RULES
online brokerage services operated on online platforms
1 INTRODUCTORY PROVISIONS
- STUDENT AGENCY TRAVEL k.s., ID:08120803, with registered office at náměstí Svobody 86/17, Brno, 602 00 Brno. registered at the Regional Court in Brno, File no: A 26679 (hereinafter referred to as "STUDENT AGENCY TRAVEL"), operates on the Czech market as one of the largest travel agencies and travel agencies operating mainly through the websites cz, studentagency.eu, dovolena.cz, jazykovepobyty.cz, letenky.cz, kralovna.cz (hereinafter referred to as "Website"). Unless expressly stated otherwise in these Rules for online intermediary services operated on online platforms (hereinafter referred to as the "Rules"), the Rules apply to the offer and sale of tours and travel services, air tickets, language, study and other stays, (hereinafter referred to as all "Tours and Services") under the trademark STUDENT AGENCY TRAVEL.
1.2 STUDENT AGENCY TRAVEL is pursuant to:
(a) Regulation (EU) 2022/2065 of the European Parliament and of the Council on the Digital Single Market for Services of 19 October 2022 (the "DSA"); and
(b) Regulation (EU) 2019/1150 of the European Parliament and of the Council on promoting fairness and transparency for business users of online intermediary services (hereinafter referred to as "P2B")
operator of "online intermediary services" operating on "online platforms" and these Rules thus set out the mandatory information and conditions set out in those regulations.
1.3 STUDENT AGENCY TRAVEL hereby expressly confirms that these Rules contain all mandatory information pursuant to Regulation (EU) 2019/1150 (P2B) and Act No. 58/2023 Coll. on Information Society Services. In case of doubt, the company is obliged to ensure their interpretation in favour of transparency towards business users."
1.4 These Rules only apply to business users (within the meaning of Article 2(1) P2B) of the Website and recipients of services (within the meaning of Article 3(b) DSA) who are entrepreneurs (hereinafter referred to as "Users"). They are therefore only intended for travel agencies, travel agencies or other travel service providers who enter into a commercial agency agreement or similar agreement with STUDENT AGENCY TRAVEL. The rules and conditions under P2B and DSA for customers are contained in STUDENT AGENCY TRAVEL's Terms and Conditions available here.
1.5 The relationship between STUDENT AGENCY TRAVEL and Users is governed by the relevant contract between STUDENT AGENCY TRAVEL and the User (the "Contract") and these Rules. In the event of a conflict between the Contract and the Rules, the provisions of the Contract shall apply.
2 DETERMINATION OF THE RANKING OF TOURS AND SERVICES ON THE WEBSITE
2.1 STUDENT AGENCY TRAVEL intends to display the maximum number of Tours and Services on the Website, and the display of Tours and Services shall be subject to the terms and conditions described later in this section of the Rules. User Identity: STUDENT AGENCY TRAVEL will always clearly display the business name and registered office of the business User whose Tours and Services are offered through the Website to ensure transparency to consumers.
2.2 The display of Tours and Services on the Website is determined by the following main ranking parameters, between which Customers can switch freely and which all have equal weight:
(a) Price;
- b) Sales;
- c) Customer ratings;
- d) Our recommendations, described in more detail in paragraph 2.6.
- e) The Customer's ability to book, purchase and pay for the Trip and Service online directly on the Website. In order to view Tours and Services that allow the above, the Customer must enable the display of only such Tours and Services in the settings of the Website;
- f) In the event that more than one User offers a Tour and Service with the same destination, location, hotel, meals, transportation, departure/arrival point, length of stay, dates (hereinafter referred to as "Same Tour and Services"), the Website will display i) such Same Tour and Services whose price is the lowest; ii) in the case of the same price, the Same Tours and Services are sorted randomly without any further specified criteria.
All main parameters (price, sales, client feedback, recommendations, online booking option) have equal weight for ranking purposes. None of the parameters are given priority unless otherwise stated in these rules. STUDENT AGENCY TRAVEL does not apply any other hidden algorithmic factors.
2.3 The main parameters determining the ranking are selected with the aim that customers using the Website to purchase Tours and Services can easily find Tours and Services that are convenient, popular and of high quality, and that they can purchase such Tours and Services in the easiest way possible. In the future, STUDENT AGENCY TRAVEL may modify any display parameters for Tours and Services, or remove and/or add new display options. STUDENT AGENCY TRAVEL will inform Users of this by amending these Rules and by email to the contact email address. The change will be notified at least 15 days in advance on a permanent medium (email). Any changes to these Rules will be notified to Business Users at least 15 days in advance on a durable medium (in particular by email or in a data box). At the same time, they will be given the opportunity to comment on them. STUDENT AGENCY TRAVEL will also keep proof of the sending of the notification and the confirmation of delivery to the Business User.
2.4 If customers consent to the use of marketing or personalised cookies on the website, their content on the website may also be modified via the respective cookies on the basis of their behaviour on the website, browsing or favourite offers.
2.5 In particular, the following Tours and Services are not included in the Tours and Services on the Website:
(a) Tours and Services of the organizing travel agency that are also offered by the intermediary travel agency as a sales representative of the organizing travel agency, provided that STUDENT AGENCY TRAVEL cooperates with both the organizing and intermediary travel agency and STUDENT AGENCY TRAVEL becomes aware of the duplicate offer of the Tours and Services.
- b) Tours and Services organized by a Slovak entity of a Czech travel agency, which are offered under similar conditions by this Czech travel agency;
- c) Non-standard Tours and Services; it is at STUDENT AGENCY TRAVEL's discretion which Tours and Services it considers non-standard;
- d) Minor Additional Services;
- e) Tours and Services very similar to Tours and Services displayed on the Website that STUDENT AGENCY TRAVEL evaluates as potentially duplicative (e.g., same Tours and Services);
2.6 Failure to display Tours and Services on the Website may also occur in the following cases:
(a) An error on the Website;
- b) An error in the User's booking system;
- c) The online capacity verification system incorrectly determines the capacity of the Tour and Services as full;
- d) The User deletes the Tour and Service from the Website;
- e) There are last available seats in the Tour reservation;
- f) In case of multiple errors in the data export caused by the User - in this case the entire offer of the User will be hidden until the export is corrected;
- g) The User fails to provide STUDENT AGENCY TRAVEL with insurance of the guarantee in case of bankruptcy according to the Act No. 159/1999 Coll., on Certain Conditions of Business and on the Performance of Certain Activities in the Field of Tourism (hereinafter referred to as the "Travel Services Act");
- h) STUDENT AGENCY TRAVEL and the User agree not to offer a particular Tour or type of Tours;
- i) The Tour and Services (or the destination hotel of the Tour and Services) has a poor customer rating;
- j) the Tour and Services (or the destination hotel of the Tour and Services) includes services rated poorly by customers;
- k) In the event of increased customer demand, STUDENT AGENCY TRAVEL may remove Tours from the Website at short notice that cannot be purchased online;
- l) During periods of increased demand, STUDENT AGENCY TRAVEL may set a minimum price for Tours displayed on the Website.
- m) The User is bankrupt or shows signs of bankruptcy or insolvency and it may be considered risky to offer the Trip to customers.
- n) STUDENT AGENCY TRAVEL has been notified by a third party that licensed materials (photos, videos) promoting the Tour infringe copyright, personality or other rights of third parties;
2.7 In the event that the Tour is not displayed for the reasons set out in the Rules, the User shall not be entitled to compensation for damages or any penalties. However, in the event of a decision or error on the part of STUDENT AGENCY TRAVEL, STUDENT AGENCY TRAVEL shall endeavour to communicate the situation with the User and, in the event of an error, to ensure that it is rectified as soon as possible.
2.8 Users are not able to influence the order in which Tours and Services are displayed for a fee. The recommendation of certain hotels from the Users' listings is not paid advertising. No preferential display is provided by STUDENT AGENCY TRAVEL for payment from Users, nor does it take into account the amount of commission agreed between STUDENT AGENCY TRAVEL and the User when ranking such positions. Specific categories such as "Our tip", "Recommended for you" or "We have selected for you" are compiled by STUDENT AGENCY TRAVEL's product department at its own discretion, in particular according to the current customer interest in certain destinations, the time of year and similar variable criteria. Therefore, there is no differential treatment for the payment of Users.
2.9 For the purposes of these Rules (paragraphs 2.6 and 3.1 of the Rules), STUDENT AGENCY TRAVEL considers the following ratings of the Tour and Services, Service or User to be "poor customer ratings" and "poor service ratings":
(a) A rating that averages less than 4.0/5 for at least 2 consecutive calendar months; or
- b) At least 10 negative ratings (2.0/5 or lower) received in 1 calendar month.
2.10 STUDENT AGENCY TRAVEL reserves the right, in the event of a poor customer rating for at least three of the User's Tours or Services, to suspend the User's account and the ability to add additional Tours in addition to not displaying or suspending the offering of the Tours/Services in question.
2.11 STUDENT AGENCY TRAVEL itself does not advertise the same or similar services as the User on the Website, therefore there is no differential treatment within the meaning of Article 7 P2B. STUDENT AGENCY TRAVEL does not treat individual Users differently either.
3 SUSPENSION OF THE OFFERING OF TOURS BY THE USER
3.1 The following reasons may lead to STUDENT AGENCY TRAVEL's decision to restrict the display or suspend the offering of User Tours and Services:
(a) Multiple data export errors caused by the User or the User's transition to a new system that impacts data export and causes errors in the display of multiple User Tours and Services or information about them on STUDENT AGENCY TRAVEL;
- b) Failure to supply insurance of the guarantee in case of bankruptcy under the Travel Services Act;
- c) Poor customer rating of the User's Tours and Services;
- d) Poor evaluation of the services offered within the Tours and User Services;
- e) The User is in bankruptcy or threatened bankruptcy within the meaning of Section 3 of Act No. 182/2006 Coll., on Bankruptcy and the Methods of its Resolution (hereinafter referred to as the "Insolvency Act")
- f) The User has filed a debtor's insolvency petition or a petition for moratorium within the meaning of the Insolvency Act;
- g) A creditor's insolvency petition has been filed against the User and, in the sole discretion and assessment of the information available to STUDENT AGENCY TRAVEL, it is expected that the User is bankrupt or threatened with bankruptcy within the meaning of the Insolvency Act (regardless of whether the insolvency court decides on bankruptcy);
- h) STUDENT AGENCY TRAVEL has become aware that any of the presumptions of insolvency in the form of insolvency within the meaning of Section 3 of the Insolvency Act has arisen in relation to the User;
- i) According to available information, enforcement proceedings have been initiated against the User within the meaning of Act No. 120/2001 Coll., on bailiffs and enforcement activities (the Enforcement Code) or a petition for judicial enforcement of a decision within the meaning of the Civil Procedure Code has been filed by at least two creditors of the User;
- j) The User's activities damage the reputation of STUDENT AGENCY TRAVEL; (i.e. in particular the dissemination of false information that may damage the company's reputation)
- k) The User has violated any obligation under the Agreement or generally binding legal regulations.
3.2 STUDENT AGENCY TRAVEL may discontinue the provision of STUDENT AGENCY TRAVEL's intermediary services by limiting the display or suspending the offering of Tours at any time and without prior notice if the reasons are met. STUDENT AGENCY TRAVEL may also use other similar mechanisms under the same conditions (e.g. hiding or preventing the use of the User's account, blocking the IP address from which the User accesses the STUDENT AGENCY TRAVEL platform, etc.). In lieu of such actions, STUDENT AGENCY TRAVEL may request the User to remedy the situation and the User shall be obliged to remedy the situation without delay.
3.3 STUDENT AGENCY TRAVEL may temporarily suspend the provision of services immediately. If STUDENT AGENCY TRAVEL decides to permanently terminate the provision of services to the User, it shall inform the User at least 30 days before the decision takes effect. Together with this decision, it shall provide written justification for the termination. The justification shall contain a reference to the specific facts, including the content of third party notifications, that led to STUDENT AGENCY TRAVEL's decision. The User shall be provided with a justification of any restriction or suspension on a durable medium, referring to the specific provisions of these Rules. STUDENT AGENCY TRAVEL may not comply with this procedure and the above time limit if.
(a) STUDENT AGENCY TRAVEL is subject to a legal or regulatory obligation requiring STUDENT AGENCY TRAVEL to terminate the provision of services to the User in a manner that makes the 30-day notification period to the User impossible to meet;
- b) if STUDENT AGENCY TRAVEL exercises its right to terminate the Agreement and the provision of the Services on the basis of an urgent reason under applicable law;
- c) if STUDENT AGENCY TRAVEL is able to prove that the User concerned has repeatedly violated the Contract or generally binding legislation, which has led to the termination of the provision of services;
- d) it is the justification of a decision in cases where STUDENT AGENCY TRAVEL is subject to a legal or regulatory obligation not to state specific facts or reasons for its decision or where STUDENT AGENCY TRAVEL is able to prove the facts referred to in point c).
3.4 If the User disagrees with STUDENT AGENCY TRAVEL's decision under this Article, the User may object to the decision within 15 days of receipt of the decision. After the objection has been submitted, STUDENT AGENCY TRAVEL shall review its decision and inform the User of the decision by e-mail. No further objections or other remedies may be lodged against the decision.
3.5 If STUDENT AGENCY TRAVEL revokes or otherwise terminates the restriction or suspension of the offer of Tours and Services or other services of the User, it shall without undue delay resume the offer of such Tours and Services and shall provide the User with access to any personal and other data obtained by STUDENT AGENCY TRAVEL prior to the effectiveness of the restriction or suspension of the offer when the User used the services of STUDENT AGENCY TRAVEL.
3.6 STUDENT AGENCY TRAVEL does not restrict the User from offering Tours and Services off the Website unless such restriction is expressly stated in these Rules.
4 RULES FOR REPORTING ILLEGAL CONTENT
4.1 STUDENT AGENCY TRAVEL establishes a procedure for reporting and removing illegal content that appears on the Website. The same rules also apply to other websites and applications operated by STUDENT AGENCY TRAVEL. Illegal content is defined as content that violates legal regulations (e.g. copyright, data protection or consumer protection regulations), the Agreement or these Rules.
4.2 The procedure set out in this Article of the Rules applies both to situations where the User is the notifier of illegal content and to situations where STUDENT AGENCY TRAVEL discovers in the course of its own activities or is notified by a third party that there is illegal content posted by the User on the Website.
4.3 Content posted by the User is not actively monitored or modified by STUDENT AGENCY TRAVEL. Nor does it use automated tools to do so; all monitoring is done with human involvement only. However, STUDENT AGENCY TRAVEL is entitled to check and monitor the content posted by the User before publication and to require the User to change it without delay.
4.4 STUDENT AGENCY TRAVEL reserves the right to publish the content only after checking, to limit the visibility of illegal content or to delete illegal content.
4.5 In the event that STUDENT AGENCY TRAVEL does not publish the User's content or deletes it (or restricts its visibility) after its own review or after notification by a third party, the following rules will apply:
(a) STUDENT AGENCY TRAVEL will notify the User by email to the User's contact email address provided to STUDENT AGENCY TRAVEL in the Agreement or in the User's account that such action has occurred;
- b) If the User does not agree with such decision of STUDENT AGENCY TRAVEL, he/she may object to it within 15 days from the delivery of the decision. After the objections have been submitted, STUDENT AGENCY TRAVEL shall review its decision through a committee consisting of at least three persons from STUDENT AGENCY TRAVEL who were not involved in the initial decision and shall inform the User of the committee's decision by e-mail. No further objections or other appeals may be made against the decision of the committee.
4.6 STUDENT AGENCY TRAVEL shall clearly and specifically justify any restriction on the visibility of the content provided by the User, including its removal or disabling of access. STUDENT AGENCY TRAVEL does not assign any User Content a lower search ranking.
4.7 If the User considers that the content published by a third party on the Website violates generally binding legislation, the Agreement, these Rules or other terms and conditions of STUDENT AGENCY TRAVEL, the User may report this to STUDENT AGENCY TRAVEL via the internal complaint handling system according to Article 7 (this is a free internal system according to Article 11 of the P2B Regulation). Once STUDENT AGENCY TRAVEL receives the notification, it will proceed as follows:
(a) acknowledge receipt to the User by email without undue delay;
(b) inform the User without undue delay of the decision taken regarding the notification of the content; and
- c) provide the User with information on how to defend against such decision.
4.8 A notification of illegal content within the meaning of Article 16 of the DSA must be written in the Czech language and contain in particular the elements listed below:
(a) a sufficiently substantiated explanation of the reasons why the User claims that the information in question is illegal content;
- b) an unambiguous indication of the exact electronic location of the information (e.g., the exact URL address);
- c) identification of the User at least in the following terms: business name, registration number and registered office;
- d) identification of the person acting on behalf of the User in the following scope: name, surname, function or title authorising the User to represent the User, e-mail address;
- e) a statement confirming that the User and the person submitting the notification believe in good faith that the information and statements contained in the notification are accurate and complete.
4.9 The User acknowledges that if he/she fails to include or disclose to STUDENT AGENCY TRAVEL the necessary information required in the form (Appendix 1 to these Rules), STUDENT AGENCY TRAVEL may not be able to consider and decide on the notification due to lack of information.
4.10 STUDENT AGENCY TRAVEL shall process all notifications containing the necessary information in a timely, diligent, impartial and objective manner. STUDENT AGENCY TRAVEL does not use automated tools to evaluate notifications.
5 OTHER CONDITIONS UNDER THE DSA REGULATION
5.1 In accordance with Article 23 of the DSA, STUDENT AGENCY TRAVEL reserves the possibility to suspend, for a reasonable period of time and after issuing prior notice, the provision of its services to Users who frequently provide manifestly illegal content. Likewise, STUDENT AGENCY TRAVEL is entitled to suspend the handling of notifications and complaints from Users or other entities that frequently submit apparently unjustified notifications or complaints.
5.2 In the event of suspension of the provision of services to Users or suspension of the possibility to submit notifications and complaints pursuant to paragraph 5.1, STUDENT AGENCY TRAVEL shall be governed by the following rules:
(a) STUDENT AGENCY TRAVEL shall always take into account, as a minimum, the absolute number of objectionable items of manifestly unlawful Content or manifestly unfounded notices or complaints submitted in a particular period and their relative proportion in relation to the total amount of Content, notices or complaints in the same period when deciding on suspension;
(b) STUDENT AGENCY TRAVEL will also assess the seriousness of the abuse, including the nature of the illegal content, giving the strictest consideration to content that violates the law, infringes the rights or legitimate interests of persons (particularly copyright and personality rights), is contrary to good morals, public policy or morality, or is otherwise fraudulent, vulgar or offensive. In its assessment, STUDENT AGENCY TRAVEL shall always take into account the User's or third party's intent, if it can be inferred;
- c) in the event that the conditions for suspension are met, STUDENT AGENCY TRAVEL will suspend the User's ability to post new content or to notify or complain to anyone for a period of 2 months.
5.3 In accordance with Articles 15 and 24 of the DSA, STUDENT AGENCY TRAVEL publishes a content moderation report on the Website once a year for transparency purposes. Similarly, STUDENT AGENCY TRAVEL publishes on the Website every six months information on the average monthly number of active recipients of the service in the Union.
6 OTHER CONDITIONS UNDER THE P2B REGULATION
6.1 STUDENT AGENCY TRAVEL informs the User, in accordance with Article 3(1)(e) of P2B, that the Agreement, the Rules or any other terms and conditions applicable to the User do not affect the User's intellectual property rights. The User, by posting any content (description of the Tour, photographs, etc.) or by transmitting it to STUDENT AGENCY TRAVEL, grants STUDENT AGENCY TRAVEL a non-exclusive license to use such content for the duration of the Contract and shall cease to use it and delete all copies thereof upon termination of the Contract.
6.2 STUDENT AGENCY TRAVEL offers customers the possibility of ordering additional services (in particular travel insurance, parking, visas, optional trips, cancellation insurance and instalment financing) provided by third parties or directly by STUDENT AGENCY TRAVEL when booking a Trip and Services or other services. The current list of additional services is always published on the website. The User may offer its own alternative supplementary services via the Website only after consultation with STUDENT AGENCY TRAVEL.
6.3 STUDENT AGENCY TRAVEL has access to personal or other data provided by the User and Customers when using the Website, i.e. in particular when offering and booking Tours or other services. The categories of such data are set out in the Customer Privacy Policy documents available in the "Privacy Policy" section of the Website, or in the Contracts (Data Processing Agreement). This includes, in particular, identification, address, contact and payment data, data on orders, reviews, etc.
6.4 STUDENT AGENCY TRAVEL may process statistical and other information arising from the overall offer of Tours and Services and other services on the Website in an aggregated manner without processing personal data (e.g. statistics relating to consumer behaviour, popularity of destinations and services, etc.). STUDENT AGENCY TRAVEL does not share such data with the User unless agreed upon.
6.5 STUDENT AGENCY TRAVEL hereby informs the User that its data and content published on the Website or on any other platform provided by STUDENT AGENCY TRAVEL during the term of the Agreement or generated by the User shall not be stored by STUDENT AGENCY TRAVEL after the termination of the Agreement. Exceptions are:
(a) Personal data that may be further processed by STUDENT AGENCY TRAVEL in accordance with the GDPR and the Contract (Personal Data Processing Contract) subject to certain requirements (e.g. on the basis of a legitimate interest or legal obligation);
- b) Other data that STUDENT AGENCY TRAVEL must record in order to enable customers to exercise their rights under the travel contract or consumer rights;
- c) Anonymised statistical data that STUDENT AGENCY TRAVEL obtains in the course of the cooperation with the User;
- d) Data pursuant to Article 30 of the DSA, which STUDENT AGENCY TRAVEL must keep for six months after the termination of the contractual relationship with the User (i.e. in particular name, registered office, registration number, telephone number, e-mail, information on registration in the Commercial Register and payment account information).
6.6 If the User needs access to data provided to STUDENT AGENCY TRAVEL by him or by customers, he may request STUDENT AGENCY TRAVEL to provide him with this information. STUDENT AGENCY TRAVEL may charge a fee for providing this data. If no legal or contractual obstacles prevent this, STUDENT AGENCY TRAVEL will disclose this information to the User. After the termination of the contract, STUDENT AGENCY TRAVEL shall retain the data to the extent provided by law and these Rules for a period of six months. The Business User has the right to request access to the data via e-mail or data mailbox. STUDENT AGENCY TRAVEL will provide the data in electronic form (CSV or XLSX format) without undue delay, no later than 30 days after receipt of the request. If no technical or contractual access is possible, this fact will be explicitly stated in the confirmation delivered to the business user.
6.7 Access to data by STUDENT AGENCY TRAVEL
STUDENT AGENCY TRAVEL has access not only to the personal data of customers necessary to make a reservation, but also to non-personal data provided by business users or consumers or generated by the use of the Platform. This includes, in particular, statistical data on traffic, searches, orders and customer feedback. This access is necessary for the operation and administration of the Platform and for the purpose of improving the service.
6.8 Access by business users to their data
The Business User has the right to access the data provided to STUDENT AGENCY TRAVEL in connection with his/her use of the Platform (in particular, data on offers, prices, photos, descriptions) and data generated in connection with his/her own tours and services (e.g. booking numbers, customer reviews, demand statistics). This data is made available upon request by the user, in a machine-readable format (CSV, XLSX, XML), within 30 days of receipt of the request.
6.9 Access to aggregated data
The business user shall also have the right to access aggregated data relating to all users of the platform (e.g. overall trends in demand for destinations, average service ratings). This aggregated data does not contain personal data of customers or trade secrets of other Business Users and is made available under the same conditions as the data referred to in paragraph 6.8.
6.10 Sharing of data with third parties
STUDENT AGENCY TRAVEL may only provide data to third parties if this is necessary for the proper functioning of the platform (e.g. payment service providers, insurance companies, IT service providers). If data is also shared for other purposes (e.g. marketing, statistical analysis), the business user is informed in advance of this sharing and has the option to exclude this sharing via a written request sent to the contact address of Student Agency Travel.
6.11 If the dispute between STUDENT AGENCY TRAVEL and the User is not resolved by negotiations between the responsible representatives of both parties within the meaning of the Agreement within 30 days from the date of submission of the initiative of one party to the other party to initiate negotiations, such dispute may be resolved by mediation pursuant to Act No. 202/2012 Coll., on Mediation.
6.12 Either party may initiate legal proceedings at any time before, during or after the mediation.
6.13 At the User's request before or during the mediation, STUDENT AGENCY TRAVEL shall make available to the User information on the functioning and effectiveness of the mediation concerning STUDENT AGENCY TRAVEL's activities.
6.14 Mediation: in accordance with Article 12 of the P2B, STUDENT AGENCY TRAVEL states that it is prepared to cooperate in the out-of-court settlement of disputes with at least two mediators. The mediators for out-of-court dispute resolution are:
- Filip Horák, JUDr. Filip Horák, Attorney at Law, Radnická 11, 602 00 Brno,info@judr-horak.cz , +420 739 563 557, who is also a registered mediator.
- JUDr. Roman Vaněk, Ph.D., Attorney at Law, Registration number 08476, email rovan@volny.cz, Phone +420606261189
6.15 Access to data by business users
- During the term of the contract, the business user has the right to access data that:
(a) provided directly to STUDENT AGENCY TRAVEL (e.g. data about its offers, prices, descriptions, photographs),
b) generated in connection with the offering of its tours and services (e.g. booking statistics, customer reviews, demand data). - STUDENT AGENCY TRAVEL will allow the Business User to access this data by:
- data export in machine-readable format (CSV, XLSX, XML),
- upon request sent to the company's contact e-mail address or via the user portal. - Access to the data will be provided to the business user without undue delay, at the latest within 30 days of receipt of the request.
- If some data cannot be accessed for technical or legal reasons (e.g. due to the protection of customers' personal data under the GDPR), STUDENT AGENCY TRAVEL will explicitly notify the business user of this fact.
- After the termination of the contract, the business user may request access to the data for a period of six months; after this period, STUDENT AGENCY TRAVEL only retains the data to the extent required by law.
- If there is no technical or contractual access to certain data, STUDENT AGENCY TRAVEL shall explicitly state this fact in the confirmation delivered to the business user.
7 SENDING A COMPLAINT OR NOTIFICATION
7.1 The User shall send a complaint or notice referred to in these Rules or arising from the legal provisions contained in the DSA and/or P2B to STUDENT AGENCY TRAVEL by means of the completed form attached as Appendix 1 to these Rules (hereinafter referred to as the "Form") to the email address (hereinafter referred to as the "Contact Address"). You may communicate in Czech or English.
If you encounter content on this Website that you believe to be illegal, you may report it. To report illegal content, please fill out this form, and send it to nezakonnyobsah@studentagency.cz .
If you represent a public authority and wish to report illegal content, or send another report, please use the email address . digitalniobsah@studentagency.cz
If you represent a User and wish to report a problem or complaint with the display of your listings, please use the email address REKLAMACE@STUDENTAGENCY.CZ
Within three working days, the Provider will send an acknowledgement of receipt of the complaint and within 30 days at the latest, the Provider will comment on the investigation carried out and send the conclusion of the complaint.
7.2 The User may use the contact form for filing complaints according to the P2B regulation regarding:
(a) STUDENT AGENCY TRAVEL's alleged failure to perform its obligations under P2B in a manner that affects the User;
- b) technical problems directly related to the provision of STUDENT AGENCY TRAVEL's services to the User under the Agreement or these Rules that affect the User;
- c) actions or conduct of STUDENT AGENCY TRAVEL that are directly related to the provision of services by STUDENT AGENCY TRAVEL to the User under the Agreement or these Rules and that affect the User;
7.3 The contact address is also the point of contact pursuant to Articles 11 and 12. The authorities of the Member States and the European Union may communicate with STUDENT AGENCY TRAVEL in Czech and English, the Users in Czech.
7.4 The User's complaint must:
(a) be written in the Czech language;
- b) contain information that it is a complaint filed under these Rules;
- c) contain identification of the User in the following scope: business name, registration number and registered office;
- d) contain the identification of the person authorized to represent the User in the following scope: name, surname, function, or title authorizing the person to represent the User;
- e) contain a sufficiently specific statement of the facts that are the subject of the complaint.
7.5 A representative of STUDENT AGENCY TRAVEL will acknowledge receipt of the complaint to the User at the e-mail address provided by the User in the Form. Information on the handling of the User's complaint will also be sent to this email address within a reasonable period of time. If the User has not provided an email address in the complaint, STUDENT AGENCY TRAVEL will investigate the complaint in the same way and will contact the User if it has other contact details for the User.
7.6 STUDENT AGENCY TRAVEL may ask the User who has filed a complaint to complete the information and documents necessary to resolve the User's complaint. STUDENT AGENCY TRAVEL may reject the complaint if the User fails to provide the requested cooperation within a reasonable period of time.
7.7 The User may similarly use the Contact Address to report the appearance of specific information within the STUDENT AGENCY TRAVEL Website and Services that the User considers to be illegal content.
7.8 The User may, for a period of 6 months from the date on which he/she receives information about a decision made by STUDENT AGENCY TRAVEL, lodge a complaint via the Contact Address against the decision taken following the notification pursuant to paragraph 7.7 or against the decisions listed below:
(a) the decision whether or not to remove or make inaccessible the information in question or to restrict its visibility;
- b) a decision whether or not to suspend or terminate the provision of services to the User, in whole or in part;
- c) the decision whether or not to suspend or terminate the User's account.
For a complaint under this provision, the rules under paragraph 7.4 shall apply mutatis mutandis.
7.9 If STUDENT AGENCY TRAVEL concludes on the basis of a complaint that its decision is unjustified or that the information to which the complaint relates is neither illegal nor incompatible with the terms and conditions, it shall cancel its decision without undue delay.
7.10 Together with the reasons for the decision on the complaint, STUDENT AGENCY TRAVEL shall inform the User of the possibility of an out-of-court settlement of the dispute and other available remedies. The User may use the dispute resolution options listed below even if STUDENT AGENCY TRAVEL does not decide on the User's complaint at all:
(a) There is currently no designated certified body for out-of-court dispute resolution in the Czech Republic. As soon as it has been designated in accordance with Article 21 of the DSA, STUDENT AGENCY TRAVEL will inform the User about this body in the context of the decision on the complaint. This body does not have the power to impose a binding dispute resolution on the parties.
- b) The User is entitled at any stage of the dispute resolution with STUDENT AGENCY TRAVEL to initiate judicial or administrative proceedings to challenge the decision of STUDENT AGENCY TRAVEL in accordance with the applicable law.
7.11 The system is based on the principles of transparency and equal treatment in the same situations and the resolution of complaints in a manner that is proportionate to their importance and complexity.
7.12 Internal Complaints Handling System STUDENT AGENCY TRAVEL operates an internal system for handling complaints from business users as defined in Article 11 of the P2B Regulation. This system is available to all business users free of charge and is used to resolve all complaints relating to:
(a) alleged breaches of the obligations set out in the P2B Regulation,¨
- b) technical problems directly related to the provision of online intermediary services,
c) any other conduct or decision of STUDENT AGENCY TRAVEL that has a direct impact on a Business User.
STUDENT AGENCY TRAVEL shall produce and publish a summary report on the operation and effectiveness of its internal complaints handling system once a year. This report shall be publicly available on the company's website in the "Terms and Conditions" section and shall be easily accessible to business users without the need to register.
In particular, the report includes:
- the total number of complaints received,
- the average time taken to resolve them,
- the proportion of complaints that were found to be justified,
- an overview of the measures taken to remedy and improve the functioning of the platform.
STUDENT AGENCY TRAVEL undertakes to keep this system transparent and accessible, including keeping reports for at least the last three years.
7.13 Lodging a complaint. A complaint shall be submitted via the form (Appendix 1) or electronically to the designated contact address. Once a complaint has been submitted, an acknowledgement of receipt is sent to the business user within 3 working days.
7.14 Handling of complaints Complaints are handled in an impartial manner by the designated department of STUDENT AGENCY TRAVEL, which is not involved in the decision against which the complaint is directed. The complaint shall be resolved without undue delay, at the latest within 30 days of receipt, unless circumstances require a longer period. In this case, the business user shall be informed of the reasons for the extension and the new deadline.
7.15 Recording and escalation of complaints. STUDENT AGENCY TRAVEL shall maintain a record of all complaints received and their outcomes for a period of at least 3 years. If the Business User does not agree with the resolution of the complaint, he/she has the option of using mediation as per Article 6.7 of these Rules or going to court.
7.16 The Business User acknowledges that if it suspects that a violation has occurred, is occurring or is very likely to occur, it may report its suspicions without fear of any negative consequences, in particular retaliation, through the System. The User will be entitled to protection under Act No. 171/2023 Coll., on the protection of whistleblowers, provided that at the time of the notification he/she was in good faith as to the truth of the information contained therein and the notification was made in accordance with the law. Notification may be made through the System orally or in writing in accordance with the Act and the Whistleblower Policy available at the address below. The recommended channel for notifications is the secure web interface accessible from https://www.studentagency.cz/whistleblowing-studentagencytravel.
These Rules are effective from 25.08.2025 and replace the previous Rules dated 15.08.2021.
Form for notification of illegal content or violation of P2B regulation
Please send the completed form to the contact email address