Data Processing Addendum

This page describes the data-processing framework for Gondola Inc. and its tour and activity operator customers. If you are visiting an operator's website, read our Privacy Policy and that operator's privacy notice.

Part of your existing service agreement

This Data Processing Addendum (DPA), revision October 11, 2026, supplements the Gondola Terms of Service or other service agreement that governs your account (the Agreement). It covers personal information Gondola processes on your instructions to provide your selected services. It does not require a separate signature or acceptance screen where your Agreement and applicable law permit incorporation through a terms update.

For an existing customer, Gondola will provide direct written notice identifying this DPA version, the changes, the processing schedules, and a prospective effective date. This DPA applies only when validly incorporated using the amendment mechanism in that customer's Agreement and applicable law, after any required notice period and any required approval. Continued service use after the notified date counts only where that mechanism permits it. Posting this page alone does not amend an existing customer's Agreement. For a new customer, the DPA forms part of the Agreement when that Agreement incorporating it takes effect.

A customer-specific agreement or offer that restricts changes, including a promise that changes do not apply to existing customers, remains controlling as to whether and how this DPA can be adopted. This update does not change agreed prices, price locks, program inclusions, renewal terms, or other commercial promises. Any separately agreed processing terms remain in place unless validly amended. A visitor to an operator's website does not become a party to this DPA by viewing a page or footer link.

The revision date identifies the text, not an automatic or retroactive effective date. Gondola will retain the applicable version and the notice and adoption record for each account. You can request the version, effective date, and schedules applicable to your account from support@gondola.travel. This update does not authorize new collection, new marketing purposes, or retroactive model training on previously collected personal information.

Standard terms and express modifications

The Common Paper DPA Standard Terms Version 1.1 are incorporated by reference with the following express modifications. The versioned source remains unchanged; these modifications are part of Gondola's DPA.

Adoption and Cover Page: the separate Cover Page signature or electronic-acceptance requirement in “Using this DPA,” Section 10.1, and the Section 11 definition of “Cover Page” is replaced by the adoption mechanism above. “Cover Page” means this addendum together with the customer identity and Agreement identified in the applicable account or order records and the processing schedules supplied as part of its adoption. Those records identify the contracting parties; they do not, by themselves, establish acceptance. Section 10.1 starts the DPA when it validly becomes part of the Agreement. Its duration and surviving data-protection obligations otherwise remain unchanged.
Security reports: Section 5.2 applies only to audit standards and reports expressly identified in the applicable Security Policy. No independent audit, report, or certification is represented unless expressly identified there. Sections 5.1 and 5.3 remain unchanged.
Precedence: applicable EEA standard contractual clauses or the UK Addendum take precedence. Subject to them, these express modifications and the applicable processing schedules control over the Common Paper Standard Terms. The resulting DPA controls over conflicting Agreement provisions only for the processing it covers. This precedence does not override the adoption restrictions or preserved commercial promises described above.

Processing covered by the customer schedule

The following schedule covers only the services selected by the customer and documented instructions under the Agreement. Account-specific processing details supplied with the DPA form part of that schedule; listing a possible service does not enable it or authorize a new use.

Service and purpose: hosting and operating customer websites, delivering enquiries and booking integrations, measuring visits, producing analytics and booking-attribution reports, providing instructed retargeting and customer communications for that customer, and supporting and securing those services. One customer's records are not used for campaigns for Gondola or other customers.
People: website visitors, people making enquiries or bookings, activity participants whose information is supplied through integrations, and customer personnel using the service.
Data: names and contact information; enquiry content; booking references, products, dates, amounts, and status; page paths, referrers, campaign parameters, timestamps, interactions, IP and device information, approximate location, and visit or session identifiers. Where enabled, interaction analysis includes heatmaps and session replay.
Operations: collection and receipt, storage and organization, analysis and matching of visits to enquiries or bookings, reporting to authorized customer users, transmission through instructed integrations, support, and return or deletion.
Frequency and duration: processing occurs as visitors use the website and integrations send records. Processing continues for the service period and any limited return, deletion, or legally required retention period under the Agreement, the applicable retention schedule, and Section 7 of the Standard Terms. The account-specific schedule identifies retention and deletion periods, including backups and any saved replay records.

Where the customer determines why and how personal information is processed, it is the controller and Gondola is the processor. Where the customer is itself a processor, Gondola may act as its subprocessor. Processing for Gondola's separate business purposes is described in our Privacy Policy and must not be treated as processing on the customer's instructions.

Account details and applicable safeguards

Gondola Inc., 103 Fern Bluff Way, Cary, NC 27518, United States, is the provider. The customer is the contracting entity in the applicable account or order records, with its recorded contact details. Gondola’s privacy and security contact is support@gondola.travel. The processing schedules supplied as part of adoption identify the Agreement, selected services, approved subprocessors and their countries and tasks, verified technical and organizational security measures, retention and deletion details, and any special-category data and safeguards. These details must be completed and supplied before this DPA takes effect; missing required information is not treated as “none” or “not applicable” under the Standard Terms.

The Standard Terms address processing instructions, subprocessor approvals and changes, security incidents, assistance with privacy requests, audits, international transfers, and return or deletion. A reference to those terms does not constitute a claim that Gondola holds a particular security certification.

EU, UK, Swiss, and other jurisdiction-specific provisions apply where the relevant law and transfer conditions apply to the processing. A customer’s billing address alone does not determine that applicability. Where required, the applicable transfer annexes, governing-state selections, and safeguards must be completed before the relevant transfer. To request your processing schedules or discuss an agreement that requires a different amendment process, contact support@gondola.travel.

Source and license

The DPA framework uses the Common Paper Data Processing Agreement, available under Creative Commons Attribution 4.0 International (CC BY 4.0). The versioned Standard Terms are incorporated subject to the express modifications above. Gondola's adoption provisions and processing schedule are additions; Common Paper does not endorse Gondola.