1. Coverage

This Privacy Policy (“Policy”) outlines how ICS Travel Group collects, uses and manages personal data in connection with its website, including any personal information submitted via newsletter subscriptions, blog sign-ups, event registrations or contact forms.

The term “you” refers to individuals accessing or interacting with the Website. The terms “ICS Travel Group”, “we”, “us”, or “our” refer to ICS Travel Group, a leading inbound and destination management company, and our affiliated sub-companies.

Please note that individuals considered minors under applicable local laws are not permitted to register for, use or purchase any services offered through the website. ICS Travel Group does not knowingly collect personal data from minors. Should such information be inadvertently provided, it will not be retained or used.

2. Purpose

At ICS Travel Group, we recognize the importance of transparency regarding the collection, use, disclosure, transfer and storage of personal information. This Privacy Policy has been developed to inform you of our data handling practices and to outline how we process your personal data when you interact with our website or any of our digital platforms, in accordance with applicable data protection regulations.

We encourage you to read this Policy in conjunction with any other privacy notices or policies we may provide on specific occasions when personal data is being collected or processed. This Policy is intended to supplement those notices and does not override them.

We are committed to protecting your privacy and understand that the collection, use and disclosure of personal data carry significant responsibilities. We take these obligations seriously and handle all personal information with the utmost care and respect.

3. Data Controller Responsibility

Under applicable data protection laws, a “data controller” is defined as the individual or legal entity that determines the purposes and means of processing personal data. For the purposes of this Privacy Policy, ICS Travel Group acts as the data controller unless explicitly stated otherwise. This means ICS Travel Group is responsible for deciding how your personal data is collected, used and protected in relation to its services and digital platforms.

4. Categorization Data

Personal data refers to any information that identifies, relates to or could reasonably be linked to an individual. It does not include data where identifying information has been removed (anonymous data).

ICS Travel Group may collect personal data directly from you or indirectly through our partners and service providers during your interactions with us. Additionally, we may process aggregated data, such as statistical or demographic information, for analytical and business purposes. While this aggregated data may be derived from your personal data, it is not classified as personal under applicable laws unless it can
be used to directly or indirectly identify you.

We do not intentionally collect any sensitive personal data via our website. This includes information relating to race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, union membership, health data, genetic or biometric information or data regarding criminal convictions or offences.

The personal data we collect, use, store and transfer may include, but is not limited to, the following categories:

Contact Data: Such as your business address, email address and telephone numbers.

Identity Data: Including your first name, last name, title and user credentials or identifiers.

Marketing and Communication Data: Including your preferences for receiving marketing materials and your engagement with such communications. We may also track whether our communications are opened and read to enhance the relevance and effectiveness of our outreach.

Profile Data: Information gathered through your interactions with our website, such as referral sources, visited pages, form submissions and usage patterns.

Technical Data: Including device and system-related data such as IP address, browser type and version, time zone settings, login credentials, operating system, platform and plug-in details when accessing our website or online booking platform.

Usage Data: Information reflecting how you navigate and use our website and digital services.

5. Methods of Data Collection

We only collect personal data when it is voluntarily provided to us or automatically gathered through the use of our digital platforms. The main ways in which personal data is collected include the following:

(a) Direct Interactions:

You may provide us with personal data when you engage with ICS Travel Group directly, including but not limited to the following circumstances:

When making a booking or purchase via our website, through correspondence with our customer service team (email, phone, messenger, etc.) or in person, for example during trade shows.

When registering for an account, subscribing to our newsletters, participating in promotions or contests, submitting inquiries or completing forms on our website.

When providing feedback, responding to surveys or taking part in customer research initiatives.

When engaging with us during online or offline events, marketing campaigns or via pages we manage on third-party platforms or locations.

(b) Cookies and Automated Technologies:

We automatically collect certain technical data about your browsing behavior and device when you visit our website. This information is gathered through cookies, web server logs and similar tracking technologies. Such data may include your IP address, browser type, operating syste, and browsing patterns.

(c) Third Parties and Public Sources:

We may also obtain personal data from third-party sources, including:

Technical data from analytics providers (such as Google Analytics) that help us understand how users interact with our website and services.

6. Legal Grounds for Processing Personal Data

ICS Travel Group processes your personal data only where permitted by applicable data protection laws.
The legal bases on which we rely include the following:

(a) Performance of a Contract:

Processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into such a contract. This includes, for example, managing your bookings or travel arrangements.

(b) Compliance with Legal Obligations:

Processing is required in order to comply with legal or regulatory obligations to which we are subject. This may include retaining certain transactional data for tax or auditing purposes.

(c) Legitimate Interests:

Processing is necessary for the purposes of our legitimate interests or those of a third party, provided such interests are not overridden by your fundamental rights and freedoms. For instance, it is in our legitimate interest to ensure the security and proper functioning of our websites, portals and systems, or to improve our services through usage analysis. We ensure that any potential impact on your rights is carefully assessed before proceeding under this basis.

(d) Consent:

In some cases, we may rely on your explicit consent to process your personal data. This is typically the case when sending you direct marketing communications from third parties via email or SMS. Where consent is used as the basis for processing, you have the right to withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.

ICS Travel Group does not engage in personal data processing where our legitimate interests are overridden by the potential impact on you, unless required or otherwise permitted by law or with your express consent.

7. Personal Data Usage

ICS Travel Group processes your personal data only when permitted by applicable law and where a valid legal basis exists. The personal information we collect is used to support and enhance our relationship with you and may be processed for the following purposes:

(a) To inform you of our latest product announcements, promotional offers, events and news related to our services. These communications aim to enhance your experience with us. You may opt out of such communications at any time by using the unsubscribe option provided.

(b) To improve our products and services by using personal data for internal development, marketing analysis and service optimization. This includes tailoring our offerings to better match your preferences and travel interests.

(c) To send important administrative information, including service updates, confirmations, changes to our terms, conditions or policies, and other essential operational messages relating to your interactions with ICS Travel Group.

(d) To provide you with secure access to your account and related services, including booking details, travel itineraries and preferences.

(e) To personalize your experience on our Website by customizing content and displaying relevant offerings based on your preferences and browsing behavior.

(f) To send you updates about products and services provided by ICS Travel Group and our affiliated entities. This may also include payment reminders, travel vouchers and industry updates through newsletters. You may unsubscribe from marketing communications at any time using the links provided in our emails.

Personal data may also be used internally for research, auditing and analytical purposes to improve business performance and operational efficiency.

8. Collecting and Using of Non-Personal Data

Non-personal data refers to information that cannot be used to identify an individual, either directly or indirectly. ICS Travel Group may collect such data related to customer interactions across our websites, platforms or services.

This type of information may include aggregated statistical data regarding user behavior, preferences and usage patterns. We use this non-personal data for internal research, analysis, product development, performance monitoring and to enhance the overall user experience.

Aggregated and anonymized data may also be shared with third-party partners or service providers for the purpose of improving service offerings, supporting promotional initiatives or enhancing customer satisfaction. In all cases, the information shared does not personally identify any individual.

9. Cookies

ICS Travel Group uses cookies and similar technologies to enhance and personalize your experience on our website. These tools help us analyze website traffic, understand user behavior and improve functionality.

10. External Links

For your convenience, our website may contain links to external websites operated by third parties. Please be aware that once you click on such a link, you will be subject to the privacy policy of that third-party website. ICS Travel Group does not control these external sites and is not responsible for their content, practices or policies. We encourage you to review the privacy statements of any third-party websites you visit.

11. Disclosure of Personal Data to Third Parties

We may disclose personal data to third parties when necessary to process bookings, respond to inquiries or provide travel-related services. Your personal data may also be shared with service providers who perform functions on our behalf, including but not limited to:

• processing payments and reservations
• managing customer service
• handling logistics and travel documentation
• supporting IT systems and data storage
• conducting market research and satisfaction surveys

All third parties engaged by ICS Travel Group are required to maintain the confidentiality and security of your personal data and to use it only for the purposes for which it was disclosed.

Additionally, we may disclose your personal data under the following circumstances:

• To regulatory, governmental or legal authorities when required by applicable law, regulation, court order or legal process.
• To professional advisors such as legal counsel, auditors or insurers for the purposes of obtaining professional services.
• To potential buyers, investors or merger partners in the event of a business reorganization, acquisition or sale.

In such cases, personal data will remain subject to the principles outlined in this Policy.

12. International Data Transfers

As ICS Travel Group operates on a global scale, certain affiliated companies and other recipients of your personal data may be located in countries where the data protection standards do not necessarily match those of your home country. We take appropriate steps to ensure that any such transfer of personal data is compliant with applicable laws and is protected through robust contractual measures and security safeguards. These measures include implementing necessary technical and organizational security protocols to safeguard your personal data when transferred internationally.

13. Protection and Security

ICS Travel Group is committed to ensuring the security of your personal data by adopting appropriate technical and organizational measures to mitigate risks associated with data processing. Our security measures include, but are not limited to:

• Pseudonymization and encryption of personal data.
• Ensuring the confidentiality, integrity, availability and resilience of processing systems and services.
• Providing mechanisms to restore access to personal data in the event of physical or technical incidents.
• Regularly testing, assessing and evaluating the effectiveness of our security measures.

We also ensure that individuals with regular access to personal data are adequately trained and informed of their rights and responsibilities. While no security system is completely immune from risks, ICS Travel Group continues to employ best practices in data protection and security. We require all third parties processing your data to implement similar security standards. By interacting with our website or services, you acknowledge and consent to this Policy and the security practices we have in place.

14. Marketing and Opt-Out Rights

ICS Travel Group respects your preferences regarding the use of your personal data for marketing purposes. If you prefer not to receive marketing communications from us, we will honor your request and refrain from sending such materials. Additionally, if you request us to cease processing your personal data for marketing purposes, we will comply accordingly.

During the registration process or subsequent interactions, you may opt to receive communications such as product updates, promotions, special offers or travel opportunities directly from us or through third-party service providers. You can unsubscribe or adjust your preferences at any time by following the opt-out instructions included in each marketing communication.

15. Marketing and Third-Party Advertisers

Our Website may feature advertisements from third-party companies. We do not share your personal data with these advertisers unless you have explicitly granted us permission to do so – separately from any general consent provided during registration. These third-party advertisers may use cookies, pixel tags and similar technologies to collect session data regarding the advertisements you view and your browsing interests.

They may also combine this data with information gathered from your visits to other websites to serve you targeted advertisements for products and services relevant to your interests. When you click on a third-party advertisement or link, you will be redirected to an external site. ICS Travel Group is not responsible for the privacy practices or content of those external websites. We strongly recommend that you review the privacy policies of any third-party sites you visit, as their policies may differ significantly from ours.

16. Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including meeting legal, regulatory, accounting or reporting obligations, fulfilling contractual services and handling legal claims or complaints.

Your data will be maintained in our systems according to our internal document management, retention and destruction policies and in compliance with applicable laws. In some cases, retention may continue beyond the conclusion of our relationship, for example, to support refund claims, resolve disputes or comply with legal obligations.

Where appropriate, we may anonymize your data so that it is no longer identifiable. Anonymized data may be retained and used indefinitely for analytical, research or statistical purposes without further notice to you.

17. Policy Changes

This Privacy Policy is effective as of 1 May 2025. ICS Travel Group reserves the right to amend or update this Policy at any time. If significant changes are made, we will notify you via email or through a clear notice on our Website.

We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Continued use of our Website following the publication of changes will signify your acceptance of those updates.

18. Rights

Under applicable data protection laws, including the General Data Protection Regulation (GDPR), you have specific rights regarding your personal data. ICS Travel Group respects these rights and is committed to responding to requests in accordance with the law.

Your rights include:

(a) Right to Be Informed

You have the right to receive clear, transparent and easily understandable information about how your personal data is used. This Privacy Policy is intended to provide that information.

(b) Right of Access

You have the right to request access to your personal data and to obtain confirmation of whether we process your personal data, along with other details such as the purpose of processing, categories of data involved and recipients of your data.

(c) Right to Rectification

You may request the correction or completion of inaccurate or incomplete personal data. Where applicable, we will inform any third parties with whom we shared the data of the rectification.

(d) Right to Erasure

In certain circumstances, you may request the deletion of your personal data. This is not an absolute right and each request will be assessed according to legal obligations and our data retention practices.

(e) Right to Restrict Processing

You may request the restriction of your personal data processing in specific situations, such as when you contest the data’s accuracy or object to  processing, or if the data is no longer needed for our purposes but required by you for legal claims.

(f) Right to Data Portability

Where applicable, you may request to receive your personal data in a structured, commonly used and machine-readable format. This right applies to data provided by you and processed with your consent or under a contract, via automated means.

(g) Right to Object

You have the right to object to the processing of your personal data in certain situations, including when it is processed based on our legitimate interests or for direct marketing purposes. We will clearly inform you of this right at the point of data collection.

(h) Right Not to Be Subject to Automated Decision-Making

You have the right not to be subject to decisions made solely by automated processing, including profiling, where such decisions may produce legal effects or significantly affect you.

You may exercise any of the above rights by contacting us at: sales@icstravelgroup.com

We do not charge a fee to access your personal data or to exercise your rights. However, we may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. In some cases, we may refuse a request where legally permitted.

To protect your personal data, we may request specific information to confirm your identity before processing your request. We may also follow up with you to clarify or expedite your request.

We aim to respond to all legitimate requests within one calendar month. If your request is particularly complex or involves multiple inquiries, we will notify you of any delay and keep you updated throughout the process.

If you have any questions or concerns about this Privacy Policy or your personal data, please contact us at the email address provided above.