1. IMPORTANT INFORMATION AND WHO WE ARE - Twin Star Journeys respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, store, share, and safeguard your personal information when you visit our website, contact us, or use our travel planning services. It also explains your rights under U.S., UK, and EU privacy laws, including the EU General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR), and applicable U.S. state privacy laws, such as the California Consumer Privacy Act (CCPA/CPRA).
This policy should be read together with any additional privacy or fair processing notices we may provide on specific occasions. This privacy policy supplements those notices and is not intended to override them.
Controller - Twin Star Journeys (referred to as “Twin Star Journeys”, “we”, “us”, or “our” in this policy) is the controller of your personal data when operating under EU/UK GDPR, and a “business” for purposes of U.S. state privacy laws.
We have appointed a Data Privacy Manager who oversees questions relating to this policy. If you have any questions, including requests to exercise your legal rights, please contact us using the details below.
Contact Details
Legal Entity: Twin Star Journeys
Email: fun@twinstar.travel
Postal Address: 904 Pacific St Suite 202 Brooklyn, NY 11238 U.S.A.
Telephone: +1.212.256.8984
For UK/EU data subjects, you may also contact us regarding GDPR-related concerns at the above contact information.
Complaints - You have the right to lodge a complaint with a relevant supervisory authority:
EU residents: your local EU Data Protection Authority
UK residents: the Information Commissioner’s Office (ICO) at www.ico.org.uk
U.S. residents: your applicable state Attorney General
We would appreciate the chance to address your concerns first, so please contact us before contacting a regulator.
Changes to This Policy - We review this policy regularly and may update it at any time. The latest revision date appears at the top of this page. Historic versions can be obtained by contacting us. Please keep us informed if your personal information changes during your relationship with us.
Third-Party Links - Our website may include links to third-party websites, plug-ins, or applications. Clicking those links may allow third parties to collect or share your data. We do not control these sites and encourage you to read the privacy policy of each site you visit.
2. THE DATA WE COLLECT ABOUT YOU - “Personal data” means any information that identifies an individual. We may collect, use, store, and transfer different categories of personal data, including:
Identity Data - Name, title, date of birth, gender, and similar identifiers.
Contact Data - Billing address, email, telephone numbers, mailing address.
Financial Data - Payment card information and billing details.
Transaction Data - Details of payments, refunds, booking histories, and itineraries.
Technical Data - IP address, browser type, login data, time zone settings, device identifiers, and similar technologies.
Profile Data - Usernames, passwords, preferences, interests, feedback, survey responses, and prior itinerary information.
Usage Data - Information about how you use our website and services.
Marketing and Communications Data - Your preferences for receiving marketing and updates from us or our partners.
Aggregated Data - Statistical or demographic data that does not directly identify you.
Special Category Data (Sensitive Data) - We may collect sensitive information only when necessary to provide travel services and only with your explicit consent:
Health or Mobility Information - Needed to ensure safe, appropriate travel arrangements.
Dietary Requirements or Religious Information - When relevant to your preferences or itinerary; may reveal religious beliefs. Failure to provide necessary sensitive data may limit our ability to provide certain services safely or legally.
If You Fail to Provide Required Data - If we need personal data to perform a contract with you and you do not provide it, we may not be able to deliver your requested services.
3. HOW WE COLLECT YOUR PERSONAL DATA - We collect data through:
Direct Interactions - You may provide data by:
Submitting travel enquiries or booking services
Creating an online account
Subscribing to updates or newsletters
Entering competitions or surveys
Contacting us via email, phone, social media, or forms
Automated Technologies - We automatically collect Technical Data using cookies, logs, and similar technologies. See our Cookie Policy for details.
Third Parties - We may receive data from:
Analytics providers (e.g., Google Analytics)
Advertising networks
Payment processors
Travel suppliers
Publicly available sources
Information About Others - If you provide data about someone else (e.g., family members, travel companions), you must ensure they consent and understand how their data will be used.
4. HOW WE USE YOUR PERSONAL DATA - We use personal data only when allowed by law. Most commonly:
To perform a contract with you (e.g., planning or fulfilling travel services)
For legitimate interests, provided your rights are not overridden
To comply with a legal obligation
Based on your consent, when required (e.g., marketing or special category data)
You may withdraw your consent at any time.
Purposes for Using Your Data
✔ Booking and itinerary creation
✔ Payment processing
✔ Relationship management
✔ Competitions, surveys, customer engagement
✔ Website administration
✔ Marketing, analytics, and personalization
5. MARKETING AND OPTING OUT - We may send marketing based on your preferences or prior interactions. You may opt out at any time by:
Clicking “unsubscribe”
Emailing us at fun@twinstar.travel
Contacting us using the details in Section 1
We will not sell your data.
6. COOKIES - Our website uses cookies to enhance functionality and analyze usage. You may disable cookies through your browser settings, but some features may not function correctly. See our Cookie Policy for details.
7. DISCLOSURE OF YOUR PERSONAL DATA - We may share your data with:
Travel suppliers (airlines, hotels, operators)
Payment processors
Customs, immigration, security agencies when required
Professional advisers (legal, insurance, accounting)
Marketing and analytics service providers
Law enforcement when required
Third parties in the event of business restructuring
We require all third parties to process your data securely and lawfully.
8. INTERNATIONAL DATA TRANSFERS - Because Twin Star Journeys works with global travel partners, your data may be transferred outside:
We use appropriate safeguards, including:
EU/UK Standard Contractual Clauses
Adequacy decisions
Additional contractual protections
Contact us for more details.
9. DATA SECURITY - We use appropriate organizational, technical, and physical safeguards, though no system is completely secure. If you suspect unauthorized use of your data, email us immediately at fun@twinstar.travel
10. DATA RETENTION - We retain personal data only as long as necessary to:
Provide services
Fulfill legal obligations
Resolve disputes
Maintain business records
We may anonymize data for research or statistical purposes.
11. YOUR LEGAL RIGHTS - Depending on where you live, you may have rights to:
Under UK/EU GDPR:
Access your data
Correct inaccuracies
Request deletion
Restrict processing
Object to processing
Data portability
Withdraw consent
Under U.S. state laws (e.g., CCPA/CPRA):
Know what data is collected
Access your data
Request deletion
Opt out of data sharing or selling
Non-discrimination for exercising rights
To exercise these rights, contact us at fun@twinstar.travel
12. CHANGES TO THIS POLICY - We may update this policy from time to time. The current version will always be posted on our website.
