Axel Hotel San Sebastián - Adults Only

1. Introduction

DEB TRAVEL FZCO (“we”, “our”, “us”) values your privacy and

is committed to protecting your personal data in accordance with the applicable

laws and regulations of the United Arab Emirates, including the Dubai

International Financial Centre (DIFC) Data Protection Law No. 5 of 2020,

Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE

PDPL), and relevant international standards such as the EU GDPR, when

applicable.

This Privacy Policy explains how we collect, use, store, and

safeguard your information when you engage with our services through deb.travel

or via direct communication.

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2. Data Controller

Corporate Name: DEB TRAVEL – FZCO

Registered with: IFZA, Dubai, United Arab Emirates

Business License: Validly issued by IFZA Free Zone Authority

Address: Dubai, United Arab Emirates

Contact Email: info@deb.travel

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3. What Personal Data We Collect

We may collect the following categories of personal data:

               •             Identification data: Full name,

passport/ID details, nationality, date of birth.

               •             Contact details: Email address,

telephone number, physical address.

               •             Travel-related information: Flight

details, accommodation preferences, transfers, and activities.

               •             Payment details: Limited

information necessary to process transactions securely (processed via trusted

payment providers).

               •             Technical data: IP address,

browser type, device information, location data, and cookies.

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4. Purpose of Processing

We process your personal data for:

               •             Service delivery: To arrange

travel, accommodation, transportation, and activities.

               •             Customer support: To respond to

inquiries, complaints, or requests.

               •             Marketing and communications: With

your consent, to send offers, updates, and travel insights.

               •             Compliance: To fulfill our legal,

tax, and regulatory obligations in the UAE and internationally.

               •             Security and fraud prevention: To

safeguard our systems and users.

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5. Legal Basis for Processing

               •             Contractual necessity: To deliver

booked travel services.

               •             Consent: For marketing and

promotional communication.

               •             Legal obligation: As required

under UAE tax, immigration, or regulatory laws.

               •             Legitimate interest: For improving

services, maintaining security, and preventing fraud.

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6. Data Sharing and International Transfers

We may share your personal data with:

               •             Service providers and suppliers:

Airlines, hotels, car rental companies, and activity operators to fulfill your

bookings.

               •             Technology and payment providers:

For secure transaction processing and customer support.

               •             Authorities and regulators: When

legally required by UAE or international law.

               •             Business partners: Only with your

explicit consent.

Some service providers may be located outside the UAE. In

such cases, we ensure data is transferred under adequate safeguards in

compliance with UAE PDPL and international standards.

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7. Data Retention

               •             Travel services data: Retained

until the service is completed, plus an additional 5 years as per UAE tax and

accounting obligations.

               •             Marketing data: Retained until you

withdraw your consent.

               •             Legal and security records:

Retained as required under applicable UAE laws.

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8. Your Rights

In line with UAE PDPL and applicable international

standards, you have the right to:

               •             Access your personal data.

               •             Request rectification of

inaccurate data.

               •             Request deletion of your data when

legally permissible.

               •             Restrict processing under certain

conditions.

               •             Withdraw consent at any time for

marketing.

               •             Request data portability where

applicable.

               •             Object to processing for

legitimate reasons.

To exercise these rights, please contact us at

privacy@deb.travel and provide proof of identity.

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9. Security Measures

We implement robust technical and organizational measures to

protect your data against unauthorized access, alteration, disclosure, or

destruction. All payment-related data is handled through PCI-DSS compliant

providers.

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10. Cookies & Analytics

Our website uses cookies to improve user experience and

analytics (including Google Analytics). You can manage cookie preferences

through your browser settings.

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11. Updates to This Policy

We may update this Privacy Policy to remain compliant with

UAE regulations or business requirements. Substantial changes will be notified

via email or prominently displayed on our website.

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12. Contact Us

For questions, concerns, or data protection requests:

DEB TRAVEL – FZCO

Dubai, United Arab Emirates

privacy@deb.travel