Privacy Policy

1. Who We Are

Spira Travel is a travel company headquartered in Armenia, specializing in expert-led, deeply curated journeys across Armenia, Egypt, Georgia, Ethiopia, and beyond. We design travel experiences that go far beyond sightseeing — immersive, meaningful, and built around genuine human connection.

Website: www.spiratravel.com
Email: [email protected]
Phone: +374 55 55 35 71

Spira Travel acts as the data controller for all personal information collected through our website and services. Where we work with third-party partners to deliver your journey, those partners may act as independent data processors subject to their own privacy obligations.

2. Our Commitment to Your Privacy

At Spira Travel, your trust is the foundation of everything we do. We are fully committed to protecting your personal information and being completely transparent about how we collect, use, store, and safeguard it.

This Privacy Policy has been designed to comply with:

• The General Data Protection Regulation (GDPR) — for clients in the European Union and European Economic Area
• The California Consumer Privacy Act (CCPA) — for clients in the State of California, USA
• The Law of the Republic of Armenia on Personal Data Protection
• Other applicable international data protection standards

By using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy.

3. What Information We Collect

3.1 Information You Provide Directly

When you make an inquiry, book a trip, or contact us, we may collect:

• Full name, date of birth
• Email address, phone number, and postal address
• Passport number, nationality, and expiry date (required for travel arrangements)
• Sensitive data: dietary requirements, allergies, health conditions, mobility needs, and medical information relevant to your safety and comfort during travel
• Travel preferences, interests, bucket list destinations, and special requests
• Emergency contact details
• Payment and billing information
• Any other information you voluntarily share in communications with us

3.2 Information We Collect Automatically

When you visit spiratravel.com, we automatically collect:

• IP address and approximate geographic location
• Browser type, version, and language settings
• Device type, operating system, and screen resolution
• Pages visited, links clicked, and time spent on each page
• Referral source and search terms used to find our website
• Cookie identifiers and session data

3.3 Information From Third Parties

We may receive information about you from:

• Travel agents and partner agencies who refer clients to us
• Social media platforms if you interact with our profiles or ads
• Analytics and advertising platforms we use to improve our marketing
• Publicly available sources where relevant to delivering our services

4. Legal Bases for Processing Your Data (GDPR)

For clients in the EU and EEA, we process your personal data only where we have a valid legal basis to do so:

• Contractual Necessity — Processing required to fulfill your booking and deliver your travel experience
• Legitimate Interests — Improving our services, preventing fraud, and maintaining business records, where these interests are not overridden by your rights
• Legal Obligation — Processing required to comply with applicable laws and regulations
• Consent — For marketing communications and non-essential cookies, where we ask for and rely on your explicit consent
• Vital Interests — In rare emergency situations where processing is necessary to protect your life or safety during travel

You have the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Sensitive Personal Data

Spira Travel may collect and process sensitive categories of personal data, including health information, dietary requirements, and accessibility needs, solely for the purpose of ensuring your safety, comfort, and the successful delivery of your travel experience.

We process this data only:

• With your explicit consent
• Where necessary to protect your vital interests
• In accordance with applicable data protection laws

Sensitive data is handled with the highest level of care, shared only with partners directly involved in delivering your trip, and never used for marketing or any purpose beyond what is strictly necessary.

6. How We Use Your Information

To deliver your travel experience:

• Process your booking and manage your full itinerary
• Coordinate with local partners, hotels, expert guides, and operators
• Arrange transportation, accommodation, and exclusive experiences
• Communicate all necessary travel information before, during, and after your trip

To manage our relationship with you:

• Respond to inquiries, requests, and complaints
• Send booking confirmations, invoices, and travel documents
• Handle changes, cancellations, and refunds
• Provide post-trip follow-up and feedback collection

To improve our services:

• Analyze website usage and improve its performance and design
• Understand traveler preferences to create better experiences
• Conduct internal research, reporting, and business planning

To market our services (with your consent):

• Send newsletters, travel inspiration, and exclusive offers
• Notify you of new destinations, programs, and expert-led experiences
• Retarget website visitors with relevant content on social media and advertising platforms

To meet legal and financial obligations:

• Comply with applicable laws, tax regulations, and reporting requirements
• Maintain financial and accounting records
• Respond to lawful requests from regulatory or legal authorities
• Detect, prevent, and respond to fraud or security threats

7. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your experience and help us understand how our site is used.

Types of cookies we use:

• Strictly Necessary Cookies — Essential for basic website functionality. Cannot be disabled.
• Analytics Cookies — Help us understand visitor behavior so we can improve our website. Providers include Google Analytics.
• Marketing and Retargeting Cookies — Used to deliver relevant ads and measure campaign effectiveness across platforms including Facebook and Instagram.
• Preference Cookies — Remember your settings, language, and preferences for a smoother experience.

You can manage, accept, or reject non-essential cookies at any time through our cookie settings panel. Disabling certain cookies may affect the functionality of parts of our site.

For more information on cookies generally, visit www.allaboutcookies.org.

8. Who We Share Your Information With

We never sell your personal data to third parties under any circumstances. We share your data only where necessary and with parties who are contractually obligated to protect it:

• Local travel partners and operators — Hotels, expert guides, drivers, and experience providers required to fulfill your trip
• Airlines and transportation providers — Where flights or transfers are included or arranged
• Payment processors
• Travel insurance providers — Where insurance is purchased or arranged through us
• Referring travel agents and partner agencies — Limited data sharing to coordinate bookings and communications
• Analytics and marketing platforms — Including Google Analytics and Meta platforms, under strict data processing agreements
• Legal and regulatory authorities — When required by law, court order, or to protect the rights, property, or safety of Spira Travel, our clients, or others

All third-party partners are carefully vetted and required to process your data lawfully, securely, and only for the purposes we specify.

9. Payment Security and PCI-DSS Compliance

Spira Travel takes the security of your financial information extremely seriously. All payment transactions are processed through certified, PCI-DSS (Payment Card Industry Data Security Standard) compliant third-party payment providers.

We do not store, process, or transmit full credit card numbers on our own servers. All financial transactions are encrypted using SSL/TLS technology.

If you have any concerns about payment security, please contact us directly at [email protected].

10. International Data Transfers

As a global travel company operating across Armenia, Egypt, Georgia, Ethiopia, and beyond, your personal data may be transferred to and processed in countries outside your own. Some of these countries may have different data protection standards than your home country.

Where we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission (for EU data transfers)
• Data processing agreements with all international partners
• Working exclusively with partners who demonstrate adequate data protection standards

11. Travel Agent and Partner Data

If you were referred to Spira Travel by a travel agent or partner agency, we receive only the personal data necessary to plan and deliver your trip. We process this data solely on behalf of and in coordination with your referring agent, in accordance with this Privacy Policy and any applicable data sharing agreements.

Travel agents and partners who send clients to Spira Travel are responsible for ensuring their clients are aware that their data will be shared with us for the purpose of delivering travel services.

12. California Residents — CCPA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know — Request disclosure of the categories and specific pieces of personal information we have collected about you
• Right to Delete — Request deletion of your personal information, subject to certain exceptions
• Right to Opt-Out — We do not sell personal information. However, if this changes, you will have the right to opt out
• Right to Non-Discrimination — We will never discriminate against you for exercising your CCPA rights

To exercise your CCPA rights, contact us at [email protected] with the subject line: CCPA Privacy Request.

13. How Long We Keep Your Data

We retain your personal data only as long as necessary:

• Booking and trip records — Seven years for legal, financial, and accounting compliance
• Sensitive health and travel data — Deleted within 90 days of trip completion unless retention is required by law
• Marketing data — Until you unsubscribe or withdraw consent
• Website analytics data — 26 months
• General correspondence — Three years from last interaction
• Payment records — Seven years in accordance with financial regulations

Once data is no longer needed, it is securely deleted or irreversibly anonymized.

14. Data Breach Response

In the unlikely event of a personal data breach, Spira Travel will:

• Contain and assess the breach immediately
• Notify the relevant supervisory authority within 72 hours where required by law
• Inform affected individuals without undue delay if the breach is likely to result in high risk to their rights and freedoms
• Document all breaches internally regardless of whether notification is required
• Take immediate corrective action to prevent recurrence

If you suspect your data has been compromised, contact us immediately at [email protected].

15. Your Rights

Depending on your location, you have the following rights:

• Right to Access — Request a copy of the personal data we hold about you
• Right to Rectification — Request correction of inaccurate or incomplete data
• Right to Erasure — Request deletion of your data, subject to legal obligations
• Right to Restriction — Request that we limit processing of your data in certain circumstances
• Right to Data Portability — Receive your data in a structured, machine-readable format
• Right to Object — Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent — Withdraw consent for marketing or optional processing at any time
• Right to Lodge a Complaint — File a complaint with your local data protection authority

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before processing your request.

16. Children’s Privacy

Our services are not directed at children under the age of 16. We do not knowingly collect personal data from children without verified parental or guardian consent. Where travel arrangements include minors, we collect only the data strictly necessary for travel logistics, with the explicit consent of a parent or legal guardian.

If you believe we have inadvertently collected data from a child without appropriate consent, please contact us immediately and we will delete it promptly.

17. Data Security

We implement robust technical and organizational security measures to protect your personal data, including:

• SSL/TLS encryption across all website communications
• PCI-DSS compliant payment processing
• Restricted internal access to personal data on a strict need-to-know basis
• Regular security audits, vulnerability assessments, and staff training
• Secure data storage with access controls and audit logs
• Data minimization practices — we collect only what we truly need

While we apply industry-leading standards, no method of internet transmission is 100% guaranteed secure. We encourage you to contact us directly with any security concerns.

18. Third-Party Websites and Links

Our website may contain links to third-party websites, partner pages, and social media platforms. This Privacy Policy applies only to spiratravel.com. We are not responsible for the privacy practices of any external websites and strongly encourage you to review their privacy policies before sharing any personal information.

19. Social Media

Spira Travel maintains active profiles on Facebook and Instagram. Interactions on these platforms are governed by their respective privacy policies. We do not control or take responsibility for how these platforms collect or use your data. We use social media platforms for marketing purposes and may use anonymized audience data provided by these platforms to reach relevant travelers.

20. Changes to This Privacy Policy

We review and update this Privacy Policy periodically to reflect changes in our practices, services, technology, or legal requirements. When we make material changes, we will:

• Update the date at the top of this page
• Post a clear notice on our website
• Where appropriate, notify you directly by email

We encourage you to review this policy periodically. Continued use of our website following any changes constitutes your acceptance of the updated policy.

21. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the Republic of Armenia. For EU clients, GDPR provisions take precedence where applicable. For California clients, CCPA provisions apply as required. Any disputes arising from this policy shall be subject to the jurisdiction of the competent courts of the Republic of Armenia, unless otherwise required by applicable consumer protection law in your country of residence.

22. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us:

Spira Travel

Email: [email protected]
Phone: +374 95 55 55 55
Website: spiratravel.com
Instagram: instagram.com/spiratravel
Facebook: facebook.com/spiratravel

We are committed to responding to all privacy-related requests promptly, transparently, and with the respect your data deserves.