Privacy Policy

1. Introduction

In this Privacy Policy, we, Botajon (also "we", "us"), describe what we do with your data when you use https://botajon.com/en, our other websites or apps (collectively "website"), obtain services from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. In addition, we may inform you about the processing of your data separately.


If you disclose data to us or share data with us about other individuals, such as family members, co-workers, etc., we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Policy.


This Privacy Policy is aligned with the EU General Data Protection Regulation (GDPR) and the Swiss Data Protection Act (DPA). However, the application of these laws depends on each individual case.


This Privacy Policy is not part of a contract with you. We can change this Privacy Policy at any time. The version published on this website is the current version.

2. Controller

The Controller of data processing as described in this Privacy Policy (i.e. the responsible person) is Botajon. You can notify us of any data protection related concerns using the following contact details:


info@botajon.com

3. Collection and Processing of Personal Data

We primarily process personal data that we obtain from our clients and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users when operating our website.


Member Accounts & Bookings: When you create an account to access our exclusive member pricing and discounts, we collect your name and email address. When you make a hotel booking, we do not collect your payment information but only guest details necessary to secure the reservation.


AI Chatbot Data: If you use our AI Travel Assistant, we collect the text of your interactions to provide relevant destination advice and to improve the accuracy of our AI models.


Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g., commercial registers, internet, social media) or we may receive such information from authorities or other third parties. Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities, information about you in correspondence and discussions with third parties, information about you given to us by individuals associated with you (e.g., family) in order to conclude or process contracts with you, information about you found in the internet (insofar as indicated in the specific case, e.g. in connection with job applications, marketing/sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP address, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, referring website, localization data).

4. Purpose of Data Processing and Legal Grounds

We primarily use collected data in order to conclude and process contracts with our clients and business partners, in particular in connection with our travel services to our clients and the procurement of products and services from our suppliers and subcontractors, as well as in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as a client or an employee of a business partner.


In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties') legitimate interest, such as:


  • providing and developing our services, website and other platforms, on which we are active;
  • communication with third parties and processing of their requests (e.g., job applications, media inquiries);
  • review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
  • advertisement and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);
  • market and opinion research, media surveillance;
  • asserting legal claims and defense in legal disputes and official proceedings;
  • prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
  • ensuring our operation, including our IT and our website.

If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters or carrying out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

5. Cookies and Tracking

We typically use "cookies" and similar techniques on our website, which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website. If you revisit our website, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the website ("session cookies"), we may use cookies in order to save user configurations and other information for a certain time period (e.g., two years) ("permanent cookies"). Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies for the purpose of saving user configuration (e.g., automated log in), in order to understand how you use our services and content, and to enable to show you customized offers and advertisement.


We may use Google Analytics or similar services on our website. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google Ireland Ltd. (located in Ireland), Google Ireland relies on Google LLC (located in the United States) as its sub-processor (both "Google"), www.google.com) and which allow us to measure and evaluate the use of our website (on an anonymized basis).


In addition, we use plug-ins from social networks such as Instagram and X on our websites. This is visible for you (typically based on the respective symbols). We have configured these elements to be disabled by default. If you activate them (by clicking on them), the operators of the respective social networks may record that you are on our website and where on our website you are exactly and may use this information for their own purposes.

6. Data Transfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing set out in Section 4, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:


  • Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, banks, insurance companies).
  • Hotel Providers & Booking APIs: To fulfill your accommodation Booking, we must securely transmit your name, contact details, and booking parameters to the specific hotel property, or to our global distribution API partners, who facilitate the reservation. These partners may be located anywhere in the world depending on your travel destination.
  • Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests.

Certain Recipients may be within Switzerland but they may be located in any country worldwide, in particular depending on travel destinations of clients. Also, you must anticipate your data to be transmitted to any country in Europe and the USA where our service providers are located.


If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception.

7. Retention Periods for your Personal Data

We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible.


8. Data Security

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

9. Obligation to Provide Personal Data To Us

In the context of our business relationship you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to enter into or carry out a contract with you. In addition, the website cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).

10. Profiling

We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about products possibly relevant for you more accurately. For this purpose, we may use evaluation tools that enable us to communicate with you and advertise you as required, including market and opinion research.

11. Your Rights

In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectification and erasure of your personal data, the right to restriction of processing or to object to our data processing, in particular for direct marketing purposes, for profiling carried out for direct marketing purposes and for other legitimate interests in processing in addition to right to receive certain personal data for transfer to another controller (data portability).


In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 2 above.


In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).