parts of the website or platform from working.
10. Children
The website and platform are intended for businesses and are not directed at children. We do not knowingly collect personal data from children through the website. Customers may process data about child travellers within the platform, for example passenger names and ages for a booking, and do so as controllers under their own privacy notices.
11. Changes to this policy
We may update this policy from time to time. The latest version will always be on this page with its "last updated" date. If we make significant changes, we will take reasonable steps to let you know, for example by email or a notice on the website.
12. Contact us
For questions about this policy or how we handle personal data, contact us at [privacy contact email], through our contact page or by post at [registered address].