Privacy Policy

1. PRIVACY POLICY

TravMedia ("TravMedia" / "we" / "our" / "us") takes your privacy very seriously and is committed to protecting and respecting your privacy.

This privacy policy (together with the Terms of Use for use of Website (as defined below) and the Services (as defined in the Terms of Use), which you can find here) sets out the basis on which any personal data we collect from you, or that is provided by you through your use of the TravMedia website (https://us.travmedia.com) (the “Website”) and the Services, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

TravMedia is the data controller.

This privacy policy applies to:

Visitors of the Website, i.e. someone who is only visiting the Website, but is not accessing the Services; and/or
Users of the Services, i.e. someone who can access the services via a registration.

This privacy policy does not apply to websites that you may be able to access via links on the Website or the Services and/or activities offered by third parties. Please ensure that you review any relevant policies on any third party websites before proceedings. We are not responsible for the collection or use of your personal data from these third party websites. This privacy policy also does not apply to websites run by our sister companies, including (but not limited to) https://www.food4media.com, https://www.property4media.com and https://www.homes4media.com.

CONTRACT

Unless you are a Visitor, you will have entered into an agreement with TravMedia for the use of the Services (the “Contract”). Please note that the information you provide to us (whether it is personal or non-personal information) will also be governed by the Contract.

DATA WE COLLECT FROM YOU OR ABOUT YOU AND OUR SOURCES OF THAT DATA

We will collect the following data about you:

Data you give us. You may give us data about you:

when you fill out a form on the Website or the Services;
when you register or subscribe to use the Services;
when you report a problem with the Website or the Services;
if you sign up to receive marketing communications form us about products or services we offer;
if you complete a survey, for example, about the Services;
when you provide us with feedback, opinions and / or comments regarding the Website or the Services;
when you transmit or upload content including, but not limited to photographs, opinions and reports to the Services;
if you contact or correspond with us (for example, by phone, e-mail or otherwise) for any other reason (for example, to request further services from us); and
when you use any interactive services on the Website or the Services.

Data we collect about you. We will automatically collect the following

when you use the Website or use the Services, details of your usage (including the date, time, location or duration of the usage);
if you visit the Website or use the Services, certain technical information, for example, the type of device (and its unique device identifier) you use to access the Website or the Services, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform; and
information about your visit to the Website and Services including the full Uniform Resource Locators (URL), clickstream to, through and from the Website or Services (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Data we collect or are provided with personal data from third parties. We may be given or collect personal data bout you by / from third parties:

such as event organisers who we partner up with; and
when a user of the Services uploads data to the Services. We require them to confirm that they have provided with the appropriate notices and/or obtained the appropriate consents from you to do so.

PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR DATA

We will process the personal data held about you for the purposes stated below:

Purpose of processing	Type of personal data	Legal basis for processing
To enable us to process your registration for access to the Services	Your name, gender, job title, organisation details, address, telephone number, email address and preferences	Performance of our contract with you
To enable us to identify you and any accounts you hold with us	Your name, username and email address	Performance of our contract with you
To upload and share your content to the Services (such as a travel blog)	Your name, username and the content you have requested to upload	Performance of our contract with you or consent if the content is a photograph
To monitor your use of the Services	Your name, username and email address	Legitimate Interest – to allow us to ensure that the Services is used in accordance with the terms and conditions
To provide the Services to other users of the Services	Your name, username, email address and content (for example, photographs)	Performance of our contract with you or consent if the content is a photograph
To deal with any enquiries, correspondence, concerns or complaints you have raised	Your name, information about the issue raised, organisation (if applicable), phone number and email address	Legitimate Interest – to allow us to improve the Services
To ensure that the Website and the Services are presented in the most effective manner for you and for your device	Technical information as mentioned above	Legitimate Interest – to allow us to present the Website and Services better
For our internal operations, including data analysis, testing, research, statistical purposes and troubleshooting	Technical information as mentioned above	Legitimate Interest – to better understand our Users and continuously improve the Website and the Services
As part of our efforts to keep the Website and the Services safe and secure	Technical information as mentioned above	Legitimate Interest – to improve and ensure the safety of the Website and the Services
To suggest content you may be interested in	Your name, username and email address	Consent
To allow users to use and access the Services worldwide	Your name, gender, job title, organisation details, address, telephone number, email address, preferences and content uploaded by you	Consent
To provide you with information, products or services that you request from us or which we feel may interest you	Your name, username and email address	Consent
To notify you about changes to any element of the Terms and Conditions, Website or Services, for example, an update or upgrade	Your name, username and email address	Performance of our contract with you

Where we need to collect personal data by law or as part of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you with the Services.

Where we have a legal basis to use your personal data without consent (as we have described above), this policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.

Where consent is required for our use of your personal data as described above, we will request your consent. Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non mandatory information), you consent to our use of that personal data as set out in this policy. For example, we will only process your personal data for marketing purposes if we have your consent to do so.

You can always change your mind about our processing of your personal data. If you change your mind you can update your account settings within the Services, or contact us by email at legal@TravMedia.com, or in respect of marketing messages you can unsubscribe by using the unsubscribe link at the bottom of our marketing messages.

YouTube

In certains sections of the site, we make use of YouTube API Services. By continuing to use these services, you are bound by and agree to the YouTube Terms of Service (https://www.youtube.com/t/terms) and the YouTube Privacy Policy (https://policies.google.com/privacy).

Data collected from YouTube API Services is used for the display of content from YouTube, and may include videos on your YouTube Channel as well as analytics about your content.

Data collected is updated frequently and stored for no longer than 30 days.

Along with the deletion of stored Data, you can also revoke access to your data via the Google security settings page at https://security.google.com/settings/security/permissions.

You can contact us if you have any questions regarding your Data at legal@TravMedia.com.

MARKETING

We would like to provide you with information by email about our products and services which may be of interest to you. We will provide you with marketing communications unless you ask us not to.

If you no longer wish to receive marketing communications from us, please contact us by email at legal@TravMedia.com or by clicking the unsubscribe button in marketing communication.

You can also manage your preferences by updating / changing the privacy settings of your account.

DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with selected third parties in accordance with this policy, including:

any member of our group of companies, including our subsidiaries and ultimate holding company;
third party who we run events with;
service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any Contract we enter into with you, but also when providing you with marketing communications;
analytics and search engine providers that assist us in the improvement and optimisation of the Website and the Services;
government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information);
in the event that we sell any business or assets or receive investment into our business, in which case we may disclose your personal data to the prospective buyer or investor;
if TravMedia or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your personal data, will be one of the transferred assets; and
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Terms and Conditions for the Services or the Website or any other contract between you and us; or to protect the rights, property or safety of TravMedia, our users, and others.

WHERE WE STORE YOUR PERSONAL DATA

Your personal data will be transferred to, processed and stored at destinations outside the European Economic Area (“EEA”), including countries in which we have offices such as the US and Australia.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. To find out which countries are covered by this, please see here.
Where there is no adequacy decision by the European Commission in respect of these countries (to the extent that they are outside the EEA), which means they are not deemed to provide an adequate level of protection to your personal data, we will still ensure that your personal data receives an adequate level of protection. We have therefore put in place the following measures to ensure that your personal data is treated by those third parties in a way that is consistent with EU and UK laws on data protection:
- EU-US Privacy Shield; and/or
- EU standard contractual clauses.

If you would like to find out more about these safeguards in respect of processing of your personal data, please contact us at legal@TravMedia.com.

The Website and the Services can also be accessed and used worldwide, which means your data may be processed outside the EEA. Please note that the country from which you are accessing personal data may not provide an adequate level of protection for your personal data.

SECURITY

All information you provide to us is stored on secure severs. We will use appropriate technical and organisational measures to safeguard your personal data.

Where we have given you (or where you have chosen) a password which enables you to access the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We maintain (and ensure that anyone we share your personal data with maintains) appropriate technical and organisational measures to ensure that an appropriate level of security in respect of all personal data we process. Unfortunately the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the Website or any of the Services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.

RETAINING PERSONAL DATA

We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this privacy policy or in accordance with our legal rights and obligations. 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 requirements.

Unless we inform you otherwise (or you request that we erase your personal data), we will retain your personal data on record for as long as you continue to use the Services. However, if you do not use the Services for 12 months then we will contact you to inform you that your data / account will be deleted within 12 months unless you access your account to stop this process.

Even if you request that we erase your data, we may still need to keep it (please see below) or may keep it in a form that does not identify you. If we are processing your personal data as part of a Contract and you have not agreed that we may use your data for marketing purposes, we will retain your personal data on record for no more than the duration of the Contract and 6 years thereafter.

YOUR RIGHTS

You have the following rights with regard to your personal data:

Access. You have the right to access data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Rectification or erasure. You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it). If you request that we erase any personal data that we require in order to provide the Services to you, you may no longer be able to use it. This right does not extend to non-personal data. It is likely to be necessary for us to retain your personal data to enable us to carry out a Contract with you and your rights under applicable law to request erasure may be limited accordingly. This means your rights under applicable law to request erasure may be limited accordingly.
Data portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller if the legal basis for processing such personal data is consent or performance of a contract.
Restriction. You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need to your personal data for the purposes for which we hold it.
Object / Change of preferences. You have a right to request that we stop processing your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object where we are processing your personal information for direct marketing purposes. For example, if you have given your consent to receive updates from us about new products or services, but have changed your mind, you have the ability to opt out from receiving such communications going forward by contacting us using the details provided below or clicking the relevant link in any communications you receive. Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to facilitate your use of the Services, you will no longer be able to use the Services following your request for us to stop the relevant processing.
Complaints. If for any reason you are not happy with the way that we have handled your personal data, please contact us. If you are still not happy, you have the right to make a complaint to the Information Commissioner's Office.
Automated decision making. We do not currently carry out decisions based solely on automated processing, including profiling. If we change our practices to do this in a way which has legal or similarly significant effects on you, you may have the right to object. If this becomes relevant in the future, we will update this policy to provide further information.

Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of any of the Services you may not be able to use the Services as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. Please allow at least 3 working days for your request to be actioned.

Please note that the rights mentioned above do not extend to non-personal data. Please also note that it is likely to be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted and/or held on the Services and to manage the Services, so therefore your rights under applicable law to request erasure may be limited accordingly.

If you would like to exercise any of the rights mentioned above, please contact us by email at legal@TravMedia.com.

2. COOKIE POLICY

We use cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer or mobile device if you agree. Cookies contain information that is transferred to your computer's or mobile device's hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of the Website and the Services. They include, for example, cookies that enable you to log into the Services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. They also enable us to see how users use the Services. This helps us to improve the way the Website and the Services work.
Functionality cookies. These are used to recognise you when you return to the Services. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to the Website or the Services, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie	Purpose
Login cookie	Keeps the user logged into the site and will log them back in if they close the browser and reopen it.
Language cookie	Remembers the chosen language by the user.
Security cookie	Links device with individual user. These show in the account settings page.
Chat windows (browser local storage)	Remembers the chat windows the user last had open.

By clicking “agree” on the cookie consent box when you first access the Website or the Services and by continuing to access and use the Services (as applicable) you accept our use of the cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website or the Services.

For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.

3. WHICH PROVISIONS OF THE PRIVACY POLICY AND COOKIE POLICY APPLY TO YOU?

Provisions of the privacy policy and cookie policy, which do not state who they apply to, apply to all Visitors and Users. Please note that you may be a Visitor and/or a User depending on your interaction with us.

4. CHANGES TO THE PRIVACY POLICY AND COOKIE POLICY

Any changes we make to our privacy and cookie policies in the future will be posted on us.travmedia.com/privacy-policy and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy and cookies policies. Continued use of the Website or Services (as appropriate) will signify that you agree to such changes.

5. CONTACT

Questions, comments and requests regarding the privacy policy and the cookie policy are welcomed and should be sent to legal@TravMedia.com.

Please also contact us if you would like to know more about our data processing activities, to update or amend any of your personal data which you have provided to us or if you believe our records relating to your personal data are incorrect.

These policies were last updated on Friday May 25th, 2018.