Terms and conditions

Content

Regulations

These regulations shall be applied to all offered services that are provided to the customers directly or through any third party, irrespective of the used devices. Please note that if by using our website (search for information, review the offers, etc.) or any other of our programs through any system (hereinafter – Website) and/or performing service orders you acknowledge your understanding and agreement to all provisions of the following regulations. We note that these regulations are updated regularly and we are entitled to amend one or more provisions of these regulations at any time.

This Website, its contents and facilities, online ordering service provided through the Website and other websites are owned, exercised and provided by AB „Novaturas“, the company registered and acting in the Republic of Lithuania, address A. Mickeviciaus str. 27, LT-44245 Kaunas, Republic of Lithuania, company code 135567698, company data is compiled and stored at State Enterprise Centre of Registers (www.kada.lt), by using the brand of Travel On Spot (hereinafter – Travel On Spot). All of our provided services are solely intended for a personal and non-commercial use. The following below mentioned regulations shall be applied to all offered and provided services.

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Provided services

Travel On Spot and our partners through this Website enable the different business entities to provide the accommodation services (hotels, motels, guesthouses, etc., hereinafter collectively referred to as accommodation establishments) and/or other service providers to promote and allow the potential customers to book their services. Travel On Spot and our partners also enable the visitors of Website to choose and book the selected services.

Please note that booking of some of your selected services through Travel On Spot shall mean the direct and legally binding transaction with the particular selected service provider (e.g., accommodation establishment). Travel On Spot acts only as an agent between the user who places the booking and accommodation establishment or other service provider: Travel On Spot forwards the booking information to specific accommodation establishment/other service provider (or other agents) and the booking confirmation email to the user/service recipient on behalf of specific service provider. Travel On Spot shall not provide any other service and be held liable for the services provided by third parties (as well as the other agents that may be invoked to submit or perform the booking).

Travel On Spot shall not collect and check the information about Travel On Spot and its services published by third parties. Travel On Spot shall only provide the information received from a particular service provider at its information channels by mediating between the user and accommodation establishment and/or other service provider. Only certain service providers shall be solely and entirely responsible for the information provided by Travel On Spot and published on the Website (service descriptions, photographs, prices, information on availability of the rooms and other information provided on the Website), as well as the accuracy, completeness and timely update of such information. Travel On Spot shall not check and guarantee that all information of third parties is accurate, complete and correct. This means inter alia that Travel On Spot shall not be held responsible for any errors (of spelling and/or other), disorders of service or information provisions, caused by the failure of Website, its update, repair or support works etc., as well as the submission of inaccurate or misleading information or failure to submit the information. Any specific service provider shall be solely and exclusively responsible for accuracy, completeness and correctness of information about its services provided by the Website and its compliance with all requirements of applicable legislation. All claims for the failure to provide information or its improper provision, actions, request to compensate the damage possibly caused to the users, etc. shall be only brought to specific service providers due to which actions or failure to act the negative or contrary to legislation consequences could result.

Travel On Spot shall not also be considered as an appropriate subject to bring the demands of refund for any delays, cancellations or route changes of booking confirmation or service provisions. Travel On Spot shall not also be responsible for the disturbance or termination of service provisions caused by strikes, weather conditions, governmental decisions and other force majeure circumstances, as well as for the cases of confirmation / selling more tickets / places than it was available and any other additional costs incurred by users / service recipients and other similar circumstances. All requests, claims, actions, complaints or appeals to the authorities authorized to resolve the disputes (on the quality of services, discrepancies between the booking and provided services, not provided / not fully provided or improperly provided services, etc.) shall be submitted to the direct service provider and based on its illegal actions / failure to act.

Website may provide the certain assessment of the services, however, this shall be considered as general recommendations based on subjective assessments of service users. Travel On Spot shall not provide the specific recommendations or guarantees of the services and services providers. Travel On Spot shall not also guarantee the accuracy of submitted assessments.

Travel On Spot services are solely intended for personal and non-commercial use. Bear in mind that it is strictly prohibited to resell, make discounts, use, copy, monitor (as well as by using "spider", "scrape", other similar systems and other methods), display, download or restore any information, software, proposals of products and services provided by the Website by commercial or competitive purposes. Performance of any aforementioned actions and/or the losses caused by such actions to Travel On Spot, damage to reputation or performance of commercial activity, as well as any other possible negative consequences shall be assessed and appealed to authorized institutions under the procedure set forth in legislation of the Republic of Lithuania, as well as demanded for the compensation for suffered damage and removal of consequences caused by illegal actions.

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Links to websites of third parties

Website may contain links to websites of third parties (accommodation and other service providers, etc.). These links are provided for users’ information and introduction purposes only. Travel On Spot does not control these websites and it shall not be held responsible for their contents or the fact that the users visit these websites and search for the information of interest. Travel On Spot shall not verify and check the accuracy, completeness or quality of information contained in such websites.

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Minor persons

Travel On Spot offered services are intended for adults (18 years old). The use of the services by persons under 18 years shall be only permitted under the legal care of parents, guardians or caregivers and their consent. Travel On Spot shall be entitled to delete the information received from persons under 18 years and cancel the bookings placed by such persons, upon receiving the information that these persons used the services without the authority of parents, guardians or caregivers.

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Large bookings

It is not allowed to book more than 10 rooms or other type of accommodation in the same accommodation establishment on the same date and/or under the same conditions. If Travel On Spot finds out that user / customer / service recipient have booked more than 10 rooms with different bookings, it shall be entitled to cancel the placed bookings and apply the cancellation fee for such user (if this is applied in specific situation). In this case, if the user has paid the non-refundable deposit, it shall be non-refunded for the user whose booking has been cancelled. If the user wishes to book 11 rooms or other type of accommodation, he/she shall contact Travel On Spot consultants and submit this request directly. This may be done over the phone or email info@travelonspot.com. After the review of request, the consultants will contact the user on the possibility to perform the desired booking for more persons. In some cases the user may also be required to enter into a written agreement and (or) pay the non-refundable deposit for bookings placed for more persons.

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Travel safety       

The traveller shall choose the direction of travel and assess all the risks associated to this option by himself. Travel On Spot encourages the customers to carefully analyse all information associated to selected travel direction, as well as the prohibitions, warnings and advices published by state authorities in their information channels. In case of doubt regarding the safety situation in particular country or region, the users may obtain the additional information by contacting the relevant authorities on publicly available contact information. The proposal to purchase the certain services shall not in any case mean that Travel On Spot acknowledges or guarantees the safety of travel to certain countries selected by the traveller. Travel On Spot shall not also be responsible for the damage that may arise by travelling to certain countries.

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Travel documents

Please note that upon arrival or registration at a hotel (or any other accommodation establishment) all the guests (including children) are often asked to provide the documents of identity (passport or personal identity card). Each traveller shall individually care of all travel documents (passports, personal identity cards, visas and so on). Travel On Spot shall not check and shall not be responsible for suitability of personal and/or travel documents, their validity, as well as the decisions taken by accommodation establishments or other services providers in respect of the customers if they fail to provide the personal documents or provide inappropriate personal documents. Travel On Spot shall also in any case be responsible for the decisions taken by migration and border officials in respect of the travellers.

Please note that when travelling to a certain countries the traveller be required a visa, special permissions and so on, as well as the minimum requirements of passport or personal identity card validity may be applied. Please inquire about the specific applicable requirements in a particular country before your travel.

Please note that it is recommended to acquire the insurance of medical expenses, accidents and/or other cases when travelling to foreign countries. The customer shall be fully responsible for the risk of insurance, e.g. he shall decide whether to acquire the insurance and what type of insurance to acquire by himself.

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Price

The price of the services booked by the customer shall be the same as indicated in Website, excluding the cases of obvious errors. The price of services may be changed at any time; however, the performed changes shall not affect the booking placed before the change. Despite all reasonable efforts of Travel On Spot to avoid this, some prices of travel booking services in the Website may be wrong. For this reason, Travel On Spot shall reserve the right to edit the price errors or inaccuracies found in the Website and/or pending bookings placed by the wrong prices. In this case, if possible, the customers shall be able to save the placed booking at correct price or cancel the booking without any cancellation fees. Travel On Spot shall not be responsible to provide the booked services for the wrong (lower) price even in the cases when booking confirmation has been sent to the customer / received by the customer.

All prices of accommodation establishment services on Travel On Spot Website are indicated for accommodation unit (room, apartments etc.) for the entire stay, including VAT and any other taxes, unless the Website or confirmation email sent to the customer specifies otherwise. Please note that the price of offered services may be changed in case of changes of taxes affecting the pricing of services. Please also note that the accommodation service price does not usually include the supplementary services provided in the specific accommodation establishment (for example, mini bar, laundering, SPA, sports, sunbeds and sunshades, towels by the pool/sea, safe, air conditioning and similar services). These services may be charged additionally in accordance with the prices determined by the specific accommodation establishment.

In some cases, the Website may offer the proposals for specific stays to purchase the certain services at lower prices, however these prices provided by accommodation establishments may have the specific conditions, requirements and limitations, such as cancellation, refund, payment, etc. The users are advised to carefully review all information about intended to book accommodation unit, its price and other conditions of booking or refund before the booking.

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Best price guarantee

Travel On Spot endeavours to offer its customers the lowest possible price for accommodation and other services. In case if the customers who have booked the accommodation unit through Website would find the similar services at the same booking conditions but at lower than our offered price in other website, Travel On Spot will cover the difference between our offered price and lower price of similar accommodation services found by the customer under the conditions set forth below.

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Conditions of best price guarantee

We assure that we offer the best possible price of accommodation unit at the time of its booking.

If the customers find the same-booked accommodation service at a lower price in another website, they may immediately contact the call centre of Travel On Spot. In this case, the customers will be offered to purchase the selected services at the same price if they fulfil the below mentioned conditions:

1) The customer immediately after the booking placement (no later than 48 hours after the booking) have contacted the representatives of Travel On Spot and provided the detailed information about the found offer: the customer provided a link to the website of the offer and indicated the price for offered services.

2) At the moment of information check, it is possible to find the indicated offer in the internet and book the indicated accommodation service. The lower price may not be offered by website / service provider whom the user contacted in order to find out the price or by specific email sent to the user, e.g. the price of other offer shall be made public and it shall be possible to check it.

3) The same booking conditions as for the service booking through Travel On Spot are applied to the found offer, e.g. the user have chosen:

  • The same accommodation establishment;
  • The same type of room, apartment or other accommodation type;
  • The same dates of check-in and check-out;
  • The same accommodation conditions (board type, booking cancellation provisions and other conditions);
  • The booking conditions in the Website allow cancelling or amending the placed booking without any charges.

The best price guarantee shall be applied to the price of booked travel indicated in booking confirmation email, including the charges the user has paid by making the booking. The guarantee shall not be applied to the charges that the users pay to any third parties, e.g., taxes directly paid to the hotel or any other service provider.

If the aforementioned conditions are not met, the user shall retain the existing booking and may cancel it under the general cancellation procedure. 

The best price shall not be guaranteed if: 

  • The booking is placed in the website that does not provide the type of accommodation establishment or unit before the completion of the booking;
  • The booking is placed by using special membership, loyalty or similar programs, or any other discounts or special promotions offered by the other website;
  • The accommodation service is booked in the other website as a part of travel package;
  • The user have contacted Travel On Spot after his check-in at the accommodation establishment.

After the confirmation of refund request, the price difference shall be refunded to the credit card or bank account of user that has been used for accommodation booking service in Website of Travel On Spot. Please note the funds shall be transferred to appropriate account within 30 calendar days or within the other payment period.

Travel On Spot shall reserve the right to amend the conditions of best price guarantee, terminate its validity or limit its conferment to any person without prior notice and without assuming any additional obligations in relation to customers in its sole discretion, at any time and for any reason. The application of best price guarantee to the specific customer shall be determined in accordance with the guarantee application conditions applicable at the time of request submission.

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Service fee

Travel On Spot services are free. During the service provision we do not apply any additional (booking, brokerage) charges possibly increasing the price of accommodation unit booking.

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Payment by credit card or bank transfer

In accordance with the payment conditions determined by specific accommodation service provider (usually accommodation service providers offer to purchase the services for which the partial or full payment is non-refundable) the payment during the booking is placed by secure online payment (offered and supported by the user‘s bank) to Travel On Spot. The payment is securely handled through the third party intermediaries and made directly from credit / debit card or bank account of the user to Novaturas account.

Please carefully read the information about the accommodation unit and booking, payment and non-refundable payment conditions before the booking.

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Currency exchange

The currency exchange instrument at the Travel On Spot Website is provided for informational purposes only. It is not fully accurate and information is not updated in real time. The currency rates of the instrument may be different from the current rates.

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Cancellation and no-show

By booking the accommodation unit in accommodation establishment the users agree with the applicable cancellation and no-show rules of the booked accommodation establishment services and all additional conditions valid at the moment of booking or stay including the services and/or products offered by accommodation establishment (the terms and conditions applied by accommodation establishment may be obtained from a specific accommodation establishment; it is also possible to read them prior to booking). The general conditions of cancellation and no-show are provided at the Website, information and promotional websites of accommodation establishments and booking confirmation email. Please note that in some cases when accommodation services are booked at the special prices and offers, it is not allowed to cancel or amend the bookings. The users are recommended to carefully read all information about the accommodation unit and cancellation or no-show conditions before the booking. We also note that in accordance with the conditions of accommodation establishment and booking the orders that require to make the initial deposit or (partial or full) payment may be cancelled (without the prior notice), if the required (remaining) amount is not paid by the due date. Late payment, incorrect information of the bank, debit / credit cards, invalid debit / credit cards or insufficient amount of funds are the exclusive responsibility of the user. Therefore, in such cases, the users shall not be entitled to a refund of non-refundable payment, excluding the specific cases when the accommodation establishment agree to allow the user to operate beyond its established payment conditions.

In order to review, amend or cancel the booking, users shall follow the instructions specified in booking email. Please note that the users may be required to pay for the booking cancellation in accordance with cancellation, (advanced) payment or no-show conditions of accommodation establishments and the users shall not be entitled to remuneration of (advanced) payment. We recommend the users to carefully read cancellation, (advanced) payment or no-show conditions of accommodation establishments before the booking and timely make all payments for specific booking.

No-show of the customer to the booked place of accommodation shall be considered as cancellation of the booking.

After the reservation the amendments (duration of the stay, additionally ordered services, amendments of customer names, surnames etc.) shall not be allowed, excluding the cases if accomodation description or booking confirmation indicates otherwise. Any amendments shall be considered as the cancellation of the booking. Amendments associated to the extension of stay are only allowed if this is possible; in this case, the price of booked services shall be recalculated.

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Accommodation features and procedure  

Category

Neither globally, nor in the European Union there is a single classification system or standard for accommodation establishment. Therefore, the standards of the similar hotel categories may differ depending on the country. The hotel category depends on room size, its installation, service level, amount of provided services etc. The requirements for the category and their interpretation may differ in every country. For instance, 5* category hotel in one country may not necessarily be the same quality as the hotel of same category in other country.

Official category of hotel or apartments is indicated in the description of every hotel or apartments. If the official category is not indicated, this means the hotel or apartment applied to the competent authorities to get an official category; therefore, it does not currently have an official category in a foreign country. There may also be the case that categories of hotels or apartments in specific country are not mandatory. Please note that in many countries (Spain and so on) category of hotel of apartments may be indicated by letters or keys. It is sought to use the unified system of hotel classification, however, part of the hotels or apartments may still use letters or keys for classification.

For the convenience of customers, Travel On Spot may also provide the assessments of accommodation establishments based on subjective evaluations and feedback. Such assessment is biased and it only helps to aim the customer orientate and select the desired hotel. Such assessment shall not be identified with the official hotel category in the country.

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Hotel night

The beginning of hotel night on the arrival day is 2 PM – 6 PM; the end of hotel night on the leaving day is 10 AM – 12 PM. On the last travel day the hotel room shall be left until 10 AM - 12 PM. Hotel management team will inform you about the exact conditions of checkout. After leaving the room, you can leave the baggage at the hotel luggage storage or dedicated room. If possible, the hotel administration may accommodate the guests earlier or extend the leaving time. For this service, the customer usually has to pay an additional fee determined by hotel administration.

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Rooms

In a hotel there could be double, single rooms, apartments (hotel room with separate living and sleeping areas, it may also be equipped with a kitchen; an apartment may sometimes consist of few transient rooms, such as the bedroom and living room), studios (one room with a small hall, it may also be equipped with the kitchen) and other types of accommodation.

Please note that one double or two twin beds may be in a standard double room, depending on the hotel interior. Usually there are no triple rooms in the hotels. If the place for third or fourth person is booked, the double room may be usually supplemented by folding bed, sofa or folding chair. Even if the hotel room type is shown as triple, the third person may sleep in additional bed, sofa or folding chair. Some hotels may lease the baby cot (usually the customer has to pay for it in a hotel). Please note that in some hotel rooms accommodating 3 or 4 persons (2 adults and 1 or 2 children), the first and/or second child may not be given a separate bed or the bed may be placed at an extra charge.

The room area in a hotel description usually includes the bedroom, bathroom and balcony or terrace.

Some hotels offer lower type of rooms called Eco, Economy and so on. The room of this type is the lowest type of rooms in a hotel with a fewer amenities than a standard type of room. An exact room description is provided in the description of specific hotel. It is recommended to book Eco or Economy rooms for unpretentious guests. The number of such rooms may be limited.

The hotel administration at its discretion accommodates the guests on the day of arrival in the booked type of rooms. Seaside, poolside, garden side etc. rooms are provided by the hotels by the additional surcharge paid by the customer. Otherwise, such request may only be satisfied if possible. The concept „Sea side“ shall not necessarily mean the geographical position of the room in relation to the sea (that does not mean „sea view“). Usually there is no direct view to the sea in such rooms (room windows face the sea at an angle); buildings or plants may obstruct sea view.

Some hotels, apartments or studios may require to pay the deposit of the amount (by credit card or cash – depending on hotel rules) fixed by hotel, apartments or studios, which shall be refunded on the leaving day if there is no damage to inventory of hotel, apartments or studios.

The requests to stay in the specific floor of the hotel, adjoining rooms etc. shall be considered as the additional desires of the customer, which do not bind Travel On Spot and hotel. They may be satisfied only if possible. All your requests in English shall be indicated during the booking.

Please note that local municipalities of the resorts may at any time introduce the so-called pillow, tourist, ecological taxes or other charges that may be required to pay at the spot, e.g. during the check-in at a hotel or any other time. Travel On Spot shall not be responsible for the decisions taken by local municipalities or state authorities.

Please also note about the cases when accommodation establishments (hotels) change their name or trademark. The change of name or trademark shall not be considered as amendment of your booking.

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Housekeeping 

During the housekeeping the floors are cleaned, the carpeting is vacuumed, bathroom and toilet are cleaned up, rubbish is taken away and the beds are made. The rooms of higher category hotels are cleaned every day and the rooms of lower category hotels – 1 or 2 times per week.

Bed linen and towels are changed 1–2 times per week. If the customer uses kitchen, he shall take care of its cleanliness.

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Catering 

The exact board type is indicated in hotel description. The meals are served at the hotel restaurant during limited hours. If the customers leaving the hotel early in the morning or returning to hotel late in the evening wish to receive meals at different time, in some cases (at the hotel administration procedure) there is a possibility (sometimes for an extra charge) to have the early breakfast or late dinner food packages.

The usual type of board is „buffet“ (self-service or served by hotel staff). Sometimes the guest has to choose the main course of a few offered.

The hotel administration determines the catering services provision procedure, time and place of catering, variety of meals and beverages, depending on the specifics of the country, hotel category etc. The food and beverages at the hotel restaurants, cafes and bars listed in hotel description shall be served at the procedure determined by hotel administration and paid in accordance to the ordered type of catering. At the decision of hotel administration some beverages and meals may be offered for additional charge, even if the catering at hotel is „all inclusive“ or „all inclusive +”. Please also note that the amount of drinks, their place and time of supply may be limited even if the catering type „all inclusive“ or „all inclusive +” is booked. Hotel staff provide information on such beverages, meals and their prices.

Usually it is not allowed to keep and prepare the food in hotel rooms without a kitchen. In a hotels where customer find coffee or tea in a room on the arrival date or it is allowed to prepare the drinks (indicated in hotel description) the resources of these beverages are usually not supplemented.

Please note the clothing during the dinner shall meet the hotel category.

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Services

Hotel administration shall determine the frequency of entertainment events and their procedure. Usually there are less entertainment events or other provided services at the hotel at the beginning or at the end of tourist season.

It is not always possible to list all services provided in a hotel or extra paid services in a hotel description. Please ask the hotel administration to provide the information on provided paid and free services. Often the amount of paid and free services may differ during the season.

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Noise and maintenance

Many offered hotels are in the close proximities of restaurants, cafes and discos. Entertainment events in many hotels often last until late during the tourist season. The traffic sometimes enhances the noise. In hotels close to the airport, the guests may hear the noise of taking off and landing planes. Hotel administration shall not be responsible for the noise outside the hotel. If you wish to stay quiet, we advise to carefully read the descriptions of hotels or inquire more and select the hotel in quiet place, further away from the noisy entertainment. In some periods maintenance and repair works can take place at the accommodation units, which can also cause noise. Information about such maintenance and repair works can be provided to the client if he addresses the concrete chosen accommodation unit, Travel on Spot publishes such information only in case services providers inform Travel on Spot about such works. Travel on Spot does not take responsibility for decisions to carry out maintenance and repair works in the accommodation units taken by the administration of services providers, duration of such works and possible inconveniences caused to the clients due to such works.

 

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Claims

If you think your booked services were not provided or provided improperly, the claim shall be made in writing to hotel administration during your stay, because the disagreements are likely to be resolved and eliminated on the spot. If you make a claim after your stay, there will be no time to deal with the issue. If the guest does not make a claim in writing during his stay, he will lose his right to claim for remuneration. If the disagreements are not solved during the stay, you can make a direct claim to accommodation establishment in writing within 15 business days after the end of your stay. Please provide the copies of tourism services provision agreement with the claim. You may also send the claims through Travel On Spot: info@travelonspot.com – your claims shall be immediately sent to direct service provider.

Travel On Spot shall not be responsible for force majeure circumstances that could not be avoided during the stay. We do not accept the claims for services not included to description of specific services.

Your selected hotel may accommodate the guests in the other hotel of the same or higher category, if there is no possibility to accommodate the guests in formerly booked hotel. In this case, the customer cannot claim for remuneration.

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Limitation of liability 

In accordance with these regulations and provisions of legislation, Travel On Spot may be held responsible only for the direct damage or loss possibly incurred to the users for the default / improper performance associated with the services provided by Travel On Spot. The compensated amount of damages shall be limited to amount of specific user booking indicated in booking confirmation email (in case of one or more related events).

Travel On Spot, Travel On Spot representatives, branches, companies cooperating with Travel On Spot, distributors, websites cooperating with Travel On Spot, licence owners, agents or other entities associated to the development and promotion of Website shall not in any case be held responsible for:

(a) any indirect losses, operation failures, loss of profit or income, loss of contracts, damage to reputation or image,

(b) any inaccuracies of accommodation establishment / services description information provided in the Website (including the prices, photos, availability and assessments),

(c) services and products provided by accommodation establishments / other service providers,

(d) any direct and/or indirect losses the users could suffer due to use of Website, inability to use the Website or delays (of information, price changes, booking confirmation etc.), or

(e) any personal injury, death, damage to property and costs of legal proceedings, failure to comply with the rules, intentional and negligent offenses, information insufficiency, omission, incorrect information, violations or actions of civil law for which the accommodation establishment (its staff, managers, agents, representatives or companies cooperating with establishment) is responsible, including any (full or partial) cancellations, lack of accommodation units, strikes, force majeure circumstance or any other events to which Travel On Spot did not have direct and/or indirect impact.

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Intellectual property rights

Software required to provide the services of Travel On Spot, available or used by the Website and intellectual property rights (including the copyrights) to the contents and information of the Website belong to Travel On Spot and its suppliers, unless otherwise specified.

Travel On Spot by exclusive ownership owns all rights to the Website which provide and/or make available the services (including customers feedback and their translated contents), names and interests (all intellectual property rights) (of design and facilities). Users or any other third parties shall not be entitled to copy, link or use (hyper- or other) links, publish, promote, sell, integrate, use, combine or otherwise use the contents of the Website (including all translations and customer feedback) or Travel On Spot trademark without the prior written consent of its owners. Any violation of the aforementioned rights, abuse, or any other indicated or similar action (including the copyrights and rights to databases) shall constitute the substantial violation of intellectual property rights.

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Privacy policy

This Privacy Policy (hereinafter referred to as the Policy) provides important information about how our Company collects and processes personal data of its clients and other persons, how it uses such data and what measures it undertakes to protect it. In order to ensure your awareness, we recommend you read to carefully this Policy and to get acquainted with the information provided in it.

I. DEFINITIONS

The following definitions are used in this Policy:

The Company, or we means AB "Novaturas" – Lietuva (company registration code: 135567698; company address: A. Mickevičiaus g. 27, LT-44245, Kaunas, Lithuania; Company website: www.novaturas.lt, www.travelonspot.com, flights.novatours.eu). The Company described under this Policy is a controller of personal data.

GDPR means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance).

Dada subject means a natural person from which the Company receives and processes the personal data.

Employee means a person with whom the Company concluded an employment contract or any contract of similar character and, upon the decision of the head of the Company, such a person is authorized to process personal data or whose personal data is processed.

Personal data means any information about a natural person whose identity was defined or whose identity is possible to define (data subject); a natural person is a person whose identity can be defined either directly or indirectly, in particular by using such identifiers as name and surname, personal identification number, location identifier or Internet identifier data, or several identity attributes of such a person like physical, physiological, genetic, mental, economic, cultural, or social identity attributes.

Data recipient means a natural or legal person to whom the personal data is provided.

Data provision means the disclosure of personal data by transfer or other means making such data available (except for publication in the media).

Data processing means an operation conducted with personal data: collecting, recording, storing, classification, grouping, merging, changing (amending or correcting), supplying, publishing, using, logical and (or) arithmetical operations, search, dissemination, destruction or any other activity or collection of such activities

Automatic data processing means data processing operations done by automatic or semi-automatic means.

Data processor means a legal or natural person (who is not the employee of the data controller) authorized by the data controller to process personal data.  Data processor and/or its authorization procedures can be defined under laws or other legal acts.

Data controller means a legal or natural person who, alone or together with other persons, defines data processing purposes and methods. If the purposes of data processing are defined under laws or other legal acts, the data controller and /or its authorization procedures may be defined under such laws or other legal acts.

Personal data of special categories means the data related to the racial or ethnic origin of a natural person, his/her political, religious, philosophical, or other beliefs, membership in professional unions, health, sexual life, as well as the information about previous criminal convictions.

Health data means the personal data related to the physical or mental health of a natural person including the data about provision of the health services revealing the information about the health status of such a natural person.

Consent means data provided upon free will, a specific and unambiguous expression of the will of a properly informed person with a statement or unambiguous action, with which he/she agrees gives his/her consent to process the personal data related to him/her.

Direct marketing means activities for proposing to persons goods or services and/or for asking their opinions about such proposed goods or services, made by email, telephone, or any direct method.

Internal Administration means the activities ensuring an independent functioning of the data controller (structure management, personnel management, management of the available material and financial resources and their use, clerical work).

Other definitions used in this Policy are in compliance to the GDPR or other applicable legal acts.

II. DATA PROCESSING PRINCIPLES

The general principles

The employees of the company when carrying their functions and processing personal data, shall follow the GDPR and other legal acts and this Policy, as well as to follow the requirements of internal documents of the Company executing or supplementing such requirements.

The personal data can be processed only in legal, fair, and transparent manner. In addition, the Company must be able to provide proof that it actually follows the principles of data processing defined under this Policy.

Purpose limitation

Personal data may only be collected for the specified and clearly defined and legal purposes and shall not be processed in contradiction to such proposes. Regarding the personal data related to the employees, the legal purposes, for example, are the management of human resources and internal administration (assignment to duties, and revoking from them, payment of salaries, work management and other human resources issues related to the employees).

Storage and deletion of personal data

Personal data may be kept in a form which permits identification of the data subjects for no longer than it is necessary for the purposes for which personal data is processed.

Data quality and proportionality

The personal data shall be accurate and updated when needed. All reasonable means shall be undertaken to ensure that the personal data which are not accurate, taking into consideration the purposes of their processing, shall be deleted or corrected in an immediate manner.  Moreover, the personal data shall be adequate, suitable, and only such (and for the exact amount of) which is necessary for the purposes of their collection and/or processing. The personal data shall be processed in such a way as, by applying technical and organizational instruments, as to be able to ensure proper security of the personal data, including the protection of the data processing without permission or illegal data processing, and from unintentional loss or damage, illegal access.

If the Company doubts the correctness of the personal data it processes, it shall suspend the actions of such processing, to check and correct the data.

III. WHAT DATA WE COLLECT AND FOR WHICH PURPOSES WE STORE IT

Data processing purposes

The Company processes the data of the persons visiting the websites of the Company and/or purchasing the services offered for the following purposes:

  • for processing of the purchase (order) of services, administration;
  • for the identification of the data subject in the information systems of the Company;
  • for the identification of the data subject during the login to his/her account at the website of the Company (when the Company provides with such an opportunity);
  • for issuing of coupons, approvals, invoices, and other financial documents;
  • for solutions of problems related to the execution, presentation, and use of the services,
  • for communications with the data subject if the terms and conditions of the services purchased by the data subject change;
  • for the execution of other contractual obligations;
  • for direct marketing purposes;
  • for business analysis and statistical analysis, general studies which allow to improve services and their quality.

The data can be processed for other purposes which are indicated when you provide your personal data to the Company.

Data processing when purchasing the tourism services offered by the Company

During the purchase of the tourist services, depending on specific types of services (travel direction), the Company, upon the purposes defined under this Policy, collects and processes the following personal data: name, and surname, sex, date of birth or personal identification code, the data of a document proving the personal identity, address, phone number, email address, payment card data, personal contact information (phone number, email address), citizenship, information about the special needs, personal information of the persons who travel together (names, surnames, dates of birth or personal identification codes, salutations, and citizenships, other personal data which are requested during the purchase of service. The data is provided during the execution of an agreement, purchasing a service, as well as during the consultations by phone, email, or by providing the information through other persons.

The Company, in this case, processes your personal data on the the following legal basis:

  • seeking to ensure a proper provision of services and high quality of the provided services (legitimate interest);
  • on the basis of your consent (when the data of special categories (health) are processed);
  • for the purpose of execution of the Agreement;
  • for the execution of own duties as of the travel organizer, defined under the legal acts.

Data processing after creating an account at the website of www.novaturas.lt

For the purpose of the registration at website www.novaturas.lt and usage of the account, the Company collects and processes email address and the information about the proposals of an interest to the account user. In the account, it is also possible to provide the data in advance which are processed for the purchase of the tourism services (see above).

The Company, in this case, processes your personal data on the the following legal basis:

  • in order to ensure the quality of the provided services (legitimate interest);
  • on the basis of your consent which you express with your active actions providing the data not mandatory for the registration;
  • on the basis of execution of this Agreement.

You may also be allowed to log in to the www.novaturas.lt system with the existing accounts of your social networks. For more information how the data of the users are processed and used you can ask from your social media networks providers and administrators.

Data processing after creating an account ant using hotel booking services via www.travelonspot.com

During the registration at the website www.travelonspot.com and using the service of hotel booking offered by the Company, or by providing feedback on the hotels visited, the Company, for the purposes defined under this Policy collects and processes the following personal data: name and surname, sex, address, phone number, email address, payment card  data, names and surnames, dates of both, personal contact information and travel selections of the persons travelling together. The data is provided during the execution of an agreement, purchasing a service, as well as during the consultations by phone, email, or by providing the information through other persons.

The Company, in this case, processes your personal data on the the following legal basis:

  • in order to ensure the quality of the provided services (legitimate interest);
  • on the basis of your consent which you express with your active actions providing the data not mandatory for the registration;
  • on the basis of execution of this Agreement.

When advertising the accommodation entities and the services provided by them as well as promoting and improving the services provided social networks are used (e.g., our website has direct links integrated with the social channels). At the website www.travelonspot.com, the information becomes available to the social network provider when the user clicks one of the buttons of the social networks after registering with his/her social network account This information may be shown at the profile of the social network user and seen by other members of the network.

You may also be allowed to log in to the system of www.travelonspot.com using the existing accounts of your social networks. For more information how the data of the users are processed and used you can ask from your social media networks providers and administrators.

Clients feedback

After visiting any accommodation entities selected and booked from the Internet website, Travel on Spot/Novaturas  asks the user to provide feedback on the accommodation entities, services provided,  If the data subject objects to indicate his/her name net to the feedback provided, the comment may be published by only indicating the nickname of anonymously. When providing the feedback the data subject agrees  for showing it for example, at the information page of the website of the accommodating entity, in mobile applications, social network accounts or social network applications, on websites of a relevant accommodating entity or websites of our partners - for the purpose of informing of other travellers. The feedback provided by users on the discretion of Travel on Spot/Novaturo can also be used for marketing purposes, promotion of sales or improvement of services quality, and can be published on internet website or other social media channels: newsletters, advertisements, programmes and other channels belonging to, used and processed by Travel on Spot/Novaturas. Travel on Spot/Novaturas has the right to remove certain feedback on own discretion. If the user indicates that certain comment of the guest was useful or not useful, this information may be used together with the information provided by other users by sorting and defining the sequence of the comments provided.

Data processing when using flight booking services atflights.novatours.eu

During the purchase of air tickets at website flights.novatours.eu, the Company, for the purposes indicated under this Policy, collects and processes the following personal data: greetings of the travelling persons, their names, surnames, child birth date, contact information of the person who purchases the tickets (phone number and email address), as well as information about the payment. In certain cases (after contacting separately), the following personal data may be collected and processed: the data proving the personal identification. The data is provided during the execution of an agreement, purchasing a service, as well as during the consultations by phone, email, or by providing the information through other persons.

This data is processed upon the legal basis of the agreement execution.

Processing of personal data when providing other services

When obtaining gift coupons, child escort or other services offered by the Company, for the purposes defined under this Policy, and on the basis of the agreement execution, the Company may process other personal data. The scope of the processed data depends on the specific service which you want to obtain. The data to be provided to be able to provide a service, are indicated during the ordering of the service.

Processing of personal data when using mobile devices

When you use your mobile devices, the data may be collected for the purpose of indicating the type of your mobile device, device settings, geographical coordinates (longitude and latitude).

Processing of personal data when administering and investigating complaints and/or requests

The Company processed the personal data indicated by you when you submit to the Company a request and/or complaint in this internet website, by email, post, or telephone.

The Company processes your personal data under the cases indicated upon the following legal basis:

  • seeking to administer requests and/or complaints, to ensure the quality of the services provided (legitimate interest);
  • on the basis of your consent expressed by your active actions when you submit a request and/or complaint;
  • for the execution of own duties as of the travel organizer, defined under the legal acts.

The Company, seeking to investigate your request and/or complaint, provide information and ensure the quality of its services, has the right to register the information provided by you at the internal information system of the Company.

The Company requests to follow at least these minimal personal data protection requirements when you address the Company:

  • not to indicate such personal data, as personal ID code, date of birth, bank account number, vehicle state registration number, real estate data, health data, other personal data of special categories or any sensitive personal data, and similar neither in the subject of your request and/or complaint (your email letter, documents provided in writing, on the internet website), neither in the attached titles of files;
  • in the request and/or complaint text or during the telephone call not to indicate personal personal data of special categories or any sensitive personal data, and similar identification code, bank account number, vehicle state registration number, real estate data, health data or any other data if such data has no direct relationship with the request and/or complaint, and to indicate the personal data of other persons only as much as it is necessary for the purposes of the submitted request and/or complaint.

Should the Company need any additional information for the investigation of your request and/or complaint, it will use your contact information to be able to contact you.

The Company also wants to draw your attention that the personal data of the persons who contacted the Company with their requests or complaints, may be transferred to the company UAB "Aviaturas ir partneriai" belonging to the Company group, and that this company helps to ensure fluent and prompt administration of complaints.

Processing of personal data of the shareholders of the Company

The Company processes the personal data of its shareholders in its operations:

  • for the purpose of internal administration;
  • for the purpose of execution of its legal liabilities related to the registration and processing of the data of the Company shareholders, the accounting of shares, and execution of other liabilities applicable to them.

Processing of personal data of other administrative bodies of the Company

The Company in its activities processes the personal data of the members of the administrative bodies of the Company:

  • for the purpose of internal administration;
  • seeking to execute its legal obligations related to the administrative bodies (head of the Company, the board of observers, committees, and etc.) formation, organizing of their activities, providing of the data of the administrative body and its members to the public registers and for registration at such registers, application of the Law on the Financial Accounting of Companies (e.g. statement of the data of the board and its members in the annual report), and similar.

The processing of personal data of the administrative bodies of the Company is mandatory on the basis defined bu legal acts.

Data processing for the purposes of employees’ selection

By applying for a vacancy in the Company, for example, when sending the CV by email info@novaturas.lt, or contacting the Company in relation to the vacancy announcement, the Company collects and processes the personal data provided in your letter and CV.

The Company processes the data you provided:

  • for the purposes of staff selection;
  • on the basis of your consent which you express with your active actions when providing your personal data.

The Company stores your data provided via this internet website in relation to the staff selection for 12 months.

The Company wants to draw your attention that the fact of providing of any personal data for the purpose of staff selection and the storage of such data does not mean the application to the vacancies wanted. If you find an advertisement in the website of the company or employment search websites in relation to your wanted vacancy, we invite you to apply directly by using the email address indicated in such an advertisement.

If you, however, provide your personal data in this website seeking to participate in a specific competition, but the Company selects another applicant who meets its needs better, the Company will store the personal data you provided till the end of the specific competition, and if you provide your consent for any further processing of this data for other staff competitions, then your data will be stored for one year after the end of such a competition, unless you revoke your consent earlier.

The Company informs that for the purpose of evaluation of your application, it can apply for recommendations to your previous employers you indicated and request information on your qualification, processional, and business skills. The Company can request such information from your existing employee only having received your separate consent. 

The Company also wants to emphasize that it can receive your personal data from the third parties, for example, the companies managing employment advertisements websites, employment agencies, when you provided your data to such companies, as well as from publicly available sources where you published your personal data.

IV. Marketing proposals and newsletters

Using the services provided by the Company and concluding tourism services provision agreements the data subject can upon his/her own will agree to allow to use his/her personal data provided for the marketing purposes of the Company by expressing such of his/her consent in an appropriate graph of the tourism services provision agreement with his/her signature.

The data subject may agree to receive the information sent by the Company:

  • After visiting the website of the Company (novaturas.lt, www.travelonspot.com, flights.novatours.eu) and subscribing for Company newsletters.
  • By using the services provided by the Company (filling in the questionnaires of the Company after your travel by air plane, by bus on-line or during the events organized by the Company), and by concluding tourism services provision agreements (via our travel agents) by expressing your consent to receive newsletters, information notifications, proposals, discounts, sales off and etc. by marking this in an appropriate graph (e.g. by ticking).
  • If an opportunity is provided to register and become the member of the Company's club, after the registration and approval of the Company club membership, the data subject may express his/her consent to receive newsletters, information notifications, proposals, discounts, sales off and etc.
  • If you are provided with an opportunity to register to the website of the Company and to become a register user of it, after completion of the registration and after becoming the registered member of the Company website, the data subject may express his/her consent to receive newsletters, information notifications, proposals, discounts, sales off and etc.

The data subject has the right to refuse the information sent by the Company by clicking on the refusal link in the newsletter or any other letter sent to the data subject by the Company and to refuse such proposals and news.

If, when filling in the questionnaires of the Company after trips (in buses, air planes, or on-line) the data subject does not mark (e.g. by ticking) that he/she agrees to receive the news, proposals, and other information sent by the |Company - he/she will no longer receive them because the information of the data subject will be updated and the latest information provided by the data subject will be used.

If the data subject is a registered user of the Company website who does not want to receive unwanted information about the services of the Company, he/she can make the changes at an time by logging into his/her account at the Company website and marking this (e.g. by ticking) in his/her account at "My data" -> "Information settings".

The data provided by the data subject which are used for the purposes of direct marketing help to ensure a continuous improvement and development of the Company website and services provided by the Company, and provides the opportunity to offer the best proposals.

The data subject can also use his/her right to refuse to process his/her data for direct marketing purposes by informing the Company in writing by post or means of electronic communications.

V. PERIOD OF STORING OF PERSONAL DATA

The Company shall store the personal data for as long as it is necessary to reach its targets for which such data is processed (e.g. to provide services, to investigate a complaint, and etc.) as well as following the requirements of storage of such data defined under the legal acts, legal requirements for limitation periods in relation of providing or protecting against legal clams, and if such are submitted - as long as it is necessary for this purpose..

In order to implement a proper control over the duration of data storage, the Company has appropriate technical and organizational measures to ensure data deletion after the expiration of the data storage period.

VI. PRIVACY AND PERSONAL DATA SECURITY

Following the GDPR and other documents regulating data protection, the Company applies measures to prevent illegal access to or illegal usage of the data of the data subject. The Company ensures that the data provided by data subjects will be protected from any illegal actions: illegal changes of the personal data, their disclosure or destruction, theft of personal identity, fraud or similar illegal actions.

The Company uses appropriate technical and organizational security measures, appropriate business systems and procedures in place to protect and defend the personal data of the data subject entrusted to the Company. The Company uses security systems, technical and physical measures restricting access to the personal data of the data subject and its use at the servers of the Company. Only the staff of the Company with special permissions can see the personal data of the data subject provided to the Company, and only for work purposes.

The Company uses only such data processors which guarantee the implementation of all necessary technical and organisational measures for the protection of personal data, and which follow such measures.

VII. USE OF COOKIES

When you visit our website, we want to provide information and functions specially customized only for you. Cookies are needed for this purposes. They are small elements of information, text files, saved in your Internet browser. For more information on the types of cookies we use and how you can control them you can find in our Company Cookies Policy at www.novaturas.lt.

VIII. TRANSFER OF PERSONAL DATA

 

The Company may use the services of certain service providers (data processors) to manage your personal data. These data processors are the following: the company providing services to the data centre, companies doing the analysis of Internet browsing and internet activities and providing related services, companies designing software, providing, supporting and developing it, companies providing information technology structure services, companies providing communication, security, recruitment, call centre services, and other service providers to which the personal data is disclosed only to the extent needed to provide their services.

If there are sufficient legal grounds (e.g. when it is necessary for concluding or executing the agreement with you and when the information about this transfer was properly provided for you), the data can be transferred to our business partners or agents.

We would like to inform you that certain data related to your visits at out website (IP address, cookies, technical information on the browser you use, other activities related to your browser and information related to your browsing at our website), browsing statistics, analyses, for relevant purposes can be transferred or made available to the subjects operating both in the European Economic Area (EEA), as well as out of this area (e.g. when we use Google Analytics service, when such a subject ins a company registered in the United States of America).

We would also like to draw your attention that if you select a trip outside the EEA, the data you provided may be transferred to our partners operating in such countries and helping us to organize your trip: airlines, hotels, representatives of the Company at the direction of the trip, etc.

We would like remind that the level of personal data protection outside the EEA countries can be lower compared to the EEA countries, and this means a higher level of risk for illegal data processing, but we will meticulously evaluate the conditions under which such data of yours will be processed later and secured after the transfer of the data to the above-mentioned subjects. Your data to such receivers will be transferred only to such scope which is needed to perform the agreement made with you and to provide services for you. With the major partners from the third countries the Company concludes Standard Conditions for Agreements approved by the European Commission about which you can get more information using the Contacts of the Company indicated below:

To other data receivers your personal data may be submitted only on the basis defined under legal acts.

IX. RIGHTS OF THE DATA SUBJECT

You, in relation to your personal data, have the following rights:

  • to get to know about your personal data and how this data is processed;
  • to demand to correct incorrect, inexact, or incomplete data;
  • to demand to delete your personal data or to limit the processing of such data when such data is processed without following the requirements defined under legal acts or when there is another legal basis;
  • to demand to transfer your personal data to another data processor or to provide this data to you in a convenient form (applicable to the data you provided yourself and which is processed using automatized means or on the basis of your consent);
  • to disagree to the processing of your personal data if such data is processed on the basis of a legitimate interest, with the exception of cases when there are legitimate reasons for such processing or when it is necessary to submit, execute, or protect legal requirement;
  • to revoke, at any time, your consent if you personal data is processed upon the basis of your consent.

In such cases when you think your data is processed illegally or by breaching your rights related to the data processing, you have the right to appeal to the State Personal Data Protection Inspectorate (for more information please visit www.ada.lt) and to submit your complaint to it.

However, the Company recommends before submitting the official complaint, to contact the Company by email info@novaturas.ltfor trying to find a proper solution of the problem.

Some information, for example, your personal data you provided to us during your registration at www.novaturas.lt or www.travelonspot.com, or the data related to the services obtained using these accounts, you can find after logging into your user account(s).

In order to protect personal data against unauthorised disclosures, the Company, having received your request for the implementation of your rights, will have to verify your identity. For this reason the Company may ask you to indicate your name, surname, date of birth, e-mail address, or phone number, or request to appear in person in the Company or one of its offices for the purpose of checking your identity. In carrying your this check, the Company may also sent its control notification to the indicated contact (SMS or email) asking to perform the action of authorisation. If the verification procedure is not successful (e.g. your data will differ from the data the Company has, or you do not authorize yourself upon the SMS or email message received), the Company will consider that you are not the subject of the requested data and will reject the request you submitted.

The Company, having received your request and successfully performed the above mentioned verification, no later than within one month from the receipt of your request and completion of the verification procedure, shall provide you with the information about the actions it undertook in relation to your submitted request. Taking into consideration the complexity and number of requests, the Company may have the right to extend the period of one month up to two months by informing you about this  no later than within one month from the receipt of your request and completion of the verification procedure and shall state the reasons of such extension.

If you submit your request by electronic means and the Company would be able to verify your identity properly, you will also receive the reply from the Company by electronic means with the exception of the cases when this is impossible (e.g. due to a substantial volume of information, other actual circumstances and reasons), or if you request to reply in different ways.

Under the reasons and/or circumstances defined under legal acts, the Company may refuse to fulfil your request and the Company will inform you about such a refusal by providing the reasons.

X. LIABILITY

The data subject shall provide the Company complete and correct personal data and to inform about relevant changes of such personal data. The Company shall not be held liable for damages caused to the data subject and/or third persons if the data subject provides incorrect and/or incomplete data about himself/herself or did not inform duly and on time about the changes of such data.

It is strictly prohibited to submit false and deceitful orders. Travel, services reservation services offered at the website, can only be used for submitting a legitimate order or customized or purchase for oneself and other persons in the name of which the person submitting the order has the right to act. If the user performs any suspicious activity, frauds or abuses the travel ordering services and other service ordering services offered at the website, the Company may cancel all or part of such orders made in the name of such a user, related to his/her email or account, or to close all accounts of such a user. The Company shall have all rights to undertake necessary legal actions in cases of fraud actions performed by the user. Under such cases, the user who did the fraudulent actions shall be liable for the financial damages suffered by the Company including costs of litigation and any other consequential damages.

The data subject when purchasing the services offered by the Company or otherwise providing to the Company not own, but third persons personal data (e.g. family members, friends data and etc. who travel together) shall inform such persons that all information related to the processing of data can be found in this Policy. The data subject, by providing the personal data of other persons, including the personal data of children and/or personal data of special categories, certifies that he/she is a legitimate representative of such persons (one of the parents, guardians) and that such persons agree on such submitting of their data and processing of such data. The Company reserves the right to contact the person indicated to make sure such a consent was given.

Without providing the personal data requested by the Company, the Company will not be able to provide certain services or to ensure the quality of the services provided.

The Company shall not be liable for communication malfunctions due to which the users of the Company website and other persons could not reach its website or use the services.

The Company cannot absolutely guarantee that the functioning of the Company website will be without any interruptions, without any malfunctions or errors, that the website of the Company would be fully protected from viruses or any other malicious components. The data subject is informed that any materials read by the data subject, downloaded or otherwise received by using the website of the Company, is exclusively received upon the discretion and risk of the data subject, and only the data subject shall be held liable for the damages to the data subject and to his/her computer system.

If the data subject is a registered user of the Company website (when the Company provides such an opportunity), the data subject undertakes all risk and responsibility for the actions of the third persons in the website of the Company done by using the login data of the data subject, and undertakes to execute all obligations undertaken in relation to the usage of the login data of the data subject.

The user, when using this website, accepts and agrees to all liabilities defined under this Policy.

XI. HOW TO CONTACT US

If you have any questions related to the processing of your personal data or this Policy, or questions relayed to the implementation of your rights, please contact us:

AB “Novaturas”
info@novaturas.lt, or
Mickevičiaus g. 27, LT-44245, Kaunas, Lithuania 

Regarding the services of "Travel on Spot":

info@travelonspot.lt

The contact data of the Data Protection Officer if the Company: dpo@novaturas.lt, phone: +370 5 2649483.

XII. FINAL PROVISIONS

The Company can update this Policy at any time. The Company will inform the visitors about these updates by uploading a new version of this Policy together with the date of the last changes. The visitors understand that by continuing the use of this website after the implementation of the Policy updates, they express their consent with such changes.

Should any of the provisions of this Policy be declared as void or not applicable, this shall not have any effect to the legality of the remaining provisions of the Policy and their validity.

This Policy shall enter info force from its publication on the website of the Company.

Last Updated: March 15, 2019

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