Privacy policy
LAST UPDATED: 4th of June 2024
1. Important information and who we are
Welcome to our Mobile Application Itinfy (hereinafter referred to as “App” or “Application” in this policy).
Itinfy LLC is the controller and is responsible for your personal data (collectively referred to as "Itinfy", "we", "us" or "our" in this policy) and we understand that your information is very important to you and we collect and manage your personal data with the utmost attention and care.
This privacy policy shall be considered the basis upon which Itinfy shall rely in dealing with your data, including personal data/information, which is collected from you or added by you each time you log in or use our App or provide us with such information. By doing the foregoing, you acknowledge and consent to the terms of this policy as set out herein.
Below you shall find the information on the processing by Itinfy of your data relating to the use of Itinfy Application services offered by Itinfy.
You are also requested to read the “Terms & Conditions” of the Itinfy Application, which contains detailed information regarding the terms of our services.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on the 4th of June 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you [by SMS OR by email OR when you next start the App]. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This mobile application may include links to third-party websites/mobile applications, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites/mobile applications and are not responsible for their privacy statements. When you leave our mobile application, we encourage you to read the privacy policy of every website/mobile application you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows [the details of each of the below is defined in the Glossary]:
· Identity Data.
· Contact Data.
· Financial Data.
· Transaction Data.
· Device Data.
· Content Data.
· Profile Data.
· Usage Data.
· Marketing and Communications Data.
· Location Data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We will collect and process the following data about you:
· Information you give us. This is information (including Identity, Contact, Financial, Marketing, and Communications Data) you consent to give us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, search for an App or Service, [make an in-app purchase,] [share data via an App's social media functions,] [enter a competition, promotion or survey,] and when you report a problem with an App, or our Services. If you contact us, we will keep a record of that correspondence.
· Information we collect about you and your device. Each time you visit our App we will automatically collect personal data including Device and Usage Data. We collect this data using cookies and other similar technologies.
· Location Data. We also use [GPS technology] to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
Cookies
We use cookies [and/or other tracking technologies] to distinguish you from other users of our App to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App including our services by accessing our App you agree to our use of cookies Link.
4. How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
· Where you have consented before the processing.
· Where we need to perform a contract we are about to enter or have entered with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
Click here [LINK TO GLOSSARY: LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your personal data
Purpose/activity
Type of data
Lawful basis for processing
To install the App and register as a new App user
Identity
Contact
Financial
Device
Your consent
To process in-app access to booking our Services including (i) managing payments, fees, and charges and (ii) collecting and recovering money owed to us
Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Location
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services
Identity
Contact
Financial
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyze how customers use our Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions and/or privacy policy)
To enable you to participate in a prize draw, or competition or complete a survey
Identity
Contact
Device
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyze how customers use our Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis, and system testing
Identity
Contact
Device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyze the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Consent
Necessary for our legitimate interests (to develop our products/Services and grow our business)
5. Storage and transfer of personal data
You agree that we have the right to transfer the personal data set forth in this policy and to keep it in our possession. In the event that the local laws in your area give your data less protection than a current policy in this regard, we will take the necessary measures to protect your personal data in accordance with this policy, by submitting your personal data, you consent to such transfer, storage or processing. We will take all necessary and reasonable steps to ensure that your data is processed in a secure manner and in accordance with this policy.
With respect to processed and saved personal data, you agree that Itinfy shall be in control of such data.
If required by virtue of a law or in the case you personally requested from us, we could clear your personal information.
To maintain the safety of our databases and to perform the services on a continuous basis on your behalf, for research and analysis purposes, and for statistical purposes and to ensure compliance with applicable laws and regulations, we retain personal information and demographic information provided by users for a long period of time. You will not be responsible for the accuracy of the information you provide and will modify and update your personal information in our databases at your request.
6. Sharing and disclosure of your personal data
We may share the personal data you provide as described in this policy or as described at the time of collecting or sharing the information, including the following:
With other users
· We may share information such as your first name and your locations in question.
· Third parties: To provide a service you have ordered through a partnership or promotion offered by a third party.
· Other third parties: for example, other applications or websites that integrate with (API) or our services, or parties with APIs or services you would like to integrate with.
· The employer in which you work.
At your request
This may include sharing your information with other people at your request. For example, we may share your ETA and location with a friend at your request, or your booking information when you make a booking using our App.
With your consent
Itinfy may share your information other than as described in this policy if we notify you and you consent to the sharing.
With the general public when you submit content to a public forum
We love hearing from our users -- including through public forums such as Itinfy blogs, social media, and certain features on our network. When you communicate with us through those channels, your communications may be viewable by the public.
Social sharing characteristics
Services may be integrated with social sharing features and other related tools that allow you to share the actions you take on our services with other applications, sites or social media, and vice versa. We can use these features to share information with your friends or audience, depending on the settings you have selected with the social sharing service. Please refer to the privacy policies of these social sharing services for additional information on how they process and share your data.
Other important events for sharing your information
We may share your information:
· With entities related to Itinfy.
· With our agents, consultants, marketing partners, and other service providers on our App who will require such information to carry out any act on our behalf or to perform any obligation required by us by virtue of a contract.
· In response to any request for information by any competent authority or by virtue of any applicable law or regulation or applicable legal action.
· With law enforcement authorities, governmental authorities, or other third parties to implement or apply our terms and conditions and to investigate potential violations or if we believe that your actions were contrary to our terms and conditions of service or to protect rights, property, security of Itinfy or any other application.
· With other companies or third parties in connection with or during the negotiations on any merger or sale of the Company's assets, consolidation, restructuring, financing, or purchase of a share or the whole of our company by any other company or purchaser of any other company.
7. Your options
Marketing Opt-Out:
Itinfy gives users the opportunity to opt out of rejecting contacts from us or from our partners on the part where we request information about the visitor. You have the option to ask us not to use your personal data for marketing purposes and to delete them from the information access base.
8. Analysis and advertising services provided by others
We may allow others to provide evaluation and analysis services to the public on our behalf, to perform advertising works online on our behalf, and to track and report on the performance of such advertisements. These entities may use cookies, web beacons, software development packages, and other technologies to identify your device when you visit our App and use our Services. Also, when you visit other websites and services for further information on these technologies and service providers, please refer to the statement of our cookies.
9. Account information
You can correct/change your account information at any time by signing into your online account or application account. If you would like to cancel your account, please e-mail us at [INSERT E-MAIL].
Please note that in some cases we may retain specific information about you as required by law, or for legitimate commercial purposes to the extent permitted by law, for example, if you have a credit on your account or if you believe you have committed an act of fraud or violate our terms, we may ask you to resolve the issue before deleting your information.
10. Access rights
We will comply with individual requests regarding access, correction, and/or deletion of personal data that we store in accordance with applicable law.
11. Safety precautions
Your Itinfy profile is password-protected so that you and Itinfy’s employees who are authorised have the right to access your account information. An employee of Itinfy will not proactively contact you and request personal account information including your password.
We exert every effort to ensure the security and protection of your personal data within our system. Therefore, there are employees who are currently committed to maintaining the privacy policy set forth herein and any other privacy initiatives, periodic review of web security, and ensuring that every employee is immediately aware of and understands security practices. We cannot guarantee the protection of any data transmitted over the Internet by 100% as a result we cannot guarantee the security of any personal data transmitted or sent through the Internet, and you do so on your own personal responsibility. To the extent allowed by the applicable law, Itinfy disclaims its liability against any claim or liability that may arise in the event that any party has the personal data that was sent to us by you.
12. Data security
All information you provide to us is stored on our secure servers. Any payment transaction will be encrypted using Secured Sockets Layer technology OR [ALTERNATIVE ENCRYPTION TECHNOLOGY]. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
13. Data retention and deletion
By law we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 7 years after they cease being customers for tax, legal, and/or any other reporting requirement purposes.
In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.
In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You may request the deletion of your account at any time via the Itinfy Application.
Following such a request, Itinfy deletes the information that it is not required to retain. In certain circumstances, Itinfy may be unable to delete your account; such as if, there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete your account as described above.
Itinfy may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, if Itinfy shuts down a user's account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new or another Itinfy account in the future.
In the event that you do not use the App for a period of six months then we will treat the account as expired and your personal data may be deleted.
14. Contact us
If you have any questions, comments, or requests related to this Privacy Policy or if you have any complaints or objections regarding the way Itinfy processes your personal information. Please contact us by e-mail at [INSERT E-MAIL]
Glossary
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Description of categories of personal data
· Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
· Contact Data: billing address, email address, and telephone numbers.
· Financial Data: bank account and payment card details.
· Transaction Data: includes details about payments to and from you and details needed to access the of our Services through Itinfy App.
· Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), your mobile operating system, the type of mobile browser you use, time zone setting.
· Content Data: includes information stored on your Device, including login information, photos, videos or other digital content, check-ins, and other information.
· Profile Data: includes your username and password, bookings or orders history made by you, your interests, preferences, feedback, and survey responses.
· Usage Data: includes details of your use of any of our Apps or your visits to our App including, but not limited to, traffic data and other communication data, whether this is required for our billing purposes or otherwise.
· Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
· Location Data: We also use [GPS technology] to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.