1. About This Privacy Policy

Small Voyage takes the protection of personal information and the privacy of our travellers seriously.

This Privacy Policy explains how we collect, use, process, store and, where necessary, share your personal information when you visit our website, contact us, make an enquiry, book a tour, travel with us, subscribe to our communications or otherwise use our services.

It also explains the rights you may have in relation to your personal information and how you can contact us regarding privacy matters.

We may update this Privacy Policy from time to time to reflect changes in applicable laws, our services, technology or the way we operate our business. Where appropriate, significant changes may be communicated through our website or other suitable communication channels.

We encourage you to review this Privacy Policy periodically.

2. Who Is Small Voyage?

Small Voyage is a travel brand based in Türkiye, specialising in small-group tours and related travel services.

Small Voyage is operated by AND Seyahat Danışmanlığı Tur. Tic. Ltd. Şti.

References in this Privacy Policy to “Small Voyage”, “we”, “us” or “our” refer to AND Seyahat Danışmanlığı Tur. Tic. Ltd. Şti., unless otherwise stated.

For the purposes of applicable data protection legislation, the entity responsible for processing your personal information is:

Company: AND Seyahat Danışmanlığı Tur. Tic. Ltd. Şti.
Address: Cumhuriyet Mah. Atatürk Blv. No:70/11, Ürgüp/Nevşehir, Türkiye
Email: info@smallvoyage.com

For personal data processing activities carried out in Türkiye, we take into account the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and other applicable legislation.

Where applicable to individuals located in the European Economic Area or the United Kingdom, we also take into account the requirements of the EU General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR”).

3. What Personal Information Do We Collect?

The personal information we collect depends on how you interact with Small Voyage and the travel services you request or purchase.

3.1. When You Make an Enquiry or Book a Tour

When you enquire about or book a Small Voyage tour, we may collect some of the following information:

  • full name;
  • date of birth;
  • nationality;
  • gender or title, where relevant;
  • email address;
  • telephone number;
  • country of residence;
  • billing information;
  • booking details;
  • tour and departure date;
  • accommodation details;
  • transportation or flight information;
  • passport information;
  • a copy of your passport where required;
  • travel insurance information;
  • emergency contact details;
  • dietary requirements;
  • food allergies;
  • health, mobility or accessibility information where relevant to the safe delivery of the tour; and
  • other information you voluntarily provide in connection with your booking or travel arrangements.

We do not necessarily request all of this information for every booking. We aim to collect only the information reasonably required to arrange and provide the relevant travel services.

3.2. Health and Other Sensitive Personal Information

Certain tours or activities may require information about health conditions, allergies, disabilities, mobility requirements or other circumstances relevant to your safety or participation.

Such information may be considered sensitive personal information or special category data under applicable data protection laws.

We process this information only where necessary and where an appropriate legal basis exists.

Where required for your safety or the proper operation of the tour, relevant information may be shared with a tour leader, licensed guide, activity provider, medical professional, emergency service or another relevant service provider.

3.3. Information About Other Travellers

If you make a booking on behalf of another person or a group, you may provide us with personal information relating to other travellers.

You are responsible for making those individuals aware that their information will be provided to Small Voyage and for informing them of this Privacy Policy where appropriate.

If another person makes a booking on your behalf, we may receive the personal information necessary to administer your booking from that person.

3.4. Emergency Contacts

We may ask you to provide the name and contact details of a person who can be contacted in an emergency.

We will use this information only where reasonably necessary in connection with your safety, welfare or travel arrangements.

4. Payment and Financial Information

Payments for Small Voyage bookings may be made by bank transfer, credit or debit card, or through third-party payment service providers.

For online payments, we may use PayPal and Stripe. Depending on the payment infrastructure available, supported payment and card networks may include Visa, Mastercard, American Express (Amex), Discover and TROY.

When you make an online card payment, your payment information may be processed directly through the secure systems of the relevant payment service provider.

Small Voyage does not store full credit or debit card numbers, card security codes such as CVV/CVC, or similar sensitive card authentication information on its own systems.

For payment administration, accounting, refunds and compliance purposes, we may process information such as:

  • payment date;
  • payment amount;
  • currency;
  • transaction or payment reference;
  • billing information;
  • payment status; and
  • bank account information where necessary for refunds or similar transactions.

PayPal, Stripe, banks and relevant payment networks may process personal and financial information under their own privacy policies and legal obligations.

Please do not send full credit or debit card details to Small Voyage through ordinary email, messaging applications or other unsecured communication channels.

5. Website and Technical Data

When you visit the Small Voyage website, certain technical information may be temporarily processed to enable the website to function, maintain security and deliver pages to your device.

Depending on the technical infrastructure used, this information may include:

  • IP address;
  • device type;
  • browser type and version;
  • operating system;
  • pages visited; and
  • technical connection or session information.

Small Voyage does not use this technical information to individually identify, track or profile website visitors. This information is not added to individual customer profiles and is not permanently recorded or retained by Small Voyage for these purposes.

We do not sell or disclose this technical information to third parties for marketing purposes.

However, providers involved in operating the website, such as hosting, server, security or content-delivery infrastructure providers, may temporarily process certain technical information where technically necessary to provide their services or maintain system security.

Where this occurs, such processing is limited to what is reasonably necessary for the relevant technical service.

Where cookies or similar technologies are used, further information about their purpose and operation is provided in our separate Cookie Policy.

6. Marketing Communications

If you subscribe to our newsletter or other marketing communications, we may collect information such as:

  • your name;
  • email address;
  • country;
  • travel interests or preferences; and
  • information about previous Small Voyage bookings or interactions where relevant.

We may use this information to communicate with you about new tours, departure dates, destinations, travel content, offers or other Small Voyage news.

Electronic marketing communications will only be sent where we have an appropriate legal basis to do so under applicable law.

You may unsubscribe from marketing communications at any time by using the unsubscribe link contained in our marketing emails or by contacting us at info@smallvoyage.com.

Opting out of marketing communications will not prevent us from sending operational or service communications relating to an existing enquiry or booking.

7. Photography and Video

Photographs or videos may be taken during Small Voyage tours by travellers, tour leaders, guides or other individuals.

Where photographs or videos taken by or on behalf of Small Voyage clearly identify you and are intended for use on our website, social media, advertising or other marketing materials, we will obtain your consent where required by applicable law.

Where a professional photographer or videographer is scheduled to participate in a tour for promotional purposes, travellers will be informed where appropriate and any necessary permissions will be obtained.

Small Voyage is not responsible for photographs or videos taken independently by other travellers for their personal use.

8. Why Do We Process Your Personal Information?

We may process your personal information for purposes including:

  • responding to your enquiries;
  • creating and administering your booking;
  • arranging and delivering tours;
  • organising accommodation, transportation, guiding, activities and other travel services;
  • communicating with you about your booking;
  • providing pre-departure information;
  • managing operational communications during your tour;
  • managing safety and emergency situations;
  • processing payments and refunds;
  • providing customer service;
  • managing complaints and feedback;
  • improving our tours and services;
  • maintaining the functionality and security of our website;
  • preventing fraud and misuse;
  • managing accounting and financial processes;
  • complying with legal and regulatory obligations;
  • responding to lawful requests from public authorities; and
  • carrying out marketing activities where legally permitted.

9. Legal Bases for Processing Personal Information

The legal basis on which we process personal information may vary depending on your location, the information concerned and the purpose of the processing.

Where applicable, we may rely on one or more of the following grounds.

Performance of a Contract

When you book a Small Voyage tour, certain personal information must be processed in order to create and administer your booking and provide the travel services you have purchased.

Legal Obligations

We may process or retain information where required by applicable tax, accounting, tourism, travel, security or other laws and regulations.

Legitimate Interests

We may process information where reasonably necessary for legitimate business purposes, such as managing customer relationships, improving our services, maintaining website security, preventing fraud and operating our business.

Where we rely on legitimate interests, we consider the potential impact on your privacy and balance our interests against your rights and freedoms.

Consent

Where required by applicable law, we may request your consent before processing certain information, particularly in relation to certain marketing activities, photographs or videos, or sensitive personal information.

Where processing is based on consent, you may withdraw that consent subject to applicable law.

Vital Interests

In an emergency, personal information may be processed or disclosed where necessary to protect your life, health or safety, or that of another individual.

10. How Do We Collect Your Information?

We may collect personal information directly from you when you:

  • use our website;
  • contact us by email, telephone or other communication channels;
  • submit an enquiry;
  • complete a booking;
  • make a payment;
  • subscribe to our newsletter or marketing communications;
  • complete a form or survey;
  • provide feedback; or
  • communicate with us before, during or after a tour.

We may also receive information about you from another traveller who makes a booking on your behalf, a travel agent or business partner, or a travel service provider involved in your booking.

11. Sharing Your Information

In order to respond to your enquiry, administer your booking and provide the travel services you have purchased, we may share necessary personal information with:

  • hotels and other accommodation providers;
  • licensed professional tourist guides and tour leaders;
  • transportation and transfer companies;
  • drivers and vehicle operators;
  • airlines and other transport providers;
  • restaurants;
  • museums, archaeological sites and activity providers;
  • boat, balloon and other experience providers;
  • local tour operators and destination partners;
  • payment service providers;
  • banks and financial institutions;
  • reservation and operational systems;
  • IT, hosting, cloud and technical service providers;
  • email and customer communication providers;
  • accounting, legal and other professional advisers;
  • insurers or medical providers where necessary; and
  • government bodies, regulators or other authorities where legally required.

We aim to disclose only the personal information reasonably necessary for the relevant service or purpose.

Some travel providers may process your personal information independently under their own legal obligations and privacy policies.

12. International Data Transfers

Travel services can involve international transfers of personal information.

Small Voyage is based in Türkiye, but some technology, payment, reservation, communication or cloud service providers we use may operate or process information outside Türkiye.

Where Small Voyage operates tours outside Türkiye, personal information may also need to be shared with hotels, local operators, transport companies or other travel service providers in the relevant destination.

Where personal information originating from the European Economic Area or the United Kingdom is transferred internationally, appropriate safeguards required by the EU GDPR or UK GDPR will be used where applicable.

Transfers of personal information from Türkiye to other countries will be handled in accordance with the KVKK and applicable rules governing international transfers.

13. Children's Personal Information

Some Small Voyage tours may be available to children or younger travellers travelling with their parents or legal guardians.

In such cases, it may be necessary to process information including the child's name, date of birth, passport details, dietary requirements, health information or other information reasonably required to provide the travel services.

We take additional care when processing children's personal information and will seek the authorisation of a parent or legal guardian where required by applicable law.

Our website and services are not designed for children to independently create bookings or submit personal information without the involvement of a parent or legal guardian.

14. Research, Feedback and Service Improvement

We may invite you to provide feedback about your booking or travel experience.

This may include surveys, reviews or direct communication following a tour.

Where you choose to provide feedback, we may use it to:

  • evaluate our tours;
  • improve itineraries and operations;
  • understand traveller preferences;
  • improve customer service;
  • develop future products and destinations; and
  • resolve issues or complaints.

Where practical, information may be aggregated or anonymised for internal analysis.

We will not publish personally identifiable testimonials, reviews, photographs or similar material for promotional purposes where your consent is legally required unless that consent has been obtained.

15. Selling Personal Information

Small Voyage does not sell your personal information.

We do not exchange personal information for payment with data brokers or other businesses.

Personal information may only be disclosed as described in this Privacy Policy, including where necessary to provide travel services, operate our business, comply with legal requirements or where you have otherwise authorised us to do so.

16. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or as required by applicable law.

Retention periods may depend on:

  • the nature of the information;
  • the duration of our relationship with you;
  • contractual requirements;
  • accounting and tax obligations;
  • legal and regulatory requirements;
  • potential disputes or legal claims; and
  • security and fraud-prevention requirements.

When personal information is no longer required, we will take reasonable steps to delete, destroy or anonymise it, subject to applicable legal and technical requirements.

Certain booking, invoice, transaction or accounting records may need to be retained for longer periods where required by law.

17. How We Keep Your Information Secure

We use reasonable technical, administrative and organisational measures designed to protect personal information against:

  • unauthorised access;
  • loss;
  • misuse;
  • alteration;
  • unauthorised disclosure; and
  • destruction.

These measures may include access controls, secure systems, limited access to personal information and appropriate arrangements with service providers.

Where we become aware of a personal data breach, we will assess the incident and notify affected individuals and/or the relevant authorities where required by applicable law.

No internet-based system can be guaranteed to be completely secure. We therefore encourage you to take appropriate precautions when transmitting personal information online.

18. Your Privacy Rights

Depending on where you live and the applicable data protection law, you may have certain rights in relation to your personal information.

These may include the right to:

  • ask whether we process personal information about you;
  • request access to personal information we hold about you;
  • request correction of inaccurate or incomplete information;
  • request deletion of personal information where applicable;
  • request restriction of processing where applicable;
  • object to certain processing activities;
  • withdraw consent where processing is based on consent;
  • object to or unsubscribe from direct marketing;
  • request data portability where applicable;
  • obtain information about third parties to whom your information has been transferred where applicable; and
  • lodge a complaint with the relevant data protection authority.

These rights are subject to applicable law and may not apply in every circumstance.

For example, we may need to retain certain information where required by tax, accounting or other legal obligations even after you request deletion.

We may ask you to provide information necessary to verify your identity before responding to a privacy request.

To exercise your rights, please contact us at info@smallvoyage.com.

19. Rights Under Turkish Data Protection Law

Where the Turkish Personal Data Protection Law No. 6698 applies, data subjects may exercise the rights available under Article 11 of the KVKK, subject to the conditions and limitations provided by law.

These include the right to:

  • learn whether personal data is being processed;
  • request information regarding the processing of personal data;
  • learn the purpose of processing and whether the data is being used in accordance with that purpose;
  • know the third parties to whom personal data has been transferred domestically or internationally;
  • request correction of incomplete or inaccurate personal data;
  • request deletion or destruction of personal data where the applicable legal conditions are met;
  • request notification of correction, deletion or destruction to relevant third parties where applicable;
  • object to certain outcomes resulting from the analysis of personal data exclusively through automated systems; and
  • request compensation where damage has arisen as a result of unlawful processing of personal data.

Requests relating to these rights may be submitted to info@smallvoyage.com.

20. Third-Party Links

Our website may contain links to websites operated by third parties, including travel providers, payment providers or other external services.

Small Voyage does not control the privacy practices of those websites.

When you follow a link to a third-party website, the processing of personal information on that website will generally be governed by that organisation's own privacy policy.

We encourage you to review the relevant privacy policy before providing personal information to a third-party website.

21. Cookies

Our website may use cookies or similar technologies where necessary for website functionality, security or other permitted purposes.

Information about the cookies used by Small Voyage, their purposes, duration and available choices is provided in our separate Cookie Policy.

Where applicable law requires consent for particular cookies or similar technologies, they will not be activated until the required consent has been obtained.

22. Complaints

If you have concerns about how Small Voyage has collected, used, stored or otherwise processed your personal information, please contact us first so that we can review the matter.

You may contact us at:

info@smallvoyage.com

We will review privacy-related enquiries and complaints and respond within a reasonable period in accordance with applicable law.

Where applicable, you may also have the right to lodge a complaint with the competent data protection or supervisory authority in your country or jurisdiction.

23. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your privacy rights or have concerns about how your personal information has been handled, please contact:

AND Seyahat Danışmanlığı Tur. Tic. Ltd. Şti.
Small Voyage
Address: Cumhuriyet Mah. Atatürk Blv. No:70/11, Ürgüp/Nevşehir, Türkiye
Email: info@smallvoyage.com

We take privacy enquiries seriously and will respond in accordance with applicable data protection legislation.