Effective September 26, 2018
This Policy explains how we may Process your information. This Policy may be amended or updated from time to time, so please check it regularly for updates.
We may Process your personal details (e.g., your name), demographic data (e.g., your age), your contact details (e.g., your address), records of your consents, information about your interactions with our content or potential advertising, and any views or opinions you provide to us.
We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content on the Services.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.
“Process“, “Processing” or “Processed” means anything that is done with any 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.
We may Process the following categories of Personal Information about you:
We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information“.
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information“) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:
Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.
The purposes for which we may Process User Information, subject to applicable law, include:
We may Process your User Information by placing or reading Cookies and similar technologies on the Services and Channels. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to Other Information about you, including your User Information for the purposes of learning more about you so we can provide you with relevant content. We and our partners also use these technologies to analyze trends, administer the Services, collect and store information such as user settings, anonymous browser identifiers and video viewing history, supplement to our server logs and other methods of traffic and response measurement, track users’ location and movements around the Services, gather demographic information about our user base, and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns.
Tracking technologies on the Services may be deployed by Cyclades Guide and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content.
We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends, administer the Services, collect and store information such as user settings, anonymous browser identifiers and video viewing history, supplement our server logs and other methods of traffic and response measurement, track users’ location and movements around the Services, gather demographic information about our user base, and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third party companies on an individual and aggregated basis. For example, we may connect information about your IP address to known corporate or User Information and use the associated information related to aggregate content preferences to assist in our efforts to provide services to you.
We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.
We may Process your User Information where: you have given your consent, the Processing is necessary for a contract between you and us, the Processing is required by applicable law, the Processing is necessary to protect the vital interests of any individual, or where we have a valid legitimate interest in the Processing.
In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
We may disclose your User Information to: legal and regulatory authorities, our external advisors, parties who Process User Information on our behalf (“Processors“), any party as necessary in connection with legal proceedings, any party as necessary for investigating, detecting or preventing criminal offences, and any third party providers of advertising, plugins or content used on the Services.
We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Cyclades Guide advises users of the possibility of such disclosure at the time they take the survey, Cyclades Guide reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.
Cyclades Guide may use third party service companies to perform related services when you interact with the Services. Often, these third party companies employ cookies and other technologies to measure the effectiveness of website, app and email and to create a record of interaction with our content that they use in conjunction with other sites or applications, or for reporting website traffic, app use, statistics and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.
We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.
We may also engage third parties for the purpose of recognizing our users and delivering interest-based content to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, and information about your browser or operating system, (ii) combine User Information about you received from Cyclades Guide with information about you from other sites or services, and (iii) place or recognize a unique cookie on your browser.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions, and (ii) use measures to protect the confidentiality and security of the User Information, together with any additional requirements under applicable law.
Because of the international nature of our business, we may need to transfer your User Information within the Cyclades Guide, and to third parties as noted in Section 7 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet (e.g when you are connected to free or home or guest WiFi). Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.
We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.
We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.
You have certain rights including: the right not to provide your Personal Information to us, the right of access to your Personal Information, the right to request rectification of inaccuracies, the right to request the erasure, or restriction of Processing, of your Personal Information, the right to object to the Processing of your Personal Information, the right to have your Personal Information transferred to another controller, the right to withdraw consent, and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
You may directly take steps to change your preferences as follows:
Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. On some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.
Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.
Location Based Services. You may opt-out of having your Precise Location Data collected by Cyclades Guide. at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).
EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us (using the contact instructions in Section 15 below). If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact:
Our Data Protection Officer may be contacted at firstname.lastname@example.org
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