Privacy

1. Data Controller

2. What Verneus Tours is — and what it is not

Verneus Tours is a marketing and technology intermediation platform, not a tour operator. Verneus Tours does not organise, lead or directly provide the tours listed on its platform or on the external platforms with which it collaborates.

The services available through Verneus Tours are of two types:

• Tours led by independent freelance guides who collaborate with Verneus Tours. These guides are independent professionals solely responsible for the execution, content, quality and safety of their tours.
• Excursions and activities offered by external tour operator companies that partner with Verneus Tours. In these cases, the external operator is directly responsible for the provision of the service.

In both cases, Verneus Tours acts solely as an intermediary that facilitates client acquisition and provides the necessary technology and tools. The service contract is between the client and the freelance guide or tour operator carrying out the tour — not between the client and Verneus Tours. Verneus Tours assumes no responsibility for the quality, safety or execution of services provided by freelance guide collaborators or external tour operators.

3. What personal data do we process and for what purposes?

Verneus Tours carries out the following personal data processing activities. For each one, the purpose, legal basis, data processed, recipients and retention period are specified.

3.1 Managing bookings received from external platforms

3.2 Managing bookings made through verneus.com

3.3 Internal tour management tool

To facilitate operational coordination, Verneus Tours uses a proprietary internal management application accessible to guide collaborators, protected by individual username and password credentials.

3.4 Payment processing

3.5 Cookies and browsing data

The verneus.com website uses first-party and third-party cookies for the technical operation of the service and analysis of site usage. Please see our Cookie Policy for full details.

The legal basis for non-essential cookies is your consent (Art. 6.1.a GDPR), which you may withdraw at any time through the cookie preferences panel on the website.

4. External booking platforms: responsibility and privacy policies

The tourism distribution platforms through which clients can book tours with Verneus Tours are independent data controllers for the personal data they collect directly from their users. Verneus Tours receives from them only the data necessary to coordinate the execution of the booked service with the relevant guide.

Each platform has its own privacy policy. We recommend you review them, particularly regarding retention periods and the rights you may exercise directly with each platform:

5. Disclosure of data to the freelance guide responsible for your tour

In order for your tour to take place correctly, Verneus Tours discloses your identifying data to the freelance guide responsible for the tour. This disclosure occurs automatically through the internal management tool at the time the booking is confirmed.

What data is shared with the guide?

The guide has access exclusively to: the booking holder’s full name, phone number, number of adult participants, number of minors associated with the booking, tour type and date. Your email address is not shared with the guide.

Who are the guides and what is their responsibility?

The guides are independent self-employed professionals who collaborate with Verneus Tours as tourism service providers. They are solely responsible for the execution of the tour. Verneus Tours provides them with the technology platform, management tools and client base, but does not direct or supervise the execution of tours.

For the purposes of the GDPR, freelance guides act as data processors (Art. 28 GDPR) with respect to client data accessed through the Verneus Tours tool, and are bound by the following contractual obligations:

• Use client data exclusively for the purpose of providing the booked tour on the relevant date, with no use for personal purposes or disclosure to third parties.
• Contact the client only when operationally necessary in connection with the booking (time changes, meeting point updates, incidents).
• Delete any client data stored on their personal devices, including saved contacts, once the tour has concluded.
• Maintain confidentiality regarding client data accessed in the course of their duties, during and after the service.

Time-limited access

The guide’s access to booking data covers the day of the tour and the following four calendar days, allowing advance group organisation and planning. At 00:00 each day, the application automatically revokes access to data for days that have already passed. On the 1st of each month, operational data from the previous month is automatically anonymised or deleted.

6. Recipients and international data transfers

Recipients of personal data

Verneus Tours does not sell or disclose personal data to third parties for commercial purposes. Data is only shared with:

• Freelance guide collaborators of Verneus Tours, as described in section 5.
• Stripe Payments Europe, Ltd., as data processor for payment processing.
• Public or judicial authorities, where required by law.

International data transfers

One Two World Venture LLC is headquartered in the United States. When personal data of individuals located in the European Union is transmitted to Verneus Tours’ systems, this constitutes an international data transfer. Verneus Tours ensures that such transfers are carried out with adequate safeguards under Chapter V GDPR, which may include:

• Standard Contractual Clauses (SCCs) adopted by the European Commission.
• European Commission adequacy decisions, where applicable.

As Verneus Tours’ freelance guide collaborators are located in EU member states (Czech Republic, Italy, Spain, Denmark), the data disclosure described in section 5 does not generally constitute an international data transfer.

7. Retention periods

8. Minors

Verneus Tours does not collect, process or store personal data of minors. The number of minors associated with a booking is a purely operational field of the adult booker’s reservation, used solely to manage tour capacity. Verneus Tours does not know the identity, name, age or any other personal data of those minors.

Verneus Tours’ services are not directed at minors. Bookings may only be made by adults, whether directly through verneus.com or through external booking platforms.

9. Photography during tours

Photographs for Verneus Tours social media

It is standard practice for Verneus Tours’ freelance guide collaborators to photograph moments during tours for publication on Verneus Tours’ official social media channels, primarily Instagram (@verneus_tours). These images are published as Stories.

Before taking any photograph in which identifiable participants may appear, the guide informs the group that:

• A photograph is about to be taken for publication on Verneus Tours’ Instagram Stories.
• Participation is entirely voluntary and optional.
• Anyone who does not wish to appear may say so to the guide or step out of the frame without any consequences.

Voluntarily remaining in the photograph after this information has been given constitutes the participant’s explicit consent to the processing of their image for this purpose (Art. 6.1.a GDPR).

Photographs taken at the guide’s own initiative

If a freelance guide takes photographs during a tour for personal purposes or purposes other than those described above, this is the sole responsibility of the guide as an independent professional, who must obtain participants’ consent in accordance with applicable law. Any queries may be directed to legal@verneus.com.

10. Your rights under data protection law

Under the GDPR, you have the following rights regarding your personal data:

How to exercise your rights

You may exercise any of the above rights by contacting us at:

• Email: legal@verneus.com
• Subject line: “GDPR — Exercise of Rights”
• Please attach a copy of a valid identity document

We will respond to your request within a maximum of one month from receipt. This period may be extended by a further two months where necessary, with prior notice.

Right to lodge a complaint with a supervisory authority

As Verneus Tours provides services in several EU member states, the following supervisory authorities are competent depending on where you are located:

You may lodge your complaint with the authority of the country where you habitually reside, where you work, or where the alleged infringement took place.

11. Security measures

Verneus Tours has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with Article 32 GDPR:

• Access to the internal tool is restricted by individual username and password credentials for each guide collaborator.
• Automatic revocation of guides’ access to past booking data at 00:00 each day following the tour.
• Automatic anonymisation of operational data on the 1st of each month.
• Payment data processed through Stripe (PCI-DSS certified), ensuring Verneus Tours never stores card data in its own systems.
• Confidentiality and data processor agreements with guide collaborators.
• Use of secure connections (HTTPS) on the verneus.com website.

12. Cookies

Full information about the cookies used on verneus.com — including the complete list, their purpose and how to manage or disable them — is available in our Cookie Policy.

13. Changes to this policy

Verneus Tours may update this policy to reflect changes in legislation or in the company’s operations. Any material changes will be notified via a prominent notice on the website. The date of the last update is always shown at the top of this document. The current version is permanently available at verneus.com/privacy/.

14. Contact

For any questions about how we process your personal data or about this policy:

• Email: legal@verneus.com
• Contact form: verneus.com/contacto/