Read here how Hygway ApS handles, stores, and uses your data.
This Privacy Policy is established by Hygway ApS (collectively referred to as ”Hygway”, ”we”, ”us”, or ”our” in this Privacy Policy) and applies to all our customers, suppliers, and partners.
Hygway is a travel agency. Our mission is to develop unique trips around the world. To fulfill our mission, we use various partners around the world.
As part of its business, Hygway collects and processes personal information with the purpose of fulfilling the purposes described in this Privacy Policy. Hygway is the data controller in relation to the processing of personal information for these purposes.
If you have questions about the Privacy Policy or our processing of your personal information, you can contact us here:
Hygway ApS
INDIAKAJ 3
2100 COPENHAGEN
E-mail: contact@hygway.com
For us, handling personal information collected as part of our business operations is crucial to our business objectives and reputation. This Privacy Policy explains how your personal information is collected and used when you are a customer, supplier, or partner, and how you can access your personal information.
Personal information is any information about an identified or identifiable natural person. An identifiable natural person is understood to mean a person who can be directly or indirectly identified, among other things by an identification number or one or more elements that are specific to a given person’s identity.
The information we collect about you will be used for various purposes in connection with your customer relationship and the operation of Hyway’s business. The collected information may vary depending on whether you are a customer, supplier, or partner, but generally it will be information related to customer administration, supplier administration, as well as information related to Hyway’s rights and obligations.
Failure to provide personal information from your side may mean that Hygway will be unable to fulfill its obligations in connection with your customer or supplier relationship.
Hygway collects and processes, as a general rule, only ordinary personal data. However, in specific cases in connection with booking a trip, it may be necessary for us to process sensitive personal data (e.g., information about special meals on your flight or information about the need for special assistance on your trip) as well as information about CPR numbers (e.g., in connection with obtaining a passport copy for a visa application) in order to be able to deliver the desired trip to you.
Hygway will typically collect the following information:
Information you provide us when booking a trip with us, e.g., online via the website, via email or phone, including contact details (first name, middle name(s), last name, address, phone number, email address, and optionally position), CPR number (for visa applications, etc.), passport number, bank details, payment card details, information you provide us regarding your special preferences for the trip (e.g., information about special dietary needs, need for special assistance related to illness, etc.), health information, height and weight information, purpose of the trip, information about the languages you speak, citizenship, bonus card numbers, membership in our partner associations’ clubs, contact information for your nearest relatives, expenses (in connection with business or treatment trips), information you provide us about your preferences regarding marketing or communication, as well as information you provide us if you contact us with a question to report a problem, or when you otherwise contact us in connection with your customer relationship with us.
Hygway may also obtain credit information from credit reference agencies for the purpose of assessing your financial stability and creditworthiness in connection with your customer relationship.
Information you provide us in connection with entering into a supply or collaboration agreement, including contact information (work, job title, first name, middle name(s), last name, address, phone number, and email address), information you provide us about your preferences regarding marketing or communication, as well as information you provide us if you contact us with a question, to report a problem, or when you otherwise address us as part of our collaboration.
Hygway uses cookies to improve the user experience on our website. When you continue to navigate on Hygway’s site, you give consent to the storage of cookies for this purpose. For more information about our cookie handling, including how to avoid automatic storage, read more here.
On our website, we offer a chat function, provided by tidio.com, our chatbot provider. This feature is designed to help you easily find the information you are looking for and to improve your user experience. To optimize the performance of the chat function, data from interactions are collected and analyzed. Therefore, we encourage you to avoid sharing sensitive personal information in the chat. You can read more about how we handle and store data related to the chat function.
Hygway processes your personal information for the purposes stated below. Note that not all of the stated purposes, categories of information, recipients of information, or types of information processing apply to you in all cases.
Hygway processes your personal information solely to the extent necessary in connection with your customer, supplier, or collaboration relationship (where in each case account is taken of any interests) or in accordance with applicable law.
Hygway processes your personal information in connection with the establishment and ongoing administration of your customer relationship with Hygway as part of the operation of our business, including booking trips and delivering our other products (such as visa applications, travel insurance, transfer services, etc.), maintaining our customer records, invoicing, collections, marketing, statistics, etc. All statistics and analyses are prepared in an anonymized format and therefore do not contain information that can be directly attributed to you as an individual.
Hygway processes your personal data in connection with the administration of supplier and/or partnership relationships, where you are a supplier or partner, or are a contact person at a supplier or partner with whom Hygway collaborates as part of the operation of our business, including maintaining our CRM register with information about our contacts at our suppliers and partners.
Hygway processes your personal data in connection with compliance with laws and regulations to which Hygway is subject in connection with the operation of the business or to fulfill various reporting or information obligations in accordance with applicable laws and regulations.
Hygway does not use your personal information to make decisions that are based solely on automated processing, including profiling.
Hygway strives to ensure that all personal information we process is accurate and up-to-date. Therefore, we ask you to always inform us of any changes in your personal details (e.g., change of address or payment information), so that we can ensure your personal information is always correct and up-to-date. If you have created a travel profile with us, we ask you to log in to your profile and update it in case of any changes.
Hygway uses marketing cookies, which are specialized cookies that collect information about a user’s browser history and preferences to deliver targeted and personalized advertising. When we share data with companies like Meta (owner of Facebook and Instagram), it is those companies that then have responsibility for your data once the transmission has occurred. Here are examples of marketing cookies.
First-party cookies:
Third-party cookies:
When your data (email, name, website visits, order data) is stored for email marketing and automation at Hygway, you can expect the following:
Unsubscribing from Hygway email marketing can be done at the bottom of all sent newsletters and automated emails, or by contacting Hygway at contact@hygway.com to be unsubscribed manually.
The information is processed to fulfill the agreement with you to send you the newsletter, in accordance with GDPR Article 6, paragraph 1, sub-b, which you have consented to receive under the Marketing Act.
We process the information based on our legitimate interest in marketing our services, in accordance with GDPR Article 6, paragraph 1, sub-f.
Our assessment is that your interests and fundamental rights do not outweigh this interest, because:
It is also our assessment that Hygway is a joint data controller for the processing of the provided information with the social media providers. In this regard, reference is made to the agreements on joint data responsibility, which the respective providers make available, where you can read more about the distribution of responsibilities in connection with the processing activities, which we are joint data controllers of.
Hygway processes your information as a general rule on one of the following grounds:
(1) This consent, (2) entering into or fulfilling your contract with Hygway, (3) the interests of Hygway being legitimate, i.e., the purposes described above, (4) fulfilling a legal obligation imposed on Hygway, (5) protecting the vital interests of you or another natural person, (6) the processing is necessary to establish, exercise or defend a legal claim, and (7) the processing is necessary to comply with Hygway’s or your labor, health, and social legal obligations arising from national law or EU law. There may also be situations where we process your personal data for the legitimate interests of a third party with regard to the purposes described above, unless the interest in your interests outweighs it.
Hygway only provides information to the extent necessary as part of the operation of our business, including to be able to provide your trip and the other products you have purchased from us in connection with it.
Hygway will typically provide personal information to the following recipients in connection with booking a trip and thus related products:
A GDS is an IT network system owned or operated by a company that enables transactions between the travel industry’s service providers, primarily airlines, hotels, car rental companies, and travel agencies. A GDS connects services, prices, and bookings by consolidating products across the three travel sectors, namely flight reservations, hotel reservations, and car rentals.
Hygway uses the following GDS as part of our business: Amadeus.
Hygway provides personal information to airlines in connection with booking your travel. For booking your flight, we will typically provide information such as first name, middle name(s), last name, departure airport, destination, date of outbound and return travel, date of birth, frequent flyer number, special requests related to your travel, including booking special menus during the flight and if needed, special assistance on the flight or at the airport for the selected airline.
In connection with travel to special destinations, we may also provide your passport number, passport expiration date, and your weight to the airline.
Hygway provides personal information to the hotels you will be using on your trip. For the purpose of booking your hotel stays, we will typically provide information such as first name, middle name(s), last name, destination, arrival and departure date, room category, bonus card number, special requests related to your trip, including special meal requests during your hotel stay and any need for special assistance during your hotel stay in connection with disability or illness.
Hygway provides personal information to car rental companies if you need a vehicle during your trip. For the purpose of booking your rental car, we will typically provide information such as first name, middle name(s), last name, pickup location, rental period, vehicle category, bonus card number, special requests related to the rental of the vehicle, including special arrangements in connection with disability or illness, child seats, etc.
Hygway provides personal information to bus companies if you are taking a bus trip as part of your travel (e.g., in connection with day trips to known tourist attractions, etc.). For the purpose of booking your bus trip, we will typically provide information such as first name, middle name(s), last name, pickup location, date and time of the bus trip, destination, and special requests related to the bus trip, including the booking of special menus during the bus trip and if necessary, the need for special assistance during the hotel stay due to disability or illness.
Hygway provides personal information to shipping companies if you are taking a ship trip as part of your travel (e.g., in connection with day trips to known tourist attractions, cruises, etc.). For the purpose of booking your ship trip, we will typically provide information such as first name, middle name(s), last name, destination, route, date and time of departure and return, and special requests related to the ship trip, including the booking of special menus during the voyage and if necessary, the need for special assistance during the voyage due to disability or illness.
A bedbank is an IT-network system owned or operated by a company that enables transactions between the service providers in the travel industry, primarily hotels and travel agencies or end customers. Hygway provides personal information to bedbanks to book the hotels you need for your trip. To book your hotel stays through a bedbank, we will typically provide information such as first name, middle name(s), last name, destination, arrival and departure date, room category, bonus card number, special requests related to your trip, including ordering special meals during your hotel stay and if needed, special assistance during your hotel stay related to disability or illness.
If as part of your journey you need to participate in excursions or require transfers, [Hygway] may provide personal information to travel agents. The travel agent is responsible for arranging the relevant excursion or transfer by ordering the desired services from local suppliers at the destination. For the purpose of booking your excursions, transfers, etc., we typically provide information about first name, middle name(s), last name, date and time of arrival and/or departure, type of vehicle, destination, as well as special requests in connection with the transfer or excursion, including booking special menus and/or the need for special assistance due to disability or illness.
As part of your booking process with us, you have the option to add a travel and/or cancellation insurance. If you wish to add such insurance, we will provide personal information to the insurance company for their processing of the insurance with them. For the issuance of a travel and/or cancellation insurance, we typically provide the insurance company with information such as first name, middle name(s), last name, email address, destination, departure and return date, and type of trip.
Hygway collaborates with the following insurance companies as part of our business: Gouda.
As part of booking your trip with us, you have the option to rent any equipment you might need for your trip, such as ski equipment, diving equipment, and similar items. If you wish to rent such equipment, we will forward your information to the company at your destination where you should rent the equipment. For equipment rental, we typically provide the rental company with information about first name(s), middle name(s), last name, type of equipment, pickup location, rental period, as well as information about height, weight, clothing and shoe size.
When you choose Hygway, you have the option to receive a qualified offer for a trip. A qualified offer is a form of offer where a preliminary reservation of the desired trip is made in connection with the preparation of the offer. This gives you the opportunity to reserve a spot on the desired departures up to three days before you decide whether to issue a ticket for the preliminary reservation or to cancel it.
To be able to provide a qualified offer, we forward your information and the desired reservation to a GDS (as mentioned above), which makes the preliminary booking with the airline, hotel, etc.
Since information about you is forwarded to several new independent data controllers (GDS, airlines, hotels, etc.) in connection with the obtaining of the qualified offer, your information may be stored with these recipients after the offer expires—even if the offer is cancelled.
Hygway may also further transmit and/or transfer your personal information to other suppliers and/or service providers in connection with the normal operation of our business, e.g., in connection with external administration of our IT systems, analytical tasks, marketing tasks, collection, credit assessment, audit, legal assistance, etc.
For further information about the processing and protection of your personal information by our suppliers and partners, please refer to their privacy policies and terms.
Hygway strives to limit the disclosure of personal information in personally identifiable format to the greatest extent possible to thereby limit the cases where information is disclosed that can be traced back to you personally.
Hygway does not disclose your personal information unless this is necessary to be able to perform our business or meet your needs.
Due to the nature of Hygway’s business, your personal information may be transferred to countries outside the EU/EEA in connection with booking a trip with us. To be able to provide our services to you, we need to use partners and suppliers outside the EU/EEA.
Without the possibility of transferring your information to recipients outside the EU/EEA, we will not be able to deliver the desired trip to you. This applies if ordering your trip requires transferring information to recipients outside the EU/EEA, for example, to be able to book flights, hotels, etc. at your travel destination.
The data protection legislation in these countries may be less stringent than in Denmark and the rest of the EU/EEA, as in the majority of cases, these will be countries where the EU Commission has assessed that the level of data protection does not meet the level of data protection within the EU/EEA.
In the case where it is practically possible for us, the transfer of your personal data will take place based on the standard transfer agreements developed by the European Commission, which are specifically designed for this purpose. As far as transfers to the USA are concerned, these will, as far as possible, take place based on Privacy Shield. Privacy Shield is an agreement between the EU and the USA, which, among other things, establishes a strong set of data protection rules and security measures that the American companies participating in the program are obligated to comply with when processing personal data.
In certain cases, it will not, however, be practically possible for Hygway to enter into a standard data transfer agreement or apply Privacy Shield as a legal transfer basis. In such cases, the transfer of your personal information will take place under the authority of Article 49(1)(b) of the Data Protection Regulation, as the transfer of your personal information to the relevant country is necessary for the performance of the contract between you and Hygway (booking your trip) or for the implementation of measures taken at your request before the conclusion of such a contract (e.g., in connection with the issuance of a qualified offer as mentioned above under section 7).
It is therefore important that you are aware that the transfer of your personal information to countries outside the EU/EEA in connection with booking a trip with Hygway means that your personal information will not enjoy the same protection as under Danish or EU legal regulations.
There is a significant risk associated with the transfer of information that there may be no clear, precise, and accessible rules in the relevant country regarding the authorities’ access to your personal data; that there are no rules regarding the authorities’ access to your data needing to be necessary and proportionate; that the country does not have an independent and effective supervisory authority; and that the country does not have accessible and effective remedies for the registered.
If you do not wish for Hygway, in connection with booking your travel(s), to send your personal data to recipients outside the EU/EEA, please inform us no later than when booking your travel.
Hygway will under no circumstances transfer your personal data to recipients outside the EU/EEA unless this is necessary to be able to carry out our business and meet your needs, such as by delivering the desired travel to you.
Personal information is not retained longer than necessary to fulfill the purpose for which it was collected, unless retention is necessary to comply with national legal requirements, including legally mandated retention periods related to bookkeeping, etc.
It is Hygway’s policy to protect personal information by implementing adequate technical and organizational security measures. When we no longer need your personal information, we will ensure that it is deleted in a secure manner.
You always have the right to exercise your rights under the applicable data protection laws at any time. You can, among other things, request access to the personal information that Hygway possesses, as well as object to the processing of the information, including objecting to automated decisions and profiling or the use of your personal information for direct marketing. Additionally, you can request correction or deletion of any incorrect information about yourself, withdraw consent for the processing of your personal information, and exercise your right to data portability.
If you wish to exercise one or more of your rights, please contact us at e-mail: contact@hygway.com. Your request will be handled in accordance with the applicable data protection legislation at all times.
Complaints about Hygway’s processing of your personal data can be made to:
Datatilsynet
Borgergade 28, 5.
1300 København K
E-mail: dt@datatilsynet.dk
Hygway regularly reviews and updates this Privacy Policy. Therefore, you should regularly check this Privacy Policy for any changes that may affect our processing of your personal information.
