Last Updated January 2023
This privacy notice for Traveler Innovations Ltd (“Company”, “we”, “us”, or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:
The Company’s Privacy Notice applies to information collected when you use our website, as well as to any information we collect about you from third parties. This Privacy Notice does not apply, however, to non-Traveler Innovations Ltd’s products, services, or websites you may access through the Company’s website.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@doona.com.
Summary of key points
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of Contents.
What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Traveler Innovations Ltd and the Services, the choices you make and the products and features you use. Click here for more information.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We do not receive any information from third parties.
Why do we process your information?
We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Click here to learn more
How do we keep your information safe?
We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Click here to learn more
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more
How do you exercise your rights?
The easiest way to exercise your rights is contacting us via email privacy@doona.com. We will consider and act upon any request in accordance with applicable data protection laws.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register to the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Names
Phone numbers
Usernames
Passwords
Contact preferences
Contact or authentication data
Email addresses
Sensitive Information. We do not process sensitive information.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “How do we handle your social logins?” below.
Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
INFORMATION AUTOMATICALLY COLLECTED
In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browse and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location settings on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
*California requires that the Company use different terms in some instances to describe the type of information that the Company collects. For more information, please see Section 11 below regarding California privacy rights.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRVACY RIGHTS?” below).
To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like without your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set our in our Cookie Notice.
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. In the event that you interact with the Company on social media sites, that may cause your information to be published to those social media networks. On those parts of the Company’s website with social network functionality, a social network may be able to collect information about you. For example, Twitter may be able to collect data about your visit to that page, even if you don’t click on the “like” button. To control this sharing of information, you should review the privacy policy of the relevant social network.
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United States[JB1] . If you are accessing our Services form outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short:
In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK and Canada), you have certain rights under applicable data protection laws. There may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification to reassure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE” below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allow, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt our of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
Most web browsers and some mobile operation systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. IF a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use and sharing of “Personal Information” as well as rights to access, delete, and restrict the sale of certain Personal Information the Company collects about them. You may submit a request to exercise these rights by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE” below . The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” If you are a California resident, you have a right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
California residents also have the right, once per year and free of charge, to request information regarding third parties to whom the Company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes under California’s “Shine the Light” law (Cal. Civ. Code 1798.83). Personal Information under this California law means “any information that when it was disclosed, identified, described, or was able to be associated with an individual.” We do not disclose this type of personal information to third parties for their own purposes and the Company permits you to opt out of any disclosures of non-identifiable personal information. However, if you are a California resident and would like to inquire further or make such a request, please email:privacy@doona.com.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.)
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
All other individuals are defined as “non-residents”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
|
|
Category |
Examples |
Collected |
|
A |
Identifiers |
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name |
YES |
|
B |
Personal information categories listed in the California Customer Records statute |
Name, contact information, education, employment, employment history, and financial information |
YES |
|
C |
Protected classification characteristics under California or federal law |
Gender and date of birth |
NO |
|
D |
Commercial information |
Transaction information, purchase history, financial details, and payment information |
NO |
|
E |
Biometric information |
Fingerprints and voiceprints |
NO |
|
F |
Internet or other similar network activities |
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements |
NO |
|
G |
Geolocation data |
Device Location |
YES |
|
H |
Audio, electronic, visual, thermal, olfactory, or similar information |
Images and audio, video or call recordings created in connection with our business activities |
NO |
|
I |
Professional or employment-related information |
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us |
NO |
|
J |
Education information |
Student records and directory information |
NO |
|
K |
Inferences drawn from other personal information |
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics |
NO |
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
How do we use and share your personal information
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
Traveler Innovations Ltd has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Traveler Innovations Ltd. will not sell personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contact us or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
The Company retains the right to change this Privacy Notice at any time and without prior notice to you to reflect changes in personal information practices or relevant laws. If the changes are significant, we may provide a more prominent notice which may include email notification of changes to our Privacy Notice changes. The practices and policies contained in this Privacy Notice replace all previous notices or statements with respect to the same subject. Your access, use, or interaction with us, our third-party providers or our website following the posting of such changes or the updated Privacy Notice will constitute your affirmative consent to and acceptance of any such changes. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at privacy@doona.com.
If you are a resident in the European Economic Area, the “data controller” of your personal information is Traveler Innovations Ltd. Traveler Innovations Ltd has appointed privacy@doona.com to be its representative in the EEA. You can contact them directly regarding the processing of your information by Traveler Innovations Ltd.
If you are a resident in the United Kingdom, the “data controller” of your personal information is Traveler Innovations Ltd. Traveler Innovations Ltd has appointed privacy@doona.com to be its representative in the UK. You can contact them directly regarding the processing of your information by Traveler Innovations Ltd,
You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please send an email to privacy@doona.com