Datenschutzrichtlinien
Zuletzt aktualisiert am 17th February 2023
Tripmapper Ltd ("TripMapper" or "we" or "our" or “us”) respects your privacy and is committed to protecting your Personal Data.
This privacy policy (“Policy”) (together with TripMapper’s Terms of Service) contains important information on the Personal Data we collect and store about you when you visit, interact with, access or use the TripMapper website (www.tripmapper.co, the "Website"), the TripMapper mobile application ("Mobile App"), the TripMapper web application ("Web App") and any other related services that we may operate from time to time (together, the "TripMapper Services").
Please read the Policy, and any other privacy or fair-processing policy provided to you on specific occasions, so that you have a clear understanding of how we interact with your Personal Data. Any other relevant policy supplements, and does not override, the others.
Children
Please note that TripMapper Services are not intended for children, and that we do not knowingly collect Personal Data relating to children.
Third-party links
Please note that TripMapper Services contain links to and from third party websites. 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. Please check the privacy policies before you submit any Personal Data to these websites or use these services.
1. Who are we?
Here are some key details about us:
Company name: Tripmapper Ltd
Place of incorporation: England and Wales
Registered company number: 12755452
Registered address: 20-22 Wenlock Road, London, England, N1 7GU
Under the UK General Data Protection Regulation ("UK GDPR"), tailored by the Data Protection Act 2018, we are considered to be a ‘controller’. As a controller, we are responsible for, and control the processing of, your Personal Data. We are registered as a data controller with the Information Commissioner’s Office (“ICO”), which is the UK’s independent body set up to uphold information rights.
2. The data we collect about you
Personal data is information about a living individual from which that individual can be identified (whether through one piece of data alone or through a combination of data) ("Personal Data"). Anonymous data, from which a person’s identity has been removed, is not Personal Data.
In the course of our business we may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
- Identity Data, such as name and title
- Contact Data, such as email address and billing address
- Financial Data, such as bank account and payment card details
- Transaction Data, such as details about payments to and from you, details of services you have requested from us
- Technical Data, such as the type of device(s) you are using to access TripMapper Services, internet protocol ("IP") address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform
- Content Data, such as photographs
- Profile Data, such as your username and password, purchases made by you, your preferences, feedback and survey responses
- Usage Data, such as information about how you use and interact with TripMapper Services
- Marketing & Communications Data, such as your preferences in receiving marketing and communications
- Location Data, such as your current location disclosed by global positioning systems ("GPS") technology
Aggregated data
We collect aggregated data for statistical purposes, such as assessing the popularity of certain pages on our Website. Aggregated data does not reveal your identity (either directly or indirectly), and is not considered to be Personal Data. To the extent that we use or combine any aggregated data so that you can be identified, we would treat the aggregated data as Personal Data and would therefore use it only in accordance with this Policy.
In all cases, we do not collect more Personal Data than we believe is necessary.
3. How is your Personal Data collected?
We will use different methods to collect Personal Data about you:
Directly from you, for example when you:
- create a TripMapper account
- download the Mobile App
- create a TripMapper travel itinerary using our Mobile App and/or Web App
- purchase a 'Trip+' plan using our Mobile App and/or Web App
- subscribe to our publications or to any other TripMapper Services
- request marketing, or any other information, to be sent to you
- enter a competition, promotion or survey
- participate in discussion boards or other social media functions
- attend an event that we hold
- write to us to report a problem with the TripMapper Services
- give us feedback or contact us
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 your relationship with us.
From third parties and publicly available sources, for example:
- if you purchase a ‘Trip+’ plan via our payment provider
- where a TripMapper user invites you to collaborate with them on their TripMapper travel itinerary and so provides your name and your email address which identifies you
- Google Analytics (based outside the EU)
- Mixpanel who we use to track application behaviour in order to improve user experience
- public sources, such as LinkedIn, on which you may have uploaded details
From automated technologies, such as cookies and tags when you use our Website and Web App, although we do not participate in automated decision-making – for more information on automated technologies, please see our cookie policy for further details.
From location data as some of our location-enabled services require your Personal Data for the feature to work.
4. For what reasons do we use your Personal Data?
We will only use your Personal Data when the law allows us to, and we will not use it more extensively than we believe is required.
Most commonly we will use your Personal Data in the following circumstances:
- to perform a contract we are about to enter into, or have entered into, with you
- where it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests
- where it is necessary to comply with a legal obligation
Lawful bases
To process Personal Data, we must have a lawful basis. We always ensure that this is the case, and we set out below the lawful bases on which we most frequently rely. Note that more than one basis may apply at any given time. Please contact us if you would like more information on this using the contact details contained in section 15 below.
Our most frequently used legal bases are as follows:
- It is necessary for our legitimate interests, being the legitimate interests pursued by us or by a third party, except where those interests are overridden by your interests or fundamental rights and freedoms.
- Performance of a contract with you, or taking steps (at your request) prior to the performance of a contract.
- Compliance with a legal obligation to which we are subject.
Consent
Generally we do not rely on consent as a legal basis for processing your Personal Data, save where we deem it necessary. We will always be clear whenever we intend to process on the basis of consent, and we will process lawfully and only for the purpose for which consent was given.
Purposes for which we will use your Personal Data
The table below describes the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/ Activity | Type of data | Lawful basis for processing |
To register you as a new user. |
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To process and deliver TripMapper Services, or to receive your services, including: a) providing TripMapper Services to you, or receiving services from you b) managing payments c) collecting money owed to us, and making payments |
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To manage our relationship with you, including: a) notify you about changes to our Terms of Service or this Policy b) communicating with you in the ordinary course of business c) asking to you provide feedback or take a survey |
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To administer and protect our business, our Website, our Mobile App and our Web App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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To use data analytics to improve TripMapper Services, marketing, customer relationships and experiences |
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To comply with taxation laws and other binding obligations |
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To manage our business |
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Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we fairly consider that we need to use it for another reason and that is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
5. Do we share your Personal Data?
We may provide your Personal Data to the following recipients for the purposes set out in this Policy:
- any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries
- our service providers, including:
- Campaign Monitor who we use to provide email marketing services (Campaign Monitor's privacy notice can be found here)
- DigitalOcean who we use to provide hosting services (DigitalOcean's privacy policy can be found here)
- Intercom which we use to communicate with our customers, for customer support and for product tours (Intercom's privacy policy can be found here)
- Stripe who we use to provide payment processing (Stripe's privacy policy can be found here)
- suppliers with a need to receive your data
- 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. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Policy
- HM Revenue & Customs
- law-enforcement agencies, the courts, government or public agencies or officials, and any other person or entity that has the appropriate legal authority
- to respond to claims, or to protect our rights, interests, privacy, property or safety
- where it is necessary to protect your vital interests
- any other parties, where we have your specific consent to do so
In all cases, we require third parties to use your data lawfully and only for specified purposes, and to observe strict standards of security.
6. Do you have to provide Personal Data and, if so, why?
To be able to become a TripMapper customer, we will need some or all of the Personal Data described above.
If we do not receive the data, it will not be possible for you to have a TripMapper account and become a TripMapper customer.
7. Choices you have regarding Personal Data
Account settings
You can update your information at any time in the Web App and Mobile App in the ‘Account Settings’ section.
Location data
The TripMapper Services may provide features that requires your precise location and the use of location services on your mobile device. You may enable or disable these TripMapper Services within your TripMapper account and the privacy settings in your mobile device.
Marketing
We may store your contact details, and carry out marketing profiling activities, for direct marketing purposes.
If you have given your consent, or if we are otherwise permitted to do so, we may contact you about TripMapper Services that may be of interest to you.
You will be given the opportunity to opt out each time you are contacted, and you may also opt out at any other time. This will not affect the lawfulness of processing that took place prior to your opt-out. We never pass your details to third parties so that they can market to you for their own purposes.
Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your TripMapper account and your use of the TripMapper Services. For example, even if you have unsubscribed from our promotional email messages, we will still send you emails relating to security, billing, or TripMapper account services such as password reset.
Push notifications
You may manage the push notifications sent by TripMapper Services through your personal device settings.
Cookies, analytics and tracking
You also have choices regarding some of the technologies used to track your use of the TripMapper Services. For more detail see our cookie policy.
8. Cookies, Analytics and Tracking
When you use the TripMapper Services, some information such as IP address, device or browser information, logs, or clickstream information is automatically collected about your usage and activity to address technical support issues and understand how you use TripMapper Services. TripMapper uses certain tracking technologies such as cookies or third-party analytics tools to obtain such information, to distinguish you from other users of TripMapper Services and to remember your preferences. This helps us to provide you with a good experience when you use TripMapper Services, allows us to improve TripMapper Services and address technical support issues and understand how you use TripMapper Services. For more information on which cookies we use and how we use them, please see our cookie policy.
9. Transfer of Personal Data outside of the United Kingdom (“UK”)
Whenever we transfer your Personal Data from the UK to another country to meet our purposes, we will either ensure that:
- there are UK ‘adequacy regulations’ in relation to the country or territory where the receiver is located or a sector which covers the receiver (which currently includes countries in the EEA and countries, territories or sectors covered by existing EU ‘adequacy decisions’; or
- ‘appropriate safeguards’ are implemented to comply with the UK GDPR and the Data Protection Act 2018 and that we are satisfied that the data subjects (data subject meaning the identified or identifiable living individual to whom Personal Data relates) of the transferred data continue to have a level of protection essentially equivalent to that under the UK data protection regime; or
- an exemption provided for in the UK GDPR applies.
10. Data security
All information you provide to us is stored on our secure servers. The TripMapper Services operate from data centers in the United Kingdom.
We have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only our members, authorised employees and third parties processing data on our behalf have access to your Personal Data.
All our members and employees who have access to your Personal Data are required to adhere to our privacy policy and we have in place contractual safeguards with our third-party data processors to ensure that your Personal Data is processed only as instructed by us.
We take all reasonable steps to keep your data safe and secure and to ensure that only those with a legitimate interest to access your data can do so. Once we have received your Personal Data, we will use procedures and security features to try to prevent unauthorised access.
Please contact us using the details in section 15 below if you would like more information about this.
No method of transmission over the Internet or method of electronic storage is completely secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
11. For how long will we keep your Personal Data?
We will only retain your Personal Data for as long as is reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
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.
12. Your information rights
We would like to draw your attention to the following rights that you have in relation to your Personal Data:
- 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:
a) if you want us to establish the data's accuracy
b) where our use of the data is unlawful but you do not want us to erase it
c) 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
d) 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. You also have the right to ask us not to continue to process your Personal Data for marketing purposes.
Please note:
- you will be asked to provide proof of your identify to ensure we are dealing with the correct person, and we may ask you to provide further details to assist us in the provision of such information
- we do not ordinarily charge a fee to enable you to have access to your Personal Data or to exercise other rights. However, in some circumstances we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances
In all cases, we will reply within the time limits set by law.
Please contact us using the details in section 15 below if you would like to know more about, or to exercise, these rights. These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website.
13. Changes to this Policy
We may change this Notice from time to time. You should check this Policy on our Website occasionally, in order to ensure you are aware of the most recent version.
14. What should you do if you have a complaint?
We hope that you will be satisfied with the way in which we approach and use your Personal Data. Should you find it necessary, you have the right to raise a concern with our supervisory authority, the ICO.
However, we very much hope that if you have a complaint about the way in which we handle your Personal Data, you will contact us in the first instance using the contact details in section 15 below, so that we have an opportunity to resolve it.
15. Contact
If you would like to contact us about this Policy or our use of Personal Data, including if you wish to receive further information, our details are as follows:
For the attention of: The Privacy Manager
E-mail: hello@tripmapper.co
16. Translations of this Policy
This Policy is written in the English language. If any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.
17. Other
This Policy complies with the United Kingdom’s GDPR and Data Protection Act 2018. You agree that we may collect and use your Personal Data in accordance with this Policy and that you will not hold TripMapper accountable for any potential non-observance of your local data legislation if outside the United Kingdom.
