The data controller responsible for your personal data is:

Zilika SRL (Zilika Travel Tech) Operating the brand: Gadobo VAT Number: BE1000.573.707 Website: www.gadobo.com

For any data protection inquiries, please contact us at: privacy@gadobo.com

We collect and process the following categories of personal data:

We process your personal data on the following legal bases under Article 6 GDPR:

(a) Performance of a contract (Art. 6(1)(b)): processing necessary to provide our marketplace services, facilitate transactions between Buyers and Sellers, and manage your account.

(b) Legitimate interests (Art. 6(1)(f)): fraud prevention, platform security, improving our services, and internal analytics. We have conducted balancing tests to ensure our legitimate interests do not override your fundamental rights.

(c) Legal obligation (Art. 6(1)(c)): compliance with Belgian and EU tax, accounting, and anti-money laundering requirements.

(d) Consent (Art. 6(1)(a)): marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

We use your personal data for the following purposes:

(a) To create and manage your Gadobo account.

(b) To facilitate the listing, bidding, sale, and transfer of non-refundable travel bookings between Buyers and Sellers.

(c) To process payments through our third-party payment processors and hold funds in escrow as described in our Terms and Conditions.

(d) To communicate with you regarding your transactions, account, and any disputes.

(e) To detect and prevent fraud, unauthorised transactions, and other illegal activities.

(f) To comply with legal and regulatory obligations.

(g) To improve our website, services, and user experience through aggregated analytics.

(h) To send you marketing communications about Gadobo services, where you have opted in. You can unsubscribe at any time.

We do not sell your personal data. We share your data only with the following categories of recipients, and only to the extent necessary:

(a) Other users: when you list or purchase an Offer, relevant transaction details (name, booking reference) are shared between Buyer and Seller to facilitate the transfer.

(b) Payment processors: to process transactions securely.

(c) Airlines and travel providers: where necessary to verify or complete a booking transfer.

(d) Insurance partners: where bookings are submitted through our insurer portal, relevant booking data is shared with the submitting insurance partner for recovery purposes.

(e) IT and hosting providers: cloud infrastructure, email services, and analytics tools that process data on our behalf under data processing agreements.

(f) Legal and regulatory authorities: where required by law, court order, or regulatory request.

(g) Professional advisors: lawyers, accountants, and auditors where necessary.

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place, including:

(a) European Commission adequacy decisions;

(b) Standard Contractual Clauses (SCCs) approved by the European Commission;

(c) Other lawful transfer mechanisms under Chapter V of the GDPR.

You may request a copy of the safeguards in place by contacting us at privacy@gadobo.com.

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

(a) Account data: retained for the duration of your account and for 3 years after account closure, unless longer retention is required by law.

(b) Transaction data: retained for 7 years after the transaction to comply with Belgian tax and accounting obligations.

(c) Communication data: retained for 2 years after the last interaction.

(d) Marketing data: retained until you withdraw consent or unsubscribe.

(e) Technical and usage data: retained in aggregated/anonymised form indefinitely for analytics; identifiable data retained for up to 12 months.

Under the GDPR, you have the following rights in relation to your personal data:

(a) Right of access (Art. 15): you may request a copy of the personal data we hold about you.

(b) Right to rectification (Art. 16): you may request correction of inaccurate or incomplete data.

(c) Right to erasure (Art. 17): you may request deletion of your data, subject to legal retention obligations.

(d) Right to restriction (Art. 18): you may request that we restrict the processing of your data in certain circumstances.

(e) Right to data portability (Art. 20): you may request your data in a structured, commonly used, machine-readable format.

(f) Right to object (Art. 21): you may object to processing based on legitimate interests or for direct marketing purposes.

(g) Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.

(h) Right to lodge a complaint: you have the right to lodge a complaint with the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit) or the supervisory authority in your Member State of residence.

To exercise any of these rights, contact us at privacy@gadobo.com. We will respond within 30 days.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

(a) Encryption of data in transit (TLS/SSL) and at rest.

(b) Access controls limiting data access to authorised personnel on a need-to-know basis.

(c) Regular security assessments and vulnerability testing.

(d) Use of PCI DSS-compliant third-party payment processors.

No method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 18, we will take steps to delete it promptly.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by posting the updated policy on our website with a revised "Last updated" date. We encourage you to review this policy periodically.

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

Zilika SRL (Zilika Travel Tech)
Email: privacy@gadobo.com
Website: www.gadobo.com

Cookies are small text files placed on your device when you visit a website. They help the website recognise your device and remember information about your visit, such as your preferences and actions.

We use cookies for the following purposes:

Some cookies on our website are placed by third-party services that appear on our pages. We do not control these third-party cookies. The third parties that may set cookies on our site include:

(a) Google (Analytics, Ads): privacy policy at https://policies.google.com/privacy

(b) Payment processors: as required for secure transaction processing.

(c) Social media platforms: if you use social login or sharing features.

We encourage you to review the privacy policies of these third parties.

When you first visit our website, you will be presented with a cookie consent banner that allows you to:

(a) Accept all cookies;

(b) Reject all non-essential cookies;

(c) Customise your cookie preferences by category.

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

You can also control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of our website.

(a) Session cookies: deleted when you close your browser.

(b) Persistent cookies: retained for varying periods depending on their purpose, typically between 30 days and 24 months.

(c) Third-party cookies: retention periods are determined by the third party. Refer to their respective privacy policies.

Under the ePrivacy Directive (2002/58/EC) as transposed into Belgian law, and in conjunction with the GDPR:

(a) Strictly necessary cookies: no consent required (exempt under Art. 5(3) ePrivacy Directive).

(b) All other cookies: require your prior consent, which we obtain through our cookie consent banner.

We may update this Cookie Policy from time to time. Changes will be posted on this page with a revised "Last updated" date.

If you have questions about our use of cookies, please contact:

Zilika SRL (Zilika Travel Tech)
Email: privacy@gadobo.com
Website: www.gadobo.com