Tripfy Software, S.L. (¨Tripfy¨) is committed to keeping our visitors informed about how we use the information we gather on our web site, at our mobile optimized web site, and in our mobile apps (collectively, the “web site”). By using our web site or obtaining any product or service through our web site, you agree to the collection and use of information as set forth in this policy. If you do not agree to this policy, please do not use the web site.

Please be aware that other sites accessible through Tripfy web site have their own privacy policies and data collection, use, and disclosure practices. The information practices of those other sites linked to Tripfy’s web site are not covered by this privacy policy.

 

I. Information We Collect and How We Use It

In order to better provide you with products and services, Tripfy ’s web site collects two types of information: Personal Information and Non Personal Information.

Personal Information: “Personal Information” refers to information that lets us know the specifics of who you are and can be used to identify, contact, or locate you. You may choose not to provide any Personal Information and you will still be able to access most portions of the web site. However, Personal Information may be collected from visitors seeking to obtain services offered by Tripfy on this web site, such as:

  • Registration in Premium and use of Premium;
  • Registration in Professional Guide;
  • Use of Tripfy mobile applications;
  • Requesting to be included on mailing, email, texting, landline telephone, or cellular telephone lists of Tripfy , as may be described in more detail on this web site from time to time. Additionally, online communications relating to utility services may also require follow-up contacts (such as emails, texts, and telephone “call backs”) and responses regarding the services to be utilized – including billings and payments.

Examples of Personal Information you may submit include your name or, when combined with your name or other information which could reasonably be used to identify you, your mailing address, telephone number, mobile phone number, email address, and other identification and contact information. We may also collect certain financial account information (if you choose to provide it), as well as other types of information that you may have entered when submitting an application for a Professional Guide.

Tripfy uses this Personal Information to provide services, conduct its business, and improve our visitors’ experience on our web site.

Non Personal Information: “Non Personal Information” refers to information that does not identify a specific individual by itself or in combination with other Non Personal Information. Tripfy may collect Non Personal Information by using cookies, agents, or through the collection of traffic data and location information.

Cookies: Tripfy’s web site may store cookies on your computer or other device to allow us to monitor your use of the web site. No attempts are made to identify individual users unless actions are taken to identify yourself by an “opt in,” for example:

  • Individual services are requested;
  • Inclusion on a Tripfy mailing list is requested;
  • Illegal behavior or unauthorized activities are suspected; or
  • User identification is required under law.

Cookies are used to improve the usefulness of our web site for our visitors.

Agents: We may also work with 3rd party service providers or solutions which employ “agents” to monitor, track, and analyze user behavior and traffic data on their device and on this web site. The information collected by the agents may include, without limitation: hardware model, unique device identifiers (UDID), mobile network information including phone number, the agent version, platform, SDK version, timestamp, API key (identifier for application), application version, model, manufacturer and OS version of device or hardware, session start/stop time, locale, time zone, and network status (WiFi, etc.). Information collected through the agents is used to customize services and improve web site usability. Information collected through agents may identify individual users in combination with previously provided Personal Information.

Traffic Data: Tripfy automatically collects and maintains statistical information from our web site’s data logs that concern web site activity, navigation, network traffic flow, and volume (“Traffic Data”). Examples of Traffic Data include the following:

  • Name of the domain, or URL, from which the visitor accesses the Internet (e.g., “a company.com”; “a school.edu”; or “an agency.gov”);
  • Internet Protocol (“IP”) Number;
  • Type of web browser used;
  • Web pages visited; and
  • Date and time this web site is visited.

Our primary purpose for collecting Traffic Data is to optimize the usefulness to visitors of our web site. Traffic Data is also helpful in permitting us to improve the overall user experience on our web site. Traffic Data may identify individual visitors in combination with previously provided Personal Information.

Location Information: Certain location-enabled functionality (e.g., user geolocation) made available in Tripfy web site is provided by third party providers. Your use of that functionality is subject to such third party’s terms and conditions and privacy policy (as updated from time to time). When you use such location-enabled services, Tripfy may also receive information about your actual location, like GPS signals sent by a mobile device or via your IP address. Location-enabled services may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers. Location information helps Tripfy customize and tailor services to you. Location information may identify individual users in combination with previously provided Personal Information.

Among the types of Personal Data that Tripfy collects, by itself or through third parties, there are: gender, date of birth, Cookies, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), email address, password, first name, last name, picture, profession, country, city, geographic position, various types of Data, Calendar permission, Contacts permission, Camera permission, Precise location permission (continuous), Precise location permission (non-continuous), Approximate location permission (continuous), Approximate location permission (non-continuous), Microphone permission, Phone permission, Sensors permission, Storage permission, Reminders permission, HomeKit permission, Motion sensors permission, Bluetooth sharing permission, Social media accounts permission, phone number, address, username, company name, Tax ID, VAT Number, state, province, ZIP/Postal code, Social Security number (SSN), field of activity, number of employees, User ID, marital status, website, shipping address, house number, prefix , data relating to the point of sale, language and profile picture.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Tripfy.
Unless specified otherwise, all Data requested by Tripfy is mandatory and failure to provide this Data may make it impossible for Tripfy to provide its services. In cases where Tripfy specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Tripfy or by the owners of third-party services used by Tripfy serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

 

II. Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Tripfy (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

 

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

 

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

 

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Handling payments, Handling activity data, Advertising, Remarketing and behavioral targeting, Analytics, Hosting and backend infrastructure, Registration and authentication, Contacting the User, Infrastructure monitoring, Data transfer outside the EU, Device permissions for Personal Data access, Access to third-party accounts, Content commenting, Interaction with external social networks and platforms, Managing contacts and sending messages, Social features, Content performance and features testing (A/B testing), Location-based interactions, Displaying content from external platforms, SPAM protection and Tag Management.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

 

III. Sharing Your Information with Third Parties

Tripfy  will not, without your consent, share your Personal Information with third parties for their commercial purposes except that Tripfy may share your Personal Information with third-parties, including certain affiliated companies (consistent with applicable laws and regulations) or other trusted businesses solely in order to enable them to perform services for Tripfy related to Tripfy ’s own business purposes (subject to confidentiality and security obligations).

Compliance with Laws and Public Safety: Tripfy may also disclose Personal Information if we believe in good faith that such disclosure is necessary to comply with relevant laws or to respond to subpoenas or warrants served on us or to protect or defend the rights, property, or safety of our users, others, or ourselves. Tripfy may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. We will disclose Personal Information upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. Tripfy fully cooperates with law enforcement agencies in identifying those who use our services for illegal activities. Tripfy reserves the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

Mergers and Acquisitions: In the event of a merger, consolidation, reorganization, or sale or transfer of all or substantially all of the assets or business of Tripfy , one of the assets that would generally be transferred is the information we collect from our visitors and customers (including both Personal Information and Non Personal Information). However, the use of this information by any successor entity would still be governed by the terms of this policy, as amended from time to time, including any amendment after such transaction.

 

IV. Information Security Practices

Tripfy uses commercially reasonable efforts to prevent third parties from acquiring, altering, or destroying information made available to Tripfy through this web site. These efforts include monitoring network traffic to identify unauthorized attempts to upload or change information and under some circumstances encrypting sensitive information using Secure Socket Layers (“SSL”) or other comparable technology. Monitoring also occurs to prevent any activity that is illegal, or which may subject Tripfy to legal liability or damage. Tripfy is committed to maintaining the web site’s security and its ongoing compliance with law so that this service will remain available to all visitors.

Although Tripfy takes commercially reasonable efforts to prevent unauthorized third parties from acquiring Personal Information submitted to Tripfy on this web site, an unlawful interception or acquisition by a third party may still be possible.

 

V. Children

Tripfy does not knowingly collect Personal Information from children under 13 years of age. Additionally, we are not aware of any content on our web site that would be considered harmful to children. If Tripfy learns that we have inadvertently gathered Personal Information from children under 14, we will erase such information from our records and terminate the applicable account.

 

VI. Links

This web site may provide links to various governmental, industry association and other third party web sites or materials. These links are provided for informational purposes only. Tripfy does not endorse any advice, goods or services offered by third parties. To the extent third party materials contain assertions of fact, recommendations, or any other interpretations or advice, the third party is solely responsible for the content of the third party site, and Tripfy makes no representation as to the accuracy, completeness or fitness for any purpose or use thereof. Further, Tripfy has not verified the privacy policies applicable to third party web sites or hosted materials, or determined what actions such parties will take regarding the privacy of visitors. Accordingly, you should carefully review the privacy policies of any third party sites accessible from any Tripfy web site. In no event shall Tripfy be responsible for any third party content, policies or actions. Tripfy encourages you to ask questions and to be very cautious before you disclose your Personal Information to third parties.

 

VII. Choices Regarding Marketing Correspondence

Promotional Emails: : You will have the choice to opt out of receiving promotional emails for products and/or services offered by Tripfy. Once we have processed your request, we will stop sending you, within the legally required timeframes, non-transactional promotional emails with respect to products and/or services offered by us unless you opt back in to receiving such communications. You can opt out of receiving non-transactional promotional emails from us either :

(a)   By following the unsubscribe instructions in the applicable email you receive from us (if applicable).

(b)   While you are completing our online web form (if applicable).

Our Operational Emails: Despite your choices regarding non-transactional promotional emails, we may continue to send you operational emails for non-promotional or transactional purposes, including, without limitation: billing, conservation, outage management, and safety.

 

VIII. Changes to This Privacy Policy

Tripfy reserves the right, at any time, and without notice, to add to, change, modify, or update this Privacy Policy by posting a revised policy on this web site. Any revised Privacy Policy shall be effective immediately on posting. However, any time this policy is updated, the date of modification will be posted.

 

IX. Disclaimer

Tripfy is not responsible in the event that any password provided to a user is obtained by a third party or for any unlawful activities in connection with this web site. In the event a user believes any password has been obtained without permission by third parties, or if the visitor has other privacy concerns, the user should contact Tripfy immediately so the password can be changed, or other steps taken as appropriate. This notification should be made to admin@tripfy.io.

 

X. Questions or Comments

If you have any questions or comments regarding:

(a)   Our web site Privacy Policy.

(b)   Any other questions about this web site, Tripfy or its services, please contact Tripfy by e-mail at admin@tripfy.io, or by regular mail at:

Tripfy Software, S.L.
Privacy Policy
Calle Altabaca, 16. Principal C
29018, Málaga. España

 

Please note, however, that information regarding these contacts or correspondence with Tripfy may be retained in a file that is specific to you.

 

 

Last updated September 28, 2018