Last updated: 6th January 2022

Kletter Kft On Privacy

What is our philosophy regarding Data Protection and Privacy?

We believe that we as a provider of a wide range of services need to be as open and straight forward as possible regarding our usage of Personal Data provided by our visitors and clients or the online travel agents, travel operators or other travel companies (let’s call them “Travel Suppliers”). We hereby commit to defend Your Personal Data from any illegal usage, or data leaks and data breaches. We’ll do everything in our power to forward your personal data to third parties who provide the adequate measures of safety and security for the protection your personal data requires.

Along with our Terms of Service , this policy explains how we collect and handle your Personal Data across all of our websites, mobile apps and other services in as plain and simple manner that is possible. We can only speak for ourselves, so this policy doesn’t cover the collection or use of your data by any of the Travel Suppliers we feature. That means when you make a booking request with a Travel Supplier, your information will be processed by them in accordance with their own privacy policy and terms and conditions. But don’t worry, we’ll always give you the links, so you can read them before making a booking.

If you have any form of question or suggestion, please feel free to contact us!

About Data Processing In General

Here we give you a general explanation how we process your Personal Data.

On reasons for using Personal Data

We use your Personal Data to provide you – our User – with our services, for the purpose of presenting and managing bookings, and maintaining and improving our infrastructure.

We use your Personal Data:

  • for marketing (sharing travel information, or photographs)
  • to manage bookings
  • to enhance the quality of our service and thus elevating your user experience.

We use your Personal Data:

  • To perform a contract
    • For our Travel Suppliers:
      • to create a "trek" for the visitors
      • to create a user profile on trekhunt.com
    • For our Visitors:
      • to manage bookings
  • Because it is in our legitimate interest
    • to understand users and to improve and secure our service
      • via analysing usage and user data
      • via creating maintenance and security logs
    • to provide customer support
      • via an on-platform chat board
    • to provide “trek” for visitors
      • via scraping

We also use anonymised personal data for statistical purposes.

On collecting Personal Data

We only collect the personal data we absolutely need, and nothing more. This happens by you directly providing us your personal data, us observing how you use the website, we receiving personal data to charge our partners on successful redirects.

We can’t help you find your dream trip without information. So, when you use our services, we must collect, keep and share some personal data and ask that you agree to that in line with this policy.

You directly provide us with

  • Searched and given data regarding travel and activities (destination, date, details of the activity)
    • Personal contact information (required for booking)
    • Any data which constitutes Personal Data you upload to your profile (photographs, reviews, names etc.)
  • We generate automatically during your visit on our website
    • IP Address or your location
    • information about your device or browser
    • website URL you visited us from
    • third party sites you visit when you leave our website
    • details of the bookings you made via our service
  • We receive from Third Parties
    • when you log on to our website from a social media platform
    • when you visit our website via a promotional partner
    • when you’re redirected to a Travel Supplier’s website or app to complete your booking, we collect information from them about whether you went ahead with your trip and what you booked

Our services are not intended for children under 16 years of age, and no one under the age of 16 should provide any information to, on or via our services. We don’t knowingly collect personal data from children under 16 and will delete any that we learn we have collected or received that was not provided by, or with express consent on behalf of, the child’s parent or legal guardian.

On retention periods

We only keep your data as long as we absolutely need or are required to by law, that is within 30 days that you cancel your account or the trek is modified.

The retention time depends on the purpose by which we collect and process Personal Data.

When we process data:

  • To perform a contract
    • For our Travel Suppliers:
      • to create a "trek" for the visitors
      • to create a user profile on trekhunt.com
    • For our Visitors:
      • to manage bookings
  • Because it is in our legitimate interest
    • to understand users and to improve and secure our service
      • via analysing usage and user data
      • via creating maintenance and security logs
    • to provide customer support
      • via an on-platform chat board
    • to provide “trek” for visitors
      • via scraping

You can contact us any time about deleting your personal data, and if there’s no contractual or legal reason to keep your Personal Data, we comply your request as soon as possible.

On location of data storage

We store your personal data only where we are certain that the appropriate safety, security, and legal measures have been made.

We are using public cloud providers with servers mainly in Ireland. These servers are provided and/or supported by our contracted third parties acting under our instructions.

We only store European users’ personal data outside the European Economic Area where a European Commission-approved method of validating the transfer has been put in place.

On Personal Data security

We respect your privacy and safeguarding your personal data is embedded in our culture. We use a combination of industry-standard and good practice methods to protect it. We limit access to only those Trekhunt employees who must come into contact with your information to do their jobs and deliver our services.

Unfortunately, no website or app can guarantee complete security, but we have created an organization-wide security program designed to keep your personal data as safe as possible. It uses a range of technical, organizational and administrative security measures and good practice techniques, depending on the type of data being processed. For example, the computer systems we use to store your data have access limitations and are hosted with reputable vendors. We use TLS and HTTPS encryption to protect your personal data when we transfer it across the internet. And we carry out security assessments on Third Party Processors who handle your data.

To make sure we maintain a culture of ‘Privacy by Design’, we provide thorough data protection and privacy training to all Trekhunt group employees. We develop our services with the goal of using the minimum amount of personal data possible, including through use of data minimization techniques like anonymization and pseudonymization. Also, whenever we develop or update our services in ways that involve the collection or use of new forms of personal data, we conduct a privacy impact assessment to understand, and reduce, the likelihood of any unintended impact on you.

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Trekhunt, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of trekhunt.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party travel suppliers, technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Trekhunt. The updated list of these parties may be requested from Trekhunt at any time.

Miscellaneous information

About legal usage of personal data, maintenance, and user requests.

Usage of Personal Data for compliance with a legal obligation

The User's Personal Data may be used for legal purposes by Trekhunt in Court or in the stages leading to possible legal action arising from improper use of trekhunt.com or other related services. The User declares to be aware that Trekhunt may be required to reveal personal data upon request of public authorities. Trekhunt only provides personal data if the requesting third party provides the proper and exact legal basis of its request.

Usage of Personal Data for our legal claims

We may disclose your information where necessary to enforce our Terms of Service or other agreements, or to a prospective or ultimate buyer if Trekhunt itself (or part of our business) is sold. We may also disclose your information if necessary to prevent, detect or prosecute illegal or suspected illegal activities, including fraud, or to prevent other damage or where necessary in response to legally binding requests, legal action against us, or to enforce our rights and claims.

Additional information regarding processing of Personal Data

In addition to the information contained in this privacy policy, Trekhunt may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request. Please see the contact information at the beginning of our policy.

Maintenance and System logs

For operation and maintenance purposes, trekhunt.com and third-party service providers may collect files that record interaction with trekhunt.com (System logs) use other Personal Data (such as the IP Address) for this purpose.

About “Do Not Track” requests

Trekhunt does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to our privacy policy

Trekhunt reserves the right to make changes to our privacy policy at any time by giving notice to its Users on this page and possibly within trekhunt.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to Trekhunt. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

On Personal Data of Visitors

Here you can find all the information about how we collect and process personal data of our Visitors on trekhunt.com

We only use the Personal Data of Visitors:

  • To perform a contract
    • to validate bookings
    • to facilitate bookings
  • Because it is in our legitimate interest
    • to understand users and to improve and secure our service
      • via advertisements
      • via analyzing usage and user data
    • to provide customer support
      • via an on-platform chat board

Support Chat Window

We use the services of Intercom Ltd. – to be specific: Intercom Support – to provide you with an instant and easy to use customer support.
While you use the Intercom Support the following Personal Data gets processed:

  • E-mail address:
    • Since to use our website it is not required to have an account, we might ask you for your e-mail address.
    • This personal data shall be used for the sole purpose of customer care as long as you don’t create an account or book a “trek”.
    • If you don’t create an account or book a “trek”, your e-mail address shall be deleted after 1 year that the matter you reached out to us was solved or finished other ways.
  • Any given name for yourself you provide us with
    • Same rules apply to this data as the rules of the e-mail address above.
  • The whole “free text chat”:
    • Your conversation with our employee constitutes personal data, which may be stored for 1 year. However, if the matter is serious, or it requires us to store it for a longer period, we shall provide you with this information.

Rights and Questions

You may exercise certain rights regarding your data processed by Trekhunt. You have the right to do the following:

  • Withdraw your consent at any time: you have the right to withdraw consent where you have previously given your consent to the processing of their Personal Data.
  • Object to processing of your data: you have the right to object to the processing of your data if the processing is carried out on a legal basis other than consent.
    • Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Trekhunt or for the purposes of the legitimate interests pursued by Trekhunt, you may object to such processing by providing a ground related to your situation to justify the objection.
    • But: should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether Trekhunt is processing Personal Data for direct marketing purposes, you can reach out to us.
  • Access your data: you have the right to learn if data is being processed by Trekhunt, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and seek rectification: you have the right to verify the accuracy of your data and ask for it to be updated or corrected.
  • Restrict the processing of your data: you have the right, under certain circumstances, to restrict the processing of your data. In this case, Trekhunt will not process your data for any purpose other than storing it.
  • Have your Personal Data deleted or otherwise removed: you have the right, under certain circumstances, to obtain the erasure of your Data from Trekhunt.
  • Receive your data and have it transferred to another controller:
    • You have the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
    • This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which you’re part of or on pre-contractual obligations thereof.
  • Lodge a complaint: you have the right to bring a claim before your competent data protection authority.

Exercising your rights:

Any requests to exercise your rights can be directed to Trekhunt through the contact details provided in this document (link). These requests can be exercised free of charge and will be addressed by Trekhunt as early as possible and always within one month.

On Personal Data as part of treks and trek management

Here you can find all the information about how we collect and process personal data as part of the “treks” we present at trekhunt.com, either via having it received from a Travel Supplier or by scraping in from the internet.

We only use the Personal Data as part of “treks” and trek management:

  • To perform a contract
    • to validate bookings
    • to facilitate bookings
  • Because it is in our legitimate interest
    • to understand users and to improve and secure our service
      • via advertisements
      • via analyzing usage and user data
    • to provide customer support
      • via an on-platform chat board

On our website, we present and suggest to you a wide range of travels and activities (hereinafter: “treks”) provided by companies or other enterprises, sole entrepreneurs – these we call jointly our “Travel Suppliers”.

Some of our Travel Suppliers have a contractual relation with Trekhunt, and some Travel Suppliers are scraped from the internet.

Performance of Contract

If we have a contract with the Travel Supplier, we act as Data Processors for the Travel Supplier. This means that we provide the platform for the Travel Supplier for them to present their services or “treks”.

To perform this contract, we need data regarding the “trek” we want to promote, so we receive directly or scrape from the appointed website:

  • Personal data for contact information of a natural person associated with the Travel Supplier:
    • Name
    • Address
    • Phone number
    • E-mail address
  • Personal data for promotion reasons
    • Location
    • Photographs

To facilitate the presentation of the “treks”, a Travel Supplier may create an Account on trekhunt.com, so that they could submit or create their own “treks”. For the Travel Suppliers’ user profile, we need:

  • First name
  • Last name
  • E-mail address
  • Country
  • Photograph or another picture for an avatar.

In these cases, Trekhunt acts as Data Processor, and the Data Controller is the Travel Supplier. This means, that if you want to exercise your rights as a data subject, the Travel Supplier is the competent party. Of course, if you have trouble reaching out to the Travel Supplier, Trekhunt gladly assists you.

For more information about your rights as a data subject please click here.

For our contact information please click here.

Legitimate Interest

Trekhunt within its legitimate interest scrapes websites for travels or activities so that we could provide treks to our visitors.

When we’re scraping websites within our legitimate interest, we collect the same data as when we scrape websites while performing our contractual obligations:

  • Personal data for contact information of a natural person associated with the Travel Supplier:
    • Name
    • Address
    • Phone number
    • E-mail address
  • Personal data for promotion reasons
    • Location
    • Photographs

Regarding the Personal Data we obtain by scraping websites the Data Controller and Data Processor is Trekhunt. Please contact us if you want to exercise your rights as a data subject.

For more information about your rights as a data subject please click here.

For our contact information please click here.

Retention Period

Regarding Personal Data Trekhunt is processing:

  • by fulfilling our contractual obligation: we store the Personal Data till 30 days after the term of the contract.
  • by scraping other websites: Every Personal Data is kept for as long as it is online on the webpage we scraped. Once Personal Data is no longer available on the website, Trekhunt deletes it from its own systems 30 days after we re-scraped the website in question.

Rights and Questions

You may exercise certain rights regarding your data processed by Trekhunt. You have the right to do the following:

  • Withdraw your consent at any time: you have the right to withdraw consent where you have previously given your consent to the processing of their Personal Data.
  • Object to processing of your data: you have the right to object to the processing of your data if the processing is carried out on a legal basis other than consent.
    • Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Trekhunt or for the purposes of the legitimate interests pursued by Trekhunt, you may object to such processing by providing a ground related to your situation to justify the objection.
    • But: should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether Trekhunt is processing Personal Data for direct marketing purposes, you can reach out to us.
  • Access your data: you have the right to learn if data is being processed by Trekhunt, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and seek rectification: you have the right to verify the accuracy of your data and ask for it to be updated or corrected.
  • Restrict the processing of your data: you have the right, under certain circumstances, to restrict the processing of your data. In this case, Trekhunt will not process your data for any purpose other than storing it.
  • Have your Personal Data deleted or otherwise removed: you have the right, under certain circumstances, to obtain the erasure of your Data from Trekhunt.
  • Receive your data and have it transferred to another controller:
    • You have the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
    • This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which you’re part of or on pre-contractual obligations thereof.
  • Lodge a complaint: you have the right to bring a claim before your competent data protection authority.

Trekhunt uses Cookies for greater user experience, to understand usage and for statistics.

For the meaning of terms such as ’cookie’ or ’web beacons’ and ’pixels’, ’tracking codes’ please visit our collection of definitions!

We use cookies to collect information for use in line with the purposes set out in our privacy- and cookie policy.

Trekhunt also uses cookies to record information about experiments or new improvements we might test to track how you use our services and find out whether they were effective. Cookies on our website may be set by us, third parties we’re working with, or independent third parties (such as Facebook).

Cookies used by Trekhunt

Necessary Cookies

These can’t be turned off.

Necessary cookies enable core functionality. The website cannot function properly without these cookies and can only be disabled by changing your browser preferences.


Analytical Cookies

You can turn these ON or OFF any time!

Analytical cookies help us to improve our website by collecting and reporting information on its usage.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of trekhunt.com, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States

Privacy Shield participant.

User Interface Customization Cookies

You can turn these ON or OFF any time!

We use some cookies to customize the user interface for you. Such cookies include language, currency preferences and special filters you have set previously.

Social Sharing Cookies

You can turn these ON or OFF any time!

We use some social sharing plugins, to allow you to share certain pages of our website on social media. These plugins place cookies so that you can correctly view how many times a page has been shared.

The interaction and information obtained through trekhunt.com are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to log out from the respective services to make sure that the processed data on trekhunt.com isn’t being connected back to the User’s profile.

List of social sharing plugins:

Facebook / Twitter

How to manage Cookies

Our visitors can manage preferences for Cookies directly from within their own browsers and prevent – for example – third parties from installing Cookies.

Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookies that may have saved the initial consent for the installation of Cookies by this website – at any time.

You can find information about how to manage Cookies in the most commonly used browsers at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Internet Explorer.

The use of Facebook Pixel

Trekhunt uses Facebook Pixel, which is a snippet of JavaScript code that allows us to track the activity of our Visitors on www.trekhunt.com. We use it to measure the effectiveness of our ads, to define custom audiences for ad targeting, for dynamic ads campaigns, and to analyze that effectiveness of our website's conversion funnels.

Third Parties

Here we explain why, when and with which Third Parties we share personal data.

  • We share personal data only if:
    • you ask us to do so
    • it’s necessary for our service, that is mostly for booking.
    • legal reasons (claims, or requests by authorities)
  • Your personal data is collected:
    • by social sharing logins and plugins,
    • by data processors that contribute in providing our services to you on our behalf.

About Our Use of Third Party Data Processors

These third parties only process your personal data under our instructions. These third parties are Data Processors.

We require all of our contracted Third Party Data Processors to:

  • Process the Data only as instructed or as we gave them explicit consent
  • Have the necessary and obligatory security measures
  • Demonstrate compliance with the applicable data protection laws
  • Ensure authorized process and confidentiality
  • Only engage another processor with our explicit consent
  • Assist us in the fulfilment of the controller's obligation to respond to requests for exercising the data subject's rights

We will put in place appropriate measures to ensure that the personal data is adequately protected if the Third Party Data Processor is outside of the European Economic Area.

Our Third Party Data Processors

Payment processors

To securely store or handle payments information (credit or debit card details) if you provide us with your credit or debit card details we store these in a PCI-compliant data vault provided by an industry-leading third party payment processor.

Providers of email management and distribution tools

If you send bookings via trekhunt.com, or sign up to receive Trekhunt newsletters or other marketing messages, we will manage the delivery of these to you using a third party email distribution tool.

Providers of data aggregation and analytics software services

These enable us to effectively monitor and optimize the delivery of our services.

Providers of customer support platforms

That assist us in communicating or providing customer support services to you – for example, we manage and respond to any messages you send to us via our help center using a third party communications management tool.

Providers of online cloud hosting and storage services

These providers run our infrastructure and our code in scalable public cloud environments. Additionally, all our databases are hosted in public cloud environments.

Sharing or allowing processing outside of our control

Travel purchase

  • If you purchase a travel within our services’ booking platform, your submitted personal data will be shared with the chosen Travel Supplier and/or their contracted third party if it’s necessary for fulfilling your request.
  • In such occasions you always get an opportunity to review the Travel Supplier’s privacy policy and terms and conditions first.
  • Trekhunt may also share personal data with the Travel Supplier for their or our standard verification and fraud-detection purposes.

We will share personal data with third parties where you expressly authorize us to.

The competent supervisory authority of Trekhunt

For complaints and exercising your data subject rights.

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)
Hungarian National Authority for Data Protection and Freedom of Information
Address: H-1125 Budapest, Hungary, Szilágyi Erzsébet fasor 22. c.
Phone nr.: +36 1 391 1400
Fax nr.: +36 1 391 1410
e-mail: privacy@naih.hu or ugyfelszolgalat@naih.hu
web: https://www.naih.hu
coordinates: É 47°30'56''; K 18°59'57''

Terms, Definitions and their Meanings for our Privacy Policy

Find here the legal and technical terms used throughout this privacy policy.

Cookies

A cookie is a small data file that is stored on your computer or device. Cookies record things like your preferences and settings, helping to give us the information we need to provide you with the most consistent and relevant experience. Cookies consist of portions of code installed in the browser that assist Trekhunt in providing our service. Some services for which Cookies are installed may also require the User's consent. Where the installation of Cookies is based on consent, such consent can be freely withdrawn at any time.

Data Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of trekhunt.com. The Data Controller, unless otherwise specified, is the Owner of trekhunt.com

Data Processor

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Subject

The natural person to whom the Personal Data refers.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Personal Data

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. For example, this includes information that may of itself identify you such as your name, contact details, trek itinerary, internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.

Service

The service provided by trekhunt.com as described in the relative terms (if available) and on this site/application.

Third Party

Any natural or legal person who does not have a direct connection with a legal transaction but who might be affected by it. In the case of the services of Trekhunt, a Third Party individual is a natural or legal person, who is not in direct connection with the legal relations between Trekhunt and the Data Subject

Tracking codes

Tracking codes are snippets of code placed in the page to measure things like visits and interactions. We use tracking codes to find out more about how you interact with our services, the adverts you see and more generally, how you use us.

Travel Supplier

Natural or legal person who provides Trekhunt with optional activities around the world wide web, and which optional activities get presented on Trekhunt’s website.

trekhunt.com

Trekhunt’s online webpage by which the Personal Data of the User is collected and processed.

Trek

Any activity / travel provided by a Travel Supplier and gets presented on Trekhunt’s platform

Usage Data

Information collected automatically through trekhunt.com (or third-party services employed in trekhunt.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use trekhunt.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using trekhunt.com who, unless otherwise specified, coincides with the Data Subject – User may be a Visitor or a Travel Supplier.

Visitor

A natural or legal person who visits www.trekhunt.com or contacts Kletter Kft.

Web beacons and pixels

Web beacons or pixels are small, transparent image files inside a web page or email. We use them to understand how you interact with our services, or if you’ve redirected to a Travel Supplier’s website or app. We might use the pixel to confirm if you went on to book with them, and what you booked. We also use pixels to gather information such as whether you’ve opened an email, so that we can improve our communications to you.