Privacy policy

1. Who we are

Campvoya is a brand of UAB EERIV Europe, a private limited company registered in Lithuania (company code 304431887), with its registered office at J. Savickio g. 4-7, LT-01108 Vilnius, Lithuania.

UAB EERIV Europe is the data controller for the personal data described in this policy. In this policy, "Campvoya", "we", "us" and "our" mean UAB EERIV Europe acting through its Campvoya brand.

For any question about this policy or your personal data, email us at info@campvoya.com or write to us at the address above.

2. What this policy covers

This policy explains how we handle personal data when you visit campvoya.com and when you join our waitlist and newsletter.

Campvoya is not taking bookings yet. Before we do, we will publish an updated privacy policy that explains how we handle the information needed for bookings, including information about participants.

3. The information we collect

Information you give us

When you join the waitlist, you give us:

• your first name
• your email address
• who you are signing up as (a parent or guardian, a school or youth organization, a camp provider, travel partner or agent, or other)
• your consent to receive our newsletter
• if you choose to give it, your phone number and your consent for us to call you or message you on WhatsApp

If you email us, call us or message us, we also receive your contact details and anything you choose to tell us. When we speak with you, our team may write a short note about the conversation (for example, "interested in summer camps, call back in March") so we can follow up properly.

Information collected automatically

• Sign-up records: the date and time you signed up and confirmed your email address, the IP address used and the type of browser. We keep these as proof of your consent.
• Newsletter activity: once we start sending newsletters, whether our emails are delivered and opened and which links are clicked. This helps us send emails people find useful and remove addresses that no longer work.
• Technical data: when you visit our website, our server processes basic technical information, such as your IP address, browser type and the pages requested, to deliver the website and keep it secure.

We do not ask for, and ask you not to send us, sensitive information such as health details, or any information about children, through the waitlist form or by email at this stage.

4. How we use your information and why

The EU General Data Protection Regulation (GDPR) requires us to have a legal basis for each use of your personal data. Here is what we do and why:

We use your details only for Campvoya. We do not use them to market other products or services, and we do not make decisions about you based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

5. Children

Campvoya creates programs for young people aged 6 to 17, but our waitlist and newsletter are for adults aged 18 and over: parents, guardians, schools, youth organizations and partners.

We do not knowingly collect personal data from anyone under 18 through this website. If you believe a child has signed up, please email info@campvoya.com and we will delete their details promptly.

6. Who we share your information with

We never sell or rent your personal data. Our waitlist is stored in our own database. We share personal data only with service providers who help us run Campvoya. They act as our data processors: they may use your data only on our instructions and must keep it secure under a data processing agreement with us.

• Website and database hosting: Hostinger (Hostinger International Ltd., Cyprus), which hosts campvoya.com and the database where the waitlist is stored, on servers in the European Union.
• Email: Hostinger (Hostinger International Ltd., Cyprus) also provides our email service, which sends the email asking you to confirm your address and handles messages you send to info@campvoya.com.
• Newsletter service: when we start sending newsletters, we may use a specialist newsletter service to send them and manage unsubscribes. We will name it in this policy before we share any of your details with it.

WhatsApp: if we message you on WhatsApp, the service is provided by WhatsApp (WhatsApp Ireland Limited for users in Europe, part of Meta). WhatsApp processes your phone number and the messages under its own terms and privacy policy, which you accepted when you started using WhatsApp. Messages are end-to-end encrypted.

We may also disclose personal data where the law requires us to, for example to a court or public authority, or where it is necessary to establish, exercise or defend legal claims.

7. Transfers outside the European Economic Area

We aim to store your data within the European Economic Area (EEA). Some of our service providers, or companies they work with, may process data in other countries. When that happens, we make sure your data stays protected by relying on a European Commission adequacy decision (including the EU–US Data Privacy Framework where the recipient is certified under it) or on the European Commission's Standard Contractual Clauses, with additional safeguards where needed.

You can ask us for more information about these safeguards by emailing info@campvoya.com.

8. How long we keep your information

• Waitlist and newsletter details: until you unsubscribe or ask us to delete them. If you don't open any of our emails for 24 months, we will remove you from the list.
• Phone number and call notes: until you ask us to stop calling or messaging you, unsubscribe, or ask us to delete them. When you ask us to stop calling, we delete your phone number.
• Unconfirmed sign-ups: if you don't confirm your email address, we delete the sign-up within 30 days.
• Proof of consent and unsubscribe records: for 3 years after you unsubscribe, so we can show we acted lawfully. After that, we keep only your email address on a "do not contact" list so we don't email you again by mistake.
• Emails you send us: for up to 2 years after our last exchange, unless we need them longer for a legal reason.
• Backups: our hosting provider keeps automatic backups of our database for a limited time. Data we delete is removed from backups when they expire.
• Website technical logs: for no more than a few weeks, unless needed to investigate a security incident.

9. Your rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you and receive a copy.
• Correct data that is wrong or incomplete.
• Delete your data ("the right to be forgotten").
• Restrict how we use your data in certain situations.
• Receive your data in a portable format, or ask us to send it to another organization.
• Object to our use of your data based on legitimate interests. You can object to direct marketing at any time, and we will stop.
• Withdraw your consent at any time, for example by clicking "unsubscribe" in any of our emails, telling us during a call, or replying "STOP" on WhatsApp. Unsubscribing stops all emails, calls and messages. This does not affect anything we did with your consent before you withdrew it.

To use any of these rights, email info@campvoya.com. We will reply within one month. If your request is complex, we may extend this by up to two more months, and we will tell you why. We may ask you to confirm your identity before we act on a request. Using your rights is free.

10. Cookies

Our public website does not use cookies, analytics or advertising trackers, and our fonts are hosted on our own server, so visiting the site does not send your data to third parties. The only cookie we use is a strictly necessary sign-in cookie for our own staff in our private admin area. If we ever add cookies that are not strictly necessary, we will ask for your consent first and update this policy.

11. How we protect your information

We use appropriate technical and organizational measures to protect your personal data, including encrypted connections (HTTPS), password-protected access limited to the people who need it, a record of who accessed and exported data, and regular backups. If a personal data breach is likely to put your rights at risk, we will notify the supervisory authority and, where required, tell you directly.

12. Complaints

If you have a concern about how we handle your data, please contact us first at info@campvoya.com so we can try to put it right.

You also have the right to complain to a data protection authority, in particular in the EU country where you live or work, or where you believe the problem happened. Our lead supervisory authority is Lithuania's State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania, vdai.lrv.lt.

13. Changes to this policy

We will update this policy when the way we handle personal data changes, including before we open bookings. The date at the top shows when it was last updated. If we make a significant change, we will tell people on our waitlist by email before it takes effect.