COOKIE POLICY — TRAVELLIN

Last Updated: 20/02/2026

This Cookie Policy explains how BETZONE s.r.o., operating the Travellin platform, uses cookies and similar technologies on travellin.info and related Travellin digital services.

Travellin is committed to using cookies and similar technologies lawfully, transparently and proportionately.

For users in the European Economic Area, the use of cookies and similar technologies is subject to the applicable ePrivacy rules as well as, where personal data is involved, the GDPR. The EDPB confirms that Article 5(3) of the ePrivacy Directive applies not only to traditional cookies but also to certain similar technologies. (European Data Protection Board)

1. COMPANY INFORMATION

Legal entity: BETZONE s.r.o.
Trading / Platform name: Travellin
Legal form: Společnost s ručením omezeným (s.r.o.)
Jurisdiction of establishment: Czech Republic
Registered office: Maletín 9, 789 01 Maletín, Czech Republic
Company registration number (IČO): 28802471
VAT / Tax identification number (DIČ): CZ28802471
Registration court: Krajský soud v Ostravě
File / Registration reference: C 76632

General enquiries: info@travellin.info
Booking enquiries: bookings@travellin.info
Privacy enquiries: privacy@travellin.info
Telephone: +420 732 844 855
Website: travellin.info

2. WHAT IS A COOKIE?

A cookie is a small text file or similar identifier that a website may store on a user’s device or access from that device.

Cookies may allow a website to:

• remember preferences;
• maintain a session;
• maintain authentication;
• remember language or currency;
• preserve search settings;
• provide security;
• measure website performance;
• understand website usage;
• remember consent choices;
• support affiliate attribution;
• or provide advertising and personalised functionality.

Cookies may be:

First-party cookies

Cookies placed by Travellin or by a service operating on Travellin’s behalf.

Third-party cookies

Cookies placed or accessed by a third-party service when you use Travellin.

The European Commission similarly distinguishes first-party cookies from third-party cookies and session cookies from persistent cookies. (European Commission)

3. SIMILAR TECHNOLOGIES

This Policy is not limited to traditional browser cookies.

Depending on the technologies actually deployed on Travellin, it may also cover:

• pixels;
• web beacons;
• tracking URLs;
• local storage;
• session storage;
• SDKs;
• advertising identifiers;
• device identifiers;
• fingerprinting technologies;
• tags;
• scripts;
• server-side identifiers;
• and other technologies capable of storing or accessing information on a user’s device.

The EDPB’s current guidance makes clear that the ePrivacy rules are technology-neutral and can extend beyond conventional cookies to similar technologies. (European Data Protection Board)

4. WHY TRAVELLIN USES COOKIES

Travellin may use cookies and similar technologies for several purposes.

These purposes are divided into the following categories:

1. Strictly Necessary
2. Preferences / Functionality
3. Analytics
4. Affiliate & Referral
5. Advertising / Marketing
6. Personalisation
7. Security & Fraud Prevention

Not every category will necessarily be active at all times.

The actual cookie inventory depends on the technologies currently deployed on the Travellin Platform.

5. STRICTLY NECESSARY COOKIES

Strictly necessary cookies are used to provide functionality that the user has requested or that is technically necessary to operate the website.

Examples may include cookies required for:

• session management;
• authentication;
• account login;
• shopping cart functionality;
• checkout;
• security;
• fraud prevention;
• load balancing;
• maintaining booking-session information;
• language selection where necessary for the requested service;
• currency selection where technically necessary;
• consent-management functionality;
• and basic website operation.

These cookies may be essential to the operation of the Platform.

Where a cookie is genuinely necessary for a service requested by the user, applicable law may permit it to operate without consent.

This exemption should not be interpreted broadly: Travellin will not classify analytics, advertising or optional tracking cookies as “necessary” merely because they are useful to Travellin.

6. CONSENT FOR NON-ESSENTIAL COOKIES

Where applicable law requires consent before storing or accessing information on a user’s device, Travellin will seek valid consent before activating the relevant technology.

The EDPB states that, under Article 5(3) of the ePrivacy Directive, storing information or gaining access to information already stored on a user’s terminal equipment generally requires consent unless a specific exemption applies. (European Data Protection Board)

Accordingly:

Travellin will not rely on “continued browsing” as consent.

A user must take an affirmative action where consent is required.

The EDPB has specifically stated that merely continuing to browse does not constitute valid consent and that withdrawal must be as easy as giving consent. (European Data Protection Board)

7. COOKIE CONSENT BANNER

Where non-essential cookies are used, Travellin may display a cookie-consent interface when a user first visits the Platform.

The interface should provide users with appropriate choices, such as:

Accept All

Reject All / Necessary Only

Manage Preferences

The precise wording may vary according to the consent-management technology used.

The essential principle is that rejecting optional cookies should not require substantially more effort than accepting them.

The European Commission specifically warns against deceptive cookie interfaces where accepting is easy but rejecting requires additional steps. (European Commission)

8. COOKIE CATEGORIES

8.1 Strictly Necessary

These cookies support essential Platform functions.

Typical purposes:

• authentication;
• session management;
• security;
• checkout;
• booking;
• cart;
• fraud prevention;
• consent storage;
• technical operation.

Consent: May not require consent where a legal exemption applies.

8.2 Preference / Functionality

These cookies remember choices made by the user.

Examples:

• language;
• currency;
• region;
• search preferences;
• interface settings;
• recently selected options;
• and other functionality preferences.

Consent: Where required by applicable law, consent will be requested.

8.3 Analytics

Analytics cookies may help Travellin understand:

• how users navigate the Platform;
• which pages are visited;
• which searches are performed;
• how long pages are used;
• where technical errors occur;
• how the booking funnel performs;
• and how the Platform can be improved.

Examples of analytics services may include Google Analytics, Matomo or another analytics provider if actually installed on the production website.

Consent: Where required, analytics cookies will remain disabled until valid consent is obtained.

9. AFFILIATE AND REFERRAL COOKIES

Travellin may participate in affiliate and referral programmes.

Affiliate technologies may be used to establish that a user:

1. arrived through a particular referral;
2. interacted with a supplier;
3. completed a qualifying transaction;
4. or otherwise generated an attributable booking.

Affiliate tracking may use:

• cookies;
• URL parameters;
• click identifiers;
• transaction identifiers;
• pixels;
• server-side attribution;
• or similar technologies.

The purpose is generally to establish commercial attribution and calculate commissions.

Affiliate tracking must not automatically be classified as “necessary” merely because it generates revenue for Travellin.

Where the relevant technology requires consent under applicable law, Travellin will seek consent before activation.

Additional information is contained in the Affiliate & Referral Disclosure.

10. ADVERTISING AND MARKETING COOKIES

Where implemented, advertising cookies may allow Travellin or authorised advertising partners to:

• measure advertising;
• limit repetitive advertising;
• understand advertising performance;
• create audience segments;
• deliver relevant advertising;
• or measure conversions.

Advertising cookies are generally not necessary for the basic operation of the Platform.

Accordingly, where consent is legally required, these technologies will not be activated until appropriate consent has been obtained.

11. PERSONALISATION COOKIES

Travellin may use functionality that remembers:

• destinations;
• searches;
• preferred language;
• currency;
• previous interactions;
• selected travel preferences;
• or similar settings.

Personalisation may improve the relevance and usability of the Platform.

Where the technology is not strictly necessary and consent is required, it will be subject to the user’s cookie preferences.

12. SECURITY COOKIES

Security technologies may be used to:

• identify suspicious activity;
• prevent automated abuse;
• protect accounts;
• detect fraudulent transactions;
• prevent session hijacking;
• protect checkout;
• and defend the Platform against attacks.

Where such technologies are genuinely necessary for security, they may fall within a relevant exemption.

Travellin will assess the specific technology and purpose rather than automatically treating all security-related technologies as exempt.

13. SESSION COOKIES

Session cookies generally remain active only during a browser session.

They may be used to maintain:

• login state;
• booking progress;
• search state;
• checkout state;
• temporary preferences;
• and other short-lived information.

They are generally deleted when the browser session ends, although technical implementation may vary.

14. PERSISTENT COOKIES

Persistent cookies remain on the device for a defined period or until manually deleted.

They may be used for:

• remembering preferences;
• recognising returning users;
• consent management;
• analytics;
• affiliate attribution;
• advertising;
• or other permitted purposes.

The duration should be appropriate to the specific purpose.

15. COOKIE LIFESPANS

Travellin may use cookies with different durations.

Examples include:

• session;
• several hours;
• several days;
• several weeks;
• several months;
• or longer where legally justified.

Travellin should not retain cookies for an unnecessarily long period.

The cookie inventory published through the live consent-management system should identify the actual duration of each deployed cookie wherever technically possible.

16. COOKIE CONSENT RECORDS

Where consent is required, Travellin may store information showing:

• that consent was given;
• the date and time;
• the categories accepted;
• the consent-management version;
• and, where appropriate, technical information necessary to demonstrate the consent state.

This information is used to:

• remember the user’s choice;
• prevent repeated consent prompts;
• honour withdrawal;
• and demonstrate compliance where necessary.

17. WITHDRAWING COOKIE CONSENT

Users may change or withdraw their optional cookie choices at any time.

Travellin should provide a persistent and easily accessible mechanism such as:

Cookie Settings

or

Manage Privacy Preferences

The mechanism should remain available after the initial consent decision.

Withdrawal must be as easy as giving consent. This is expressly reflected in EDPB guidance concerning consent. (European Data Protection Board)

18. WHAT HAPPENS AFTER WITHDRAWAL?

When a user withdraws consent for a category of optional cookies, Travellin will seek to:

• stop activating the relevant technology;
• prevent future placement where technically possible;
• stop relevant optional processing;
• and respect the user’s updated preference.

Withdrawal does not necessarily delete information that was lawfully collected before withdrawal.

Where applicable, deletion or further processing will be governed by the Travellin Privacy Policy and applicable law.

19. COOKIE BANNER — REQUIRED IMPLEMENTATION STANDARD

The Travellin cookie-management system should be configured so that:

Before consent

Optional:

• analytics;
• advertising;
• affiliate tracking;
• behavioural tracking;
• personalisation;

remain blocked where consent is legally required.

After acceptance

Only the categories actually accepted may activate.

After rejection

Optional categories remain blocked.

After withdrawal

The relevant optional categories are disabled.

On subsequent visits

The previously recorded choice is respected until:

• the user changes it;
• consent expires according to the configured policy;
• or a new consent request is legally/technically required.

20. NO PRE-TICKED OPTIONAL CONSENT

Travellin will not rely on pre-selected optional cookie categories as a substitute for affirmative consent where consent is required.

Consent must be:

• freely given;
• specific;
• informed;
• and unambiguous.

The European Commission describes these requirements for valid GDPR consent. (European Commission)

21. NO IMPLIED CONSENT

Travellin will not state:

“By continuing to use this website, you agree to cookies.”

Such wording should not be used as a substitute for affirmative consent where consent is legally required.

22. THIRD-PARTY COOKIES

Third-party services embedded in Travellin may potentially place their own cookies or use similar technologies.

Examples could include:

• analytics providers;
• payment services;
• maps;
• video providers;
• social-media providers;
• affiliate networks;
• advertising providers;
• fraud-prevention services;
• booking suppliers;
• and API-connected services.

The exact third-party technologies must be verified against the live website.

Travellin does not control every technology operated independently by third parties.

Users should review the relevant third party’s privacy and cookie information where appropriate.

23. PAYMENT SERVICES

Certain payment pages or payment components may be provided by third-party payment providers.

These providers may use cookies or similar technologies for:

• security;
• fraud prevention;
• authentication;
• payment processing;
• or technical operation.

The specific processing depends on the payment provider actually used by Travellin.

24. BOOKING SUPPLIERS

Travel suppliers and booking technology providers may use cookies or similar technologies when their systems are embedded, redirected, mirrored or otherwise integrated into Travellin.

The relevant supplier may operate under its own privacy and cookie policy.

Travellin will seek to ensure that the integration is technically configured in accordance with applicable consent requirements.

25. AFFILIATE NETWORKS

Affiliate networks may use tracking mechanisms to determine whether a qualifying transaction originated from Travellin.

Depending on the network, attribution may occur through:

• first-party cookies;
• third-party cookies;
• tracking pixels;
• URL parameters;
• click IDs;
• server-to-server tracking;
• or other attribution mechanisms.

The actual implementation must be documented in Travellin’s technical cookie inventory.

26. ANALYTICS PROVIDERS

If Travellin uses analytics providers, their technologies should be listed in the live cookie-management interface.

The list should identify, where available:

• provider;
• cookie name;
• purpose;
• duration;
• first/third-party status;
• category;
• and relevant privacy documentation.

Travellin should not publish a provider as an active cookie provider unless that provider is actually deployed.

27. ADVERTISING TECHNOLOGIES

If advertising technology is deployed, Travellin should identify:

• provider;
• purpose;
• cookies;
• identifiers;
• retention period;
• recipients;
• and applicable consent mechanism.

Advertising technology should remain blocked where consent is required until valid consent is obtained.

28. COOKIE INVENTORY

Travellin will maintain a technical cookie inventory.

The inventory should include at minimum:

The public-facing cookie settings should be synchronised with the actual production cookie inventory.

29. COOKIE SCANNING

Travellin should periodically scan the production website to identify:

• unknown cookies;
• newly introduced cookies;
• third-party scripts;
• pixels;
• trackers;
• local-storage mechanisms;
• tags;
• and other technologies.

This is particularly important because WordPress, Elementor, WooCommerce, payment systems, analytics services, affiliate networks and third-party APIs can introduce technologies without the legal page itself being manually updated.

30. WORDPRESS AND WEBSITE TECHNOLOGIES

Travellin’s technical architecture may involve WordPress and associated services.

Depending on the final production configuration, technologies may be introduced by:

• WordPress;
• WooCommerce;
• Elementor;
• hosting infrastructure;
• caching systems;
• security systems;
• consent-management systems;
• payment integrations;
• analytics;
• affiliate integrations;
• and custom Travellin software.

The actual production environment must be scanned rather than relying solely on documentation from software vendors.

31. CACHE AND PERFORMANCE TECHNOLOGIES

Travellin may use caching and performance technologies to improve:

• page speed;
• reliability;
• scalability;
• and technical performance.

Some caching mechanisms may store information locally or server-side.

Where a technology involves access to terminal equipment within the scope of applicable ePrivacy rules, its legal classification should be assessed according to its actual function.

32. COOKIE SECURITY

Where technically appropriate, cookies may be configured using security attributes such as:

• Secure;
• HttpOnly;
• SameSite;
• appropriate domain restrictions;
• appropriate path restrictions;
• and suitable expiration.

The precise configuration depends on the cookie’s purpose.

33. COOKIE SECURITY AND PAYMENT DATA

Travellin should not use ordinary cookies to store full payment-card numbers, CVV/CVC codes or other sensitive payment credentials.

Payment information should be handled through appropriately secured payment infrastructure.

34. COOKIE DATA AND PERSONAL DATA

A cookie itself may not always constitute personal data.

However, cookie identifiers can become personal data where they can be linked to an identifiable person.

Where cookie-related information constitutes personal data, the Travellin Privacy Policy also applies.

The GDPR therefore remains relevant to cookie processing where personal data is involved. The EDPB expressly notes the interaction between the GDPR and the more specific ePrivacy rules governing cookies. (European Data Protection Board)

35. INTERNATIONAL TRANSFERS

Some third-party cookie and tracking providers may process information outside the European Economic Area.

Where personal data is transferred internationally, Travellin will seek to use an appropriate lawful transfer mechanism where required.

Further information is provided in the Travellin Privacy Policy.

36. USER RIGHTS

Where applicable, users may have rights under GDPR including:

• access;
• rectification;
• erasure;
• restriction;
• portability;
• objection;
• and withdrawal of consent.

Requests concerning personal data may be sent to:

privacy@travellin.info

37. COOKIE-RELATED PRIVACY REQUESTS

If you believe Travellin has:

• incorrectly placed a cookie;
• failed to honour your preference;
• failed to process withdrawal correctly;
• or otherwise mishandled cookie-related information,

you may contact:

privacy@travellin.info

Travellin will investigate the issue and take appropriate action where necessary.

38. BROWSER CONTROLS

Most modern browsers allow users to:

• view cookies;
• delete cookies;
• block cookies;
• restrict third-party cookies;
• or receive warnings before cookies are placed.

However, disabling all cookies may affect functionality.

For example:

• account login may stop working;
• booking sessions may not be maintained;
• checkout may not function correctly;
• preferences may not be remembered;
• and certain website functionality may become unavailable.

Browser controls are therefore an additional mechanism and do not replace Travellin’s consent-management system.

39. DELETING EXISTING COOKIES

Users can generally delete existing cookies through browser settings.

Deleting cookies does not necessarily prevent them from being placed again during a future visit.

To prevent future optional cookies, the relevant Travellin cookie preferences should also be changed.

40. MOBILE DEVICES

Mobile browsers and applications may use:

• cookies;
• local storage;
• SDKs;
• advertising identifiers;
• device identifiers;
• or similar technologies.

The same privacy principles apply where relevant.

41. DO-NOT-TRACK SIGNALS

Browser “Do Not Track” signals are not necessarily technically or legally equivalent to a cookie-consent withdrawal.

Travellin will assess applicable technical signals according to the technologies and legal requirements applicable to its Platform.

42. COOKIE POLICY AND PRIVACY POLICY

This Cookie Policy should be read together with the Travellin Privacy Policy.

The Privacy Policy explains:

• what personal data Travellin processes;
• why it is processed;
• legal bases;
• recipients;
• international transfers;
• retention;
• and data-subject rights.

This Cookie Policy explains the specific use of cookies and similar technologies.

43. COOKIE POLICY AND AFFILIATE DISCLOSURE

Where affiliate tracking is used, this Cookie Policy should be read together with the Travellin Affiliate & Referral Disclosure.

Affiliate tracking may allow Travellin to receive a commission when a qualifying transaction occurs.

Such commercial attribution does not change the user’s right to control optional cookies where consent is required.

44. COOKIE POLICY AND TERMS & CONDITIONS

Acceptance of the Travellin Terms & Conditions does not automatically constitute consent to optional cookies where separate consent is required by applicable law.

Contractual acceptance and cookie consent are separate legal mechanisms.

45. CHANGES TO THIS COOKIE POLICY

Travellin may update this Cookie Policy where:

• new technologies are introduced;
• suppliers change;
• cookies change;
• laws change;
• regulatory guidance changes;
• analytics systems change;
• affiliate systems change;
• advertising technologies change;
• or the Platform architecture changes.

The “Last Updated” date will be amended accordingly.

46. ACTUAL COOKIE LIST — IMPORTANT

The following categories are approved as the legal structure of Travellin’s cookie inventory:

A. Strictly Necessary Cookies

For:

• authentication;
• sessions;
• security;
• booking;
• checkout;
• cart;
• consent management;
• fraud prevention;
• technical operation.

B. Preference Cookies

For:

• language;
• currency;
• region;
• interface preferences;
• search preferences.

C. Analytics Cookies

For:

• website analytics;
• performance measurement;
• conversion measurement;
• error analysis.

D. Affiliate / Referral Cookies

For:

• referral attribution;
• click attribution;
• qualifying transaction attribution;
• commission calculation.

E. Advertising Cookies

For:

• advertising;
• conversion measurement;
• audience measurement;
• remarketing where lawfully permitted.

F. Personalisation Cookies

For:

• recommendations;
• personalised content;
• remembered travel preferences.

47. PROHIBITION ON FALSE COOKIE DECLARATIONS

Travellin must not publish a fictional cookie list.

For example, Travellin must not state that it uses:

• Google Analytics;
• Meta Pixel;
• Travelpayouts cookies;
• Stripe cookies;
• Hotjar;
• Microsoft Clarity;
• Google Ads;
• TikTok Pixel;
• or any other third-party technology

unless that technology is actually deployed on the production environment.

Likewise, a provider must not be omitted merely because it was not intentionally added by the Travellin development team.

The live technical implementation controls the final cookie inventory.

48. REQUIRED PRODUCTION AUDIT

Before this Cookie Policy is published as the final production document, the Travellin development team must conduct a complete technical cookie audit.

The audit should inspect:

1. Homepage;
2. Search page;
3. Results page;
4. Single travel-product page;
5. Hotel pages;
6. Flight pages;
7. Activities;
8. Cruises;
9. Car rental;
10. Equipment rental;
11. Voucher pages;
12. Cart;
13. Checkout;
14. Account/login;
15. payment screens;
16. confirmation pages;
17. affiliate redirects;
18. supplier/API integrations;
19. embedded maps;
20. embedded media;
21. analytics;
22. advertising;
23. CRM;
24. WooCommerce;
25. Elementor;
26. security plugins/services;
27. caching/CDN;
28. consent-management system;
29. custom Travellin scripts;
30. server-side tracking.

The audit must identify every cookie and similar technology that is actually active.

49. CONSENT MANAGEMENT REQUIREMENT

The Travellin consent-management platform should technically enforce the legal choices made by the user.

It should not merely display a banner while optional scripts continue to load.

Where consent is required:

No consent = no optional technology activation.

This is particularly important for:

• analytics;
• advertising;
• behavioural tracking;
• affiliate cookies;
• retargeting;
• personalisation;
• and other non-essential technologies.

50. COOKIE CONSENT LOG

The consent-management system should maintain a reliable record of:

• consent state;
• categories selected;
• timestamp;
• consent version;
• and relevant technical identifier.

This enables Travellin to demonstrate that consent was obtained where required.

51. CONSENT WITHDRAWAL TEST

The production system must be tested to verify that:

Accept → optional technologies activate where permitted.

Reject → optional technologies remain blocked.

Change preferences → only selected categories activate.

Withdraw → previously enabled optional technologies are disabled as technically possible.

Return later → the system respects the updated preference.

52. NO DARK PATTERNS

Travellin must not design its cookie interface to manipulate users into accepting optional technologies.

In particular, the interface should not:

• hide rejection;
• make rejection substantially harder;
• use misleading colours or wording;
• pre-select optional categories;
• falsely claim cookies are necessary;
• or imply that browsing constitutes consent.

The European Commission specifically identifies such deceptive cookie interfaces as problematic under EU rules. (European Commission)

53. SUPERVISORY AUTHORITY

For Travellin’s Czech establishment, the relevant national data-protection supervisory authority is:

Úřad pro ochranu osobních údajů
Office for Personal Data Protection
Czech Republic

Depending on the circumstances, an individual may also have rights to complain to another competent supervisory authority under GDPR.

54. CONTACT

For all cookie and privacy enquiries:

BETZONE s.r.o. — Travellin
Privacy: privacy@travellin.info
General: info@travellin.info
Bookings: bookings@travellin.info
Telephone: +420 732 844 855
Registered office: Maletín 9, 789 01 Maletín, Czech Republic
IČO: 28802471
DIČ: CZ28802471

55. FINAL LEGAL AND TECHNICAL REQUIREMENT

This Cookie Policy is intended to serve as the master legal Cookie Policy for Travellin, but the final public cookie table must be generated from the actual production environment.

The legal document and the technical implementation must remain synchronized.

If a new analytics platform, affiliate network, payment provider, advertising pixel, booking API, WordPress plugin, Elementor component, CRM integration or custom tracking mechanism is introduced, the cookie inventory and, where necessary, this Cookie Policy and consent configuration must be reviewed.

The governing principle is:

Travellin must never use the Cookie Policy to describe what the website is supposed to do; it must accurately describe what the production website actually does.

That distinction is especially important because EU rules can apply to technologies beyond traditional cookies, and the EDPB’s current guidance expressly takes a technology-neutral approach. (European Data Protection Board)

Travellin therefore commits to maintaining an auditable relationship between the live technical cookie inventory, the consent-management platform, the Privacy Policy and this Cookie Policy.