Privacy Policy

Who is responsible for your data

Altamar is the trading name of its operating company, whose registered details are published here before bookings open. We decide how your personal data is used, so we are its controller. You can reach us about privacy at concierge@example.com.

What we collect

• Your conversations with Livia, and what you tell us about your trip: dates, destinations, guests, tastes, occasions, dietary and medical needs.
• Your account: your email address, your name and what Livia remembers from one conversation to the next, which is who travels with you, your tastes and must-haves, what you have loved before, your budget, how you like to be reached and the journeys you have discussed.
• Contact and booking details: name, email, phone, date of birth, nationality, country of residence and guests' names.
• Identity documents: a photograph of your passport, and the details read from it.
• Payment and compliance details: who is paying, where funds come from, payment records, and the results of sanctions, identity and media checks. Card numbers are entered on the Bank of Georgia's payment page and do not reach us.
• Your declaration of funds, if you give one, at member onboarding or with a booking: your occupation, where your wealth comes from and roughly how much it is, who will pay and from which bank, what you expect to spend with us in a year, and whether you, your family or a close associate hold a prominent public role. At member onboarding, also your date of birth, your partner's name and the number of your children under eighteen.
• Technical details: your IP address, which we use to limit abuse, server logs, and the signals from your browser used to check that you are a person.

If you give us details of other people, please tell them, and make sure you have their permission.

Why we use it, and our legal basis

• To research, propose and arrange your travel, and look after you during it: to perform our contract with you, or to take steps at your request before one.
• To check that you are a person before you talk to Livia: in our legitimate interest in keeping automated visitors out.
• To sign you in and let Livia remember how you like to travel: to perform our contract with you, and in our legitimate interest in a secure, personal service.
• To verify identity, screen against sanctions lists and prevent fraud and money laundering: to meet legal obligations, and in our legitimate interest in lawful, safe operations.
• To take payment, keep accounts and meet tax rules: to perform our contract and meet legal obligations.
• To keep the site secure and improve our service: in our legitimate interest.
• To handle health or dietary information you give us: with your explicit consent, which you can withdraw, although we may then be unable to arrange some services.
• To send you marketing: only with your consent.

AI and automated checks

Livia is an AI system built on models provided by Anthropic. Your messages are processed by those models to reply to you and to research options. A separate model reads your passport photograph so that the details can be checked by our software, and another searches public web sources for adverse media or political exposure connected with the names in a booking.

These tools flag matters for review. They do not make the final decision: if a check needs attention, a person reviews it and makes the decision, and records the reason. You can ask for a person to review any outcome that affects you.

Your concierge also uses an AI assistant, built on the same models, to find and summarise conversations and bookings. It reads them for your concierge; it cannot change them or contact you.

If you apply for membership, we keep what you tell us in your application and your member onboarding, check your name, your partner's and any payer's against the sanctions lists as we do for bookings, and keep the record of your membership and its payments for as long as the law requires.

Your declaration of funds is read by your concierge only. Our software compares each booking with it, to decide whether that booking needs a question of its own; it decides nothing about you. The assistant your concierge uses can say whether your onboarding is complete, but is not given what it says about your money.

Who sees your data

Your concierge, and the following only as far as each needs it:

• suppliers, such as hotels, yacht and aircraft operators, cruise lines and restaurants, who need guest details to provide their service and meet their own legal duties;
• Anthropic, which provides the AI models;
• JSC Bank of Georgia, and any other bank or payment provider that handles your payment;
• Cloudflare, whose Turnstile service checks that you are a person, and sees your IP address and technical details of your browser;
• Google, if you choose to sign in with Google, which tells us your name and email address;
• Resend, which delivers the sign-in codes we email to you;
• our hosting, database, email and messaging providers, including Telegram, through which your concierge is told of new requests and can ask the assistant about them (with fewer personal details than in our own systems);
• professional advisers, and regulators, courts, banks and law enforcement where the law requires it or to protect our legal rights.

We do not sell your personal data, and we do not share it for advertising.

International transfers

Travel is international, so your data may go to suppliers and providers outside your country, including in countries whose laws protect data less strongly. Where the law requires it, we use recognised safeguards such as standard contractual clauses, or rely on the need to perform the contract you asked for.

How long we keep it

Sign-in codes expire after ten minutes. Enquiries that do not lead to a booking are kept for up to two years, and what Livia remembers is kept with your account until you ask for it to be forgotten. Reservation, identity, payment and compliance records, including passport images and every declaration of funds you have given us, are kept for five years after our relationship ends, or longer if the law requires, and are then deleted.

How we protect it

Passport images are encrypted before they are stored, and only your concierge can view them. Access to the back office is restricted, and connections to the site are encrypted. No system is perfectly secure, but we will tell you and the relevant authority of any breach where the law requires it.

Your rights

Depending on where you live, you may ask us to give you a copy of your data, correct it, delete it, restrict or object to how we use it, or transfer it. You may withdraw consent at any time, and ask for a person to review an automated outcome. Some data must be kept for legal reasons, and we will say so if that applies.

You can see what Livia remembers on your account page, and ask for it to be forgotten there. Livia then starts afresh. Records of past conversations and bookings are kept as this policy describes, unless you ask us to delete them and the law allows it.

Write to concierge@example.com to use these rights. We will reply within the time the law sets. You may also complain to Georgia's Personal Data Protection Service or to the data protection authority where you live.

Cookies and browser storage

We do not use advertising or analytics cookies. We use up to three strictly necessary cookies: one records that you have passed the check and links your conversation to this browser for up to 30 days, one keeps you signed in for up to 60 days or until you sign out, and one protects Google sign-in for ten minutes. The site also keeps a reference to your conversation in your browser's session storage, so that a reload does not lose your place, and it is cleared when you close the tab. Our fonts are served from our own site, so that loading a page does not tell a third party you are here.

Children

The site is for adults. We hold children's details only when an adult gives them to arrange travel for the child.

Changes

We will update this policy when our practices change. The date at the end of this page shows the latest version, and we will tell you directly about any significant change that affects a booking you have made.