Effective date: 25 May 2018
In simple terms:
We process Your profile data (name) to improve, analyze and personalize the Services for You. We have enhanced our privacy center to provide You with more ability to access and control Your data.
1. WHAT PERSONAL INFORMATION WE COLLECT
1.1 USER PROFILE
When You create a user profile in the Services and confirm being the holder of a certain number, MyTRIPS will collect the information provided by You. In order to create a user profile, You must register Your first name, last name and email. MyTRIPS may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. demographic information and additional contact information that is publicly available.
1.2 INSTALLATION AND USE
When You install and use the Services, MyTRIPS will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: device ID or unique identifier; device manufacturer and type; device and hardware settings; SIM card usage and details; applications installed on your device; ID for advertising; ad data, operating system; web browser; operator; connection information; screen resolution; usage statistics; default communication applications; access to device address book; device log and event information; logs, keywords and meta data of incoming and outgoing calls and messages; version of the Services You use and other information based on Your interaction with our Services such as how the Services are being accessed (via another service, web site or a search engine); the pages You visit and features you use on the Services; the services and websites You engage with from the Services; content viewed by You, content You have commented on or sent to us and information about the ads You see and/or engage with; the search terms You use; order information and other usage activity and data logged by MyTRIPS’s servers from time to time.
Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Policy.
1.3 THIRD PARTY SERVICES
You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third party services to create Your user profile or log in to our Services, share information with such third party services, or to connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information and information about the advertisements You have been shown or may have clicked on). You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third party service. We will never store any passwords created for any third party services.
2. HOW WE USE YOUR PERSONAL INFORMATION
2.1 PROVIDE, IMPROVE AND PERSONALIZE OUR SERVICES
MyTRIPS may use the personal information collected to provide, maintain, improve, analyze and personalize the Services to its Users. More specifically, MyTRIPS may use such information to:
Log in to Your personal account in order to use all the features of MyTRIPS.
2.2 STATISTICAL DATA FROM THE SERVICES
We use aggregated or anonymized personal information for statistical and analytical purposes. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise. We may collect, use, transfer, and disclose non-personal information for any purpose.
2.3 PERSONALIZE OUR ADVERTISING AND COMMUNICATIONS
Subject to the choices You make upon registration and in Your settings at any time, we may use the information collected, as set out above, to provide You with location and interest based advertising, marketing messaging, information and services. We may also use the collected information to measure the performance of our advertising and marketing services. Furthermore, we may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, SMS and similar notifications about MyTRIPS’s and our business partners’ products and services. We also use the collected information to respond to you when you contact us.
2.4 COMPLIANCE WITH LAWS AND PREVENTION OF FRAUDULENT OR ILLEGAL ACTIVITIES
We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of MyTRIPS, its Users or any other person and verify provided User profile information with third party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.
3. DISCLOSURE OF PERSONAL INFORMATION
MyTRIPS may disclose personal information if we believe such action is necessary to:
comply with the law, or legal process served on us;
protect and defend our rights and the enforcement of our agreements; or
protect the security and safety of Users or members of the public or other aspects of public importance, provided, of course, that such disclosure is lawful.
We transfer information to trusted vendors, service providers, and other partners who support our business and Services, such as providing technical infrastructure services, bug testing, analyzing how our Services are used, measuring the effectiveness of ads and services and facilitating payments as well as potential partners who may wish to work with us to provide other services that interact or are integrated with our Services. MyTRIPS will always require these third parties to take appropriate organizational and technical measures to protect personal information and to observe applicable legislation. Subject to the choices You make upon registration and in Your settings, MyTRIPS may share personal information with third party advertisers, agencies and networks (such as Google). Such third parties may use this information for analytical and marketing purposes e.g. to provide measurement services and targeted ads and for improvement of products and services.
We may disclose and transfer Your Information to our associated or affiliated organisations or related entities and to any third party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
4. LEGAL BASES AND DATA RETENTION
MyTRIPS will collect and process Your personal information in order to perform the contract with You (e.g. to deliver the Services), based on Your consent (i.e. the choices You make upon registration) or based on a legitimate interest of MyTRIPS (which is not overridden by your interests or fundamental rights and freedoms). Such legitimate interests of MyTRIPS include to protect and maintain the security of the Services, to create and maintain spam blocking directories, to understand and improve our Services and user relationships and to administer our business and customer support. Where we process data based on Your consent, You may withdraw your consent at any time via Your settings.
5. INFORMATION SECURITY AND TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES
The MyTRIPS Services require by their very nature that Your personal information will be transferred to other Users across the globe. MyTRIPS may also use cloud based services and subcontract storage or processing of Your information to third parties located in countries other than Your home country in order to provide the Services, including e.g. the USA. Information collected within the Europemay, for example, be transferred to and processed in a country outside of Europe, which may not provide the same level of protection for personal data as within Europe. We use Model Contractual Clauses adopted by the EU Commission as a legal mechanism for the international transfer of data to a third party located in a country outside Europe. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. MyTRIPS has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.
6. ACCESSING YOUR PERSONAL INFORMATION
Right of access: You may request a confirmation as to whether or not personal information is being processed by MyTRIPS and to obtain a copy of that information. We may decline to process requests that are vexatious or frivolous or extremely impractical, jeopardize the privacy of others, or for which access is not otherwise required by applicable law.
Right to rectification: You may request rectification if Your personal information is inaccurate.
Right to erasure: You may request that your personal information is erased in certain situations e.g. if it is no longer necessary to provide the Services to You.
Right to object: You may object to the processing of Your personal information in certain situations e.g. for use of Your data for ad targeting.
Right to restriction: You may request restrictions of the processing of Your personal information in certain situations e.g. if Your personal information is inaccurate or unlawfully processed.
Right to data portability: You may request to receive personal information provided by You in machine readable format.
7. CHILDRENs PRIVACY
We do not intentionally or knowingly collect or solict information from children under the relevant age of consent under the laws of their respective jurisdictions or knowingly allow such persons to register for the Services. The Services are not directed at children under the relevant age of consent under the laws of their respective jurisdictions. If you believe that we might have information from or about a child under the relevant age of consent, please contact us at [email protected]
9. CONTACT US
You can also send Your enquiries via email to [email protected]