Last updated March 21, 2019
“Applicable Laws” means the GDPR and any data protection, privacy or other laws to the extent applicable to TripJunction Asia Limited.
“Personal Data” means individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual.
“Non Personal Data” means information that does not personally identify you and does not reveal your specific identity as an individual, such as anonymized information.
The terms “Controller”, “Processor”, “Processing”, “Supervisory Authority” and “Personal Data Breach” shall have the meanings ascribed to them in the GDPR.
“Visitor(s)” means Data Subjects who browse our Website.
“Platform” means our online marketplace for aircraft parts and/or related services connecting Guests and Guides, which can be accessed through our Website and API Integrations.
“Website” means our public website available at https://www.tripjunction.com. Our Platform is a section of our Website which can be accessed only by registered Users.
“Guest” means a Data Subject which is registered to the Website and uses the Platform in order to purchase local tours and activity services, whether acting on its own behalf or on behalf and under authorization of a legal entity with whom the Data Subject is employed, contracted or otherwise affiliated.
“Guide” means a Data Subject which is registered to the Website and uses the Platform in order to offer local tours and activity services, acting on behalf of and under authorization of a legal entity with whom the Data Subject is employed, contracted or otherwise affiliated.
“User(s)” means a registered Guest or Guide that uses of our Platform.
“Services” means the provision of our Platform, including all actions related to the facilitation and support of transactions on the Platform, and general support for usage of the Platform.
“GDPR” means the General Data Protection Regulation (EU) 2016/679, as amended from time to time.
This Policy was originally written in English. If you are reading a translation and it conflicts with the English version, please note that the English version prevails.
3. The Types Of Personal Data That We Collect
3.1. Personal Data That You Provide To Us
Guest information. If you are a potential Guest, we will ask you to provide certain Personal Data in order for you to register to the Platform, and for us to perform our Services; through our Sign up hyperlink on the Website or through the “Create a new account” hyperlink on the Website or through the Platform. The nature of the Services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list): name, email address, location, phone number, birth date, portrait photograph, and identification document (“Contact Details”).
Guide Information. If you are a Guide, we may ask you for your Contact Details, as well as bank account information. In addition, we may ask you for a list of the users who can access the company account.
While using the Platform, Users may upload documents and share Personal Data (“Disclosing Users”) with other Users (“Recipients”). We do not advise it, however, if you are a Disclosing User and you choose to upload documents containing Personal Data to the Platform and to otherwise share Personal Data with Recipients in order to conclude a transaction; we will be responsible strictly for our Processing of the Personal Data shared (which is limited to storing the Personal Data in your account), subject to this Policy. However, TripJunction shall not be liable in any way for any Processing of a Disclosing User’s Personal Data by a Recipient. If you are a Disclosing User, you hereby waive any claim against TripJunction for any damages incurred by your disclosure of Personal Data to a Recipient.
3.2. The Personal Data That We Collect Or Generate
If a Visitor and/or User browses our Website, we may collect Personal Data. This includes (by way of a non-exhaustive list): Screenshots/videos of the TripJunction’s screens of the User while browsing the Website, audio recordings of support and customer service conversations with Users, a User’s device Internet Protocol (IP) address through the use of “cookies”. For more information about the cookies we use, please see Section 11 below.
4. Non Personal Data
4.1. In addition to the categories of Personal Data described above, we will also process further anonymized information and data that does not identify a specific individual, including but not limited to:
a) Information that a Visitor’s/User’s browser sends (“Log Data”). This Log Data may include, but is not limited to, non-identifying information regarding the User’s device, operating system, internet browser type, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, the web page you were visiting and information you search, etc.
b) A Visitor/User session identifier which allows us to identify the User on the server side.
4.2. We may collect this Non-Personal Data through the Website and/or Platform in the following ways:
b) Use of other analytical tools, including tools which are supplied by third party service providers. For more information see Section 8 “Sharing Data With Others” below.
5. The Purposes For Processing Personal Data
5.1. Personal Data, of Visitors and Users, is used for the following primary purposes (as may be updated from time to time), in order to:
a) provide and operate the Services;
b) monitor and analyze use of the Services and study and analyze the functionality of the Services;
c) provide ongoing customer assistance, technical support and maintain the Services;
d) provide service announcements and notices, promotional messages and market the our Services;
f) better understand your needs, both on an aggregated and individualized basis, in order to further develop, customize and improve our Services based on Visitor’s and Users’ preferences, experiences and difficulties;
g) communicate with you and contact you to obtain feedback from you regarding the Services;
h) disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Services;
i) enable the Service’s tools and features,
j) to create aggregated statistical data and other aggregated and/or inferred Non-Personal Data, which we or our business partners may use to provide and improve our Services; and
k) as otherwise authorized by you.
5.2. We may use your email address to contact you when necessary, including in order to send you reminders, offers and to provide you information and notices about the Services. At any time, you may choose (opt out) whether your Personal Data is to be used for sending such marketing materials which are not an essential part of the services on the Website. You may exercise your choice by contacting us at: firstname.lastname@example.org
6. How We Use Non Personal Data
6.1. We may use information that is Non Personal Data, of Visitors and Users, for the same purposes we use Personal Data (where applicable) and in addition in order to:
a) compile anonymous or aggregate information,
b) disclose to third party vendors, service providers, contractors or agents who perform tasks on our behalf in connection with the Services,
c) monitor and analyze use of the Services and for the technical administration and troubleshooting of the Services, and
d) provide us with statistical data.
6.2. We use anonymous, statistical or aggregated information, which may be based on extracts of your Personal Data, for legitimate business purposes including for testing, development, improvement, control and operation of the Services. We may share such information with our third party providers. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your Personal Data only subject to the terms of this Policy, or subject to your prior informed consent.
7. The Legal Basis For Use Of Personal Data
7.1. We will only process a Visitor’s or User’s Personal Data where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use the Personal Data. In almost all cases the legal basis will be:
a) To provide the Services and otherwise perform agreement.
b) To fulfill a legitimate interest that we have as a business.
c) Because you consented to us using the Personal Data for a particular purpose.
More information on the basis of processing:
a) Processing the Personal Data is required for performing the Services, for example: we must process your Personal Data including information about your name and password in order to identify you for you to use the Services.
b) Processing the Personal Data is required for fulfilling our or a third party’s legitimate interests, for example: (1) we collect information about use of our Website in order to identify and prevent its abuse; (2) we use Personal Data to maintain and improve our Services by identifying usage trends and technical issues.
c) A Visitor/User consents to the processing of Personal Data for one or more specific purposes, for example: to the extent that a Visitor consents, we will send it information about our Services.
7.2. It is hereby clarified that the legal bases detailed above are the legal bases for actions to process Personal Data, carried out by us in accordance with the GDPR. If processing of Personal Data is subject to other Applicable Laws, then the legal basis for processing Personal Data may differ according to those Applicable Laws.
8. Sharing Data With Others
8.1. We do not sell, rent or lease your Personal Data. We may share your Personal Data with service providers and other third parties, if necessary to fulfil the purposes for collecting the information, such as cloud vendors, subcontractors providing us processing services, etc., provided that any such third party will commit to protect your privacy as required under the applicable laws and this Policy.
8.2. We may also share Visitor’s and/or User’s Personal Data with companies or organizations affiliated with us, such as subsidiaries and parent companies, with the express provision that their use of such Personal Data must comply with this Policy.
8.4. Additionally, a merger, acquisition or any other structural change may require us to transfer your Personal Data to another entity, provided that the receiving entity will comply with this Policy.
8.5. We may need to disclose Personal Data in response to lawful requests by public authorities or law enforcement officials, including meeting national security or law enforcement requirements. We cooperate with government and law enforcement officials to enforce and comply with the law.
9. Transfer Of Data Outside Your Territory
9.1. We may store, process or maintain Personal Data in various sites worldwide, including through cloud based service providers worldwide. Where the GDPR applies and we transfer Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the EEA, for example, this may be done in one of the following ways:
a) the country that we send the Personal Data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
b) the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
c) where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
d) in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.
9.2. You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described the Section “CONTACT US” below.
9.3. If you are located in a jurisdiction where transfer of your Personal Data to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer or the storage, processing or maintenance of the information in other jurisdictions by using the Services.
10. Access Rights
10.1. In all of the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge.
10.2. At any time, you may contact us at: email@example.com and request to know what Personal Data we keep about you. We will make reasonable efforts to locate the data that you request to access.
10.3. Under your right of access, you may obtain confirmation from us of whether we are processing Personal Data related to you, receive a copy of that data, so that you could verify its accuracy and the lawfulness of its processing, request the correction, amendment or deletion of the Personal Data if it is inaccurate, incomplete, outdated or processed in violation of applicable law. However, we may retain certain information as deemed required by us in accordance with applicable laws, or for legitimate business reasons, for the duration as required under applicable laws.
10.4. In addition, we may delete any Personal Data pursuant to our policies, as in effect from time to time.
10.5. When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you questions to better understand the nature and scope of data that you request to access.
10.6. We may redact from the data which we will make available to you, any Personal Data related to others.
11.2. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Website.
11.3. When you browse the Website, our cookies collect non-Personal Data as detailed in Section 4.1 above.
11.4. We may use automated devices and applications to evaluate usage of our Service. We use these tools to help us improve our Services, performance and user experience including by tracking page content, and click/touch, movements, scrolls and keystroke activities. We may also engage third parties to track and analyze Service data or provide other services on our behalf. Such third parties may combine the information that we provide about you with other information that they have collected from other sources. This Policy does not cover such third parties’ use of the data and such use is governed by such third parties’ privacy policies.
12. Data Security
12.1. We take the safeguarding of Personal Data and Non Personal Data very seriously, and use a variety of systems, applications and procedures to protect the information from loss, theft, damage or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the information. These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
12.2. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and for further enhancing the security of our Services and protection of our Users’ privacy.
12.3. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. In addition, you should take steps to protect against unauthorized access to Personal Data stored on your premises as well as defining limited access rights to such information on a need to know basis.
12.4. If you receive an e-mail asking you to update your information with respect to the Services, do not reply and please contact us at firstname.lastname@example.org.
13. Data Retention
13.1. We retain different types of information for different periods, depending on the purposes for processing the Personal Data, our legitimate business purposes as well as pursuant to legal requirements under the Applicable Laws. We may retain Personal Data for as long as necessary to support the collection and the use purposes under this Policy and for other legitimate business purposes, for example, for storing data, for documentation, for cyber-security management purposes, legal proceedings and tax issues.
13.2. We may store aggregated Non Personal Data without time limit. In any case, as long as you use the Platform and/or Services and/or browse our Website, we will keep information about you, unless we are legally required to delete it, or if you exercise your rights to delete the information.
14. Our Policy Toward Children
Our Platform, Services and Website are not meant to be used by or for persons under 18, as such, we do not knowingly collect Personal Data from minors younger than 18. If you are under 18, please do not enter, access and/or use the Services on this Website and Platform.
15.2. If we need to adapt the Policy to legal requirements, the amended Policy will become effective immediately or as required.
15.3. Your continued use of the Services following such notice shall constitute your consent to any changes made and a waiver of any claim or demand in relation to such changes. If you do not agree to the new or different terms, you should not use and are free to discontinue using the Services.
16. Applicable Law And Dispute Resolution
17. Contact Us
For further information about this Policy, please contact our customers services department at email@example.com.
We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact us and we will make good-faith efforts to address your concerns. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.
Copyright © 2019, TripJunction Asia Limited. All rights reserved.
Last Update: March 2019