Last updated April 20, 2020.
• Travltalk mobile and web application (App or Website) once you have downloaded a copy of the App or Website onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App or Website (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This App or Website is not intended for children and we do not knowingly collect data relating to children. You must be at least 18 years of age to create an account on Travltalk and use the App or Website. By creating an account and using the App or Website you represent and warrant that you are 18 or over.
Important information and who we are:
Should you wish to speak to us please email: [email protected]
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
It may change and if it does, these changes will be posted on this page. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or Website or the Services. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links:
Our Travltalk Website or App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services..
The data we collect about you:
We collect, use, store and analyse the following data as follows:
• Identity Data: first name, last name.
• Contact Data: email address.
• Financial Data: A link to your in-app purchase account, facilitated by App or Website and Google Play.
• Transaction Data: includes details about payments to and from you and details of in-App or Website purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
• Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content, check-ins.
• Profile Data: includes your userID, first name, last name, gender, date of birth, countries visited, last trip, next trip, biography and travel quote and password, in-App or Website purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our App or Websites or your visits to any of our Sites including, but not limited to, traffic data whether this is required for our own billing purposes or otherwise.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes your current location disclosed by GPS technology.
Special Categories of Personal Data
Where this Policy refers to ‘personal data’, it is referring to data about you from which you could be identified. This includes, but is not limited to your full name, your date of birth, and your contact details.
We may collect sensitive data that you may choose to provide including, but not limited to visual content in the form of photographs and videos, lifestyle, your nationality, your ethnic origin, religion, and/or your sexual orientation. We reserve the right to collect information about your health, and genetic and biometric data, or any information about criminal convictions and offences if legally required.
You have various rights to request information from us or Third Parties about how we use your data, and to prevent unlawful processes. These rights are listed under the ‘Your Legal Rights’ section.
How is your personal data collected?
When using our Travltalk App or Website, we will collect and process the following data about you:
• Information you give us.
This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App or Website, or by corresponding with us (for example, by email or chat). It includes information you provide when you download the App or Website, subscribe to any of our Services, search for an App or Website or Service, make an in-App or Website purchase, share data via an App or Website’s social media functions, enter a competition, promotion or survey, or and when you report a problem with the App or Website or our Services. If you contact us, we will keep a record of that correspondence, where possible.
• Information we collect about you and your device.
Each time you visit our App or Website we will automatically collect personal data including Device, Content and Usage Data. Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
Third Party Analytics Providers:
•Information we receive from other sources including third parties and publicly available sources.
We will receive personal data about you from various third parties from which we have integrated SDKs or formed legal partnerships with around the best in class data collection and management systems.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances (lawful basis of processing):
- Where you have consented before the processing.
By downloading the Travltalk app you give your consent for Travltalk to access the personal data outlined in this document.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal or regulatory obligation.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will only send you direct marketing communications by email or text if we have your opt-in consent. You have the right to withdraw that consent at any time by contacting us. We may send you product related emails without express opt in, if the subject matter relates to key information needed to use the app, such as software updates.
• We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
This sets out:
1. The type of data we use;
2. The purpose/activity for which we will use your personal data; and
3. The lawful data basis for processing.
Type of data we use:
• Marketing and Communications
The purpose/activity for which we will use your personal data and the lawful basis for processing:
To install or login to the App or Website and register you as a new App or Website user.
You give your consent:
To process in-App or Website purchases and deliver Services including managing payments and collecting money owed to us.
To manage our relationship with you including notifying you of changes to the App or Website or any Services.
To administer and protect our business and this App or Website including troubleshooting, data analysis and system testing.
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you.
To measure and analyse the effectiveness of the advertising we serve you.
To monitor trends so we can improve the App or Website.
Disclosures of your personal data
When you consent to providing us with your personal data, you are also giving your consent to share your personal data with the third parties set out below for the purposes set out in the table above:
Internal Third Parties such as, but not limited to:
o Google Tag Manager
o Google API
o Google Analytics
IT and system administration services
- Service providers, professional advisers acting as processors including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
All information you provide to us is stored on our secure servers. Any payment transactions carried out are handled by your App Store.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App or Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Certain Services include interaction with other users. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach. This includes:
• ensuring parties involved are aware they have no right to do this;
• removing personal user access to any platforms containing our user data from parties; and
• police and legal involvement.
We will notify you and any applicable regulator when we are legally required to do so.
We will keep your personal data for as long as you are using the App or Website. In the event that you do not use the App or Website for a period of 5 years then we will treat the account as expired and your personal data may be deleted.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data: see below for further information.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to:
• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
o if you want us to establish the data’s accuracy;
o where our use of the data is unlawful but you do not want us to erase it;
o where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
o you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
App or Website applicable law
You can write to us at our registered office at:
5 Fleet Place, EC4M 7RD, London, UK
Alternatively, please email us at [email protected]
Phew….you made it to the end! Well done, you now know all about what data we store about you and how we use it. That’s important stuff!
We really care about data ethics and love feedback. Let us know what you think – we welcome our user feedback anytime, so drop us an email to [email protected]