Last updated September 12th, 2022
Thank you for choosing to impact Africa through travel with Enroute54 (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at email@example.com.
TABLE OF CONTENTS
1. What information do we collect?
2. How do we use your information?
3. Will your information be shared with anyone?
4. Who will your information be shared with?
6. How long do we keep your information?
7. How do we keep your information safe?
8. Do we collect information from minors?
9. What are your privacy rights?
10. Data breach
11. Controls for do-not-track-features
12. Do California residents have specific privacy rights?
13. Do we make updates to this policy?
14. How can you contact us about the policy?
1. WHAT INFORMATION DO WE COLLECT?
We collect personal information that you voluntarily provide to us such as name, address, contact information, passwords, security data and payment information, when registering to use our services, expressing an interest in obtaining information about us or our products and services and when participating in activities on our services or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us, the service and choices you make and the products and features you use. The personal information we collect can include the following:
• Publicly Available Personal Information. We collect first name, maiden name, last name, email addresses; and other similar data.
• Personal Information Provided by You. We collect data collected from surveys; purchase history; and other similar data.
• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected. Some information, such as IP address and/or browser and device characteristics is collected automatically when you visit or navigate our services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
Online Identifiers. We collect tools and protocols, such as IP (Internet Protocol) addresses; cookie identifiers, or others such as the ones used for analytics and marketing; and other similar data.
2. HOW DO WE USE YOUR INFORMATION?
We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via our services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
Below are some definitions that will help you understand our roles and responsibilities:
“Data controller”: means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be used.
“Data processor”: in relation to personal information, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
If you provide the data and the instructions, then you are the data controller and Enroute54 is the data processor. If we determine the purposes for which we collect and use your personal information, then we are the Controller.
We use the information we collect or receive:
• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-in to our marketing emails at any time (see “What are you Privacy Rights” below).
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions and policies.
• Fulfil and manage your orders. We may use your information to fulfil and manage your orders, payments, returns, and exchanges made through our services.
• Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
• Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
• To protect our Services. We may use your information as part of our efforts to keep our services safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions and policies for Business Purposes, Legal and Contractual Reasons.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To deliver services to the user. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfil business obligations. We may process or share data based on the following legal basis:
• Consent. We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract. Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
• Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on our services, which will enable them to collect data about how you interact with the services over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
• Data Backup and Security
• Google Drive Backup
• Invoice and Billing
• Website Hosting
6. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect data from, solicit data from or market to children under 18 years of age. By using our services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data, we have collected from children under the age of 18, please contact us at firstname.lastname@example.org
9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you have questions or comments about your privacy rights, you may email us at email@example.com
Cookies and similar technologies. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services we provide.
10. DATA BREACH
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when we believe you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that we become aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information we will promptly investigate the matter and notify the applicable Supervisory Authority no later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with our services, you have the right to request removal of unwanted data that you publicly post on our services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
13. DO WE MAKE UPDATES TO THIS POLICY?
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact us at firstname.lastname@example.org