Privacy Policy & Personal Data Protection

Smart Galapagos is a travel company offering personalized travel experiences, including Galápagos Island Hopping, Galápagos cruises, and tailor-made travel arrangements.

For the purposes of applicable data protection legislation, the responsible entity is the organization that determines why and how personal information is processed.

For questions about this policy or requests concerning your personal information, please contact us using the details above.

This Privacy Policy explains how Smart Galapagos collects, uses, stores, and shares personal information through its website, inquiry forms, travel-planning communications, and advertising lead forms on third-party platforms, including Facebook and Instagram.

It applies to information provided directly by visitors and prospective customers, as well as information collected through our digital services where applicable.

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

• Full name.
• Email address.
• Telephone number, when voluntarily provided.

• Intended travel dates or approximate travel period.
• Number of travelers.
• Approximate travel budget.
• Destination, itinerary, accommodation, activity, or other travel preferences you share with us.
• Information contained in messages and inquiries.

Some third-party platforms may prefill contact information from a user's account. You should review the information displayed in a form before submitting it.

We ask that you do not submit payment-card information, passport details, or other sensitive information through our advertising lead forms.

We may process personal information for the following purposes:

• To respond to inquiries and requests for information.
• To understand your travel plans and recommend suitable travel options.
• To prepare personalized itineraries, quotations, and proposals.
• To communicate with you about an inquiry or potential booking.
• To coordinate travel services when you decide to proceed with a reservation.
• To manage our customer relationships and maintain business records.
• To operate, protect, and improve our website and digital services.
• To measure the performance of our advertising and marketing activities, where applicable.
• To comply with legal obligations and establish, exercise, or defend legal claims when necessary.

We will not use your information for unrelated purposes without an appropriate legal basis and any additional notice or consent required by applicable law.

Depending on the circumstances and applicable law, the processing of personal information may be based on:

• Your request for information or steps taken at your request before entering into a contract.
• The performance of a contract or the preparation of a requested travel arrangement.
• Your consent, where consent is required.
• Compliance with applicable legal obligations.
• Another lawful basis available under applicable data protection legislation.

Where processing is based on consent, you may withdraw that consent, subject to applicable law. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

The appropriate legal basis will be determined according to the specific purpose and processing activity.

We may share relevant personal information with the following categories of recipients when necessary for the purposes described in this policy:

We do not sell personal information as a standalone product. We share personal information with service providers and other recipients only as described in this policy or as otherwise permitted or required by applicable law.

Smart Galapagos uses service providers that may process personal information outside Ecuador, depending on their infrastructure, the services used, and their applicable terms.

For example, information processed through HubSpot may be transferred to or processed in the United States and other jurisdictions where HubSpot, its affiliates, or its subprocessors operate. Google may also process information on servers located outside the country in which a visitor resides. Booking-related information processed through WeTravel and information handled by other technology or service providers may also be subject to international processing.

Where personal information is transferred internationally, Smart Galapagos will apply the safeguards and comply with the requirements applicable to the relevant transfer under the data protection laws that apply to our processing activities.

Smart Galapagos retains personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including responding to inquiries, preparing quotations, managing bookings, providing travel services, complying with legal obligations, and resolving disputes.

Retention periods vary depending on the type of information and the purpose for which it is processed:

• Unconverted leads: Personal information relating to inquiries that do not result in a booking may generally be retained for up to 12 months after the last meaningful interaction, unless an ongoing inquiry, applicable legal obligation, or other valid reason justifies a different retention period.
• Active inquiries: Information may be retained for as long as necessary to respond to the inquiry and support the requested travel-planning process.
• Customers and booking records: Information may be retained for the duration of the customer relationship and for any additional period required by applicable accounting, tax, contractual, legal, or claims-related obligations.
• Marketing contacts: Information used for marketing communications will be retained only while there is an appropriate legal basis and a continuing purpose for that processing. Applicable unsubscribe requests and objections will be respected.
• Website analytics data: Analytics information will be retained according to the applicable configuration, the purposes for which it is collected, and relevant legal requirements. Where appropriate, information may be aggregated or anonymized.

When personal information is no longer necessary for its intended purpose and no valid legal or other justification supports further retention, Smart Galapagos will securely delete or irreversibly anonymize it in accordance with applicable law.

These retention practices are reviewed periodically to ensure that personal information is not kept longer than necessary.

We take appropriate technical, organizational, and administrative measures designed to protect personal information against unauthorized access, loss, alteration, disclosure, or misuse.

Access to personal information should be limited to authorized personnel and service providers who need it for legitimate business purposes.

No method of transmission or electronic storage can be guaranteed to be completely secure. We will manage personal information in accordance with applicable security and data protection requirements.

Subject to the conditions and limitations established by applicable law, you may have the right to:

• Request access to your personal information.
• Request correction or updating of inaccurate or incomplete information.
• Request deletion of personal information.
• Object to certain processing activities.
• Request restriction or suspension of processing where applicable.
• Request portability of your personal information where legally available.
• Withdraw consent where processing is based on consent.
• Challenge decisions based solely on automated processing where the law provides that right.
• Lodge a complaint with the competent data protection authority.

We may need to verify your identity before completing certain requests. We will respond within the applicable legal deadlines.

If you believe your data protection rights have been violated, you may also contact the competent supervisory authority, including Ecuador's Superintendencia de Protección de Datos Personales where applicable.

We may contact you to respond to an inquiry or provide travel information you have requested.

Receiving a quotation or submitting an inquiry does not automatically mean that you have subscribed to unrelated promotional communications.

Where required by law, we will obtain the appropriate consent before sending marketing communications. You may opt out of marketing messages at any time using the instructions provided in the message or by contacting us.

Our website uses Google Analytics 4 to understand how visitors interact with our website, measure traffic, and improve our digital services.

These technologies may collect technical and usage information, including browser and device information, pages visited, and interactions with the website.

Where required by applicable law, non-essential analytics cookies and similar technologies will be used only after the visitor has been provided with the required information and has given valid consent. Visitors must be able to manage their cookie preferences through the website's available consent controls.

Our website’s cookie and analytics configuration will be maintained and reviewed to ensure that the technologies in use, their purposes, and the applicable consent choices are accurately explained.

Our advertising inquiry forms are intended for adults planning travel.

Where a trip involves children, a parent or authorized guardian should provide any necessary information about accompanying minors. We do not knowingly seek unnecessary personal information directly from children through advertising lead forms.

Any processing of children's personal information will be handled in accordance with applicable law.

Smart Galapagos does not currently use automated decision-making to evaluate individual travel inquiries or recommend travel arrangements without human review.

Our team reviews the information you provide, including your travel dates, group size, budget, and preferences, and uses professional judgment to recommend travel options that may suit your needs.

Third-party platforms, including advertising platforms, may independently use automated systems to select or deliver advertisements in accordance with their own terms and privacy policies. Such platform activities are separate from Smart Galapagos' human review of travel inquiries and preparation of recommendations.

Our website and communications may contain links to third-party services, including social media platforms and travel-service providers.

Those third parties may process personal information under their own privacy policies and terms. Smart Galapagos does not control the privacy practices of independent third-party services.

We encourage you to review their policies when using their services.

We may update this Privacy Policy when our business practices, service providers, technology, or legal obligations change.

The latest version will be published on this page with its updated date. Where required by law, we will provide additional notice or obtain consent for changes affecting how personal information is processed.

For questions about this Privacy Policy, the processing of your personal information, or requests to exercise your privacy rights, please contact: