Clear rules are the first step to protecting your and your client's data.
I. What kinds of information do we collect?
To provide TravelCicle.net, we must process information about you. The types of information we collect depend on how you use our Products.
Things you and others do and provide.
- Information and content you provide. We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. It can also include what you see through features we provide, such as our camera, so we can do things like suggest masks and filters that you might like, or give you tips on using portrait mode. Our systems automatically process content and communications you and others provide to analyse context and what's in them for the purposes described below.
- Networks and connections. We collect information about the people, Pages, accounts, hashtags and groups you are connected to and how you interact with them across our Products, such as people you communicate with the most or groups you are part of. We also collect contact information if you choose to upload, sync or import it from a device (such as an address book or call log or SMS log history), which we use for things like helping you and others find people you may know and for the other purposes listed below.
- Your usage. We collect information about how you use our Products, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Products, and what posts, videos and other content you view on our Products.
- Things others do and information they provide about you. We also receive and analyse content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync or import your contact information.
As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use. For example, we use information collected about your use of our Products on your phone to better personalize the content (including ads) or features you see when you use our Products on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad we showed you on your phone on a different device.
Information we obtain from these devices includes:
- Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
- Device operations: information about operations and behaviours performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
- Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
- Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
- Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network, so we can do things like help you stream a video from your phone to your TV.
II. How do we use this information?
We use the information we have (subject to choices you make) as described below and to provide and support TravelCircle.net and related services described in the TravelCircle.net Terms. Here's how:
Provide, personalize and improve our Products.
We use the information we have to deliver our Products, including to personalize features and content (including your Circle Feed & Plan Feed,) and make suggestions for you on and off our Products. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others (including any data with special protections you choose to provide where you have given your explicit consent); how you use and interact with our Products; and the people, places, or things you're connected to and interested in on and off our Products.
Location-related information: We use location-related information-such as your current location, where you live, the places you like to go, and the businesses and people you're near-to provide, personalize and improve our Products, including ads, for you and others. Location-related information can be based on things like precise device location (if you've allowed us to collect it), IP addresses, and information from your and others' use of TravelCircle.net (such as check-ins or events you attend).
Product research and development: We use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
Ads and other sponsored content: We use the information we have about you-including information about your interests, actions and connections-to select and personalize ads, offers and other sponsored content that we show you. Learn more about how we select and personalize ads, and your choices over the data we use to select ads and other sponsored content for you in the TravelCircle.net Settings.
Provide measurement, analytics, and other business services.
We use the information we have (including your activity off our Products, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services and understand the types of people who use their services and how people interact with their websites, apps, and services. Learn how we share information with these partners.
Promote safety, integrity and security.
We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off.
Communicate with you.
We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
III. How is this information shared?
Your information is shared with others in the following ways:
Sharing on TravelCircle.net
People and accounts you share and communicate with
When you share and communicate using our Products, you choose the audience for what you share. For example, when you upload a Location, you select the audience for the post via the Circle feature, this selects the group you are sharing the information with.
Public information can be seen by anyone, on or off our Products, including if they don't have an account. This includes your TravelCircle.net username; any information you share with a public audience; information in your public profile.
Content others share or re-share about you
You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with. For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot, or re-share that content to others across or off our Products. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content, and that person can change the audience later.
People can also use our Products to create and share content about you with the audience they choose. For example, people can share a photo of you in a Location Post, mention or tag you at a location in a post, or share information about you in their posts or messages. If you are uncomfortable with what others have shared about you on our Products, you can report the content.
Information about your active status or presence on our Products.
People in your networks can see signals telling them whether you are active on our Products, including whether you are currently active on TravelCircle.net, or when you last used our Products.
Apps, websites, and third-party integrations on or using our Products.
When you choose to use third-party apps, websites, or other services that use, or are integrated with, our Products, they can receive information about what you post or share. New owner.
If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.
IV. What is our legal basis for processing data?
- Consistent with your consent, which you may revoke at any time through the TravelCircle.net Settings.
- As necessary to comply with our legal obligations.
- To protect your vital interests, or those of others.
- As necessary in the public interest.
- As necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalized, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
V. How can you exercise your rights provided under the GDPR?
Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data. Learn more about these rights, and find out how you can exercise your rights in the TravelCircle.net Settings. You also have the right to object to and restrict certain processing of your data. This includes:
- The right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications.
- The right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.
VI. Data retention, account deactivation and deletion
We store data until it is no longer necessary to provide our services, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.
When you delete your account, we delete things you have posted, such as your photos and status updates, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using the Products, you can deactivate your account instead. To delete your account at any time, please visit the TravelCircle.net Settings.
VII. How do we respond to legal requests or prevent harm?
We access, preserve and share your information with regulators, law enforcement or others:
In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of the Products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.
Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.
VIII. How do we operate and transfer data as part of our global services?
We share information globally and with those you connect and share with around the world in accordance with this policy. Information controlled by TravelCircle.net will be transferred or transmitted to, or stored and processed in, the United Kingdom or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide the services set forth in the TravelCircle.net Terms and to globally operate and provide our Products to you. We utilize standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States and other countries.
IX. How will we notify you of changes to this policy?
We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Products.
X. How to contact TravelCircle.net with questions?
You can learn more about how privacy works on TravelCircle.net. If you have questions about this policy, you can contact us as described below.
You can contact via email at: email@example.com