Privacy Policy

Personal Data Protection in accordance with GDPR

📍 FraVeRa Journey 🌐 Netherlands / EU 📅 Effective Date: April 2026
✓ GDPR Compliant | Regulation (EU) 2016/679
  • § 1 Controller
  • § 2 Data Scope
  • § 3 Sources
  • § 4 Purposes
  • § 5 Legal Bases
  • § 6 Health Data
  • § 7 Recipients
  • § 8 Transfers
  • § 9 Cookies
  • § 10 Storage
  • § 11 Rights
  • § 12 Complaints
  • § 13 Security
  • § 14 Breaches
  • § 15 Changes
§ 1

Personal Data Controller

1.1. Controller Status

The controller of personal data within the meaning of European Union law is FraVeRa Journey, an economic activity registered in the Kingdom of the Netherlands, operating as a disclosed travel agent.

Legal Basis

Article 4(7) GDPR - definition of data controller.

"controller" means 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.

Source: Regulation (EU) 2016/679, OJ EU L 119 of 04.05.2016, EUR-Lex.

1.2. Information Obligation

The controller fulfills the information obligation towards data subjects through this Privacy Policy, made available on the website.

Legal Basis

Article 13(1) GDPR - obligation to provide information when collecting data from the data subject.

Source: Regulation (EU) 2016/679, OJ EU L 119 of 04.05.2016, EUR-Lex.

1.3. Identification Data

The controller's identification data, including legal form, country of registration, registration number and contact details, are indicated in the Impressum and in the contact section of the website.

Legal Basis

Article 13(1)(a) GDPR - obligation to indicate the identity and contact details.

1.4. No Joint Controllers

FraVeRa Journey processes personal data independently and does not act as a joint controller of personal data within the meaning of Article 26 GDPR.

1.5. No Data Protection Officer

FraVeRa Journey is not obliged to appoint a data protection officer, as it does not meet the criteria specified in Article 37(1) GDPR.

1.6. Applicable Law

The controller is subject to the law of the Kingdom of the Netherlands as a Member State of the European Union where it has its establishment, while simultaneously applying the directly applicable GDPR.

Legal Basis

Article 3(1) GDPR - territorial scope.

National law NL: Uitvoeringswet AVG (UAVG), wetten.overheid.nl

§ 2

Scope of Personal Data Processed

2.1. Data Minimization

The controller processes only such personal data that are adequate, relevant and limited to what is necessary for the clearly defined purposes of processing.

Legal Basis

Article 5(1)(c) GDPR - data minimization principle.

2.2. Identification Data

The controller may process identification and contact data, in particular name, surname, email address, telephone number and other data necessary for contacting and identifying the Client.

Legal Basis

Article 6(1)(b) GDPR - performance of a contract.

2.3. Travel Preferences

The controller may process data concerning the planned trip, accommodation preferences, dates, scope of services and other organizational information.

2.4. Technical Data

The controller may process technical data including IP address, browser data, device, operating system and cookie identifiers, to the extent permitted by law and consent given.

Legal Basis

• Article 6(1)(a) GDPR - consent

• Article 5(3) ePrivacy Directive

Implementation NL: Telecommunicatiewet Article 11.7a

2.5. Health Data

The controller may process health data only when necessary for organizing a health or spa stay and only to the extent voluntarily provided. Not processed for diagnosis or treatment purposes.

Legal Basis

• Article 9(2)(a) GDPR - explicit consent

• Article 9(2)(h) GDPR - health care organization

2.6. No Excessive Data

The controller does not process personal data that are not necessary to achieve the purposes indicated in this Privacy Policy.

§ 3

Sources of Personal Data

3.1. Direct Collection

Data obtained directly from the data subject in the course of contact initiated by that person.

3.2. Online Forms

Data collected through forms on the website, technically handled by BASIN as processor.

3.3. Communication

Data from email correspondence, telephone conversations, and other direct communication.

3.4. Voluntary Documents

Documents or information voluntarily provided, including health data for stay finalization.

3.5. No Covert Sources

The controller does not collect personal data from covert sources, third-party databases or publicly available registers for the purpose of creating customer profiles.

3.6. Articles 13 and 14 GDPR

Article 13 GDPR applies in most cases (data collected directly). Article 14 GDPR applies only in exceptional situations.

§ 4

Purposes of Personal Data Processing

4.2. Offer Preparation

Preparing trip offers and taking steps before entering into an agency services contract.

4.3. Agency Services

Providing agency services including advice, intermediation, coordination and support.

4.4. Communication

Ongoing communication with the Client related to trip organization.

4.5. Partner Transfer

Transferring data to Partners providing main services (hotels, sanatoriums, transport).

4.6. Health Stays

Organizing health or spa stays and transferring information to medical Partners.

4.7. Legal Obligations

Fulfilling accounting, tax and archiving obligations.

4.8. Analytics (GA4)

Statistical analysis of website traffic using Google Analytics 4, only after obtaining user consent.

Legal Basis

Article 6(1)(a) GDPR - consent

4.9. Marketing

Marketing and remarketing purposes (Google Ads, Meta Ads) only after obtaining user consent, without combining with health data.

§ 5

Legal Bases for Processing

5.1. Primary Legal Act

Processing is carried out on the basis of Regulation (EU) 2016/679 (GDPR).

5.2. Contract Performance

Article 6(1)(b) GDPR - Necessary for performance of a contract or steps before entering into a contract.

5.3. Legal Obligation

Article 6(1)(c) GDPR - Necessary for compliance with legal obligations (accounting, tax).

5.4. Consent

Article 6(1)(a) GDPR - Processing based on voluntarily, knowingly and unambiguously expressed consent.

5.5-5.7. Special Categories (Health Data)

• Article 9(1) - General prohibition on processing health data
• Article 9(2)(a) - Explicit consent exception
• Article 9(2)(h) - Health care organization exception

5.8. Cookies

Article 5(3) ePrivacy Directive - Consent required for storing/accessing information in terminal equipment.

5.9. Withdrawal of Consent

Article 7(3) GDPR - Right to withdraw consent at any time, without affecting prior lawful processing.

§ 6

Special Category Data - Health Data Rules

⚕️ Health Data Protection

Health data is subject to special protection under GDPR Article 9. Processed only when absolutely necessary for organizing health and spa stays, with explicit consent and strict security measures.

6.1. Definition

Health data means personal data relating to the physical or mental health of a natural person, including information about the use of health care services (Article 4(15) GDPR).

6.2. General Prohibition

Processing of health data is generally prohibited unless one of the legalizing premises is met (Article 9(1) GDPR).

6.3-6.4. Exceptions

• Explicit consent (Article 9(2)(a))
• Health care organization (Article 9(2)(h))

6.5. Professional Secrecy

Under Article 9(2)(h), data must be processed by or under responsibility of a person subject to professional secrecy (Article 9(3) GDPR).

6.6. Processing Stages

Preliminary stage: Only descriptive health information for matching stays.
Finalization stage: Health data transferred to Partner only to extent necessary for service performance.

6.7-6.8. Consent Standards

Consent must be freely given, specific, informed and unambiguous. Demonstrable under Article 7(1) GDPR. Withdrawal possible at any time under Article 7(3) GDPR.

6.9. No Medical Advice

The controller does not provide medical advice, make diagnoses or therapeutic decisions. Health data processed solely for organizing and coordinating stays.

6.10. No Automated Decisions

No automated decision-making or profiling based on health data (Article 22(1) GDPR).

6.11-6.13. Security & Accountability

• Storage limitation - Deleted or anonymized after organizational purposes (Article 5(1)(e))
• Security measures - Access restriction and authorization control (Article 32)
• Accountability - Compliance documentation (Article 5(2))

§ 7

Recipients of Personal Data

7.1. Disclosure Principle

The controller discloses personal data only to specified categories of recipients and only to the extent necessary to achieve the purposes of processing.

7.2. Service Partners

Sanatoriums, clinics, spa facilities, hotels, medical entities and transport companies - only to extent necessary for service performance.

7.3. Health Data Transfer

Only if necessary for health/spa services and on appropriate legal basis (explicit consent or health care basis).

7.4. IT Providers

IT service providers, hosting, email, form systems (BASIN) - exclusively as processors under Article 28 GDPR.

7.5. Analytics/Marketing

Google and Meta - only after user consent, to extent resulting from consent configuration and Consent Mode v2.

7.6. Public Authorities

Public authorities or authorized entities if obligation arises from EU or Dutch law.

7.7. No Sale of Data

The controller does not sell, provide for a fee or exchange personal data with other entities for commercial purposes unrelated to service provision.

7.8. Access Restriction

Access to personal data is restricted to entities and persons for whom such access is necessary to achieve processing purposes.

7.9. Accountability

The controller documents transfers of personal data to recipients and is able to demonstrate compliance with GDPR.

§ 8

Transfer of Personal Data Outside EU/EEA

8.1. General Principle

Transfer of personal data to third countries or international organizations is permissible only on the terms specified in Chapter V of the GDPR (Article 44).

8.2. Adequacy Decision

Transfer is permissible if the European Commission has decided that the country ensures an adequate level of protection (Article 45(1) GDPR).

8.3. Appropriate Safeguards

If no adequacy decision, transfer may take place with appropriate legal safeguards, in particular standard contractual clauses (Article 46 GDPR).

8.4. Technology Providers

For tools provided by entities outside EU/EEA (Google, Meta), transfer takes place only in accordance with Chapter V GDPR mechanisms.

8.5. Transfer Impact Assessment

For transfers based on standard contractual clauses, the controller conducts a transfer impact assessment to verify whether third country law undermines safeguards (CJEU Judgment C-311/18 - Schrems II).

8.6. Health Data Transfers

Health data is transferred outside EU/EEA only in exceptional cases, if conditions of Chapter V GDPR and Article 9 GDPR are jointly met.

8.7. Derogations

In absence of adequacy decision and safeguards, transfer may take place only on basis of exceptions in Article 49 GDPR, applied restrictively.

8.8. Information Obligation

The controller informs data subjects about intention to transfer data outside EU/EEA and about applied safeguards or exceptions (Article 13(1)(f)).

8.9. Documentation

The controller documents all cases of data transfer outside EU/EEA and is able to demonstrate compliance with GDPR.

§ 9

Cookies and Similar Technologies

9.1. Definition

Cookies and similar technologies (including localStorage, sessionStorage, pixels, tags and online identifiers) constitute information stored or read in the user's terminal equipment.

Legal Basis

Article 5(3) of Directive 2002/58/EC (ePrivacy)

Implementation NL: Telecommunicatiewet Article 11.7a, wetten.overheid.nl

9.2. Classification by Purpose

The controller uses necessary, analytical and marketing cookies, where cookies other than necessary are activated only after obtaining user consent.

9.3. Necessary (Technical) Cookies

Necessary cookies are used solely to ensure the proper functioning of the website and its basic features and do not require user consent.

Legal Basis

Article 5(3) second sentence of Directive 2002/58/EC - exception for "strictly necessary" cookies.

"...this shall not prevent any technical storage or access for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or as strictly necessary in order to provide an information society service explicitly requested by the subscriber or user."

9.4. Analytical Cookies (GA4)

Analytical cookies are used for statistical analysis of website traffic using Google Analytics 4, only after obtaining user consent.

Legal Basis

• Article 6(1)(a) GDPR - consent

• Article 5(3) ePrivacy Directive

Sources: GDPR; Directive 2002/58/EC; GA4 Documentation

9.5. Marketing Cookies

Marketing and remarketing cookies (Google Ads, Meta Ads) are used only after obtaining user consent for displaying personalized advertisements and analyzing campaign effectiveness.

9.6. Consent Management Platform (CMP)

The controller uses a consent management platform (CMP) that allows the user to express, refuse or change consent for the use of cookies.

Legal Basis

Article 7(1) and (3) GDPR - proof of consent and its withdrawal.

9.7. Google Consent Mode v2

The controller uses Google Consent Mode v2, which transmits consent signals to Google for categories: ad_storage, analytics_storage, ad_user_data, ad_personalization.

9.8. Lack of Consent

Lack of consent for analytical or marketing cookies does not affect the ability to use the website, except for functions directly related to these cookies.

Legal Basis

Article 7(4) GDPR - voluntariness of consent.

9.9. Storage Period

The cookie storage period depends on their type and is indicated in the detailed Cookie Policy or in the CMP settings.

9.10. Transparency

The controller ensures easy access to information about cookies used and enables changing consent settings at any time via a link in the website footer.

§ 10

Personal Data Storage Period

10.1. Storage Limitation Principle

Personal data are stored in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Legal Basis

Article 5(1)(e) GDPR - storage limitation principle.

10.3. Offer Preparation Data

Stored for duration of contact and after termination for time necessary to secure any claims.

10.4. Contract Data

Stored for duration of contract and after termination for period required by law or until expiry of limitation periods.

10.5. Legal Obligations

Stored for period resulting from applicable law, in particular tax and accounting law.

10.6. Health Data

Stored only for period necessary to organize and carry out health stay, then promptly deleted or anonymized.

10.7. Consent-based Data

Stored until consent is withdrawn or until they lose usefulness for the purpose consent was given.

10.8. Analytics/Marketing

Stored in accordance with validity period of cookies or until user withdraws consent.

10.9. Deletion and Anonymization

After the storage period expires, personal data are deleted or anonymized in a manner that prevents identification of the data subject.

10.10. Accountability

The controller documents the adopted data storage periods and is able to demonstrate their compliance with GDPR principles.

§ 11

Rights of the Data Subject

📋 Your Rights Under GDPR

As a data subject, you have comprehensive rights regarding your personal data. These rights are exercised free of charge unless requests are manifestly unfounded or excessive.

Right to Information

Receive information concerning processing in a concise, transparent, intelligible and easily accessible form.

Article 12(1) GDPR

Right of Access

Obtain confirmation whether personal data are being processed and access to the personal data.

Article 15 GDPR

Right to Rectification

Obtain without undue delay the rectification of inaccurate personal data and completion of incomplete data.

Article 16 GDPR

Right to Erasure ("Right to be Forgotten")

Obtain erasure of personal data when data are no longer necessary for the purposes for which they were processed.

Article 17 GDPR

Right to Restriction

Obtain restriction of processing in cases indicated in the GDPR.

Article 18 GDPR

Right to Data Portability

Receive personal data in a structured, commonly used, machine-readable format and transmit to another controller.

Article 20 GDPR

Right to Object

Object at any time to processing based on legitimate interest of the Controller.

Article 21 GDPR

Right to Withdraw Consent

Withdraw consent at any time, without affecting lawfulness of processing based on consent before withdrawal.

Article 7(3) GDPR

Right Not to be Subject to Automated Decisions

Not to be subject to a decision based solely on automated processing, including profiling.

Article 22 GDPR
11.11. Right to Lodge a Complaint

The data subject has the right to lodge a complaint with the competent supervisory authority if he or she considers that processing infringes GDPR provisions.

Competent authority in NL: Autoriteit Persoonsgegevens - autoriteitpersoonsgegevens.nl

Legal Basis

Article 77(1) GDPR

11.12. Exercise Procedure

The controller implements rights of the data subject without undue delay, no later than within one month of receipt, with possibility of extension in indicated cases.

Legal Basis

Article 12(3) GDPR

§ 12

Right to Lodge a Complaint with Supervisory Authority

12.1. General Principle

The data subject has the right to lodge a complaint with a supervisory authority if he or she considers that the processing of personal data infringes GDPR provisions.

Legal Basis

Article 77(1) GDPR

12.2. Competent Authority

The competent supervisory authority is the Autoriteit Persoonsgegevens in the Kingdom of the Netherlands.

Website: autoriteitpersoonsgegevens.nl

12.3. Choice of Authority

The data subject may lodge a complaint with the supervisory authority in the Member State of his or her habitual residence, place of work or place of the alleged infringement.

12.4. Independence from Other Remedies

The right to lodge a complaint is independent of other legal remedies, including the right to lodge a complaint with a court.

12.5. Cooperation Obligation

The controller cooperates with the competent supervisory authority in the performance of its tasks and provides all required information.

12.6-12.7. Judicial Remedies

• Article 78 GDPR - Right to effective judicial remedy against decision of supervisory authority
• Article 79 GDPR - Right to effective judicial remedy against the Controller

12.8. No Fees

Lodging a complaint with the supervisory authority is free of administrative charges.

§ 13

Technical and Organizational Security Measures

13.1. Security Obligation

The controller implements appropriate technical and organizational measures to ensure a level of security of personal data appropriate to the risk.

Legal Basis

Article 32(1) GDPR

13.2. Selection Criteria

State of the art, implementation costs, nature, scope, context and purposes of processing, and risk assessment.

13.3. CIA Triad

Confidentiality, Integrity and Availability of data and resilience of processing systems.

13.4. Access Control

Access granted only to authorized persons and only to extent necessary to perform their tasks.

13.5. Technical Measures

IT system security, access protection, encryption and pseudonymization to extent adequate to risk.

13.6. Health Data Security

Heightened protection standards including access restrictions, transfer control and shortened storage.

13.7. Testing

Regular testing, measuring and evaluating effectiveness of applied measures.

13.8. Processor Security

The controller uses only processors providing sufficient guarantees to implement appropriate technical and organizational measures.

13.9. Breach Procedures

The controller has procedures enabling detection, reporting and assessment of personal data breaches.

13.10. Accountability

The controller documents applied security measures and is able to demonstrate compliance with GDPR.

§ 14

Personal Data Breaches

14.1. Definition

A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.

Legal Basis

Article 4(12) GDPR

14.2. Response Procedures

The controller implements procedures enabling immediate detection, analysis and assessment of each personal data breach.

14.3. Risk Assessment

After detecting a breach, the controller conducts an assessment of the risk of infringement of rights or freedoms of natural persons.

14.4. Reporting to Authority

If a breach may result in risk to rights and freedoms, the controller reports it to the supervisory authority without undue delay, no later than 72 hours from becoming aware.

Legal Basis

Article 33(1) GDPR

14.5. Report Scope

The report includes: nature of breach, categories of data, possible consequences, and measures taken or proposed.

14.6. Documentation

The controller documents all personal data breaches, regardless of whether they were subject to reporting obligation.

14.7. Notification to Data Subject

If breach may result in high risk to rights and freedoms, the controller notifies the data subject without undue delay.

Legal Basis

Article 34(1) GDPR

14.8. Exceptions to Notification

Notification not required if technical measures eliminating risk have been applied or other premises in Article 34(3) GDPR are met.

14.9. Health Data Breaches

Breaches involving health data are subject to particularly rigorous risk assessment and as a rule qualify as high-risk breaches.

14.10-14.11. Cooperation & Accountability

The controller cooperates with supervisory authority and is able to demonstrate compliance of breach response procedures with GDPR.

§ 15

Changes to Privacy Policy

15.1. Right to Update

The controller is entitled to make changes to the Privacy Policy in the event of changes in law, changes in manner or scope of processing, changes in applied technologies or business development.

15.2. Up-to-Date Information

The controller ensures that information provided to data subjects is up-to-date, reliable and corresponds to actual manner of data processing.

15.3. Publication of Changes

The current version of the Privacy Policy is published on the website and marked with the date of entry into force.

15.4. Information Obligation

If changes concern essential aspects of processing, the controller ensures fulfillment of information obligations towards data subjects.

15.5. No Retroactive Effect

Changes to the Privacy Policy do not have retroactive effect and do not affect lawfulness of processing carried out before entry into force of changes.

15.6. Legal Obligation Changes

Changes introduced to adapt to mandatory provisions of law apply from date of entry into force of those provisions.

15.7. Accountability

The controller documents the Privacy Policy update process and is able to demonstrate compliance with GDPR principles.

15.8. Entry into Force

This Privacy Policy enters into force on the date of its publication, unless another date is expressly indicated.

FraVeRa Journey

Registered in the Kingdom of the Netherlands

Operating as a disclosed travel agent under EU law

© 2026 FraVeRa Journey. All rights reserved.