Last Modified: December 19, 2019 | Previous Versions
Travel Tripper LLC d/b/a Pegasus (the “Company”, “us”, “we”, “our”, or “Pegasus”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the Website, and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On the Website.
- In email, text, and other electronic messages between you and the Website.
- Through mobile and desktop applications, if any, that you download from the Website or use to access the Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
- Through any other means associated with or relating to the Website.
This policy does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by the Company or any third party (including our affiliates and subsidiaries); or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Our Website is not intended for children under eighteen (18) years of age. No one under age eighteen (18) may provide any personal information to us or on or through the Website.
We do not knowingly collect personal information from children under the age of thirteen (13). If you are under thirteen (13), do not use or provide any information on this Website or on or through any of its features or register on the Website (if such feature is available), make any purchases through the Website (if such feature is available), use any of the interactive or public comment features of this Website (if such feature is available) or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.
If we learn we have collected or received personal information from a child under thirteen (13) years of age without verification of parental consent, we will delete that information.
If you believe we might have any information from or about a child under the age of thirteen (13), please contact us at: firstname.lastname@example.org.
Information We Collect About You and How We Collect It.
We may collect several types of information from and about users of our Website, including information:
- By which you may be personally identified, such as name, mailing address, e-mail address, telephone number, or any other information that the Website collects which is defined as personal information, personally identifiable information or personal data pursuant to applicable law (collectively, “personal information“);
- That is about you but individually does not identify you, such as the geographic location from which you accessed the Website; and
- About your internet connection, the equipment you use to access our Website, your browsing history, and usage details.
We collect this information:
- Directly from you when you provide it to us;
- Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, mobile device identifiers, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
Information We Collect About You.
The information we collect on or about you may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website (if such a feature is available), creating an account (if such a feature is available), subscribing to a service, or requesting further services or information from us.
- Information you provide to us or we acquire from your network or computing device when you report a problem with our Website and as we troubleshoot and work on the problem you reported.
- Records and copies of your correspondence (including email and mailing addresses), if you contact us.
- Any comments and information you provide to us when you use the “Contact Us” feature of our Website.
- Your responses to surveys that we might ask you to complete.
- Details of transactions you carry out on or through our Website.
- Your search queries on the Website.
- Information that our business partners collect about you, such as the services you have signed up to receive, or products you have purchased, in each case which are related to our business.
- Information you provide when you contact our customer service agents, if available.
- Any other information you provide to us, or we collect throughout your usage of or access to our Website, which we collect for a business purpose.
Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our Website and mobile applications, we may use automatic data collection technologies to collect certain information about you, your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer or mobile device and about your internet connection, including your IP address, mobile device identifier, your operating system, browser type, and the name of your mobile carrier.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically is statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our services and our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
- Analyze our services and products and perform market research.
When you visit or leave our Website by clicking a hyperlink or when you view a third-party site that includes our plugins or cookies (or similar technology), we automatically receive the URL of the site from which you came or the one to which you are directed.
We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we may use to show you local information on our mobile applications and for fraud prevention and security purposes. Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honor your settings.
What are Cookies?
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Note that while you can set your browser to not allow cookies, we may not be able to honor that request, and may track your activity and collect information about you and your online activities even when the browser is set to “do not track.”
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies and you may not be able to shut down our collection of and use of information through this technology.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Flash cookies are not managed by the same browser settings as are used for browser cookies and you may not be able to shut down our collection of and use of information through this technology.
- To identify returning users, registrants and subscribers and to allow them to be presented with a personalized version of the Website.
- To eliminate the need for returning users to re-enter their login details.
- To manage online advertising.
- To associate user activity with the third party website that referred the user to our Website.
- To determine your geographic location in order to provide you with the most relevant search results.
- To associate user activity with the email campaign that referred the user to our Site.
Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. You can usually delete and manage any cookies that have been installed in the cookie folder of your browser as well. Note that some cookies cannot be removed this way, such as persistent cookies. Please refer to Section above titled “What are Cookies?” for more information on the types of cookies you can manage using your browser settings.
You may also consult your mobile device documentation for information on how to disable cookies on your mobile device. However, if you disable all cookies, you may not be able to take advantage of all the features of this Website.
We use Google Analytics, a service provided by Google, Inc. (“Google“) to analyze traffic on our Website. Google utilizes the data collected to track and examine the use of our Website, and to prepare reports for us based on your activities online, among other uses. As part of Google Analytics, Google tracks many variables, including what website you visited prior to coming to our Website, how long you stay on a particular page, and your geographic location.]
Do Not Track
Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser’s DNT option in your browser’s preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly.
Given that there is no recognized industry standard approach to DNT settings, our website does not currently respond to DNT settings at this time.
How We Use Your Information
We may use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account and/or the Website.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection, if needed.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Website, if any.
- For behavioral tracking.
- For any other purpose as needed for our business.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
- To contact you about our own and third-parties’ goods and services that we think may be of interest to you.
- to enable us to display advertisements to our advertisers’ target audiences.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business and assist us in providing services and offering our products.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
- To third parties to market their products or services to you.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to change your password from time to time. We also highly recommend that you use a password that is dissimilar to and cannot be easily found by unauthorized third parties who may have obtained your login credentials to other sites. Keep in mind that if you use the same password for all websites, if someone obtains your credentials for one site, they may be able to then use those credentials to log into any other site you use.
Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted through or collected through the use of our Website. Any transmission of personal information is at your own risk.
We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope.
In particular, our Website collected the following categories of personal information from visitors to the Website within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code §1798.80(e)).
|A name, address, telephone number, education, employment, and employment history.|
|C. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|D. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|E. Geolocation data.||Physical location or movements.|
|F. Professional or employment-related information.||Current or past job history.|
Our Website obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users/consumers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose, subject to your right to opt-out. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Service providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:
- California Customer Records personal information categories.
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Inferences drawn from other personal information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers.
Sales of Personal Information
In the preceding twelve (12) months, the Company has not sold personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your rights under the CCPA and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B personal information.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request submitted via email at email@example.com we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either
- Emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request submitted via email at email@example.com to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to your email associated with that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We will not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at firstname.lastname@example.org.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at email@example.com.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of products or services.
- Suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.
Other California Privacy Rights
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes, except with our affiliates.
Changes to Our California Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Privacy of customers in the European Union
Welcome to our privacy notice for data subjects in the EU. Pegasus respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our Website and tell you about your privacy rights and how the law protects you.
Purpose of This Privacy Notice
This privacy notice aims to give you information on how Pegasus collects and processes your personal data through your use of this Website, including any data you may provide through this Website, when you contact us for information about our services and products.
This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Pegasus is made up of different legal entities including but not limited to: (i) Travel Tripper Limited; (ii) Travel Tripper India Pvt. Ltd; (iii) Pegasus Solutions Japan; and (iv) Pegasus Solutions GmbH. /. This privacy notice is issued on behalf of each of the entities (the “Pegasus Group”). When we mention “Company”, “we”, “us”, “our”, or “Pegasus” in this privacy notice, we are referring to the relevant company in the Pegasus Group responsible for processing your data. The Company is the controller and responsible for this Website.
Our full details are:
- Full name of legal entity: Travel Tripper LLC d/b/a Pegasus
- Email address: firstname.lastname@example.org
- Postal address: 370 Lexington Avenue, Suite 1601, New York, NY 10017, United States
- Telephone number: +1.212.683.6161
Please Contact Us if you would like further information on our appointed representative within the EEA.
The GDPR gives you the right to lodge a complaint with a supervisory authority, in particular in the EU (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred. You can also lodge a complaint through the EU-US and Swiss Privacy Shield Framework as set out in this policy below.
Changes to The Privacy Notice and Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together follows:
- Identity Data includes first name, last name and job title.
- Contact Data includes billing address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
- Usage Data includes information about how you use our Website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.
- We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services; or
- request marketing to be sent to you.
Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers, such as Google based outside the EU;
- search information and social media providers; and
- Identity and Contact Data from publicly availably sources.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting Us or using the “unsubscribe” link contained in any email we send you.
Purposes for Which We Will Use Your Personal Data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out below.
- To register your interest in our services:
- Contact Performance of a contract with you
- Marketing and Communications
- Performance of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
- To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
- Necessary to comply with a legal obligation
- To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you:
- Marketing and Communications
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
- To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences:
- Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
- To make suggestions and recommendations to you about goods or services that may be of interest to you:
- Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
- Promotional Offers from Us. We may use your Identity, Contact, Technical, Marketing and Communications and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and services may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
- Third-Party Marketing. We will get your express opt-in consent before we share your personal data with any company outside the Travel Tripper Group of companies for marketing purposes.
- Opting Out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or Contacting Us at any time.
- Change of Purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out above:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We contract with our third-party service providers to require that they not use your personal data for their own purposes and to authorize them to process your personal data for specified purposes and in accordance with our instructions.
If you are an EU customer your personal data will be transferred outside the European Economic Area (“EEA”).
Whenever we transfer your personal data out of the EEA, we endeavor to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
We maintain security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
Data Retention: How Long Will You Use My Personal Data?
Our intent is to retain your personal data only for so long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at: email@example.com.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Lawful Basis.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
- Third Parties.
- Internal Third Parties. Other companies in the Travel Tripper Group acting as joint controllers or processors and who are based in the UK and India, provide administration and marketing services.
- External Third Parties. Service providers acting as processors based in the United States who help us to deliver our services to you e.g. marketing automation platforms, webinar software, accounting platforms, storage platforms and cloud computing services.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers (based in the United States, United Kingdom and India) who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors based [in the United States, the United Kingdom and India] who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
May 23, 2018