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Legal Document

Privacy Policy

Effective: 1 January 2024 Last Updated: 30 March 2025 Jurisdiction: Nigeria & Germany (NDPR / GDPR)
This policy was last reviewed and updated on 30 March 2025
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Who We Are

Eujen Travels and Tours Ltd ("Eujen Travels", "we", "us", "our") is a private limited travel company registered in Nigeria (RC No. 77800) with operations also serving Nigerians resident in Germany.

We are committed to protecting your personal data in accordance with the Nigeria Data Protection Regulation (NDPR) 2019 and, where applicable to our German operations, the EU General Data Protection Regulation (GDPR).

This Privacy Policy explains what data we collect, why we collect it, how we use it, and your rights regarding it. It applies to all services offered through eujentravels.com and our offices.

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Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data:

CategoryExamplesSource
Identity DataFull name, date of birth, nationality, passport numberYou directly
Contact DataEmail address, phone number, postal addressYou directly
Travel DataItinerary details, flight preferences, hotel choices, visa categoryYou directly / Booking systems
Biometric & ID DataFingerprints, facial image, NIN, BVN (NIN/BVN enrolment only)You directly (in-person)
Financial DataPayment reference, transaction amounts (we do not store card numbers)Payment processors
Technical DataIP address, browser type, pages visited, cookiesOur website automatically
CommunicationsEmails, WhatsApp messages, enquiry form submissionsYou directly

We collect only the minimum data necessary for the stated purpose. You are not obligated to provide personal data, but some services cannot be delivered without it.

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How We Use Your Data

We use personal data for the following purposes:

  • Processing flight, hotel, cruise, and tour bookings on your behalf
  • Providing visa advisory services and preparing documentation
  • Enrolling you for NIN or BVN where you have requested this service
  • Communicating with you about your booking, itinerary, or enquiry
  • Processing payments and issuing receipts or invoices
  • Sending travel updates, reminders, or service notifications
  • Sending marketing communications (only with your explicit consent)
  • Complying with legal obligations under Nigerian and German law
  • Improving our website and service quality through analytics

We will never use your data for purposes incompatible with the reason it was originally collected.

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NIN & BVN Enrolment

This section applies specifically to Nigerians in Germany using our certified NIN and BVN enrolment services. This data is treated with the highest level of care.

During NIN and BVN enrolment, we collect biometric data including fingerprints and facial images, along with identity documents. This is special category data under GDPR and is processed only on the basis of your explicit consent and in compliance with Nigerian government guidelines.

  • Biometric data is transmitted securely and exclusively to NIMC (National Identity Management Commission) or CBN-authorised banking agents as required
  • We do not store biometric data on our own servers beyond the enrolment session
  • Identity documents are processed solely for verification and not retained after submission
  • All processing complies with both NDPR 2019 and GDPR Article 9 (special category data)

You have the right to withdraw consent at any time prior to submission. Once biometric data has been transmitted to NIMC or CBN systems, deletion requests must be directed to those authorities.

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Legal Basis (GDPR)

For clients in Germany, we rely on the following legal bases under GDPR Article 6:

PurposeLegal Basis
Fulfilling a booking or service requestContract performance (Art. 6(1)(b))
NIN / BVN enrolmentExplicit consent (Art. 6(1)(a) & Art. 9(2)(a))
Marketing emails & newslettersConsent (Art. 6(1)(a))
Legal & regulatory complianceLegal obligation (Art. 6(1)(c))
Fraud prevention & securityLegitimate interests (Art. 6(1)(f))
Website analyticsLegitimate interests (Art. 6(1)(f))

For Nigerian clients, processing is conducted in accordance with the NDPR 2019 and the Nigeria Data Protection Act 2023.

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Data Sharing

We do not sell your personal data. We may share it with the following categories of third parties only as necessary to deliver our services:

  • Airlines and hotels — to complete your booking
  • Visa processing authorities — embassies, consulates, and immigration agencies
  • NIMC / CBN-authorised agents — for NIN and BVN enrolment processing
  • Payment processors — to handle transactions securely
  • IT and communications providers — who support our website and email systems
  • Legal and regulatory bodies — where required by law

All third-party partners are required to handle your data securely and in accordance with applicable data protection law. We do not share your data with advertisers or marketing companies without your explicit consent.

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Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by law:

Data TypeRetention Period
Booking & travel records7 years (tax and regulatory requirements)
NIN/BVN enrolment session dataDeleted after successful transmission to NIMC/CBN
Customer enquiries & communications3 years from last interaction
Marketing consent recordsUntil consent is withdrawn + 1 year
Website analytics (cookies)Up to 12 months
Payment transaction records7 years (financial regulations)

After the applicable retention period, data is securely deleted or anonymised.

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Your Rights

You have the following rights regarding your personal data. To exercise any of them, contact us at info@eujentravels.com.

📋
Right to Access
Request a copy of the personal data we hold about you.
✏️
Right to Rectification
Ask us to correct inaccurate or incomplete data.
🗑️
Right to Erasure
Request deletion of your data where we no longer have a lawful basis to hold it.
⏸️
Right to Restriction
Ask us to restrict processing of your data in certain circumstances.
📦
Right to Portability
Receive your data in a portable, machine-readable format (GDPR clients).
🚫
Right to Object
Object to processing based on legitimate interests or for direct marketing.
↩️
Withdraw Consent
Withdraw consent at any time where processing is consent-based.
⚖️
Right to Complain
Lodge a complaint with NITDA (Nigeria) or your local DPA (Germany).

We will respond to all requests within 30 days. We may need to verify your identity before processing a request.

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Cookies

Our website uses cookies — small text files placed on your device — to ensure the site functions correctly and to understand how visitors use it.

Cookie TypePurposeCan Be Disabled?
NecessaryEssential for the website to function (login, consent preferences)No
FunctionalRemembers your preferences and supports sharing featuresYes
AnalyticalTracks visitor behaviour to improve our site (e.g. Google Analytics)Yes
AdvertisementDelivers relevant ads based on your browsing activityYes

You can manage cookie preferences via the cookie banner on our website or through your browser settings. Disabling certain cookies may affect site functionality.

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Contact & Complaints

For any questions, data requests, or concerns about this Privacy Policy, please contact us directly:

✉️
🇳🇬
🇩🇪
Germany (WhatsApp)

If you are not satisfied with our response, you have the right to complain to a supervisory authority:

  • Nigeria: National Information Technology Development Agency (NITDA) — nitda.gov.ng
  • Germany: The data protection authority (Datenschutzbehörde) of the German state where you reside

We take all complaints seriously and aim to resolve them promptly and transparently.

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