Your Privacy Matters
What is TripMemo®?
The affiliated services and the software of TripMemo® by itself belong to two of the registered entities under TripMemo®. They are: (1) TripMemo (UK) Limited, incorporated under the laws of United Kingdom with its registered office at 71-75 Shelton Street, Convent Gardens, London, WC2H 9JQ, United Kingdom and (2) TripMemoTechnologies Pvt LTD which has been established under the laws of Republic of India, with its registered office in Villas7, Golden Dew, Vennala P.O. , Cochin -28, India.
TripMemo® takes its form as both a website (www.tripmemo.com) and mobile applications (iOS and Android). TripMemo® is loaded with user-friendly attributes like creating lists, and our features, i.e. attributes that TripMemo® makes available, such as the ability for users to create/manage lists, posts, bookings, referrals, forums, quotations, itineraries, etc. It also makes the space interesting with Loyalty Points (polo coins), content based on destinations, species and attractions, advertisers' details, videos, raring systems, trips, quotes, tips, wish lists, reviews, photos sourced from users, and smooth widgets that facilitate a systematic and hassle-free user experience.
What type of User Data is collected?
We receive and process the details you provide to us during your account creation. The following information is collected and processed once you become a user of TripMemo® or TripMemo Go mobile applications:
As applicable as in:
On processing these personal data, TripMemo® gives you access to its services. TripMemo® processes these personal data to create your account and to allow you to avail the services.
As you interact with us and use our services, we may collect other data that you directly provide to us as a user, which includes:
TripMemo® processes this data to promote optimisation and the user’s interaction with fellow users or advertisers. The processing is necessary for the legitimate interests pursued by TripMemo® to facilitate content creation and communication between users and advertisers.
When you order products or services advertised in TripMemo®, you may have to provide personal information necessary to the advertiser or third parties such as payment gateways to complete the transaction, including the details of:
TripMemo® shall not be responsible for any such data as you will be directly sending them using third-party service providers. We do not keep the dates of your transactions in our server systems (please refer to Terms of Service agreement for more details). You are expected to note the advertisers' Terms & Conditions and Data & Privacy Policies before you proceed with any such transactions.
Though we do not track or keep your credit card name, number, passwords, or transaction details, we may keep a copy of the required transaction confirmation from the payment gateways for our records and to measure our internal arrangements with such payment gateways or advertisers, if any.
Some features and functionalities in TripMemo® require that you provide your location. This section explains when and how we use your location data.
The information we collect in order to determine your location consists of your location and/or IP address whenever you interact with, or use, our services (e.g. open the app, visit our website, etc.). We use various technologies to determine your location, such as the following:
When you Open and Use or Interact with our Apps
If you have your location services turned on whenever you open, use, or interact with our website or apps on your mobile device, we collect and use your location data from the same mobile device to tailor the services with respect to your current location (i.e. we will show your current location or a list of nearby locations and trips). If you have a current trip, we will process and store your location data as part of your trip data, thus making it visible to people who have access to your trip. We will process your location data only with your permission.
When you are Not Directly Interacting with the Apps
If you have background location data turned on by granting us permission through your device's location settings, we shall, from time to time, obtain your device's location even if you are not directly interacting with the apps. Our use of this data depends on whether you have a current trip or not:
Automatically Generated Information
TripMemo® requires certain information for the services to function properly. For this reason, TripMemo® collects automatically generated information on the use of our services. For example, we receive data:
TripMemo® requires this information for the service to work as optimally as possible (for example, to display content correctly and to keep the service secure). The processing of these personal data is therefore necessary for the legitimate interests pursued by TripMemo®.
Data Received from Third Parties
We may receive data about you from third parties if they serve us with websites or applications that integrate with our API or analytics services. This data may include but not limited to details about your activity when using the services, or on unaffiliated websites and apps, data received from web browsers or operating systems such as browser types and settings; the operating systems, device models, carriers, location information, IP address, mobile device and advertising identifiers (e.g. Apple IDFA or Google Advertising ID), as well as cookie information, pixel or other similar technology. For instance, if you created your account using Facebook, we may receive certain information from Facebook, such as your first name, last name, gender, birthday, email address, and your Facebook ID.
We currently use Google Analytics for Display Advertising. Google Analytics collects information anonymously and reports website trends without identifying individual visitors. Google Analytics uses its cookie to track visitor interactions. Website owners can view a variety of reports about how visitors interact with their website so that they can focus on optimising their place on the internet.
To Operate, Maintain and Improve the Services
We may use your data to operate/ maintain the services, and for our better understanding of your preferences so as to tailor the services to you. If you use the services when you are not logged into your TripMemo® account, we may combine the data collected while you were not logged in with your TripMemo® account, once you log in again.
We may also use your data for research and development, to improve the services, or to offer new products, features, and tools. For example, we may redesign the apps to make it easier for you to search for a travel destination, prepare an itinerary, track your trips, or when we move on to new technology platforms. The processing of your data in this context is necessary for the legitimate interests pursued by TripMemo®, namely, to improve the services and to offer new products, features, and tools.
We may also use your data to customize our Apps and Site to provide you with your own special experience. We do this by inferring your interests and preferences, considering your travel preferences and search history, or allowing you to find and add friends who are also using the Apps and Site from your device's contact list. Your Facebook account is also applicable if you have connected it with your TripMemo® account. In these situations, we do not store your contact lists. Based on your travel history and behaviour, we may, for instance, assume that you prefer birding sites instead of snorkelling points and hence, show you more recommendations for birding activities and advertisements of birding related suppliers. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by TripMemo®, namely, to give you recommendations, personalize your experience, and show you advertisements of great relevance to your type of travels and interests.
Additionally, if you give consent to sharing crash data (when the apps crash) with us, we may use that data to analyse the cause of the crash. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by TripMemo®, namely, to secure and improve the service.
To Communicate with You
We may use your data to communicate with you via email, text (only if you opt-in), or through our in-house messaging systems embedded along with your account, to inform you about new product offers, service updates, or anything else we think may be of interest to you. You can opt-out of receiving marketing and promotional communications in your app settings. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by TripMemo®, namely, direct marketing.
For Protection of Our Rights
We may use your data to protect the rights, property or safety of TripMemo®, the services, our users and employees, or any third party. For example, we may use your data if we need to enforce or apply our Terms of Service or Policies. The processing of these personal data is necessary for the purposes of all legitimate interests pursued by TripMemo®. In the event of a formal request by any statutory authorities from your country of nationality or residence or by any authorities to reveal your account details, transaction details, or any such information related to your engagement with TripMemo®, and that it is morally and legally rightful for TripMemo® to do so, we may share such data with them without serving you any notice or seeking your approval.
i. Third Party Service Providers
We may share your Personal Information with third-party service providers: a) to render the services that we offer you, b) to conduct quality assurance testing, c) to facilitate the creation of accounts, and d) to provide technical support and/or other services to TripMemo®. These third-party service providers cannot use your personal information other than to provide the services requested by TripMemo®.
ii. Affiliates and Acquisitions
iii. Other Disclosures
Data Available to People with Access to Your Trip
When you create a trip, it includes the search for destination information, activities, advertisers, suppliers, or any services that may help you to carry out your trip on TripMemo®. This trip includes the data created by you and/or collected by TripMemo® from registered members including you. The Trip Data includes your written texts, photos, your past or planned visits to businesses, establishments, destinations, sites, attractions, etc. It also includes your routes, current location, statistics about your trip, social interactions (e.g. likes, comments, or tips) by yourself or other people regarding your trip.
Data Available to People with Access to another User's Trip
If you interact with the trip of another user, people with access to that trip might see your social interactions. If the owner of a trip changes the trip’s privacy level, your social interactions with that trip might become publicly available. You can always remove your social interactions by deleting or undoing them. (Interaction with another user about the trip etc. will normally be voluntary. By doing this, the user undertakes that the privacy-level of his trip is liable to change based on the alterations in the level of privacy.)
Data Available to Your Followers
Your followers may see your publicly available data (see below), trip data (except ‘Only me’ trips), the lists of your followers, people whom you follow, and travel statistics.
Publicly Available Data
When you use the services, note that certain information is public, such as your name, TripMemo® handle, username, profile photo, hometown, country, travel choices, public trips, your social interaction on public trips of other users such as forums, your number of followers, and the number of people that you follow. These details may be followed, be searchable by search engines, and be disclosed to third parties including our partners and customers.
Data that May Be Shared with Third Party Partners and Service Providers
We may have service providers, vendors, advertisers and contractors to provide or perform services on our behalf. In these cases, we may need to share your personal data with them. When you order a service from a referral site, we will share your trip data and your order data (e.g. your name and address) with our referral partners.
We may place advertisements from our registered members or third-party advertisers in TripMemo® and related mobile sites near to your data, to generate income for TripMemo®. We may use profiling practices mentioned above to display suitable advertisements based on profiles. Our service providers, advertisers, referral partners, vendors, and contractors will be subject to binding contractual obligations to (i) only process the personal data in accordance with our prior written instructions, and not use them for any other purposes, and (ii) use appropriate measures to protect the confidentiality and integrity of the personal data together with any additional requirements under the applicable law.
When we partner with a business, we may share data with them but only in an aggregate and anonymous form, such as de-identified data about visits to places (which is not tied to individual users). We may also share or disclose aggregated, pseudonymised, and/or anonymous data to third parties, including other TripMemo® Users and developers who use our API or SDK, for analytical purposes.
We may share your data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, similar business transactions, or corporate events.
Consequences of Disclosing Information
Sharing Your Trip Data
People with access to your trip can see all your trip data (as described above). Individuals reading this information may use or disclose it to other individuals or entities without our control and your knowledge. Hence, we recommend you to be careful about including any specific information you may deem private, in trips, comments, plans, tips, or other content that you create during the use of our services.
Sharing Your Trip Real Time with Your Dear Ones
The ‘tag my trip’ (auto blogging) functionality will enable you to share your trip with a limited number of people who can use it to view your trip journal and data. Making someone a virtual traveller (tagging your journal writing tool with any TripMemo® registered user) with you implies that more people than the person you initially shared the link with, may potentially see your trip. This happens when your virtual co-traveller shares a link you sent, to a third person, or if a third person opens the link from the history of a browser which is used by multiple people. It is to be noted that your data can become accessible to people with whom you do not intend to share it.
Sharing Your Current Location
Features such as ‘Tag My Trip’ or real-time Social Media sharing may automatically make your current location available to people with access to your trip. We urge you to think carefully about using the 'Travel Tracker' functionality and to have an eye on the possible consequences of setting the privacy level of a current trip to ‘Real-Time & Everyone,’ which makes your current location visible to the public.
How does TripMemo® protect your personal information?
TripMemo® has proper technical and organisational measures to safeguard your (personal) data against loss or any other form of unlawful processing.
How long does TripMemo® keep your personal information?
TripMemo® will store your personal data as long as necessary to perform the purposes of processing stated. This means that we keep the data at least for the time you make use of our services. We remove all your personal data without any delay once you delete your account.
What Rights do Users have?
Under the European General Data Protection Regulation, the users have a number of rights regarding their personal data and the processing thereof:
You may send your request to TripMemo® at firstname.lastname@example.org. TripMemo® shall respond to your request without delay and in any event within 30 days of receipt of the request. This period may be extended by two further months if necessary, considering the complexity and number of requests. TripMemo® shall inform you of any such extension within 30 days of receipt of the request, together with the reasons for the delay.
If no action is taken on your request, TripMemo® shall inform you without delay and at the latest within 30 days of receipt of the request, the reasons for not taking action. In that case, you also have the right to lodge a complaint with the supervisory authority and to seek a judicial remedy.
Can I Opt-Out?
How to Opt -Out of Marketing/ Promotional Emails and Text Messages
You can opt-out of marketing or promotional messages at any time by adjusting your preferences in the ‘Notification Settings’ tab in the Apps. You may also unsubscribe from “Emails” in the footer of any marketing or promotional email. Please note that you cannot opt-out of the essential service emails or legal notices. By opting out of marketing or promotional emails, you may miss out on many exciting opportunities to earn Polo coins or to participate in various community-building activities.
How to Remove Background Location Sharing?
If you use our Apps and have opted to share your background location with us, you may remove your permission at any time by going to your operating device settings and toggling off background sharing. This may result in a partial or complete halt in the functioning of many features in our websites, apps and tools.
If you wish to use our referral service to tell a friend about our site, we would require the person’s name and e-mail address. We will automatically send a one-time e-mail inviting them to visit the site. TripMemo® stores this information for the sole purpose of one-time e-mailing and tracking the progress of our referral program. Your friend may contact us to request that we remove this information from our database.
What if I have Queries or Complaints?
All questions regarding the processing of customers’ personal data by TripMemo® may be addressed to email@example.com via email.
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