Vacayou Privacy Statement
Effective Date: April 12, 2021
This website, www.vacayou.com, (the “Website”) is operated and owned by WWSG Travel, Inc. dba Vacayou, a Delaware corporation (“Vacayou”, “we”, “our” or “us”). This Privacy Statement (“Privacy Statement” or “Statement”) applies to Vacayou.
Purpose and Scope of Privacy Statement
Vacayou respects your privacy and wants you to feel comfortable using our Website. We are committed to protecting your data privacy rights through compliance with this Statement.
The purpose of this Statement is to explain our privacy and data collection practices when you visit:
- the Website; or
- third-party websites and services, when you interact with our advertising and applications thereon, if those applications or advertising contain a link to this Privacy Statement.
This Privacy Statement also covers: information we collect in email, text, and other electronic communications between you and this Website, and our activities as a data controller under the General Data Protection Regulation ((EU) 2016/679 (“GDPR”).
This Privacy Statement does not cover any Personal Information collected at any other websites, mobile applications, or services (unless specifically stated on such website, mobile application, or service).
Changes and Updates to Privacy Statement
Please review this Privacy Statement carefully. If you do not agree with and consent to our policies and practices, please do not use the Website. By accessing Vacayou, you agree to this Privacy Statement. This Privacy Statement may change from time to time. If we make any material changes to this Privacy Statement, we will notify you by email or by means of a notice on the Website prior to the change becoming effective. Your continued use of Vacayou after we make changes is deemed to be acceptance of those changes, so please check the Privacy Statement periodically for updates. If new Statement terms materially affect only registered users of the Website, if any, those users will be notified separately.
Data Protection Contact
Under the current General Data Protection Regulation ((EU) 2016/679 (“GDPR”), Vacayou is not required to appoint a Data Protection Officer. However, we have appointed a Data Protection Contact who you may contact with questions in relation to this Privacy Statement or your Personal Information or data collection. You may also contact this person if you wish to exercise any of your rights as described in this Privacy Statement or pursuant to applicable data protection laws:
Data Protection Contact:
802 E. Whiting St Tampa, FL 33602
Key Points to Know
This summary highlights some important information regarding our use and sharing of your Personal Information.
- We may use the Personal Information we collect to provide you with customized trips. We may also use your Information internally for product development, customer service, and research purposes.
- We do not sell or share any of your Personal Information outside our company without your permission unless you provide us your consent, as required by law, or in the other limited circumstances spelled out in this Privacy Statement.
Vacayou abides by the following guidelines, required by GDPR, when processing your Personal Information (referred to under GDPR as “personal data”):
- Lawfulness, fairness, and transparency. Personal data is processed lawfully, fairly, and transparently.
- Purpose limitation. Personal data is collected for specified, explicit, and legitimate purposes, and only processed in a fashion that is compatible with those purposes.
- Data minimization. Personal data must be adequate, relevant, and limited to what is necessary for the purposes for which they are processed.
- Accuracy. Personal data is accurate and, where necessary, kept up to date.
- Storage limitations. Personal data is kept in a form which permits identification of data subjects for no longer than necessary.
- Integrity and confidentiality. Personal data is processed in a manner that provides appropriate security of the Personal Information, including reasonable protection against unlawful processing or accidental loss, destruction or damage.
- Accountability. Vacayou’s policies and practices demonstrate compliance with GDPR principles.
Information We Collect
Active Collection of Information
In order that you may access the Website, we may ask you to provide personal information when you access, communicate with or otherwise interact with the Website. “Personal Information” is information, that can be used, whether alone or in combination, to directly or indirectly identify a specific individual. Examples of Personal Information we may collect through the Website include, without limitation: first and last name, phone number, email address, home address, billing address, and credit card number, and other payment information. Personal Information may also include certain Usage Information (defined below) that can be used, whether alone or in combination, to identify an individual as specified by data privacy laws. We may also collect Personal Information when we communicate with you or when you sign up for emails or other correspondence from us. We provide you with opt-ins prior to our collecting Personal Information. We do not generally seek to collect sensitive Personal Information from our Website. Sensitive Personal Information is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sex life, sexual orientation, genetic or biometric information. If we do collect sensitive Personal Information, we will ask you for explicit consent at the time of collection.
Passive Collection of Information
In addition to the Personal Information that you actively provide to us, we and our third party service providers may use a variety of technologies to automatically collect certain information about your use of the Website from your computer, mobile, tablet, or other device through which you access the Website (“Usage Information”). This Usage Information may include demographic information, location data, IP address, browser type and operating system characteristics. The methods that we may use to automatically collect such Usage Information may include the following:
- Cookies and Analytics Policy. Cookies are data files that are placed on a computer when it is used to visit a website. These cookies may be used for:
- session management,
- improve user experiences,
- store authorization token that users receive when they login to private areas of the Website,
- track anonymous site usage; and
- permit connectivity with social media networks to permit content sharing.
- There are different types of cookies and other technologies used on our Website, notably:
- Session cookies. These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (such as Internet Explorer, Google Chrome, or Safari);
- Persistent cookies. These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Facebook, Pinterest, other Social Network Cookies. Our Website will allow you to share content appearing on our Website to your social media accounts through the “Like,” “Pin”, or similar buttons displayed on such pages (collectively, “Social Network Features”). To execute this offering, we embed code that such third-party social networks provide and that we do not control. If you click on these Social Network Features, those corresponding social networks know that you are logged into your social network account and therefore could also know that you are viewing our Website.
- Analytics/Performance Cookies. We also use the following analytic tools to help us analyze the performance of our Website as well as how visitors use our Website.
- Hubspot. For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy. You can opt out of being cracked through directions provided in that same link.
- Google Analytics. For more information on Google Analytics cookies, and to understand how Google uses data, visit www.google.com/policies/privacy/partners. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.
- Firebase. For more information about Firebase cookies, visit www.google.com/policies/privacy/partners. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Firebase cookie-free web browser.
- Adobe Analytics. For further information about Adobe Analytics and how they use analytics data, click here. To go directly to an opt-out tool for Adobe Analytics, click here.
- Web Beacons. We may include small graphic images called web beacons, also known as “Internet tags” or “clear gifs,” in our web pages. We may use web beacons or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to the Website and other website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Information We Receive From Third Parties
We may, from time to time, obtain information about you from third party sources. When we associate information that we obtain from third parties with Personal Information that we have collected under this policy, we will treat the acquired information like the Personal Information that we collected ourselves. We will not share information we obtain from third parties in personally identifiable form. However, we may share aggregated, de-identified, non-Personal Information as described in this policy, including information we obtained from third parties.
We do not collect Personal Information about you automatically, but we may combine Usage Information with Personal Information. To the extent we combine Personal Information with Usage Information, we will treat such information as Personal Information.
Information We Receive on Behalf of Third Parties
We perform travel booking services for other entities on occasion and may collect and use information about individuals through the methods described herein at their behest (collectively, “Booking Personal Information.”) Booking Personal Information may include the categories of information listed in the Personal information definition above. The agreements with these entities govern how we process this Booking Personal Information, not this Privacy Statement. To the extent we combine Booking Personal Information with Personal Information we have collected through our Website, we will treat the combined information in accordance with the practices described in this Privacy Statement, in addition restrictions imposed by the particular entity. While we are responsible for our processing activities on these entities’ behalf, we are not responsible for how these entities treat the Personal Information we collect on their behalf. We recommend you review their own Privacy Policies.
How We Use Your Information
We use your Personal Information that we collect about you or that you provide to us as provided in this Statement and pursuant to the chart below. We must have a valid reason to use your Personal Information, or a “lawful basis for processing.” Please note that we may process your Information without your knowledge or consent, where this is required or permitted by law. (Where you provide consent, you can withdraw your consent at any time and free of charge, but that does not affect the lawfulness of our processing based on your consent before you withdrew it. You can update your details or change your privacy preferences by contacting us as provided in the Data Protection Contact section above).
Purpose/activity for which Vacayou will process your Personal Information
Lawful basis for processing including basis of legitimate interest, if applicable
To enable you to access Personal Information on and, when available, register for an account on our Website.
It is in our and your legitimate interest to provide services to you and register you for an account on the Website, when available, at your request. This use is necessary for our legitimate interests and is proportionate.
To manage our relationship with you, which will include, but not be limited to:
(b) asking you to leave a review or take a survey;
(d) enforcing the terms of this Privacy Statement;
(e) enforcing the terms of any contract entered into with you; and
(f) understanding your preferences, usage patterns, and concerns regarding our services.
It is in our legitimate interests to:
(a) perform pursuant to the terms of a contract with you;
(b) keep our records updated, to study how customers use our products/services, and to improve the user experience;
(c)-(e) to comply with a legal obligation and enforce our rights under contract(s) with you; and
(f) keep our records updated, to study how customers use our services, and to improve the user experience.
To send you email and other communications concerning Vacayou.
To administer, protect, and improve certain functions of our business and products/services (including providing customer support, administrative services, troubleshooting, testing, system maintenance, reporting and hosting of data).
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we provide to you.
Necessary for our legitimate interests (to understand how customers use our services, to develop them, to grow our business, and to inform our marketing strategy).
To use certain data analytics and research to improve our website, services, products, marketing, customer relationships and experiences. In particular, we will analyze the most popular trips and seek to optimize trip searches.
To assist law enforcement or other regulatory bodies or legal process in any investigations relating to suspected illegal or wrongful activity, and to protect our rights, property, and safety, or the rights, property, and safety of third parties.
It is in our legitimate interests to cooperate in any investigations relating to illegal or wrongful activity and to protect our rights or the rights and remedies of third parties.
To provide you with information and services that you request from us.
It is in our legitimate interests to respond to your inquiries, provide our services, and provide information requested in order to generate and develop business.
To protect against and prevent fraud and manage and defend risks, claims, and other liabilities.
It is in our legitimate interests to protect our business and rights or the rights and remedies of third parties.
To comply with applicable legal requirements.
It is our legal obligation to comply with applicable legal requirements.
To comply with industry standards.
It is in our legitimate interests to protect our business by complying with relevant industry standards.
To perform research, distribute surveys to you, and perform product analysis and development.
It is in our legitimate interests to determine which products/services are most popular, and perform research to improve our business and offerings.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or as otherwise required by law. If we are legally permitted to do so and need to use your Information for an alternative purpose, we will notify you and we will explain the legal basis that allows us to use your Personal Information in that fashion.
You may receive marketing materials from us if you have requested information from us or have used our services and opted into receiving such information. You have the right to opt out of receiving marketing communications at any time by contacting us at the Data Protection Contact section above.
We may also use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our Website users, and other information that does not identify any individual, without restriction.
We may disclose Personal Information or other information that we collect or you provide as described in this Policy:
- To our subsidiaries and affiliates.
- To contractors, services providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose to them. We share information with entities that process information on our behalf for our business purposes. Service providers assist us with services such as data analytics, marketing and advertising, payment processing, travel and booking reservation, identity verification, website hosting, and technical support. Whether these third parties collect the Information on behalf of the Company or receive the Information from the Company, they are also under an obligation to keep the information confidential in accordance with the terms of this Policy. We prohibit third parties that receive or collect Personal Information from us to support our business to market their products or services to you.
- To a buyer to other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our Website users is among the assets transferred.
- To a prospective seller or buyer of any part of the Company’s business or assets, in which case we may disclose your Information to such prospective seller or buyer for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent, as described at the time you provide such consent.
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Vacayou, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Certain third parties may collect Personal Information about your online activities over time and across different websites when you use the Website.
We have implemented appropriate physical, technical, and organizational safety measures to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All Personal Information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. Where data processing is performed on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorized disclosure of Personal Information. Our server infrastructure is hosted by Amazon Web Services (AWS). Information on AWS data center controls can be located on their website: https://aws.amazon.com/compliance/data-center/controls/.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Vacayou retains Information only as long as reasonably necessary to fulfill the purposes for which it was collected, including for the purpose of satisfying any legal or regulatory requirement. We may retain your Information longer if necessary in the event of a complaint.
Users in the European Economic Area and Canada
Request Access to your Personal Information
You have the right to access your Personal Information. You may do so by contacting us in the Data Protection Contact section of this Statement. You may also have the right to receive Personal Information you provided to us in a commonly used and structured format in order for it to be transferred to another data controller. This right applies if your Personal Information is processed by us with your consent. It also applies for the performance of a contract and when processing is carried out by automated means.
Request Correction of your Personal Information
You may ask us to correct or remove any Personal Information that is inaccurate by contacting us as provided in the Data Protection Contact section of this Statement. Please keep us informed if your Personal Information changes during your relationship with us.
Request Erasure of your Personal Information
In certain circumstances, you may request the erasure of your Personal Information, which is referred to as the right to be forgotten.
Object to Processing of your Personal Information
You may object to processing your Personal Information for direct marketing purposes. You also have the right to object at any time to processing your Personal Information which is based on our legitimate interests, pursuant to grounds relating to your particular situation. If you object on this ground, we shall no longer process your Personal Information unless we can demonstrate compelling legitimate grounds for such processing, and those grounds override your interests, rights, and freedoms; or, to establish, exercise, or defend legal claims. Note that our inability to process your Personal Information may make it impossible for you to access or use the services offered through the Website.
Request Restriction of Processing your Personal Information
You may restrict the processing of your Personal Information to processing in certain circumstances. Note that our inability to process your Personal Information may make it impossible for you to access the services offered through the Website.
Request Transfer of your Personal Information
You may request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to updated information that you initially provide consent for us to use or where we used the information to perform a contract with you.
You have the right to withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdrew 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.
Not Be Subject to Profiling or Automated Decision-Making
You have the right not to be subject to a decision based solely on automated data processing, including profiling, where the decision has a legal or other significant effect, subject to certain exceptions.
Information from You
Upon the exercise of any of these rights, as a security measure, we may need to request specific information from you to confirm your identity and ensure your right to access your Personal Information or exercise your other rights. We do this to ensure that Personal Information is not disclosed to any person who does not have a right to receive it. We may also reach out to you for further information in relation to your request.
How to Exercise these Rights
You may exercise any of your rights as described in this Statement and under applicable data privacy laws by contacting us in the Data Protection Contact section above. Except as described in this Statement or provided under data privacy laws, we do not charge you to exercise your legal rights as stated herein. However, if your requests are manifestly excessive or unfounded (particularly if they are repetitive), we may either a) charge a reasonable fee for providing the information or taking the action requested; or b) refuse to act on the request.
Choices About How We Use and Disclose Your Information
Although we may process your Personal Information pursuant to applicable law as we have described in this Statement, we strive to provide you with choices regarding the Personal Information you provide to us, and have created mechanisms to empower you with the following control over your information:
- Tracking Technologies and Advertising. To learn more about opting out of data collection through Google Analytics, click here. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website.
- Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can withdraw your consent or opt-out by checking the relevant box located on the form on which we collect your data or at any other time by sending us an email stating your request to Ryan Schneider at email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a service purchase, or other transactions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending an email to Ryan Schneider at firstname.lastname@example.org. For this opt-out to function, you must have your browser set to accept all browser cookies.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to the contact listed in the Data Protection Contact section of this Statement.
Accessing and Correcting Your Information
To the extent the Company offers accounts through the Website:
- you may review and change your Personal Information by logging into the Website and visiting your account profile page.
- You may also send us an email at Ryan Schneider at email@example.com to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
- If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users.
The Website is not directed at children younger than the age of 13. If we learn that a user is younger than 13 years of age, we will promptly delete any Personal Information that the individual has provided to us. If you are younger than 13, do not use or provide any information on Vacayou. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
The Website may contain links to websites, Social Network Features, features and functionality controlled by third parties, including third parties that may perform and process travel bookings. If you interact with those third-party websites, both Vacayou and the third party may collect certain information about you and your use of the Website and the third-party website or service. Specifically, those websites and services may automatically collect information about your visit to their sites and may use their own tracking technologies, including cookies. Those websites and services are subject to the privacy policies of the third parties that control those websites, and not this Privacy Statement.We encourage you to check the privacy policies of such third-party websites and services before using them or disclosing any Personal Information to them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Notwithstanding anything to the contrary herein, any information we collect in connection with Social Network Features or third-party websites is subject to this Privacy Statement.
In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your “connections’” web pages, profile pages, or similar pages on a social networking or other third party website or interactive service. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website or service.
Transfer of Data from European Economic Area (“EEA”) to United States of America
If you are located in the EEA, it is necessary for us to transfer your Personal Information outside of the EEA to our Website and third-party service providers located in the United States of America and as described herein.
When Personal Information is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for Personal Information such as the United States, we take steps to provide appropriate safeguards to protect your Personal Information by implementing standard contractual clauses.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.
Notice of Transfer of Data from Canada to United States of America
If you are located in Canada, you understand that your Personal Information is being transferred from Canada to the United States of America.
If you have questions, suggestions, or complaints about this Privacy Statement or Vacayou Travel’s privacy practices, send an email to the contact listed in the Data Protection Contact section of this Statement. If you are located in the EEA or Canada, you may also have a right to complaint to your relevant supervisory authority in the EEA or Canada.