Privacy Policy

1. Who We Are

This Privacy Notice explains how Voyage Companion Ltd ("Voyage Companion", "Modulix", "we", "us", "our") collects, uses, and protects personal data when you visit our website at voyagecompanion.io or use the Modulix AI platform ("Service").

Data Controller: Voyage Companion Ltd
Registered Office: 13/6 Fairfield Gardens, Edinburgh, EH6, Scotland, United Kingdom
Contact: privacy@voyagecompanion.io

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR), the EU GDPR (where applicable), and the Data Protection Act 2018.

2. Data We Collect

We collect and process the following categories of personal data:

2.1 Information You Provide

• Account Information: Name, email address, company name, job title, phone number
• Payment Information: Billing address, payment card details (processed by third-party payment providers)
• Booking Data: Traveller information, itineraries, preferences, special requirements
• Communications: Messages, support requests, feedback

2.2 Information We Collect Automatically

• Usage Data: Pages visited, features used, search queries, booking history
• Device Information: IP address, browser type, operating system, device identifiers
• Cookies and Tracking: See our Cookie Policy for details
• Log Data: Access times, error messages, API calls

2.3 Information from Third Parties

• Travel Suppliers: Booking confirmations, availability data from GDS providers (Amadeus, Sabre), wholesalers (Hotelbeds)
• Payment Processors: Transaction status, payment verification
• Analytics Providers: Aggregated usage statistics

3. How We Use Your Data

We process your personal data for the following purposes:

3.1 Service Delivery

• Creating and managing your account
• Processing bookings and payments
• Providing customer support
• Sending service notifications and updates

3.2 Service Improvement

• Analyzing usage patterns to improve features
• Training and improving our AI models
• Developing new products and services
• Conducting research and analytics

3.3 Communication

• Responding to inquiries and requests
• Sending marketing communications (with consent)
• Providing product updates and announcements

3.4 Legal and Security

• Complying with legal obligations
• Detecting and preventing fraud
• Enforcing our Terms of Service
• Protecting our rights and interests

4. Legal Basis for Processing

Under UK GDPR and EU GDPR, we process your personal data based on:

• Contract Performance: Processing necessary to provide the Service (e.g., account management, bookings)
• Legitimate Interests: Improving our Service, analytics, fraud prevention (balanced against your rights)
• Consent: Marketing communications, optional cookies, certain data sharing (you can withdraw consent anytime)
• Legal Obligation: Compliance with tax, accounting, and regulatory requirements

5. Sharing Your Data

We share personal data with the following categories of recipients:

5.1 Service Providers

• Cloud Infrastructure: Microsoft Azure (hosting, storage)
• Payment Processors: Stripe (payment processing)
• Travel Suppliers: Amadeus, Sabre, Hotelbeds (booking fulfillment)
• Analytics Tools: Usage tracking and analytics providers
• Support Tools: Customer support and communication platforms

5.2 Business Partners

With your consent, we may share data with tour operators, travel agents, or other partners necessary to fulfill bookings.

5.3 Legal Requirements

We may disclose data to law enforcement, regulators, or courts when required by law or to protect our rights.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring entity.

6. International Transfers

Some of our service providers are located outside the UK/EEA. When we transfer personal data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs): EU-approved contracts for data transfers
• UK International Data Transfer Agreement (IDTA): UK-approved transfer mechanism
• Adequacy Decisions: Countries recognized as providing adequate protection

For more information about our international transfers and to obtain copies of safeguards, contact us at privacy@voyagecompanion.io.

7. Data Retention

We retain personal data for as long as necessary to fulfill the purposes outlined in this Privacy Notice:

• Account Data: Duration of account plus 6 years (for legal/tax purposes)
• Booking Records: 7 years (for tax and regulatory compliance)
• Marketing Data: Until you withdraw consent or request deletion
• Usage Logs: 12 months (for security and analytics)
• Support Tickets: 3 years after resolution

After retention periods expire, we securely delete or anonymize personal data unless longer retention is required by law.

8. Your Rights

Under UK GDPR and EU GDPR, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restrict Processing: Limit how we use your data in certain circumstances
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Withdraw consent for processing at any time
• Right to Lodge a Complaint: File a complaint with the Information Commissioner's Office (ICO) in the UK

To exercise your rights, contact us at privacy@voyagecompanion.io. We will respond within 30 days.

9. Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption in transit (TLS/SSL) and at rest (AES-256)
• Access controls and authentication mechanisms
• Regular security assessments and penetration testing
• Employee training on data protection
• Incident response and breach notification procedures

While we strive to protect your data, no method of transmission or storage is 100% secure. Please use strong passwords and keep your login credentials confidential.

10. Cookies

We use cookies and similar technologies to improve your experience. For detailed information about our use of cookies, please see our Cookie Policy.

You can manage your cookie preferences at any time by clicking "Cookie Settings" in the footer of our website.

11. Changes to This Policy

We may update this Privacy Notice from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated policy on our website with a new "Last updated" date
• Sending an email notification to registered users
• Displaying an in-app notification

Your continued use of the Service after the effective date constitutes acceptance of the updated Privacy Notice.

12. Contact Us