Effective date 23 May 2018
If you have any questions about your personal information email us at email@example.com, or write to us at 15 Bishopsgate, London, EC2N 3AR, United Kingdom.
We’re registered with the Information Commissioner’s Office under number ZA377297.
2. Who we are and general terms
Who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Triptease collects and processes your personal data through your use of the Offerings, including any data you may provide through the Websites or in person. The websites are 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.
The websites 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.
3. The information we collect
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:
A. Information related to your interaction with Triptease and the Offerings
- Registration and contact information. We collect information about you when you (a) register to use the Services and (b) otherwise provide contact information to us via email, mail or though our Offerings. This information you provide may include without limitation your username, first and last name, email address, mailing address or phone number.
- Payment information. When you purchase the Services, we will also collect transaction information, which may include without limitation your credit card information, billing and mailing address, and other payment-related information (“Payment Information”). We describe how Payment Information may be collected and processed in Section 7.
- Third party platforms. We may collect information when you interact with our advertisement and other content on third-party sites or platforms, such as social networking sites. This may include information gathered from social networking profiles (such as Linkedin based outside the EU) or the fact that you viewed or interacted with our content.
- Marketing and Communications information. We collect your preferences in receiving marketing from us and our third parties and your communication preferences.
B. Customer Data
You may submit various types of information and data into the Services for hosting and processing purposes (“Customer Data”). Customer Data may include without limitation:
- Personal information such as names, email addresses and phone numbers of your end user customers, potential customers and other users of and visitors to your websites (“People”), which information may be input into the Services, and
- Information contained in communications between you and People using the messaging features of the Services.
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 goods 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.
4. How we use the information we collect
We use your information in the following ways:
- To perform the contract we are about to enter into or have entered into with you;
- To provide, maintain and improve the Offerings and our other products and services, including to operate certain features and functionality of the Offerings;
- To process your inquiries and otherwise deliver customer service;
- To process your payments, we share and use Payment Information as described in Section 7 (Payment Information);
- 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;
- To control unauthorized use or abuse of the Offerings and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
- To analyze, administer or optimize the use and performance of the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole;
- To communicate directly with you regarding changes to the contract, to the T&Cs and to this policy;
- To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products, services and events. Your opt-out options for promotional communications are described in the following paragraph "Marketing & promotional communication"; and
Marketing & promotional communication
Our promotional communications are split in the following categories:
- Newsletter: updates from the blog (industry news and insights, and tips to boost your direct bookings) plus highlights from the below categories
- Product updates: recent updates and enhancements of the Triptease platform
- Events: information about the Direct Booking Summit, our main event series, plus upcoming events or webinars where you can meet us or hear from us
These communications may be sent via email, in-app messages or direct mail. You can opt out at any time and adjust your preferences as described in Section 9. We may personalize the message content based upon any information you have provided to us and your use of the Triptease Platform.
5. Sharing the information with third parties
We do not sell, trade, share or transfer your personal information to third parties except in the following limited circumstances:
- We may share your personal information with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Offerings, among other things. For example, we may provide personal information to our service providers for direct emailing of our newsletter or notification of our product/service offerings;
- We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
- We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
- We may share your personal information with our business partners who offer a service to you jointly with us, for example when running a cross-promotion;
- We may share your Payment Information to process your payments, as further described in Section 7 (Payment Information);
- We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets;
- We may share information with third-party analytics services to help understand your usage of our services; and
- We may share your personal information to a third party if we have your consent to do so.
We may also share aggregated or anonymised information with third parties for other purposes. Such information does not identify you individually but may include usage, viewing and technical information such as the types of Offering our customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which we collect throughout our technology. If we require under applicable law to treat such information as personal information, then we will only disclose it as described above. Otherwise we may disclose such information for any reason.
6. Information retention
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data. For example all application data is retained for 2 years after a client's contract has ended. This does not include information legally required to keep such as billing history for accounts. Active clients’ data is retained indefinitely.
7. Payment information
8. Other access to disclosure of your information
9. Your Control and Choices
Communication preferences. If you no longer wish to receive our newsletter and the promotional communications described in Section 5, you may opt-out of receiving them by following the instructions included on such communications (by heading to the Preference Centre) or on the Offerings. Please note, however, that you may be unable to opt-out of certain service-related communications.
How we respond to do not track signals. Your web browser may have a “do not track” setting which, when enables, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Offering do not respond to this type of signal.
10. Access and update your personal information
When you use the Offerings, we make good faith efforts to provide you with access to your personal information upon your request and either provide you the means to correct this information if it is inaccurate or to delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your information at any time. To do so, please contact us at firstname.lastname@example.org with your name and the information requested to be accessed, corrected or removed, or if you are using the Service, sign in to your account, go to your profile, and make the desired changes. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing in backup archives), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Please note that if you cease using the Service or we terminate your access to the Service in accordance with your Customer Agreement, you may no longer have the ability to access or update your information.
We may retain your information as necessary to support the Offering, comply with our legal obligations or resolve disputes. Note that content you post may remain on the Offerings even if you cease using the Offerings or we terminate your access to the Offerings.
12. Children under age 13
13. California privacy rights and disclosures
California Shine the Light Law. If you are a California resident and we disclose your personally identifiable information to third parties for such third parties’ direct marketing purposes, California’s Shine the Light Law (CA Civil Code Section 1798.83) allows you to request certain information from us about such disclosures. To make a request under the Shine the Light Law, please contact us at email@example.com. Please note that under California law, businesses are not required to respond to such requests more than once during any calendar year.
California Minors. At any time, you can delete or remove your posts using the same deletion or removal procedures described in Section 11 above, or otherwise through the Offerings. If you have questions about how to remove your posts or if you would like additional assistance with deletion you can contact our support team at firstname.lastname@example.org. Although we offer deletion capability for our Offerings, you should be aware that the removal of posts may not ensure complete or comprehensive removal of that content or information posted through the Offerings.
The security of your personal information is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Further, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect personal information about you. When you enter sensitive information (such as your password), we encrypt that information in transit using industry-standard Transport Layer Security (TLS) encryption technology. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
15. International transfer of data