Privacy Policy

This privacy notice for PT. Insight Destination Managemen, doing business as mytripology ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://www.mytripology.com, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

We are committed to protecting your personal information and your right to privacy. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. If you still have any questions or concerns about this privacy policy, or our practices with regards to your personal information, please contact us at [email protected].

1. The Data We Collect About You

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

We may collect, use, store, and transfer different kinds of personal data about you, which consist of:

• Identity Data includes first name and last name.
• Contact Data includes email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes details of previous inquiries, itineraries or bookings made by you, feedback and survey responses.
• Usage Data includes information about how you use our website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special category data:

Health/mobility data: When you make an inquiry for a travel booking with us, we will ask you to disclose whether you have a medical condition or health issue, or have any restrictions on your mobility. This is to enable us (and the operators/suppliers of your holiday) to provide for your health, safety and welfare during your trip which is our legal responsibility.  Any information of this type that you provide to us constitutes special category data under applicable data protection laws and when you provide it to us you are confirming your consent to us using such information for the purpose of making your travel arrangements, including our sharing of your information with the suppliers of your trip for this purpose (see Section 5 Disclosures of your Personal Data).

If you choose not to disclose this information to us or your consent to use it for the outlined purposes, we may not be able to provide the services you have requested due to our legal responsibility to provide you with a safe holiday.

Religious beliefs: We will also ask you to disclose to us any dietary requirements that you have and you may also choose to disclose to us your religious beliefs if this informs your particular travel itinerary choices. Religious beliefs constitute special category data. Accordingly, when you provide this information you confirm your consent to us using such information for the purpose of making your travel arrangements, including our sharing of your information with the suppliers of your trip for this purpose. 

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. In this case, we may have to cancel a service you have booked with us but we will notify you if this is the case at the time.

2. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, and Contact Data by filling in forms or by communicating with us by phone, email, or otherwise. This includes personal data you provide when you:
  • inquire about or book our travel services (either directly or via a travel agent);
  • subscribe to our newsletters or other publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • give us feedback or contact us; and
  • contact us via social media or follow/like our social media pages.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.mytripology.com/cookie-policy for further details. Whilst some of this Technical Data does not allow us to personally identify you, we may link this data with personally identifiable information you have provided to us.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data and Usage Data from the following parties:
  

  (a)  analytics providers such as Google Analytics based inside or outside the EU;

  (b)  advertising networks such as Google Ads based inside or outside the EU; and

  (c)  email marketing service providers such as “Mailchimp” based inside or outside the EU.

3. How We Use Personal Data and Why?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (i.e. in order to service your travel inquiry or your booking). This is so we can:
  • To respond to user inquiries/offer support to users.
  • To send administrative information to 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. This is so we can:
  • To send you marketing and promotional communications.
  • To deliver targeted advertising to you.
  • To identify usage trends.
  • To determine the effectiveness of our marketing and promotional campaigns.
• Where we need to comply with a legal obligation.
  • To process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you if you have not previously enquired or booked a holiday with us and in order to share your personal data with any third party for their marketing communications. We will also obtain your consent to our use of special category data as outlined in the paragraph “Special Category Data” above.

You have the right to withdraw consent to marketing at any time by contacting us or in the case of email marketing including our newsletter, if you unsubscribe.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or subscribed to our newsletter.

THIRD-PARTY MARKETING

We do not intend to share your personal data with any third party for marketing purposes. In any event we would obtain your express opt-in consent before we share your personal data with any third party for marketing purposes (as we are legally required to do).

OPTING OUT

You can ask us to stop sending you marketing communications at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. By continuing to browse the site, you are agreeing to our use of cookies. For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of Your Personal Data

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:

• Travel product and services suppliers
• Ad Networks
• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Retargeting Platforms
• Sales & Marketing Tools
• Website Hosting Service Providers

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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.

7. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Changes to This Policy

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.