The Data Controller
For the purposes of the Site and the App, the data controller is The Culture Trip Ltd. Full contact details are provided below.
For the purposes of this Policy:
-“Personal Data” means information about an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
-“Processing” means the collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction, or any other use, of Personal Data.
We may collect Users’ Personal Data, and further Process those Personal Data, as set out below.
Collection of Personal Data
The Culture Trip may collect Personal Data from Users or their devices when they:
-visit the Site;
-register to use the Site;
-use the Site, or any features or resources we make available on the Site;
-download or use the App;
-contact us by mail, phone, email or any other means; or
-otherwise interact with us.
When Users visit the Site, their devices and browsers will automatically disclose certain information. The disclosed information may include a User’s browser characteristics, IP address, device operating system, language settings, dates and times of connecting to the Site and other technical communications information. Some of this information may constitute Personal Data.
The Culture Trip may also collect any of the following types of Personal Data from Users, in the course of using the Site or the App:
-contact information (e.g., name, address, email address, phone number, or social media details);
-username and password; and
-any content that Users submit via the Site or the App.
Users may refuse to supply Personal Data when using the Site and the App, but doing so may prevent them from accessing certain features of the Site and the App respectively.
The Culture Trip may receive Personal Data about third parties from Users (for example, if third parties are identified in any communications sent from Users to The Culture Trip). Whenever Users make any such disclosures, Users must ensure that any affected third parties have consented to: (i) the disclosure of their Personal Data to The Culture Trip; and (ii) the Culture Trip’s further Processing of those Personal Data in accordance with this Policy. If Users cannot obtain such consent, Users must refrain from communicating the Personal Data of third parties to The Culture Trip. Similarly, third parties may provide The Culture Trip with Personal Data about Users. Such Personal Data will be Processed in accordance with this Policy.
Processing of Users’ Personal Data
The Culture Trip may Process Users’ Personal Data for the following purposes:
-to display the content of the Site or the App, and any customisations selected by the User;
-to improve the Site, the App and our customer service;
-to verify the User’s identity;
-to respond to Users’ service requests and support needs;
-on an aggregate basis, to understand how Users collectively use the features of the Site and the App;
-to administer content, promotions, surveys or other features of the Site or the App;
-to send Users information relevant to their interests, for the purposes of lead generation;
-to send Users communications regarding administration of their accounts and the features of the Site or the App;
-to notify Users of changes to the Site or the App;
-to perform data analyses and other Processing (including trend analysis and financial analysis);
-to give effect to the User’s legal rights;
-to share interests and other relevant information between Users;
-to protect against fraud, identity theft, and other unlawful activity;
-to exercise legal rights or defend legal claims;
-to comply with applicable laws and regulations, relevant industry standards and our policies; and
-in any other way that we notify to Users at the time of collection of their Personal Data.
Transfers of Users’ Personal Data to locations outside the EEA
We may make use of Processing facilities belonging to members of our corporate group located in jurisdictions other than the jurisdiction in which a User’s Personal Data was originally collected. In particular, some content and features of the Site and the App are provided by means of servers located outside the European Economic Area (“EEA”) (including, but not limited to, servers located in Israel). The Personal Data of all Users may be transferred to, and Processed using, those servers or other Processing facilities, as part of the operation of the Site and the App. These transfers are necessary in order to provide the Site and the App to Users in accordance with the Site’s Terms and Conditions. By providing Personal Data to The Culture Trip, or by using the Site or the App, Users transfer, and agree to the transfer of, their Personal Data to locations outside the EEA. If Users would prefer their Personal Data to locations outside the EEA, Users should not use the Site or the App, or provide any Personal Data to The Culture Trip.
Protection of Users’ Personal Data
The Culture Trip is committed to processing Users’ Personal Data securely. We adopt appropriate data Processing practices, and appropriate technical and organisational security measures, to protect against unauthorized access, alteration, disclosure or destruction of Personal Data.
Users are responsible for keeping their access credentials for the Site and the App safe and confidential. Users should notify The Culture Trip promptly if they become aware of any misuse of their access credentials, and immediately change their passwords.
We provide a SSL secured communication channel, and all data transferred using this channel are encrypted and protected with appropriate digital signatures. However, Users should be aware that the Internet is not a secure environment for Personal Data. We cannot provide absolute assurances that Users’ Personal Data will be secure during transmission across the Internet. Any such transmission is entirely at Users’ own risk.
Disclosure of Users’ Personal Data
The Culture Trip may disclose Users’ Personal Data to third parties in the following circumstances:
-We may share Users’ Personal Data with recipients within our corporate group, for the purposes of operating our business, operating the Site or the App, for the purposes of lead generation, or otherwise for the purposes set out in this Policy.
-We may share Users’ Personal Data with recipients outside our corporate group, for the purposes of operating our business, operating the Site or the App, for the purposes of lead generation, or otherwise for the purposes set out in this Policy.
-We may use third party service providers to help us operate our business, the Site or the App, or to administer activities on our behalf, such as sending out newsletters or We may share Users’ Personal Data with these third parties for the purposes set out in this Policy.
-We may share generic aggregated demographic information with our business partners, trusted affiliates and advertisers for the purposes outlined in this Policy. While we make all reasonable efforts to ensure that such information is anonymized, it is possible that Users’ Personal Data may be disclosed.
-Subject to obtaining appropriate consent, we may share Users’ Personal Data with our third party marketing partners, for direct marketing purposes. Users may withdraw their consent at any time, or object on legitimate grounds at any time to the Processing of their Personal Data, by contacting us via the Site or the App, or by using the contact information provided in this Policy. We will apply Users’ contact preferences going forward. If Users make a payment via the Site or the App, Users’ Personal Data may need to be provided to third parties (e.g., payment services providers) for the purposes of facilitating those payments.
-If we sell, merge or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other restructuring), we may disclose Users’ Personal Data to the prospective seller or buyer, or their representatives, provided that we have first taken reasonable steps to ensure the security and confidentiality of such information.
-We also may disclose Users’ Personal Data: (i) in connection with any legal proceedings, or otherwise for the purposes of establishing, exercising or defending any legal rights; (ii) if required by applicable law, regulation or legal process; (iii) in response to requests by government agencies and law enforcement authorities; (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or material financial loss; or (v) for the purposes of investigating actual or alleged unlawful activity.
Third party websites
Users may find advertising or other content on the Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by third party websites linked to or from the Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to the Site, is subject to that website’s own terms and policies.
Unsubscribing from marketing communications
From time to time, we, or our service providers, may contact Users via email or other electronic means, to provide information relating to products or services that may be of interest to those Users. If any User wishes to unsubscribe from receiving future communications, we include detailed unsubscribe instructions in each such communication. Alternatively, the User may use the unsubscribe features provided through the Site and the App respectively.
Please note that, in the event that a User unsubscribes from receiving communications relating to marketing or advertising, we may nevertheless continue to contact the User for the purposes of account administration, or as required by law.
It is the responsibility of each User to ensure that their Personal Data held by The Culture Trip is complete, accurate and up-to-date. Subject to applicable law, users may have the right to access their Personal Data held by The Culture Trip, correct any errors in those Personal Data, object on legitimate grounds to the Processing of those Personal Data, and/or request the deletion of those Personal Data. A fee may be payable for providing Users with copies of their respective Personal Data. These rights may be exercised by sending a request to firstname.lastname@example.org
A cookie is a small file that is placed on your device when you visit a website. It records information about your device, your browser and, in some cases, your preferences and browsing habits. This information can be used to improve the service delivered to you through the Site.
It is not mandatory to accept cookies. For example, users may set their browsers to produce an alert when a cookie is received, to enable them to either accept or reject those cookies in each instance. However, Users should note that refusing cookies may have a negative impact on the functionality and usability of the Site. For more information on deleting or controlling cookies, please visit www.AboutCookies.org.
The Site does not respond to or honour “Do Not Track” requests at this time.
How to contact us
The Culture Trip Ltd
11-13 Weston Street (The Leathermarket)
London SE1 3ER
Acceptance of this Policy
Your use of the Site and/or the App is deemed acceptance of this Policy. Users who do not agree to the terms set out in this Policy, must not use the Site or the App.
Revisions to this Policy
Last updated: 1 December 2015