1. Who We Are

Trustwell Travel Management ("Trustwell," "we," "us," or "our") is a luxury travel consultancy affiliated with Global Travel Collection (GTC), one of the world's premier travel consortia. We operate the website located at www.trustwelltravel.com (the "Site"). For GDPR purposes, Trustwell Travel Management acts as the Data Controller of your personal data.

Data Controller Contact:

Email: info@trustwelltravel.com

Mailing Address: 2875 NE 191st Street, Suite 202, Aventura, FL 33180

2. What Information We Collect

2.1 Information You Provide Directly

We collect personal information you voluntarily provide when you:

• Submit an inquiry or contact form

• Request a consultation or voyage proposal

• Subscribe to our newsletter or communications

• Book travel services through our platform or advisors

This information may include:

• Full name, email address, phone number, and mailing address

• Passport details, date of birth, and nationality (for booking purposes)

• Travel preferences, dietary restrictions, and accessibility needs

• Payment and billing information (processed through secure third-party processors)

• Emergency contact information

• Health-related information when necessary for travel accommodation (processed under explicit consent)

2.2 Information Collected Automatically

When you visit our Site, we and our service providers may automatically collect:

• IP address, browser type, and device identifiers

• Pages visited, time spent, and referring URLs

• Cookie identifiers and tracking pixels (see Section 7: Cookie Policy)

• Geolocation data (country/region level)

2.3 Information from Third Parties

We may receive information about you from:

• Global Travel Collection (GTC) shared systems and affiliated advisors

• Cruise line and hospitality partners (Silversea, Seabourn, Regent Seven Seas, and others)

• Social media platforms if you interact with our content

• Referral partners, including luxury residential communities

3. Legal Bases for Processing (GDPR)

For visitors from the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data under the following lawful bases:

• Contract Performance: Processing necessary to fulfill travel bookings and service agreements

• Legitimate Interests: Improving our services, fraud prevention, network security, and direct marketing to existing clients where proportionate

• Legal Obligation: Compliance with applicable laws, including financial, tax, and anti-money laundering requirements

• Consent: For non-essential cookies, marketing communications, and health/sensitive data — you may withdraw consent at any time without penalty

4. How We Use Your Information

We use your personal data to:

• Provide, personalize, and improve our luxury travel services

• Process bookings, payments, and travel-related communications

• Send you relevant voyage proposals, newsletters, and curated travel content (with consent or legitimate interest)

• Comply with legal and regulatory requirements

• Verify identity and prevent fraud

• Respond to inquiries and provide client support

• Facilitate itinerary management and emergency assistance during travel

• Fulfill our obligations as a GTC-affiliated travel management company

• Conduct analytics and improve Site functionality

5. How We Share Your Information

We do not sell your personal data. We may share it with:

5.1 Service Providers & Travel Partners

• Cruise lines, hotels, airlines, and ground operators necessary to fulfill your booking

• Global Travel Collection (GTC) shared booking and CRM systems

• Payment processors (e.g., Stripe, Braintree) — PCI DSS compliant

• Email marketing platforms and CRM providers

• Website hosting and analytics providers

5.2 Legal & Safety Disclosures

We may disclose your data when required by law, court order, regulatory request, or to protect the safety and rights of Trustwell, our clients, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of business assets, your data may be transferred. We will provide notice before your personal data becomes subject to a different privacy policy.

5.4 International Transfers (GDPR)

If we transfer your data outside the EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission or adequacy decisions where applicable.

6. Your Rights

6.1 U.S. Residents

Depending on your state of residence (California, Virginia, Colorado, Connecticut, and others), you may have the right to:

• Know what personal information we collect and how it is used

• Access, correct, or delete your personal data

• Opt out of the sale or sharing of your data (we do not sell data)

• Non-discrimination for exercising your privacy rights

6.2 EEA / UK / Swiss Residents (GDPR Rights)

You have the right to:

• Access: Request a copy of your personal data

• Rectification: Correct inaccurate or incomplete data

• Erasure (Right to be Forgotten): Request deletion, where no legal obligation to retain applies

• Restriction: Limit processing in certain circumstances

• Data Portability: Receive your data in a structured, machine-readable format

• Object: Object to processing based on legitimate interests or for direct marketing

• Withdraw Consent: At any time, without affecting prior lawful processing

• Lodge a Complaint: With your local supervisory authority (e.g., ICO in the UK)

To exercise any of these rights, contact us at: privacy@trustwelltravel.com. We will respond within 30 days (GDPR: within 1 month, extendable by 2 additional months for complex requests).

7. Cookie Policy

We use cookies and similar tracking technologies on our Site. By using our Site, you consent to our use of cookies in accordance with this policy.

Types of cookies we use:

• Essential Cookies: Required for Site functionality — no consent required

• Analytics Cookies: Help us understand how visitors use our Site (e.g., Google Analytics) — require consent in EEA

• Marketing/Preference Cookies: Used to personalize content and ads — require consent

• Third-Party Cookies: Set by embedded content from our travel partners

You can manage cookie preferences via our Cookie Consent Banner (on first visit) or your browser settings. Note that disabling certain cookies may affect Site functionality.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this Policy or as required by law. Typical retention periods:

• Active client records: Duration of relationship plus 7 years (for financial/tax compliance)

• Booking and transaction data: 7 years (financial regulations)

• Marketing data: Until opt-out or 3 years of inactivity

• Website analytics data: 26 months (standard GA retention)

• Health/sensitive data: Deleted promptly after travel is completed, unless legally required

9. Data Security

We implement industry-standard technical and organizational security measures, including:

• SSL/TLS encryption for all data in transit

• Access controls and role-based permissions for staff

• Secure, encrypted storage for sensitive personal data

• Regular security assessments and vendor vetting

• Incident response procedures for data breaches

In the event of a data breach that poses a risk to your rights, we will notify affected individuals and relevant supervisory authorities in accordance with applicable law (GDPR: within 72 hours of awareness).

10. Children's Privacy

Our Site and services are not directed to children under the age of 16 (or 13 in the U.S. under COPPA). We do not knowingly collect personal data from minors without verifiable parental consent. If you believe we have inadvertently collected data from a minor, contact us immediately at privacy@trustwelltravel.com and we will delete it promptly.

11. Third-Party Links

Our Site may contain links to third-party websites (cruise lines, travel partners, GTC resources). We are not responsible for the privacy practices of those sites and encourage you to review their individual privacy policies.

12. Changes to This Policy

We may update this Privacy Policy periodically. When we make material changes, we will post a prominent notice on our Site and, where required by law, seek renewed consent. The date at the top of this document reflects the most recent revision.

13. Contact Us

For privacy-related inquiries, requests, or complaints:

• Contact: info@trustwelltravel.com

• Website: www.trustwelltravel.com

• Mailing Address: 2875 NE 191st Street, Suite 202, Aventura, FL 33180