Wanderly.
Data Protection & Discretion

Privacy Policy & Client Dossier Protection

How Wanderly safeguards high-net-worth traveler personal identifiable information (PII), flight manifests, and confidential communications.

Effective Date: October 12, 2026·Version: v3.4 (Institutional)· Fiduciary & Regulatory Verified

Executive Fiduciary Summary

Wanderly operates under an uncompromising principle of discretion. We adhere to the General Data Protection Regulation (EU GDPR), the UK Data Protection Act 2018, and the California Consumer Privacy Act (CCPA/CPRA). We never sell or broker guest telemetry, and all transactional emails are dispatched via encrypted Zoho ZeptoMail pipelines.

1. Global Regulatory Compliance (GDPR, UK DPA & CCPA)

Wanderly Private Journeys Ltd. ("Wanderly", "we", or "the Operator") acts as a Data Controller in respect of personal data collected through wanderly.com, our concierge consultation desks, and our private aviation/expedition manifests.

We comply comprehensively with:

  • Regulation (EU) 2016/679 (EU GDPR): Governing lawful processing, data minimization, and international cross-border transfers.
  • UK Data Protection Act 2018 (UK GDPR): As registered with the Information Commissioner's Office (ICO).
  • California Consumer Privacy Act (CCPA / CPRA): Cal. Civ. Code § 1798.100 et seq., including mandatory opt-out protections and non-discrimination guarantees.

2. Form Data Processing & Zoho ZeptoMail Routing

When you submit a 4-Step Consultation Dossier via our platform (including full legal name, private email, telephone/WhatsApp, target destination, and budget tier), your request is processed under strict end-to-end transport layer security (TLS 1.3).

Transactional Architecture

Confirmation and dispatch telemetry is executed via Zoho ZeptoMail Dedicated Transactional SMTP Gateway (smtp.zeptomail.in:587). Data in transit is secured with high-grade TLS encryption and authenticated relay credentials.

Inquiries are routed directly to our designated operations concierge desk and never exposed to public repositories, ad networks, or third-party CRM aggregators.

3. Open-Tracking Pixel Transparency

To verify that your confidential journey proposal reaches your primary inbox and is not suppressed by spam gateways, confirmation emails contain a server-side 1x1 transparent GIF open-tracking pixel:

<img src="https://wanderly.com/api/public/track?ref=WLY-XXXXXX" width="1" height="1" style="display:none" />

This tracking mechanism logs only the timestamp and anonymous reference code (ref). It does not write persistent third-party cookies, record device fingerprinting, or leak traveler data to advertising exchanges.

4. Data Subject Rights & Data Erasure Protocols

Under Chapter III of the GDPR and § 1798.105 of the CCPA, you retain sovereign rights over your digital dossier:

  • Right of Access & Portability: You may request an exported machine-readable copy of your itinerary dossiers and communications.
  • Right to Rectification: Immediate correction of flight manifests, passport details, or dietary records.
  • Right to Erasure ("Right to be Forgotten"): Complete purge of your contact data from our active concierge systems upon request, subject only to statutory tax retention laws.

To exercise any of these rights, contact our Data Protection Officer directly at privacy@wanderly.com. All requests are satisfied within 72 business hours free of charge.

5. Absolute Zero Third-Party Sale Guarantee

We Do Not Sell or Monetize Your Personal Data.

Wanderly has never sold, rented, monetized, or shared guest PII with commercial data brokers, ad networks, or marketing consortia. Information is shared strictly on a need-to-know basis with licensed ground operators (e.g. FBO private terminal agents, luxury villa concierges) solely to execute your confirmed itinerary.

Statutory Declarations

Technical & Statutory Clauses

Click each section below to review the explicit regulatory articles and statutory language.

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