Privacy Policy

By accessing the Platform, by using the Services or providing / making available information for use by us, you agree to the practices and policies outlined in this Privacy Policy and you hereby consent to our collection, use and sharing of information as described in this Privacy Policy. If you do not wish to agree to these terms, do not access the Platform or use the Services. Furthermore, you hereby waive any rights or requirements under any laws or regulations in any jurisdiction which require an original (non-electronic) signature or delivery or retention of non-electronic records, to the extent permitted under applicable law.

GENERAL

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you through the use of our Services, or the use of the Platform, how that information may be used or disclosed by us and the safeguards we use to protect it.

Our Platform and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices. Please read this document carefully to understand our policies regarding your information and how we will treat it.

By using or accessing the Platform or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Platform, or the Services, is deemed to be acceptance of such changes, so please check periodically for updates

When you use or access the Platform or the Services, you do so at your own discretion and provide any such personal details requested at your own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed below.

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INFORMATION WE COLLECT:

In order for you to access the Platform and/or the Services, you will be required to provide us with certain information that personally identifies the person such information belongs to (“Personal Information”). Personal Information includes the following categories of information:

a) Identity Data

Includes first name, last name, username, or similar identifier and age. When you contact us, we may collect information such as your first name, last name, email address and phone number. We may ask for your date of birth to send you birthday offers or anniversary offers.

b) Contact Data

includes billing address, invoicing address, email address and telephone numbers.

c) Financial Data

Includes bank account and payment card details. We use a third party payment provider to collect financial data and all credit card information for all transactions that go through the Platform. It follows secure encrypted processes a standard for the e-commerce industry.

d) Transaction Data

Includes details about payments and other details of Services you have availed.

e) Technical Data

Includes internet protocol (IP) address, your login data, 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

f) Account Data

Includes your username and password, Bookings made by you, your interests, preferences, feedback, and survey responses

g) Usage Data

Includes information about how you use the Platform and Services

h) Marketing and Communications Data

Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

i) Booking Data

Includes information relating to Bookings and special requests

j) Cookies Data

k) Third Parties

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Platform. We work closely with third parties (including, for example, travel partners, sub-contractors, advertising networks, analytics providers, search information providers, software suppliers) and may receive information about you from them.

l) Analytics

Includes third-party analytics services (such as Google Analytics) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Platform, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

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 by law as this data does not directly or indirectly reveal your identity.

We also collect some non-personally identifiable information (ourselves or using third party services) using web analytic tools. We use third-party services that use tracking technologies to capture aggregate usage and volume statistics about interactions on our Website and Services.

We may collect Booking Data about you for the purposes of making a booking for a tour. You agree that we may process your Booking Data that you may provide to us in order to complete your booking and that such Booking Data may be transferred to our relevant Travel Partners for this purpose

We also get information on how you use our Services, such as tracking information, to enable our Services to be used correctly, we may need to use tracking information. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

• a) you have given consent to the processing of your personal data for one or more specific purposes;
• b) if processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
• c) if processing is necessary for compliance with a legal obligation to which we are subject;
• d) if processing is necessary to protect the vital interests of you or of another natural person;
• e) if processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
• f) if processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

If we receive personal information in the course of providing our Services to you from another data subject, we expect you to have complete responsibility for ensuring that the contents of this Privacy Policy are brought to their attention and you have obtained their consent in the process.

If you choose not to provide the personal information we request, you can still visit most areas of the Platform, but you may be unable to access certain options and services that involve interaction. You have the final decision on whether to proceed with any activity that requests personal information.

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 our Services). In this case, we may have to cancel a Booking reservation you have with a Travel Partner, but we will notify you if this is the case at the time.

COLLECTION OF YOUR DATA

We (or third-party data processors, agents and sub-contractors acting on our behalf) may collect, store, and use your personal information by way of different methods to collect data from and about you including through direct interactions.

This includes personal data you provide when you enquire about our Services or Travel Partner Services, create an account on the Platform; request marketing to be sent to you; enter a competition, promotion, or survey; or give us some feedback.

We may automatically collect technical data about your computer/mobile 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. We shall contract with third parties to supply our Services to you on our behalf. These include our Travel Partners for reservations, payment processing, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data.

OUR USE OF YOUR INFORMATION We may use your Personal Information to recommend you Service to identify or interact with you on social media, to send you information about Travel Partners, our Company, our Services, or to contact you when necessary in furtherance of a request, enquiry, or a Booking. We may use your geolocation to provide services to you. We may use your data to customize and tailor your experience on the Platform, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences. Without limitation to the foregoing, your information may be used:

• (i) To develop, enhance, market, sell or provide our products or services, or those of companies with which we have a commercial relationship;
• (ii) To communicate information pertaining to Services you avail
• (iii) To issue invoices, administer accounts, collect, and process payments;
• (iv) To provide tips or guidance on how to use Platform, the facilities we offer, inform you of new features, or provide other information that may be of interest to you;
• (v) To personalize the service we provide to you, tailor your experience to your requirements and make more appropriate recommendations;
• (vi) To send you e-mails, e-newsletters, personalized offers via direct messaging or other communications about our services;
• (vii) To collect feedback on Travel Partners, your Bookings, the Platform, or the Services;
• (viii) To process and track your transactions and to send you information about Us, our affiliates’, service providers’ and business partners’ products and services and other information and materials that may be of interest to you;
• (ix) To audit compliance with our policies, contractual, and statutory obligations;
• (x) To prevent fraudulent transactions on the platform;
• (xi) To collect payments;
• (xii) To analyse software usage patterns for improving product design and utility;
• (xiii) To analyse anonymized practice information for commercial use; and
• (xiv) As permitted by, and to comply with, any legal or regulatory requirements or provisions; or for any other purpose to which you consent.

PURPOSES FOR WHICH WE WILL USE YOUR INFORMATION

We have set out below, a description of the purposes for which we use your personal data, and which of the relevant lawful basis that we rely on to do so, including where your personal data is passed to the relevant third party Travel Partners, for the purposes of providing our Services. 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.

Details on our Platform, to register new customers, including completing registration forms or to submit an enquiry with us.

• Type of data: (a) Identity (b) Contact (c) Booking Data.
• Lawful basis for processing: (a) Performance of a contract with you (b) Consent (for use of Booking Data).

Information to process Bookings including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Process bookings and passing your personal data to our relevant Travel Partners for confirming a booking and for Travel Partner to provide Travel Partner Services (d) Undertake reviews.

• Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Booking Data.
• Lawful basis for processing: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent (for use of Booking Data).

Information to manage our relationship with our customers, or prospective customers which will include: (a) Notifying about changes to our terms (b) Asking to leave a review or take a survey (c) Correspondence (d) For internal administrative purposes.

• Type of data: (a) Identity (b) Contact (c) Account (d) Marketing and Communications.
• Lawful basis for processing: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services).

To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

• Type of data: (a) Identity (b) Contact (c) Technical
• Lawful basis for processing: (a) 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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation.

To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

• Type of data: (a) Identity (b) Contact (c) Account (d) Usage (e) Marketing and Communications (f) Technical.
• Lawful basis for processing: 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 Platform, Services, marketing, customer relationships and experiences

• Type of data: (a) Technical (b) Usage.
• Lawful basis for processing: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform 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.

• Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Account (f) Marketing and Communications.
• Lawful basis for processing: Necessary for our legitimate interests (to develop our products / services and grow our business).

Monitoring and preventing unlawful acts.

• • Type of data: All categories
  • Lawful basis for processing: Necessary for the purposes of the prevention or detection of an unlawful act, and must be carried out without the consent of the data subject so as not to prejudice those purposes, and is necessary for reasons of substantial public interest.

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 that 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.

DISCLOSURE OF INFORMATION

Except as described in this Policy, we will not, without your consent, disclose information about you.

We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

1.Any information that you voluntarily choose to include in a publicly accessible area of the Platform will be available to anyone who has access to that content, including other Users and Travel Partners.2.We will disclose information about you to Travel Partners and other third parties to assist you with Services.3.We may work with third-party service providers to provide various services. These third-party service providers may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.4.We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to

(i) take precautions against liability;(ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) enforce our policies, to protect ours or others’ rights, property, or safety; (iv) investigate and defend ourselves against any third-party claims or allegations; (v) protect the security or integrity of the Service and any facilities or equipment used to make the Service available; (vi) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

Information about users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

We may make certain aggregated, automatically-collected, or otherwise non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.

We do not allow our third-party service providers to use your personal data for their own purposes (unless you give them permission to do this yourself) and only permit them to process your personal data for specified purposes and in accordance with our instructions.

DATA SECURITY

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. For example, we take physical and electronic process-specific security measures, including firewalls, personal passwords, and encryption and authentication technologies. Such measures include, but are not limited to, secure sockets layer encryption, routine security audits and scans, routine updating and patching of all servers, services, and applications, as well as usage of code intended to block attacks.

Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, you should understand that there is no such thing as complete security, and we do not guarantee that there will be no unintended disclosures of your Personal Information. If we become aware that your Personal Information has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as required by applicable law.

DATA RETENTION

As a general rule, the personal data that is processed by us as set forth herein is not retained for longer than necessary for the purpose for which it was processed. More specifically, we retain and delete your personal data as follows:

1. Usage data will be retained indefinitely for the purpose of monitoring the historical performance of our Platform.
2. Personal Information shall be retained till such time as you continue to avail our Services, following which an aggregate version thereof shall be retained.
3. Your account related data will be retained for a period of [•] years after our last transaction with you, after which it will be deleted unless required for auditing or legal reasons.

Notwithstanding the aforementioned, in some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the period we need to access the data for the provision of services, receiving payment, resolving business or other issues or any other auditing or legal reasons. Further, notwithstanding this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

COOKIES

Cookies are small pieces of information saved by the browsers. You can set your browser to notify you whenever a cookie is sent to you, giving you the option to decide whether or not to accept it. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.

Some of the web pages on our Platform may use cookies to serve you customized contents for your return visits to our Platform. Cookies also help us in authentication, enhancement of security, display targeted information and most importantly, help us improve your experience on the Platform.

When you visit our Platform, we may place a number of cookies in your browser. These are known as First Party Cookies and are required to enable to hold session information as you navigate from page to page within the Platform. For example, we use cookies on our Platform to understand visitor and user preferences, improve their experience, and track and analyse usage, navigational and other statistical information. Additionally, cookies allow us to bring you advertising both on and off the Platform and bring customized features to you. You can control the use of cookies at the individual browser level. If you elect not to activate the cookie or to later disable cookies, you may still visit our Platform, but your ability to use some features or areas of the Platform may be limited.

CONTROLLING PERSONAL INFORMATION

Under the GDPR, you have the right to: a) request access to, deletion of or correction of, your personal data held by us at no cost to you; b) request that your personal data be transferred to another person (data portability); c) be informed of what data processing is taking place; d) restrict processing; e) to object to processing of your personal data; and f) complain to a supervisory authority. To enforce any of the foregoing rights or if you have any other questions about our Platform or this Privacy Policy, please contact us at team@goodpass.co

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 could refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within three months. Occasionally it could 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.

UPDATES AND CHANGES TO PRIVACY POLICY

We may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way we treat User’s personally identifiable information, or in the Privacy Policy itself, we will display a notice on the Platform or send Users an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services.