Privacy Policy

Deep Snitch Travel ("we," "our," "us," or "Company") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://deepsnltch.com and use our investment services.

By accessing or using our website and services, you agree to the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our website or services.

1. Company Information

Deep Snitch Travel is a registered travel investment company operating under German law:

• Company Name: Deep Snitch Travel
• Registration Number: 09865199
• Registered Address: Level 8, 275 Napoleon View, East Roryton, VIC 8869, Germany
• Email: [email protected]
• Phone: +50270508736

2. Information We Collect

2.1 Personal Information

We collect personal information that you voluntarily provide to us when you:

• Register for an investor account
• Subscribe to our presale opportunities
• Submit contact forms or inquiries
• Subscribe to our newsletter
• Participate in investment opportunities
• Communicate with our customer support team

The personal information we collect may include:

• Full name (first and last name)
• Email address
• Phone number
• Postal address
• Date of birth
• Government-issued identification documents
• Financial information (bank account details, investment amounts)
• Tax identification numbers
• Investment preferences and risk tolerance
• Employment and income information

2.2 Automatically Collected Information

When you visit our website, we automatically collect certain information about your device and browsing behavior:

• IP address
• Browser type and version
• Operating system
• Device information
• Pages visited and time spent on pages
• Referring website addresses
• Date and time of visits
• Click-stream data

2.3 Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect information about your interactions with our website. This includes:

• Essential Cookies: Necessary for website functionality and security
• Analytics Cookies: Help us understand how visitors use our website
• Marketing Cookies: Used to deliver relevant advertisements
• Preference Cookies: Remember your settings and preferences

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Service Provision

• Processing and managing your investment applications
• Creating and maintaining your investor account
• Providing access to presale stages and investment opportunities
• Processing transactions and payments
• Communicating about your investments and account status
• Providing customer support and responding to inquiries

3.2 Legal and Regulatory Compliance

• Verifying your identity (KYC/AML compliance)
• Preventing fraud and unauthorized transactions
• Complying with German and EU financial regulations
• Meeting tax reporting requirements
• Responding to legal requests and court orders
• Protecting our legal rights and interests

3.3 Marketing and Communications

• Sending investment opportunity notifications
• Distributing newsletters and market updates
• Providing information about new presale stages
• Conducting investor surveys and research
• Organizing investor events and webinars

3.4 Website Improvement

• Analyzing website usage and performance
• Improving user experience and functionality
• Developing new features and services
• Troubleshooting technical issues
• Ensuring website security

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to fulfill our investment services agreement with you
• Legal Obligation: Processing required to comply with German and EU financial regulations, including BaFin requirements
• Legitimate Interests: Processing necessary for our legitimate business interests, such as fraud prevention and marketing
• Consent: Processing based on your explicit consent for specific purposes, such as marketing communications

5. Information Sharing and Disclosure

We may share your information with the following parties:

5.1 Service Providers

We engage third-party companies to perform services on our behalf:

• Payment processors and financial institutions
• Identity verification services
• Cloud hosting providers
• Email and communication platforms
• Analytics and marketing services
• Legal and accounting professionals

5.2 Business Partners

• Hotel and travel service partners (for investment fulfillment)
• Financial institutions managing investment vehicles
• Co-investment partners (with your consent)

5.3 Regulatory Authorities

• BaFin (German Federal Financial Supervisory Authority)
• Tax authorities
• Law enforcement agencies (when legally required)
• Financial intelligence units

5.4 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change and provide options regarding your information.

5.5 With Your Consent

We may share your information with other parties when you have given explicit consent for such sharing.

6. Data Security

We implement comprehensive security measures to protect your personal information:

• 256-bit SSL/TLS encryption for data transmission
• AES-256 encryption for data storage
• Multi-factor authentication for account access
• Regular security audits by third-party cybersecurity firms
• Secure data centers with physical access controls
• Employee training on data protection and confidentiality
• Incident response procedures and breach notification protocols
• Regular software updates and security patches

Despite our security measures, no system is completely secure. We cannot guarantee absolute security of your information transmitted through our website.

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services and maintain your account
• Comply with legal and regulatory requirements
• Resolve disputes and enforce agreements
• Maintain business records and archives

Specific retention periods include:

• Account Information: Duration of account plus 10 years after closure (German commercial law requirement)
• Transaction Records: 10 years from transaction date (tax law requirement)
• KYC/AML Documents: 5 years after business relationship ends (German Money Laundering Act)
• Marketing Data: Until consent is withdrawn or 3 years of inactivity
• Website Analytics: 26 months

8. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

8.1 Right to Access

You can request confirmation of whether we process your personal data and obtain a copy of your data.

8.2 Right to Rectification

You can request correction of inaccurate or incomplete personal data.

8.3 Right to Erasure ("Right to be Forgotten")

You can request deletion of your personal data, subject to legal retention requirements.

8.4 Right to Restriction of Processing

You can request limitation of how we process your data under certain circumstances.

8.5 Right to Data Portability

You can request your data in a structured, machine-readable format for transfer to another provider.

8.6 Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes.

8.7 Right to Withdraw Consent

Where processing is based on consent, you can withdraw consent at any time.

8.8 Right to Lodge a Complaint

You can file a complaint with your local data protection authority if you believe we have violated your privacy rights.

To exercise these rights, contact us at: [email protected]

We will respond to your request within 30 days as required by GDPR.

9. International Data Transfers

Your information may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions recognizing equivalent data protection
• Binding Corporate Rules for intra-group transfers
• Privacy Shield certification (where applicable)

10. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child under 18, please contact us immediately, and we will delete such information.

11. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

12. Marketing Communications

You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in our emails
• Adjusting preferences in your account settings
• Contacting us at [email protected]

Note that you will continue to receive transactional and service-related communications even if you opt out of marketing.

13. Cookie Management

You can control cookies through:

• Our cookie consent banner when you first visit the website
• Browser settings to block or delete cookies
• Third-party opt-out tools for advertising cookies

Disabling certain cookies may limit website functionality.

14. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of sale of personal information
• Right to deletion of personal information
• Right to non-discrimination for exercising privacy rights

We do not sell personal information to third parties.

15. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or business operations. We will notify you of material changes by:

• Posting the updated policy on our website with a new effective date
• Sending email notification to registered users
• Displaying a prominent notice on our website

Your continued use of our services after changes become effective constitutes acceptance of the updated Privacy Policy.

16. Contact Information

17. Supervisory Authority

You have the right to lodge a complaint with the German data protection supervisory authority:

Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Graurheindorfer Str. 153
53117 Bonn, Germany
Website: www.bfdi.bund.de