Privacy Policy

1. How We Obtain Information About You

We may collect personal data that you choose to provide to us through the Site, including, but not limited to, your first and last name, physical address, e-mail address, or telephone number, such as when you:

Register on the Site, to create a User Account;
Fill out a form on the Site;
Sign-up to receive direct marketing communications on the Site;
Make purchases on the Site;
Sign-up to a feature that we offer on the Site and you provide your personal data in connection with that feature;
Attend an event that we or one of our business partners has organised;
Communicate with us (for example, on a social media platform or by sending us an email);
Vote in travelering and travelering Market awards, enter a competition, respond to a survey;
Download the travelering Market app;
Connect to the customer wifi in a travelering Market.

When you visit our Site, we also may collect certain information by automated means using technologies such as cookies, non-cookie-based tokens, web server logs, tracking pixels, and web beacons. Cookies are files that websites send to your computer or other Internet-connected device to identify your browser uniquely or to store information or settings in your browser. Your browser may tell you when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site and may not be able to purchase products that use a “shopping cart.” Non-cookie-based tokens are encoded URL-based identifiers that track e-mail click-thru activity or time-sensitive password reset keys and will work in scenarios where cookies are disabled or a session has not been initiated.

Where permitted by law, we may acquire personal data about you from third parties. This may include personal data shared between travelering affiliates and business partners, publicly-available profile information (such as your preferences and interests) on third party social media sites (such as Facebook and Twitter), and marketing lists acquired from third party marketing agencies.

We may also collect personal data in other contexts that we will notify you of at the time.

2.Information We Obtain

Information That You Provide to Us, and our legal basis for processing the personal data

Personal data that you provide directly to us will be apparent from the context in which you provide it, for example:

If you register on the Site, to create a User Account, you will generally provide your full name, email address, city preferences, email subscription and communication preferences. Our legal basis for processing your personal data in this way is that processing is necessary for the performance of a contract to which you are a party;
If you sign up to receive electronic marketing communications from us, you will generally provide your name, email address and other contact information, and your product preferences. Our legal basis for processing your personal data in this way is your consent to such processing for this purpose which shall be requested when you sign-up to such newsletters;
If you make any purchase(s) for example purchase of an Offer, or tickets for travelering events, you will generally provide your full name, email address, telephone number, postal and billing address and payment details. Payments are processed by our various payment providers whom you will supply your payment details directly. We will not store your payment card information. Our legal basis for processing your personal data in this way is that processing is necessary for the performance of a contract to which you are a party.
If you sign up to a feature on our Site, you will generally provide your name and contact information and any other information necessary to access the feature. Our legal basis for processing your personal data in this way is your consent to such processing which shall be requested as part of your compliance with the terms and conditions applicable to the feature;
If you choose to vote in travelering awards, enter a competition, or fill out a survey, you will generally provide your name, and email address. Our legal basis for processing your personal data in this way is your consent to such processing which shall be requested as part of your compliance with the terms and conditions applicable to such awards, competition, or survey;
If you make a purchase at a travelering via our dedicated ordering app, you will generally provide your full name, email address, telephone number, postal and billing address and payment details. Payments are processed by our various payment providers whom you will supply your payment details directly. Our legal basis for processing your personal data in this way is that processing is necessary for the performance of a contract to which you are a party.

Information That We Collect Automatically

Our web servers may log information such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags called “web beacons” — small files that link web pages to particular web servers and their cookies. We may also collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and e-mails to help us understand and respond to your needs.

Where the information gathered is completely anonymised, the information will not constitute personal data. Where your personal data is not in an anonymous form, our legal basis for processing your personal data in this way, is that it is in our legitimate interest to continually evaluate that personal data in operating and improving our business (and to ensure that the products and services we provide are relevant to the market) that is not overridden by your interests, rights and freedoms to protect personal data about you.

3. How We Use Information That We Obtain

Information That You Provide to Us

We may use personal data that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you. If you make a purchase on our Site, we also collect personal data because it is necessary for us to enter into a contract with you.

In addition to the uses discussed above, we may also use the personal data you provide on our Site to:

operate, evaluate, and improve our business;
develop new products and services;
perform market research;
advertise and market our products and services;
determine the effectiveness of our advertising and marketing;
analyze our products, services, and websites;
administer the Site;
segment and personalise the marketing communication that you have viewed on the Site.

We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights and freedoms to protect personal data about you.

We may also use the information to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by law that applies to us.

Other Uses of Information

In addition to the uses described above, we may use personal data that you provide to us or that we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal data and our legal basis for doing so.

4. Information We Share

We do not sell or otherwise disclose personal data that you provide to us or that we collect on our Site, except as described here. We may share personal data you provide to us or that we collect on the Site with:

Other companies in the travelering group;
Our business partners;
A named third party, for example in relation to a competition you have entered, and only where you have given consent;
service providers that perform services on our behalf.

5. Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will protect that personal data as described in this Notice.

If you are located in the European Economic Area (“EEA”) or Switzerland, we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal data if:

The country to which the personal data will be transferred has been granted a European Commission adequacy decision;
We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.

You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in the How To Contact Us section below.

6. How Long We Keep Information

The time period for which we keep personal data depends on the purpose for which we collected it. In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

Subject to any applicable legal requirements, we typically retain personal data as follows:

Personal data you provide to us when you make a purchase through our Site: we keep this personal data in order to process and deliver your purchase, and then we store it securely for seven years.
Personal data you provide when you sign-up to receive direct marketing communications: we keep most of this personal data for the duration of our relationship with you until you opt-out or until we do not have any contact with you for two years.
Personal data collected for analytics purposes: we keep this personal data for a short period of time necessary for us to carry out the analytics. We anonymise personal data used for analytics, immediately.
Website logs: we keep Site audit logs, which may contain your personal data, for several months.

7. Your Rights and Choices

If you are located in the European Economic Area (“EEA”) or Switzerland, you may have the following rights in relation to personal data that we hold about you:

To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
To request that we rectify or update your personal data that is inaccurate, incomplete or outdated.
To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
Where you have given us consent to process your personal data, to withdraw your consent; and
To request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.

You may contact us by e-mail or as described in the “How to Contact Us” section below to exercise your rights described above.

You also have the right to lodge a complaint with the data protection supervisory authority in your country.