Privacy Policy

1. Who we are

Project Exceptional is operated by Steffen Kluth, a sole trader established in Ireland.

Steffen Kluth is the data controller for the personal data described in this Privacy Policy.

Privacy enquiries can currently be sent through the contact or help channel available on Project Exceptional. A dedicated privacy email address will be added when our permanent domain is activated.

2. Information we process

We aim to collect as little personal data as reasonably necessary to operate and improve Project Exceptional.

Information you provide

When you use interactive features, contact us or use the Help Assistant, you may provide information such as your question, travel preferences, intended dates, origin, selected place or stay, and other information you choose to submit.

Information stored on your device

Project Exceptional uses browser storage to remember certain choices and make the service work, including consent preferences, Explore selections, Trip Stack selections and a temporary session reference.

Technical and usage information

Our hosting and infrastructure providers may process technical information required to deliver and secure the website, such as IP addresses, request information, timestamps and security or network logs.

If you consent to Analytics, we also use Plausible Analytics to understand how Project Exceptional is used.

3. Why we process information

We process information in order to:

• provide and operate Project Exceptional;
• remember selections and build your Explore, Plan and Trip Stack experience;
• respond to questions and requests for help;
• maintain the security and reliability of the service;
• understand and improve the service where you have consented to analytics;
• measure affiliate referrals or conversions where you have consented to affiliate and conversion tracking; and
• comply with applicable legal obligations.

4. Legal bases

Depending on the processing activity, we rely on one or more of the following legal bases under applicable data protection law:

• Consent — for optional analytics and affiliate or conversion tracking where consent is required.
• Legitimate interests — where necessary to operate, secure, maintain and improve the service, provided those interests are not overridden by your rights and interests.
• Steps taken at your request — where processing is necessary to provide a feature or respond to a request you make.
• Legal obligations — where we are required to retain or process information by law.

5. Cookies, browser storage and tracking

We distinguish between technologies needed for the service to function and optional technologies used for analytics or affiliate measurement.

Necessary

Necessary browser storage may be used to remember your privacy preferences and selections you make while using Project Exceptional. These functions are used to provide features you request and to maintain the operation of the service.

Analytics

If you choose to allow Analytics, Project Exceptional loads Plausible Analytics and uses it to understand website usage and product interactions. Plausible is not loaded by Project Exceptional before Analytics consent is given.

Affiliate and conversion tracking

Project Exceptional may earn a commission when you follow a partner link and complete a transaction with that partner. Where affiliate or conversion measurement requires optional tracking technologies, we only enable that tracking after you have given the relevant consent.

You can accept, reject or manage optional tracking separately. You can change your choice at any time using the Privacy settings control on the website.

6. Partners and service providers

We use service providers where necessary to operate Project Exceptional. Depending on the feature you use and your consent choices, these may include:

• Cloudflare — website delivery, infrastructure, networking and security;
• Supabase — database and application infrastructure;
• Plausible Analytics — optional website and product analytics;
• OpenAI — processing Help Assistant requests when the AI-powered Help feature is available and you choose to submit a request; and
• affiliate and travel partners — when you choose to follow a partner link to an external booking or service provider.

External partners operate their own websites and services. When you leave Project Exceptional and use a partner service, that partner's own privacy terms apply to its processing of your information.

7. Help Assistant

If you choose to use the Help Assistant, the question you submit and relevant context from your current Project Exceptional selections may be sent to our AI service provider in order to generate a response.

This information is not sent merely because you visit the website. It is sent when you choose to submit a Help request. Please do not include sensitive personal information in your question.

8. International data transfers

Some service providers or partners may process information outside Ireland or the European Economic Area. Where applicable, we require an appropriate lawful transfer mechanism or rely on another transfer mechanism permitted by data protection law.

9. How long we keep information

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including where needed to operate the service, respond to requests, meet legal obligations or establish, exercise or defend legal claims.

Information stored locally in your browser may remain there until it expires, is replaced, you change your preferences, or you clear your browser storage.

10. Your rights

Subject to applicable law, you may have rights including the right to:

• access personal data we hold about you;
• ask us to correct inaccurate personal data;
• ask us to erase personal data;
• ask us to restrict certain processing;
• object to certain processing;
• receive certain data in a portable format; and
• withdraw consent at any time where processing is based on consent.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

11. Complaints

If you have a concern about how we process your personal data, please contact us first so that we can try to resolve it.

You also have the right to lodge a complaint with the Irish Data Protection Commission or another competent supervisory authority.

12. Automated decisions

Project Exceptional may use your selected preferences to filter or match places and options. We do not currently use solely automated decision-making that produces legal effects or similarly significant effects concerning you.

13. Changes to this policy

We may update this Privacy Policy as Project Exceptional develops, including when we add new partners, features or processing activities. The date at the top of this page shows when the policy was last updated.