Legal Information

Privacy Policy

How SolegateUS LLC collects, uses, shares, and protects your personal data.

1. Introduction & Summary

Welcome to Soulgate! This Privacy Policy explains how SolegateUS LLC (“Soulgate,” “we,” “us,” or “our”) collects, uses, shares, and protects your personal data when you visit our website soulgateus.com, use our mobile applications (collectively, the “Platform”), or interact with our services.

Your trust is important to us, and we are committed to protecting your privacy. As an Online Travel Agency (OTA), our primary role is to act as an intermediary, connecting you with third-party airlines, hotels, tour operators, and other travel providers (“Travel Suppliers”).

This policy details what information we collect, why we collect it, who we share it with, and the rights you have concerning your data.

Key Points to Understand:

✓Our Role: We are an agent, not the direct provider of travel services. We facilitate your bookings with independent Travel Suppliers.
✓Your Contract: When you make a booking, you enter into a direct contract with the Travel Supplier, not with Soulgate.
✓Data Sharing: To complete your booking, we must share your relevant personal data with the Travel Supplier you choose. These suppliers have their own privacy policies that govern their use of your data.

We encourage you to read this policy carefully to understand our data practices. By using our Platform, you agree to the collection and use of your information in accordance with this policy.

2. What Personal Data We Collect

We collect information to provide and improve our services, facilitate your travel bookings, and communicate with you. The types of personal data we collect fall into three categories:

A. Information You Provide to Us Directly

Contact Information: Your name, email address, phone number, and physical/billing address.
Account Information: Your login credentials (username and password), travel preferences, saved lists, and other settings associated with your Soulgate account.
Booking and Travel Information: Details of your bookings, including traveler names, travel itineraries, Passenger Name Record (PNR), and any special requests (e.g., accessibility needs, meal preferences).
Payment Information: Credit or debit card details (card number, expiration date, and CVV), billing address, and other financial information required to process payments.
Identification Information: In some cases, such as for international flights or specific tours, we may be required to collect government-issued identification details like your passport number, nationality, date of birth, and gender.
Information About Others: If you book on behalf of other people (co-travelers, family members, etc.), you will provide their personal data (e.g., name, date of birth, passport information). By providing this information, you confirm that you have their consent to do so.
Communications: Records of your interactions with our customer service team, including emails, chat transcripts, and call recordings.
Reviews and Feedback: Any reviews, ratings, photos, or other content you submit to our Platform.

B. Information We Collect Automatically

Device Information: Your IP address, device type, unique device identifiers, operating system, and browser type.
Usage Data: Information about how you interact with our Platform, such as pages viewed, searches conducted, links clicked, features used, and the dates and times of your visits.
Location Data: Your general location inferred from your IP address. With your consent, we may also collect precise real-time location data from your mobile device to provide location-based services. You can manage this in your device settings.
Cookie Data: We use cookies and similar tracking technologies to operate and personalize our Platform.

C. Information We Receive from Third Parties

Travel Suppliers: After a trip, a Travel Supplier may share information with us regarding your experience, such as the fulfillment of your booking or any issues that arose.
Payment Processors: Our payment partners may provide us with information related to your payment transactions, such as confirmation of payment or notifications of fraud.
Business and Marketing Partners: We may receive information from partners with whom we offer co-branded services or engage in joint marketing activities.
Social Media Platforms: If you choose to link or log in to your Soulgate account using a social media service (e.g., Google, Facebook), we will receive certain information from that service, such as your name and email address, as permitted by your privacy settings on that platform.

3. How and Why, We Use Your Personal Data

We use your personal data for specific purposes and rely on a lawful basis for each. The table below outlines these purposes and our legal grounds for processing.

Purpose of Use	Categories of Data Used	Legal Basis (GDPR)
Facilitating and Administering Bookings	Contact, Booking, Payment, Identification, and Information About Others.	Performance of a Contract: Necessary to fulfill our agreement to facilitate your travel booking with the Travel Supplier.
Managing Your Account	Account, Contact, and Booking Information.	Performance of a Contract: Necessary to provide and maintain your user account as requested by you.
Processing Payments	Payment, Contact, and Booking Information.	Performance of a Contract: Necessary to facilitate payment for your travel services.
Communicating with You	Contact, Booking, and Communications Data.	Performance of a Contract / Legitimate Interest: To send booking confirmations, updates, and other essential service-related messages.
Providing Customer Support	Contact, Booking, Account, and Communications Data.	Legitimate Interest / Performance of a Contract: To respond to your inquiries, resolve issues, and provide assistance.
Marketing and Personalization	Contact, Account, Usage, and Cookie Data.	Consent / Legitimate Interest: For email marketing, non-essential cookies, or to personalize your experience and show relevant offers.
Improving Our Services	Usage, Device, Location, and Feedback Data.	Legitimate Interest: To analyze user behavior, understand trends, and enhance functionality.
Security and Fraud Prevention	Device, Usage, Payment, and Identification Data.	Legitimate Interest / Legal Obligation: To protect our Platform, users, and business from fraudulent activities.
Legal and Regulatory Compliance	All relevant categories as needed.	Legal Obligation: To comply with applicable laws, tax regulations, law enforcement requests, and court orders.

4. How We Share Your Personal Data

As an intermediary, sharing information is essential to our service. We only share your data as described below and for the purposes outlined in this policy.

A. Travel Suppliers

This is the most important way we share your data. To complete your booking, we must transfer your relevant personal data (such as your name, contact details, payment information, and the names of any co-travelers) to the Travel Supplier(s) you have booked with (e.g., the airline, hotel, or tour operator).

Independent Controllers: Each Travel Supplier is an independent data controller. Your data becomes subject to their privacy policy and practices once we share it with them. We encourage you to review the privacy policy of any Travel Supplier before booking. We will provide links to their policies where available during the booking process.
Direct Communication: The Travel Supplier may contact you directly to obtain additional information, confirm your booking, or provide details about the travel service.
Soulgate Responsibility: Soulgate is not responsible for the privacy practices of Travel Suppliers.

B. Third-Party Service Providers

We engage third-party companies to perform services on our behalf. These providers have access to your personal data only to perform these tasks and are obligated not to disclose or use it for any other purpose. This includes:

Payment Processors: To securely process your payments (e.g., Stripe, PayPal). Soulgate does not hold, store, or process your card information; all payment data is handled directly by Stripe or other third-party payment processors.
Customer Support Providers: To help us manage communications and provide support.
Cloud Hosting and Technology Providers: For data storage and to operate our Platform.
Fraud Prevention Services: To screen transactions for fraudulent activity.
Analytics Providers: To help us understand how our Platform is used (e.g., Google Analytics).

C. Business Partners and Marketing

Marketing Partners: We may share hashed or de-identified information with marketing partners to show you relevant ads on third-party websites. Where required by law, we will obtain your consent first.
Co-Branded Services: If we offer services in conjunction with another partner, we will share information with that partner to facilitate the service. We will make it clear when a third party is involved.

D. Legal and Governmental Authorities

We may disclose your personal data if we are required to do so by law or in the good faith belief that such action is necessary to:

Comply with a legal obligation or a request from law enforcement.
Protect and defend the rights or property of Soulgate.
Prevent or investigate possible wrongdoing in connection with the service.
Protect the personal safety of users or the public.

E. Corporate Transactions

In the event of a merger, acquisition, divestiture, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal data.

5. International Data Transfers

Our business is global, which means your personal data may be transferred to, and processed in, countries other than the country in which you reside. Travel Suppliers and our service providers may be located anywhere in the world.

These countries may have data protection laws that are different from the laws of your country. When we transfer your personal data to other countries, we will protect that information as described in this Privacy Policy and in accordance with applicable law.

6. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and other similar technologies to collect information automatically, operate our Platform, and personalize your experience.

What are cookies? Cookies are small text files stored on your browser or device. They allow us to remember your preferences, keep you signed in, and understand how you use our site.

We use the following types of cookies:

Essential Cookies: These are strictly necessary for the Platform to function. They enable core functionalities like security, account login, and processing bookings. You cannot opt-out of these cookies.
Functional Cookies: These cookies remember your choices and preferences (such as your preferred language, currency, or region) to provide a more personalized experience.
Analytics Cookies: These help us understand how visitors interact with our Platform by collecting and reporting information anonymously. This allows us to measure and improve our service.
Marketing Cookies: These are used to track your activity across websites. The intention is to display ads that are relevant and engaging for you. We will only use these with your consent where required by law.

Your Choices: You can manage your cookie preferences through adjusting your browser settings. Please note that blocking some types of cookies may impact your experience on our site.

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Account Data: We keep your account information for as long as your account is active. If you close your account, we will delete or anonymize your data, subject to the exceptions below.
Booking Data: We retain data related to your bookings for a period of up to 7 years after the trip is completed to comply with tax and legal obligations.
Marketing Data: If you have consented to receive marketing communications, we will retain your information until you unsubscribe.

8. Your Rights and Choices

You have certain rights regarding the personal data we hold about you. Depending on your location, these rights may include:

Right to Access: You can request a copy of the personal data we hold about you.
Right to Rectification: You can request that we correct any inaccurate or incomplete personal data.
Right to Erasure (Deletion): You can request that we delete your personal data, subject to certain legal exceptions.
Right to Restrict Processing: You can request that we limit the way we use your personal data.
Right to Object: You can object to our processing of your personal data, particularly for direct marketing purposes.
Right to Withdraw Consent: Where we rely on your consent to process data, you can withdraw that consent at any time.

How to Exercise Your Rights: You can exercise these rights by contacting us at contact@soulgateus.com. We will respond to your request in accordance with applicable law. We may need to verify your identity before processing your request.

9. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. This includes using encryption for data in transit, access controls, and regular security assessments. However, please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

10. Updates to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “Last Updated” date displayed on our platform.