Privacy Policy

1. Controller

The controller responsible for the processing of personal data on this website is:

You can use these contact details for privacy-related enquiries. Where a partner or travel provider independently determines the purposes and means of processing for a specific offer or service, that organisation acts as an independent controller for that processing. Its own privacy information will apply in addition.

2. Scope and role of the portal

This Privacy Policy applies to early-booker.com and to the search, comparison, contact, support and booking-management functions made available through the portal. Bigmedia24 Dynamics Ltd. provides the technology and portal infrastructure and is neither a tour operator nor an online travel agency.

Hotels, flights, car hire, activities and other travel services may be offered by independent partners or affiliate partners. If you are redirected to a partner or complete a booking through that partner, the partner may process your data under its own privacy policy.

3. Data we may process

4. Purposes and legal bases

We process personal data only for specified purposes and where an appropriate legal basis applies.

You may withdraw consent at any time with effect for the future. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. We process special categories of personal data only where an additional condition under Article 9 GDPR is satisfied.

5. Website operation and server log data

When you access the website, your browser transmits technical information that is necessary to deliver the website to our server or hosting provider. This may include your IP address, date and time, requested resource, amount of data transferred, browser, operating system and referrer.

This information may be processed to deliver the website, maintain stability and security, identify technical errors and defend against attacks. The legal basis is generally our legitimate interest in operating a secure and functional portal under Article 6(1)(f) GDPR.

6. Contact, chat and support

If you contact us by email, telephone, form or chat, we process the information you provide in order to assess, route and respond to your enquiry. Depending on the nature of the request, the legal basis may be Article 6(1)(b) GDPR or our legitimate interest in providing organised support communication under Article 6(1)(f) GDPR.

If a travel provider is responsible for your enquiry, we will only pass information to that provider where this is necessary to handle the request and legally permitted, or where you have instructed us to do so. For sensitive requests, we may ask for additional information to verify your identity.

7. Booking management, verification, cancellation and refunds

If you use functions to manage or review an existing booking, we may process the booking reference, booking email address, one-time verification codes, timestamps and the process information required for the relevant request. Verification helps protect booking information from unauthorised access.

Access to a booking-management function does not automatically cancel a booking or create a refund. Whether cancellation or a refund is available depends on the selected rate, the responsible provider and the applicable contractual conditions.

8. Partners, affiliate links and external integrations

The portal may display, embed or link to offers from external travel and technology partners. Where necessary for search, availability, price checks, referrals, attribution or booking processing, technically required information may be transmitted to the relevant partner.

With affiliate links, a partner may be able to recognise that you arrived from early-booker.com. Attribution parameters or cookies may be used to determine whether an agreed referral fee or commission is payable. Storage on your device that is not technically necessary is used only in accordance with your consent where consent is required.

External widgets may load content directly from third-party providers. This can create a connection to the provider’s servers when the content loads. Where consent is required, the integration is activated only after your selection. Please also review the privacy information of the relevant provider.

9. Cookies and similar technologies

Cookies are small pieces of information that are stored on or read from your device. Technically necessary technologies may be used where required for a function you have expressly requested. These may include security, session, language or consent settings.

Analytics, convenience or marketing technologies that are not strictly necessary are activated only after valid consent where required. You can change your selection for the future through the cookie settings provided on the website. Rejecting non-essential technologies should be as easy as accepting them.

The specific names, providers, purposes and storage periods of the cookies and technologies actually used should be kept up to date in the cookie settings or supplementary cookie information.

10. Recipients and transfers to third countries

Personal data is made available only to recipients that need it for the relevant purpose. These may include hosting and infrastructure providers, IT and security providers, communications and support services, consent-management services, technical API partners, and travel or affiliate partners.

Where a service provider processes data on our behalf, appropriate data protection obligations apply. Partners acting as independent controllers process personal data under their own privacy information.

Where personal data is transferred outside the European Economic Area, we consider the requirements of Articles 44 et seq. GDPR. Depending on the destination country, the transfer may be based on an adequacy decision, appropriate safeguards such as the EU Standard Contractual Clauses, or a statutory derogation. You can request information about applicable safeguards using the contact details above.

11. Retention periods and data security

We retain personal data only for as long as it is necessary for the relevant purpose. It is then deleted or anonymised unless statutory retention requirements, the establishment or defence of legal claims, or another legitimate reason requires longer storage.

• Technical log data is generally retained only for the period required for security and operational purposes.
• Contact and support data is retained for as long as necessary to handle, follow up and document the enquiry appropriately.
• Retention of booking-related data depends on the relevant process, legal obligations and the responsibilities of the relevant provider.
• Records of consent may be retained for as long as necessary to demonstrate compliant consent management.

We use appropriate technical and organisational measures to protect personal data against loss, manipulation, unauthorised access and unlawful disclosure. These measures may include access restrictions, secure transmission, authorisation controls, logging, and measures designed to maintain confidentiality, integrity and availability.

12. Your data protection rights

Subject to the applicable legal requirements, you may have the following rights:

• Access to information about the processing of your personal data (Article 15 GDPR),
• Rectification of inaccurate data or completion of incomplete data (Article 16 GDPR),
• Erasure of your personal data (Article 17 GDPR),
• Restriction of processing (Article 18 GDPR),
• Data portability where the statutory requirements are met (Article 20 GDPR),
• Objection to processing based on Article 6(1)(e) or (f) GDPR (Article 21 GDPR),
• Withdrawal of consent with effect for the future (Article 7(3) GDPR),
• Protection against decisions based solely on automated processing that produce legal or similarly significant effects, in accordance with Article 22 GDPR.

To exercise your rights, contact support@bigmedia24.com. We may request information necessary to verify your identity securely. Data-subject requests are handled without undue delay and within the applicable statutory time limits.

13. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority. For the controller established in Ireland, the Irish Data Protection Commission is particularly relevant:

You may also contact the supervisory authority for your habitual residence, place of work or the place of the alleged infringement. The Irish Data Protection Commission recommends that concerns are first raised in writing with the relevant controller where appropriate.

14. Changes and privacy contact

We may update this Privacy Policy if the legal framework, technologies used, partners, portal functions or processing activities change. The version published on this page is the current version.