Privacy statement
Sinbad Voyage L.L.C (hereinafter only referred
to as “Sinbad Voyage L.L.C” or ”we”) takes the protection of your personal data
as the Data Controller very seriously. We treat your personal data
confidentially and in accordance with the provisions of data protection law.
This privacy statement informs you about how, to what extent and for what
purposes we process the personal data of customers using the Sinbad Voyage
L.L.C website and App.
Version No.: 1.0
Date: 01/1/2019
I. SUBJECT OF DATA PROTECTION
Subject of data protection is personal data.
Data is personal if it can be assigned to an identified or identifiable natural
person. This includes information such as names, addresses, email addresses and
telephone numbers.
II. COLLECTION, PROCESSING AND USE OF PERSONAL DATA ON REQUEST
The use of our website and App is generally
possible without providing personal data. You are neither obliged to visit this
website nor to provide any personal data. If you do not provide us with
personal data, you might not be able to use individual functionalities of this
website. Otherwise there will be no consequences for you. The collection of
users’ personal data on our site is always on a voluntary basis, except in the
cases described in the following. We would like to point out that data
transmission over the Internet (e.g. communication by email) can have security
gaps. A complete protection of data against access by third parties is not
possible.
We collect, process and use your personal data,
which you have provided us with when booking or registering an account for our
member area, to the extent necessary in each case for the following purposes:
1. Registration and execution of the contract
» Data that you provide when setting up an
account, such as your name, email address, telephone number, mobile phone
number, address and data which will be provided depending on the service you
use
» We collect, process and use transaction data
regarding your activities on the websites (e.g. purchases, content that you
generate or that relates to your account)
» Billing and other data you provide for the
purchase
» Data collected in the context of reviews,
chats and correspondence on the website or by email, fax and post
» Other personal data that we may ask you to
provide for special purposes
» If you voluntarily provide us with additional
personal data during registration, this data will also be used for the
implementation of the usage relationship.
2. Contact establishment
If you provide us with personal data for the
purpose of contacting us, this data will be used by us as this is necessary for
the purpose of the respective communication.
3. Marketing
Sinbad Voyage L.L.C may process and use your
personal data for marketing purposes, e.g. to send emails with general
information or of an advertising nature (newsletter), on the basis of the
declaration of consent you have given us.
You can revoke the declarations of consent
granted to us in this regard at any time with effect for the future. If you wish
to opt-out of receiving these emails from us, please follow the instructions
contained in an applicable email you receive from us, which will allow you to
opt-out of receiving these types of email communications from us. In addition,
you can object to this use – insofar as we use your personal data within the
legally permissible framework for e.g. postal marketing measures. In both
cases, an email to the following address is sufficient: support@tripaloca.com.
4. Information you provide to Payment Processors
All payments made are processed by a
PCI/DSS-compliant (these are payment card industry security standards) payment
processing service engaged by us. All information collected by these
third-party providers for purposes of processing your payments is not available
to us unless you have otherwise provided this in-formation to us in connection
with your use of the Websites or our products and services.
5. Aggregate Information
We may share your information with affiliated or
unaffiliated third parties on an anonymous, aggregate basis. While this
information will not identify you personally, in some instances these third
parties may be able to combine this aggregate information with other data they
have about you, or that they receive from third parties, in a manner that
allows them to identify you personally.
III. DATA PROCESSING TO ENABLE THE USE OF THE WEBSITE
When you visit our website, we collect the
necessary data to enable you to use it (usage data). This includes your IP
address and data about the start, end and subject of your use of the website as
well as any identification data (e.g. your login data when you log into a
secure area). This data is used to provide and design the service according to
users’ preference. This data is always deleted as soon as it is no longer
required and if there are no storage obligations. For information on the
processing of pseudonymous usage profiles, see item VII.
IV. DATA PROCESSING FOR MOBILE APPLICATIONS AND DEVICES
When you download data, use our mobile
applications or access one of our websites optimized for mobile devices, we may
collect information about you and your mobile device as described above in this
statement. This can include location data, for example, if you release it for
our mobile application. We use this information to provide you with
location-based services such as search results and other personalized content,
if approved by you and your device. You can control or deactivate location
services from the settings menu on most mobile devices. If you have questions
about deactivating location services on your device, we recommend that you
contact your mobile service provider or the manufacturer of your device.
If we collect other personal data that is
transferred as a result of your use of our mobile applications or your access
to our website with a mobile device, we will obtain your express consent in
advance.
V. DATA COLLECTED FROM OTHER SOURCES
We may obtain additional information about you
from third parties to supplement our account information to the extent
permitted by law. This includes demographic and navigation data, credit check
data and other information from credit agencies, to the extent permitted by
law.
VI. COOKIES
When you visit our website, information may be
stored on your computer in the form of a cookie.
This Section describes the cookies we use and
explains why we use cookies and how we deal with the collected information. It
also explains how cookies enable our website and App to function properly and
why you may not be able to experience the full functionality of the website if
you disable the use of cookies. By visiting our website without changing your
settings, you agree to receive all cookies and other data collection tools;
however, if you do not accept the use of these cookies, you can change your cookie
settings at any time. All the companies or networks that we work with have
their own privacy policies and offer a mechanism for users to opt out tracking
and behavioral targeting available through the ad itself or through the opt out
mechanisms listed in the ‘How to control or delete cookies’ section.
1. What are Cookies?
Cookies are text files containing small amounts
of information which are downloaded to your computer or mobile device when you
visit a certain webpage. Cookies are then sent back to the originating webpage
on each subsequent visit, or to another webpage that recognizes that cookie.
Cookies are widely used to make our website work, or to work more efficiently,
as well as to provide information to the owners of the website.
Cookies do lots of different jobs, like letting
you navigate between pages efficiently, remembering your preferences, and
generally improving the user experience. Cookies may tell us, for example,
whether you have visited our website before or whether you are a new visitor.
They can also help to ensure that adverts you see online are more relevant to
you and your interests.
There are two broad categories of cookies:
» first party cookies served directly by us to
your computer or mobile device;
» third party cookies, which are served by a
third party on our behalf. We may use third party cookies for functionality,
perfor-mance/analytics, advertising/tracking and social media purposes.
Cookies can remain on your computer or mobile
device for different periods of time. Some cookies are session cookies, meaning
that they are stored only temporarily during a browsing session and expire when
you close your browser. Other cookies are persistent cookies, meaning that they
are saved on your computer or mobile device for a fixed period and are not
deleted when browser is closed. They can be used by our website to recognize
your computer or mobile device when you open your browser and browse the
Internet again.
2. Why do we use Cookies?
We use cookies for a variety of reasons,
including to:
» enable, facilitate and streamline the
functioning of and your access to our website;
» track traffic flow and patterns of travel in
connection with our website;
» understand the total number of visitors to our
Website on an ongoing basis and the types of internet browsers (e.g. Firefox,
Chrome or Internet Explorer) and operating systems (e.g. Windows or Mac OS)
used by our visitors;
» monitor the performance of our website and
continually improve it;
» customize and enhance your online experience.
3. What types of Cookies do we use?
The types of cookies used by us and our partners
in connection with our website can be classified into one of five categories,
namely “cookies necessary for essential Our purposes”, “functionality cookies”,
“performance and analytics cookies”, “advertising and tracking cookies”, and
“social media cookies’. We have set out some further information about each
category, and the purposes of the cookies we and third parties set in the
following table.
Cookies necessary for our essential purpose:
These cookies are essential in providing you
with our website and all services available through the website. These cookies
also support with features, such as access to secure areas. Without these
cookies, services you have asked for, such as transactional pages and secure
login accounts, would not be possible.
Functionality Cookies:
Functionality cookies record information about
choices you have made and allow us to tailor our website to you. These cookies
mean that when you continue to use or come back to the website, we can provide
you with our services as you have asked for them to be provided. For example,
these cookies allow us to:
– Save your location preference if you have set
your location on your homepage, and, if applicable, to receive a local weather
forecast;
– Remember settings you have applied, such as
layout, text size, preferences, and colors;
– Show you when you are logged in;
– Store accessibility options
Performance and Analytics Cookies:
We use performance/analytics cookies to analyze
how our website is accessed, used, or is performing to provide you with a
better user experience and to maintain, operate and continually improve the
website. For example, these cookies allow us to:
– Better understand the visitors of our website
in order to improve and insure present and relevant content;
– Test different design ideas for particular
pages, such as our homepage;
– Collect information about our website
visitors, such as where they are located and what browsers they are using;
– Determine the number of unique users that
visit our website;
– Improve our website by measuring any errors
that occur;
– Conduct research and diagnostics to improve
product offerings.
We use Google Analytics and many other analytics
tools to helps us understand how users engage with the website. These web
analytics services use first-party cookies to track user interactions, in our
case, this means they are used to collect information about how are visitors
are using our website.This information is used to compile reports and create
services to help us improve our website and the services associated with it.
The reports disclose website trends without identifying individual visitors.
Some services will allow you to opt out of tracking with their services
directly. For instance, while you cannot opt out of use of cookies with our
site, you can opt out of Google Analytics without affecting how you visit our
site – for more information on opting by Google Analytics across all websites you
use, visit this Google page.
Advertising and Tracking Cookies:
We may allow third party companies, including
advertising companies (such as Google), to place cookies on our website. These
cookies enable such companies to track your activity across various sites where
they display ads and record your activities, so they can show ads that they
consider relevant to you as you browse the Internet. These Cookies store
information about the content you are browsing together with an identifier
linked to your device or IP address.
These Cookies also allow us and third parties to
know whether you’ve seen an ad or a type of ad, and how long it has been since
you’ve last seen it. This information is used for frequency capping purposes,
to help tailor the ads you see, and to measure the effectiveness of ads.
Third Party Cookies:
There are various pages on our website where
third parties provide applications of their own cookies to track the success of
their services (applications) or customize applications for you. Due to how
these cookies work, we cannot access the cookies, nor can the third parties
access the data in cookies used by us. Some pages of our website may also
contain embedded content and these third-party sites may set their own cookies.
4. How to control or delete Cookies
You have the right to accept or stop cookies
from being stored on your device at any time by modifying the settings in your
web browser to reflect your cookie preferences.
Please be aware that you may not be able to use
all the interactive features of the website and/or online courses and content once
cookies are disabled.
Most browsers offer instructions on how to
change your cookie settings. These settings will typically be found in the
“options” or “preferences” menu of your browser.
5. Cookies that have been set in the past
If you have disabled one or more Cookies, we may
still use information collected from cookies prior to your disabled preference
being set, however, we will stop using the disabled cookie to collect any
further information.
VII. PSEUDONYMOUS USAGE PROFILES FOR ADVERTISING AND MARKET RESEARCH (WEB TRACKING AND ANALYSIS)
Sinbad Voyage L.L.C uses web tracking systems
for advertising, market research and to make your use of our website as
pleasant as possible. This allows us to further develop our website and tailor
content to your needs. Sinbad Voyage L.L.C and third-party businesses may use
the information collected through the Sites using cookies, web beacons, and
other similar technologies to help manage online advertising programs. This information
may enable us and our third-party advertising services and other third-party
businesses to track the actions of users online over time and across different
websites or platforms to measure statistics relating to marketing efforts, and
to deliver electronic advertisements that may be more relevant to individual
consumers and that will improve the consumer experience. For information about
how tracking works for online advertising purposes, and what happens when you
elect a do-not-track option, visit http://www.aboutads.info/choices. In addition, some third-party businesses may
provide a mechanism to opt-out of their technology. For more information about
the opt-out process, you may visit the Network Advertising Initiative website,
available at: http://www.networkadvertising.org/managing/opt_out.asp.
VIII. LEGAL BASIS FOR DATA PROCESSING
If you reside within the European Economic Area
(EEA), our processing of your personal information will be legitimized as
follows:
(i.) Whenever we require your consent for the
processing of your personal information such processing will be justified
pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation
(EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can
be done lawfully.
(ii.) If the processing of your personal data is
necessary for the perfor-mance of a contract between you and Sinbad Voyage
L.L.C or for taking any pre-contractual steps upon your request, such
processing will be based on GDPR Article 6(1) lit. (b).”). If this data is not
processed, Sinbad Voyage L.L.C will not be able to execute the contract with
you.
(iii.) Where the processing is necessary for us
to comply with a legal obligation, we will process your information on basis of
GDPR Article 6(1) lit. (c), for example complying in the fields of employment
law.
(iv.) And where the processing is necessary for
the purposes of Sinbad Voyage L.L.C’s’ legitimate interests, such processing
will be made in accordance with GDPR Article 6(1) lit. (f), for example to
detect fraud.
IX. SOCIAL NETWORKS
Our website contains links to social networks
(Facebook, Instagram, Twitter, Google+, Pinterest, LinkedIn). These social
networks are operated exclusively by third parties. If you follow the links,
information may be transmitted to these third parties. We use the so-called
2-click solution. This means, in general, that no personal data will be passed
on if you visit our site.
X. TRANSMISSION TO THIRD PARTIES
Your personal data will only be transmitted to
third parties if this is legally permitted or if you have given your prior
consent. In particular, we will not sell your data to third parties or market
it in any other way. We will only disclose your data to government authorities
as part of legal obligations or as a result of an official order or court
decision. We have bound our employees and partners to secrecy and to comply
with data protection regulations.
XI. HOW WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES
Except as set forth in this Privacy Statement or
when specifically agreed to by you, we will not disclose personal information
we gather from you to third parties unless we are required to share this
information to complete your request or for legitimate business purposes. Sinbad
Voyage L.L.C shares personal information in the following circumstances:
We may share your information with vendors or
third parties who deliver or provide goods and services or otherwise act on
behalf of or at the direction of Sinbad Voyage L.L.C. These third parties may
include, for example, our third-party (technology) providers, Suppliers and
partners. These third-party service providers will only have access to the
information needed to perform these limited functions on our behalf.
XII. DATA TRANSMISSION TO COUNTRIES OUTSIDE THE EU
As far as this is necessary for the initiation
or execution of the contract – e.g. to process bookings for activities in
countries outside the EU – we will transmit your data outside the EU. The same
applies if such a transmission turns out to be necessary for our purposes. In
this respect, we ensure that the data recipient guarantees an appropriate level
of data protection and that no other interests worthy of protection conflict
with the data transmission. Sinbad Voyage L.L.C relies on derogations as set
forth in Article 49 of the GDPR in the event no “adequacy” decision and no
other safeguards under the GDPR are in place (for example binding corporate
rules on the transfer outside the EEA). In particular, we collect and transfers
to countries outside the EU personal data only: with your explicit consent; to
perform a contract with you; in a manner that does not outweigh your rights and
freedoms. If this data is not processed and transferred, Sinbad Voyage L.L.C
will not be able to execute the contract with you or you will not have access
to any or all of the benefits and features associated with your transaction. We
endeavour to apply suitable safeguards to protect the privacy and security of
your personal data and to use it only consistent with your relationship with Sinbad
Voyage L.L.C and the practices described in this Privacy Statement. In the
event that you have any questions to this end, please contact our Data
Protection Officer.
XIII. DELETION OF DATA
We retain data for the duration of your business
relationship with us and otherwise as required under applicable law. Personal
data will be kept for no longer than is necessary for the purposes for which
your personal data are processed. We will retain your personal data as long as
you have a member account or require our services so that we can provide these
services to you.
If you are in the European Economic Area, at the
moment you withdraw your consent for the processing of your personal data, all
your personal data received and stored are erased if no longer needed by us.
Unless we are required to retain this personal data by law or to comply with
our regulatory obligations. In such a case, we will only keep this personal
data for as long as necessary. For more information on where and how long your
personal data is stored, and for more information on your rights of erasure and
portability, please contact our data privacy resource at dataprotectionofficer@tripaloca.com
.
XIV. DATA SECURITY
Sinbad Voyage L.L.C has taken the necessary
technical and organisational measures to protect the personal data provided by
you against loss, de-struction, manipulation and unauthorized access. Our
employees and all persons involved in data processing are obliged to comply
with the data protection laws and to treat personal data confidentially. Our
employees have been trained accordingly. Both internal and external audits
ensure compliance with all data protection processes at Sinbad Voyage L.L.C.
We use a secure online transmission procedure, the
so-called “Secure Socket Layer” (SSL) transmission, to protect the
personal data of our users. You can see this from the fact that an
“s” (https://) is added to the address component http://, or a green,
closed lock icon is displayed. By clicking on the icon, you will receive
information about the SSL certificate used. The display of the icon depends on
the browser version used by you. The SSL encryption guarantees that your data
is transmitted in an encrypted and complete way.
XV. EUROPEAN UNION DATA SUBJECTS RIGHT
The European Union’s General Data Protection
Regulation and other countries’ privacy laws provide certain rights for data
subjects. If you wish to confirm that Sinbad Voyage L.L.C is processing your
personal data, or to have access to the personal data Sinbad Voyage L.L.C may
have about you, or have other questions, please contact us via dataprotectionofficer@tripaloca.com.
You may also request information about: the
purpose of the processing; the categories of personal data concerned; who else
outside Sinbad Voyage L.L.C might have received the data from us; what the
source of the information was (if you did not provide it directly to Sinbad
Voyage L.L.C); where the personal data is stored and how long it will be
stored. You have a right to correct (rectify) the record of your personal data
maintained by us if it is inaccurate. You may request that we erase that data
or cease processing it, subject to certain exceptions. You may also ask us for
your personal data to be supplemented or updated, or for their transformation
into anonymous format or to block any data held in violation of the law, as
well as to oppose their treatment for any and all legitimate reasons. You may
withdraw your consent for the processing of personal data or the further
processing of personal data by us at any time. You may also request that Sinbad
Voyage L.L.C ceases using your data for direct marketing purposes. In many
countries (including EEA countries), you have a right to lodge a complaint with
the appropriate data protection authority if you have concerns about how Sinbad
Voyage L.L.C processes your personal data. When technically feasible, we
will—at your request—provide your personal data to you or transmit it directly
to another controller. You have the right to receive your personal information
in a structured and standard format.
In addition to the information contained in this
Privacy Statement, you may be provided with additional and contextual
information concerning particular services or the collection and processing of
your personal data upon request.
XVI. NO AUTOMATED INDIVIDUAL DECISION
We do not use your personal data for automated
individual decisions.
XVII. HOW CAN YOU CONTACT US?
Or by email: service@tripaloca.com
You can contact our Data protection Officer at: dataprotectionof-ficer@tripaloca.com
XVIII. CHANGES TO THE PRIVACY STATEMENT
From time to time, we may need to update or
modify this Privacy State-ment, to reflect changes in our business practices,
data collection practices or organization. We reserve the right to amend this
Privacy Statement at any time, for any reason, without notice to you, other
than the posting of the amended Privacy Statement on our website, or, if you
have provided your email address to us, sending you an email notifying you of
the amended Privacy Statement. It is strongly recommended to check the Website
often, referring to the date of the last modification listed at the top. We
will in any case not reduce your rights under this Privacy Statement without
your explicit and informed consent. If you do not agree to the changes, you
should discontinue your use of the Website, and cease providing personal
information to us, prior to the time the modified Privacy Statement takes
effect. If you continue using the Website or provide personal information after
the modified Privacy Statement takes effect, you will be bound by the modified
Privacy Statement.
