Last Updated: October 19th, 2021
INTRODUCTION AND SCOPE
The protection of Personal Information is of a particularly high priority for the management of What a Life Tours, LLC (“What a Life Tours,” “we,” “us,” or “our”). Our website visitors can browse some of the website pages without having to submit any Personal Information; however, if such a website visitor intends to use some of the features and services we provide (such as booking a tour), then it may be necessary to collect certain Personal Information from the visitor.
DEFINITIONS AND INTERPRETATIONS
- Personal Information is any information that can identify a natural individual. This may include, without limitation, a name, picture, email address, phone number, location, and IP Address of a particular user. For users in the GDPR Areas, Personal Information is the same thing as “Personal Data.”
- Processing is any operation performed on Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- Services refer to the features provided through the website (in essence, the booking and receiving of tours).
- Anonymized Information refers to the removal of Personal Information from any information in such a manner that it can no longer be attributed to a specific person without the use of additional information. This may also be referred to as non-personal information as it can no longer identify a particular individual.
- Consent refers to any freely given, specific, informed, and unambiguous indication you give, by a statement or by a clear affirmative action, which signifies your agreement to the processing of Personal Information.
When you access and use the website, we will obtain Personal Information and Anonymized Information in different ways:
Information you submit to us
We will collect the Personal Information you submit to us through your inputs on the website. This may include, without limitation, when you:
- submit booking information;
- submit your payment method information for your tour booking;
- subscribe to our newsletter in the newsletter form provided on the website;
- submit comments on any of our blogs;
- contact us for inquiries, queries, or questions; and
- submit information on any other form available on the website.
Information we collect automatically
When you access the website or interact with our content, newsletter, and social media pages, we obtain certain Personal Information and Anonymized Information using cookies, pixels, tags, and other tracking technologies, as well as Google Analytics, automatically. The information we collect automatically is mostly Anonymized Information. The information we obtain automatically include:
- Analytics and usage information. This includes information about how you use the website, including the features you use, your duration of use, the website or source of your visit to the website, etc.
- Device information. This includes the device you access the website with, including the browser name, operating system, IP address, and other identifiers.
- Transaction information. This includes your bookings and payments for tours through the website.
WHY WE COLLECT INFORMATION
We generally collect Personal Information to allow you to book a tour, process your payments, and fulfil our obligations. Other reasons for collecting your Personal Information include:
- To respond to your queries, questions, and inquiries, as well as send your newsletters and administrative notices;
- To enable you to navigate the website and access the content and pages smoothly;
- To gather information about how you use the website and provide improvements where necessary;
- To comply with our legal obligations and enforce our Terms and Conditions;
- To identify you from other users;
- To prevent fraudulent behaviors and secure our Services; and
- To perform other purposes described at the time of collection.
INFORMATION SHARING AND DISCLOSURE
We do not share or disclose Personal Information to third parties except for those described below:
Third-party service providers
Third-parties service providers who we hire may access certain Personal Information about you. What a Life Tours uses third parties to perform tasks such as payment processing, tour fulfillment, analytics gathering, website security, email sending, and advertising. Some of these third parties include Fareharbor for payment processing and Google Inc., Facebook, and Instagram for analytics, usage, and other tracking information gathering. We also use third parties to provide guided walks/tours in the respective tour locations. In order to perform their services, these service providers require access to your Personal Information. For example, our third-party walk/tour providers require your Personal Information to identify and validate you when you show up to receive your tour.
Other users of the website
If you post content, such as reviews and comments on our review pages and the website, your content will become publicly available, and any Personal Information attached to it may be visible to other users and visitors. However, where relevant, we provide a pseudonym to protect your Personal Information (for example, you can comment on our blogs under a fake name or pseudonym).
We may disclose Personal Information about you to law enforcement in response to a subpoena, court order, or other legal summonses subject to an ongoing investigation or the prevention of our intellectual property rights or those of other users or third parties. If we are required by the government to disclose Personal Information, we will comply with the law.
We may share Personal Information with another business if we engage in any business transfer action. This may include in situations where such a business acquires any of our assets; where we partner with such a business; where we merge with such a business; or where we consolidate with such a business or businesses.
Third parties at your request
We may disclose personal information to third parties if you explicitly request that we do so.
COOKIES AND TRACKING SOFTWARE
The cookies on the website and our content are set by us; however, some of our third-party service providers also set their own cookies to perform their services. For example, Google Inc. and Facebook Inc. embed cookies in Google Analytics and widgets to track user interactions on their content.
Cookies have two categories of duration: The session cookies, which last for a browsing session (i.e., they expire when you close your browser after a browsing session). Persistent cookies, on the other hand, have defined expiry dates, which may extend for months.
Users may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the browser used and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via the browser or other software programs. This is possible in all popular browsers via the settings, tools, or help sections. However, if you deactivate cookies, not all functions of our website may be entirely usable.
SUBSCRIPTION TO NEWSLETTER
You may subscribe to receive newsletters from us by submitting your email address on the form provided on the website or by ticking a box of consent on applicable places on the website. When you subscribe to our newsletter, we will occasionally inform you about news, promotions, bonuses, and offers relating to tours.
During your subscription to our newsletters, we also store your device’s IP address, as well as the date and time of subscription. We collect this information to understand the (possible) misuse of your email address at a later date, and it, therefore, serves the aim of our legal protection.
The Personal Information collected as part of your subscription will only be used to send our newsletter. In addition, we will inform subscribers email, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of Personal Information collected by the newsletter service to third parties.
You have the right to opt out of receiving newsletters at any time. You may use the link for unsubscribing at the bottom of any email we send to your email address. It is also possible to unsubscribe from the newsletter at any time directly on the website via the “Contact” section.
RETENTION PERIOD OF PERSONAL INFORMATION
What a Life Tours shall only process and store your Personal Information for the period necessary to achieve the purpose of collection and storage, or as far as applicable laws permit.
If the storage purpose is not applicable, or if a storage period prescribed by the applicable law expires, the Personal Information is routinely blocked or erased in accordance with legal requirements. For example, if you unsubscribe from our newsletter, we will remove your email address from our mailing list.
However, for any Personal Information shared through your content and those that exist with our service providers, we do not have any controls over them.
SECURITY OF PERSONAL INFORMATION
What a Life Tours have implemented numerous technical and organizational measures to ensure the most complete protection of Personal Information processed through this website. However, Internet-based data transmissions may, in principle, have security gaps; so, absolute protection may not be guaranteed. For this reason, we cannot guarantee that only authorized persons will have access to the Personal Information you share or transmit through the website.
In relation to the Personal Information we process when you use our Services, you have the following rights.
- Right of confirmation: You have the right to confirm from us if we are processing your Personal Information or not.
- Right of access and rectification: You have the right to request access to and rectify your Personal Information at any time. For example, if you believe that the payment or booking information you submit is false, you may reach out to us to correct it. You may also reach out to find out about the types and categories of Personal Information we are processing and the third parties we shared them with.
- Right to erasure: You may request that we delete Personal Information at any time, provided your request does not override the law or our legitimate interest. We may be able to delete your booking information, email address, and any information submitted via forms.
- Right to object to the processing of Personal Information: If you believe we are unlawfully processing your Personal Information or you want it unprocessed due to certain reasons, you may request that we stop processing it.
- Right to reporting: If you believe we are unlawfully processing your Personal Information in accordance with applicable law, you may report us to any supervisory authority in your jurisdiction.
- Right to withdraw your consent: Where we are processing your Personal Information based on consent, you may withdraw your consent at any time.
If you wish to exercise any of these rights above, please reach out to What a Life Tours via the “Contact.”
ADDITIONAL DISCLOSURE FOR EU AND EEA USERS
If you are submitting Personal Data to us from any location within the EU, EEA, or any country under the GDPR law, this section applies to you. With respect to your Personal Data, What a Life Tours is your Data Controller – we determine how your Personal Data is processed and used in relation to the Services.
Under the GDPR law, we are allowed to process Personal Data on the basis of one or more of the following legal bases:
- Consent: Where applicable, we will only process Personal Data if you give verifiable consent (for example, where you tick a consent box or willingly submit the Personal Data).
- Legitimate interest: We process some Personal Data and Anonymized Data – such as analytics and usage information – to provide the website, detect fraud and violations, gather analytics, measure user engagements, develop new products, and improve our website features and Services.
- Contract: We mostly collect Personal Data in order to perform and fulfill the tours you request and other obligations required of us.
- Legal compliance: We gather some Personal Data to comply with the law (for example, where we are required to collect details of transactions).
DISCLOSURE FOR USERS IN CALIFORNIA AND NEVADA
The California Consumer Privacy Act (CCPA) requires that businesses that collect Personal Information from people in California should grant their request if they wish to opt-out of the sale of Personal Information to third parties for profit. Fortunately, What a Life Tours is not engaged in the sale or transfer of Personal Information to third parties for their direct marketing activities.
Similar to the CCPA notice above, we are required to grant Nevada users their request if they wish to opt-out of the sale of their Personal Information for money consideration (as defined under Nevada law). This also applies to any future sale of such information from a third party to another third party.
Fortunately, What a Life Tours is not engaged in such activity. However, if you are using the website and Services from Nevada, you may reach out to us via the “Contact” section to request that we exclude your Personal Information from any potential future sale. Please, note that we may attempt to verify your identity before granting your request.
Do Not Track signal
The Do Not Track (“DNT”) signal is a browser setting that, when activated, prevents website operators from being able to track your online behaviors. DNT signal is not a stable mechanism; therefore, like other website operators, What a Life Tours does not currently respond to DNT signals. To learn more about DNT signals, please visit www.allaboutdnt.com.
INTERNATIONAL TRANSFER OF INFORMATION
For users who transfer Personal Data to us from locations under the GDPR law, we will only share or transfer Personal Data about you with third parties in locations outside your jurisdiction by relying on the European Union’s approved data transfer mechanisms.
In accordance with the requirements of the Children’s Online Privacy Protection Act (COPPA) and other minor laws, we do not make this website and our services available to persons under 13 years of age (or the equivalent in your location). We direct and target the website and our Service at persons of at least 13 years of age. If you are under 13 years of age, you may not submit Personal Information to us except it is done by at least a parent or legal guardian.
WE WELCOME FEEDBACK OR QUESTIONS