Table of contents:
- What information we collect, why we collect it, and how it is used
- Period of storage of collected information
- How we protect and retain your Personal Data
- How we share your Personal Data
- Additional information regarding transfers of Personal Data
- Your privacy rights
- Use by children
- Interaction with third party products
- Log files
- Analytic tools
- Specific provisions applicable under California privacy law
- Contact us
1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
(i) When you browse, or visit, our Website
(ii) When you make use of, or interact with, our Website
a. When you decide to submit a request to follow a travel destination.
You provide us with the following Personal Data: Full name, email address, and age (optional) and country chosen. We use your name and email address to send you emails with information about your chosen destination. We use your age (without your name and email address) to analyze demographic trends in user interest towards each destination. Our legal basis for collecting this information is that processing is necessary in order to take steps at the request of the data subject prior to entering into a contract, and legitimate interest. We share this information with third party platforms, such as MailChimp (CRM), Google drive (storage) and Namecheap (website hosting). Were we to not process your name and email, we would not be able to send you emails with information about your chosen destination. We also use your name and email details which you provide us with in order to send you marketing communications, in accordance with your consent (our legal basis). Where we do not process this Personal Data in this manner, we would not be able to send you marketing communications.
b. When you report inaccuracies:
Your full name, email address, country, and the information you report. We use the information you report in order to improve the coverage and accuracy of our travel restrictions database. We use your full name, email address and country for identifying fraudulent reporting, and for getting in You provide us with the following Personal Data: name (optional), email address, country, and other information such as the inaccuracies that you decide to report us, to the extent that it contains Personal Data. We use the information of inaccuracies that you report us proactively in order to improve the travel restrictions information, and for communications related to your reports (e.g., getting in touch with you for further inquiries about the information you report and/or to thank you). Were we do not process these Personal Data, we would not be able to use improve and enrich the travel restrictions information neither to communicate with you for matters related to your reports. We share your Personal Data with third party platforms, such as Mailchimp (CRM), Amazon Web Services (storage and compute), Google drive (storage), and Namecheap (website hosting).
c. When you complete our feedback survey (“Help us Improve”):
You provide us with the following Personal Data: email address (optional), age groups, with whom you usually travel with and other information you would like to see on our Website, to the extent that such information includes Personal Data. If you do not provide your email address, the feedback submissions are anonymous. We use the feedback to improve your experience on our Website and the Product. We use in an aggregated manner the age group and who you travel with (e.g., with a friend or family) to identify trends. If you supply us with your email address, we will use it to contact you for further research and/or focus groups. Our legal basis for collecting this information is the consent. We share this information with third party platforms, such as Cognito Forms (survey builder), MailChimp (CRM), Google drive (storage) and Namecheap (website hosting). Where we do not process this Personal Data in this manner, we would not be able to improve your experience of using travelbans’s Product and Website.
d. When you register When you register to use our Product (API):
When you register, we collect your email address, payment details, your company name and address, and your company registration number, to the extent that it includes Personal Data. We use this Personal Data to allow you to register to use our Product, to perform/execute the agreement, to send you e-mail notifications related to the Product (service-related communications), to manage your everyday business needs (i.e., API administration), and to answer your requests for the Product and for related activates (e.g., account management support and to provide other related services), for our accounting records, and to provide you with an invoice for your purchase. Our legal basis for collecting this information is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and legitimate interest (e.g. to sign up to the Product) and in order to comply with our legal obligations (e.g. tax laws, bookkeeping laws, etc.). We share this information with third party platforms such as PayPal (payment system), AWS (computing) and Gmail (sending you emails). Where we do not process this Personal Data in this manner, we would not be able to collect your payment and grant you access to our Product.
e. When you make use our Product (API):
When you make use of our Product we record your interaction with our API in log files. The Personal Data inside the log files includes the account identifier, internet protocol (IP) address, and action details for every action you take through the API. We use this Personal Data to understand your usage of the Product, to monitor your use of the API and for troubleshoot and support related requests. Our legal basis for collecting this information is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and legitimate interest (e.g. to assist your with your support related inquiries).. Were we to not process this information in this manner, we would not be able to troubleshoot our API.
2. PERIOD OF STORAGE OF COLLECTED INFORMATION
- Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.
3. HOW WE PROTECT AND RETAIN YOUR INFORMATION
- Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- Retention of your Personal Data. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.
4. HOW WE SHARE YOUR PERSONAL DATA
In addition to the recipients described above, we may share your Personal Data as follows:
- To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
- In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events; and/or
- Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
- Namecheap – Atlanta, US
- DigitalOcean – New York, EU
- MailChimp – US
- Google Drive – Google maintain servers around the world. For more information, regarding Google’s legal frameworks for data transfers, please visit the following links: https://policies.google.com/privacy/frameworks and https://support.google.com/policies/troubleshooter/7575787?visit_id=637039011088496587-3381196795&hl=en&rd=2#ts=7576505
Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
- When we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
- Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.
- Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
6.YOUR PRIVACY RIGHTS.
Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
- You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
- You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
- You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
- You have the right to object, to or to request restriction, of the processing;
- You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
- You have the right to object to profiling;
- You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
- You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
You can exercise your rights by contacting us at email@example.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
7. USE BY CHILDREN
We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at firstname.lastname@example.org.
8. INTERACTION WITH THIRD PARTY PRODUCTS
We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
9. LOG FILES
We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
10. ANALYTIC TOOLS
- We reserve the right to remove or add new analytic tools.
11. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
- California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com. Please note that we will respond to one request per customer each year, unless otherwise required by law.
- Our California Do Not Track Notice: We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Website
- Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
12. CONTACT US
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at firstname.lastname@example.org.