PRIVACY POLICY – ProTourNet (PTN)

Last updated: [1/12/2025]

1. Data Controller

The Data Controller is: [Albanian Odyssey SHPK]

Registered address: [Tirane, Albania]

Privacy contact email: [Info@protournet.com]

Phone (optional): [+355 69 619 1691]

If appointed, the Data Protection Officer (DPO) can be contacted at: [Info@protournet.com].

2. Scope

This Privacy Policy explains how we process personal data collected through [www.protournet.com] (the “Website”).

Note: PTN may publish a more specific privacy notice inside the platform / user area for registered users and platform actors.

3. Legal framework

We process personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR – Regulation (EU) 2016/679) where applicable, and rules on cookies and similar technologies derived from the ePrivacy framework and national implementations.

Where relevant in Albania, supervisory matters relate to the Information and Data Protection Commissioner (IDP).

4. Categories of personal data processed

Depending on how you use the Website, we may process:

A) Technical and usage data (log data)

Data automatically collected (e.g., IP address, device identifiers, browser information, date/time, visited pages) necessary for operating and securing the Website.

B) Data you provide voluntarily

• Contact details (name, email, phone) via contact forms or inquiries.
• Content of messages you send to us (free text).
• Any details needed to provide information, a quote, or a demo (if applicable).

C) Cookies and similar technologies

See the dedicated Cookie Policy.

5. Purposes and legal bases

We process personal data for the following purposes:

1. Website operation and security (fraud/abuse prevention, troubleshooting, logs)

• Legal basis: legitimate interests and/or technical necessity.

2. Handling inquiries and requests (contact, support, demos, information)

• Legal basis: contract / pre-contract steps and/or legitimate interests.

3. Legal compliance (accounting, tax, authority requests, legal defense)

• Legal basis: legal obligation and/or legitimate interests.

4. Marketing / newsletters (only if enabled and where required, with consent)

• Legal basis: consent (withdrawable at any time).

5. Analytics and improvement (statistics, performance, UX)

• Legal basis: consent where required for non-essential cookies; otherwise only where permitted and appropriately configured.

6. Processing methods and security

We process data using appropriate technical and organizational measures designed to protect against unauthorized access, disclosure, alteration, or destruction.

7. Recipients (processors and third parties)

We may share data with:

• IT/hosting providers and Website maintenance providers.
• Service providers needed for operation (email provider, CRM, security/anti-spam tools, analytics).
• Professional advisors (legal/accounting) where necessary.
• Public authorities where required by law.

Where required, such parties act as Data Processors under relevant agreements.

Third-party services list (update based on your actual stack):

• Hosting: [HOSTING PROVIDER + COUNTRY]
• Email: [SERVICE]
• Analytics: [GA4 / Matomo / other]
• Security/Anti-spam: [reCAPTCHA / Wordfence / other]
• Embedded content: [YouTube / Maps / other]

8. International data transfers

If personal data is transferred outside the EEA, we will rely on appropriate safeguards (e.g., Standard Contractual Clauses) or another valid transfer mechanism, as required by applicable law.

9. Data retention

We retain data only as long as necessary for the purposes described:

• Contact requests: until handled, plus a reasonable period for follow-up and legal protection.
• Technical logs/security: as needed for technical and security purposes.
• Marketing/newsletters: until consent is withdrawn or you request deletion.
• Legal obligations: for the periods required by law.

10. Your rights

Subject to applicable law (including GDPR where applicable), you may have the right to:

• access, rectification, erasure;
• restriction, objection;
• data portability (where applicable);
• withdraw consent at any time (without affecting prior processing).

To exercise your rights: [info@protournet.com].

11. Complaints

You may lodge a complaint with the competent supervisory authority. In Albania, the competent authority is the Information and Data Protection Commissioner (IDP). If applicable, you may also contact the supervisory authority in your EU/EEA country of residence.

12. Children

The Website is not intended for children. If you believe a child has provided personal data, contact us at [info@protournet.com] to request deletion.

13. Changes to this policy

We may update this policy from time to time. The updated version will be posted on this page with a revised “Last updated” date.