Effective January 10, 2020. Last Revised January 10, 2020
We want you to understand how and why Trade Trade News Holdings Ltd. (“TravelTradeNewsToday,” “we” or “us”) collects, uses, and shares information about you when you use our websites, mobile apps, widgets, and other online products and services (collectively, the “Services”) or when you otherwise interact with us or receive a communication from us.
What We Collect
Information You Provide to Us
We collect information you provide to us directly when you use the Services. This includes:
Account information. To create an account, you must provide a username and password. Your username is public, and it doesn’t have to be related to your real name. You may also provide an email address. We also store your user account preferences and settings.
Content you submit. We collect the content you submit to the Services. This includes your posts and comments including saved drafts, your messages with other users (e.g., private messages, chats, and TravelTradeNewsToday Internal Messaging), and your reports and other communications with moderators and with us. Your content may include text, links, images, gifs, and videos.
Actions you take. We collect information about the actions you take when using the Services. This includes your interactions with content, like voting, saving, hiding, and reporting. It also includes your interactions with other users, such as following, friending, and blocking. We collect your interactions with communities, like your subscriptions or moderator status.
Other information. You may choose to provide other information directly to us. For example, we may collect information when you fill out a form, participate in TravelTradeNewsToday-sponsored activities or promotions, apply for a job, request customer support or otherwise communicate with us.
Information We Collect Automatically
When you access or use our Services, we may also automatically collect information about you. This includes:
Log and usage data. We may log information when you access and use the Services. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, the requested URL, hardware settings, and search terms. Except for the IP address used to create your account, TravelTradeNewsToday will delete any IP addresses collected after 100 days.
Information collected from cookies and similar technologies. We may receive information from cookies, which are pieces of data your browser stores and sends back to us when making requests, and similar technologies. We use this information to improve your experience, understand user activity, personalize content and advertisements, and improve the quality of our Services. For example, we store and retrieve information about your preferred language and other settings. For more information on how you can disable cookies, please see “Your Choices” below.
Location information. We may receive and process information about your location. For example, with your consent, we may collect information about the specific location of your mobile device (for example, by using GPS or Bluetooth). We may also receive location information from you when you choose to share such information on our Services, including by associating your content with a location, or we may derive your approximate location from other information about you, including your IP address.
Information Collected from Other Sources
We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you. For example, we may receive demographic or interest information about you from third parties, including advertisers, and combine it with our own data using a common account identifier such as a hash of an email address or a mobile-device ID.
Linked services. If you authorize or link other services (e.g., third-party apps or websites) to access your TravelTradeNewsToday account, TravelTradeNewsToday receives information about your use of that service when it uses that authorization. Linking services may also cause the other service to send us information about your account with that service. To learn how information is shared with linked services, see “How Information About You Is Shared” below.
Information collected from integrations. We also may receive information about you, including log and usage data and cookie information, from third-party websites that integrate our Services, including our embeds, buttons, and advertising technology. For example, when you visit a website that uses TravelTradeNewsToday Affiliates, we may receive information about the web page you visited.
How We Use Information About You
We use information about you to:
- Provide, maintain, and improve the Services;
- Research and develop new services;
- Help protect the safety of TravelTradeNewsToday and our users, which includes blocking suspected spammers, addressing abuse, and enforcing the TravelTradeNewsToday user agreement and our other policies;
- Send you technical notices, updates, security alerts, invoices and other support and administrative messages;
- Provide customer service;
- Communicate with you about products, services, offers, promotions, and events, and provide other news and information we think will be of interest to you (for information about how to opt out of these communications, see “Your Choices” below);
- Monitor and analyze trends, usage, and activities in connection with our Services; and
- Personalize the Services and provide advertisements, content and features that match user profiles or interests. (for information about how to manage the types of advertisements you experience on our Services, see “Your Choices” below)
How Information About You Is Shared
When you use the Services, certain information may be shared with other users and the public. For example:
- When you submit content (such as a post or comment or public chat) to the Services, any visitors to and users of our Services will be able to see that content, the username associated with the content, and the date and time you originally submitted the content. TravelTradeNewsToday allows other websites to embed public TravelTradeNewsToday content via our embed tools. TravelTradeNewsToday also allows third parties to access public TravelTradeNewsToday content via the TravelTradeNewsToday API and via other similar technologies. Although some parts of the Services may be private or quarantined, they may become public (e.g., at the moderator’s option in the case of private communities) and you should take that into consideration before posting to the Services.
- When you send private messages, messages via TravelTradeNewsToday Internal Messaging, or private chats, the recipients of those messages will be able to see the content of your message, your username, and the date and time the message was sent. Keep in mind that additional users may be invited to join a private chat after you send a message. Moderators may elect to have TravelTradeNewsToday Internal Messaging forwarded to their email accounts and, as a result, any TravelTradeNewsToday Internal Messaging received by these moderators will be subject to the terms and policies of the moderator’s email provider.
- When other users view your profile, they will be able to see information about your activities on the Services, such as your username, prior posts and comments, karma, trophies, moderator status, TravelTradeNewsToday Elite status, and how long you have been a member of the Services. If you choose to make the information public, your profile may also include your voting history.
- We offer social sharing features that let you share content or actions you take on our Services with other media. Your use of these features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features (e.g., Tumblr, Facebook, and Twitter).
Please note that, even when you delete your account, the posts, comments and messages you submit through the Services may still be viewable or available on our servers. For more information, see “Your Choices” below.
Otherwise, we do not share, sell, or give away your personal information to third parties unless one of the following circumstances applies:
- With linked services. If you link your TravelTradeNewsToday account with a third-party service, TravelTradeNewsToday will share the information you authorize with that third-party service. You can control this sharing as described in “Your Choices” below.
- With our partners. We may share information with vendors, consultants, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out work for us. The partner’s use of personal data will be subject to appropriate confidentiality and security measures.
- To comply with the law. We may share information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, we will attempt to provide you with prior notice before disclosing your information in response to such a request.
- In an emergency. We may share information if we believe it’s necessary to prevent imminent and serious bodily harm to a person.
- To enforce our policies and rights. We may share information if we believe your actions are inconsistent with our user agreements, rules or other TravelTradeNewsToday policies, or to protect the rights, property, and safety of ourselves and others.
- With our affiliates. We may share information between and among TravelTradeNewsToday , and any of our parents, affiliates, subsidiaries, and other companies under common control and ownership.
- With your consent. We may share information about you with your consent or at your direction.
- Aggregated or de-identified information. We may share information about you that has been aggregated or anonymized such that it cannot reasonably be used to identify you. For example, we may show the total number of times a post has been upvoted without identifying who the visitors were.
Ads and Analytics Partners
We may partner with third-party advertisers, ad networks, and analytics providers to deliver advertising and content targeted to your interests and to better understand your use of the Services. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. For example:
Advertisers and Ad Networks
We use analytics partners (such as Google Analytics) to help analyze usage and traffic for our Services. As an example, we may use analytics partners to analyze and measure, in the aggregate, the number of unique visitors to our Services.
As a TravelTradeNewsToday user, you have choices about how to protect and limit the collection, use, and disclosure of information about you.
Accessing and Changing Your Information
You can access and change certain information directly on the ad networks website.
Deleting Your Account
You may delete your account information at any time from the user account page. You can also submit a request to delete the personal information TravelTradeNewsToday maintains about you by following the process described in the “Other Information – Data Subject and Consumer Information Requests” section below. When you delete your account, your profile is no longer visible to other users and disassociated from content you posted under that account. Please note, however, that the posts, comments, and messages you submitted prior to deleting your account will still be visible to others unless you first delete the specific content. We may also retain certain information about you as required by law or for legitimate business purposes after you delete your account.
Controlling Linked Services’ Access to Your Account
You can review the services you have linked to your account and revoke access to individual services by directly visiting the website of the service (eg: Facebook for Facebook Login, etc..)
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first- and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Controlling Advertising and Analytics
Some analytics providers we partner with may provide specific opt-out mechanisms and we may provide, as needed and as available, additional tools and third-party services that allow you to better understand cookies and how you can opt-out. For example, you may manage the use and collection of certain information by Google Analytics here.
We also offer you choices about receiving personalized advertisements. You may also generally opt out of receiving personalized advertisements from certain third-party advertisers and ad networks. To learn more about these advertisements or to opt out, please visit the websites of the Digital Advertising Alliance and the Network Advertising Initiative, or if you are a user in the European Economic Area, Your Online Choices.
Do Not Track
Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.
Controlling Promotional Communications
You may opt out of receiving some or all categories of promotional communications from us by following the instructions in those communications. If you opt out of promotional communications, we may still send you non-promotional communications, such as information about your account or your use of the Services.
Controlling Mobile Notifications
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Controlling Location Information
If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.
We take measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. For example, we use HTTPS while information is being transmitted. We also enforce technical and administrative access controls to limit which of our employees have access to non-public personal information.
We store the information we collect for as long as it is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
International Data Transfers
We are based in the United States and we process and store information on servers located in the United States. We may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law.
In connection with TravelTradeNewsToday’s processing of personal data received from the European Union and Switzerland, we adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Program (“Privacy Shield”) and comply with its framework and principles.
Please direct any inquiries or complaints regarding our compliance with the Privacy Shield principles to the point of contact listed in the “Contact Us” section below. Under certain conditions specified by the Privacy Shield principles, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the Federal Trade Commission. If we share EU or Swiss data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of EU or Swiss data in violation of the Privacy Shield principles, unless we can prove that we are not responsible for the event giving rise to the damage.
For more information about the Privacy Shield principles and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website.
Additional Information for EEA Users
Users in the European Economic Area have the right to request access to, rectification of, or erasure of their personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing; and to withdraw consent for processing where they have previously provided consent. These rights can be exercised using the information provided under “Your Choices” above or as described in the “Other Information – Data Subject and Consumer Information Requests” section below. EEA users also have the right to lodge a complaint with their local supervisory authority.
As required by applicable law, we collect and process information about individuals in the EEA only where we have legal bases for doing so. Our legal bases depend on the Services you use and how you use them. We process your information on the following legal bases:
- You have consented for us to do so for a specific purpose;
- We need to process the information to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as preventing fraud, ensuring network and information security, enforcing our rules and policies, protecting our legal rights and interests, research and development, and marketing and promoting the Services;
- We need to process your information to comply with our legal obligations.
Data Subject and Consumer Information Requests
Requests for a copy of the information TravelTradeNewsToday has about your account—including EU General Data Protection Regulation (GDPR) data subject access requests and California Consumer Privacy Act (CCPA) consumer information requests—can be submitted to TravelTradeNewsToday via the contact us page.
All other data subject and consumer requests under data protection laws should be sent via email to privacy-policy(at sign)traveltrade(dot)news from the email address that you have verified with your TravelTradeNewsToday account.
Before we process a request from you about your personal information, we need to verify the request via your access to your TravelTradeNewsToday account or to a verified email address associated with your TravelTradeNewsToday account. You may also designate an authorized agent to exercise these rights on your behalf. TravelTradeNewsToday does not discriminate against users for exercising their rights under data protection laws to make requests regarding their personal information.
Children under the age of 13 are not allowed to create an account or otherwise use the Services. Additionally, if you are in the EEA, you must be over the age required by the laws of your country to create an account or otherwise use the Services, or we need to have obtained verifiable consent from your parent or legal guardian.
Changes to This Policy
To send a GDPR data subject request or CCPA consumer request, follow the steps in the “Other Information – Data Subject and Consumer Information Requests” section above.
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