SmartNomad™ Privacy Policy
Effective
date: March 14, 2020
SmartNomad Inc.
("us", "we", or "our") operates the
https://www.smartnomad.com website and the SmartNomad
mobile application (hereinafter referred to as the "Service").
This
page informs you of our policies regarding the collection, use and disclosure
of personal data when you use our Service and the choices you have associated
with that data.
We
use your data to provide and improve the Service. By creating an account to use
the Service, you agree to the collection and use of information in accordance
with this policy. Unless otherwise defined in this Privacy Policy, the terms
used in this Privacy Policy have the same meanings as in our Terms and
Conditions.
Definitions
Service
Service
means the https://www.smartnomad.com website and the SmartNomad
mobile application operated by SmartNomad Inc.
Personal
Data
Personal
Data means data about a living individual who can be identified from those data
(or from those and other information either in our possession or likely to come
into our possession).
Usage
Data
Usage
Data is data collected automatically either generated by the use of the Service
or from the Service infrastructure itself (for example, the duration of a page
visit).
Cookies
Cookies
are small files stored on your device (computer or mobile device).
Data
Controller
Data
Controller means the natural or legal 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, processed.
For
the purpose of this Privacy Policy, we are a Data Controller of your Personal
Data.
Data
Processors (or Service Providers)
Data
Processor (or Service Provider) means any natural or legal person who processes
the data on behalf of the Data Controller.
We
may use the services of various Service Providers in order to process your data
more effectively.
Data
Subject (or User)
Data
Subject is any living individual who is using our Service and is the subject of
Personal Data.
Information
Collection and Use
We
collect several different types of information for various purposes to provide
and improve our Service to you.
Types of Data Collected
Personal
Data
While
using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you
("Personal Data"). Personally identifiable information may include,
but is not limited to:
We
collect data to create and maintain your account. In addition, we collect
and use information necessary to provide services. Such information can
include preferences for various travel categories (e.g., Nature, Adventure,
Shopping), preferred flight and hotel brands, loyalty account numbers, cuisine
preferences, and other information necessary to provide you with the requested
services. We may use your Personal Data to contact you with newsletters,
marketing or promotional materials and other information that may be of
interest to you. You may opt out of receiving any, or all, of these
communications from us by following the unsubscribe link or the instructions
provided in any email we send.
To
provide you with the full range of the Services, you should expect us to
collect and use any of the following data:
Usage
Data
We
may also collect information that your browser sends whenever you visit our
Service or when you access the Service by or through a mobile device
("Usage Data").
This
Usage Data may include information such as your computer's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that you visit, the time and date of your visit, the time spent on
those pages, unique device identifiers and other diagnostic data, and other
browsing-related data.
When
you access the Service with a mobile device, this Usage Data may include
information such as the type of mobile device you use, your mobile device
unique ID, the IP address of your mobile device, your mobile operating system,
the type of mobile Internet browser you use, unique device identifiers, your
mobile carrier, and other diagnostic data.
Location
Data
We
may use and store information about your location if you give us permission to
do so ("Location Data"). We use this data to provide features of our
Service, to improve and customize our Service.
You
can enable or disable location services when you use our Service at any time by
way of your device settings.
Tracking
& Cookies Data
We
use cookies and similar tracking technologies to track the activity on our
Service and we hold certain information.
Cookies
are files with a small amount of data which may include an anonymous unique
identifier. Cookies are sent to your browser from a website and stored on your
device. Other tracking technologies are also used such as beacons, tags and
scripts to collect and track information and to improve and analyze
our Service.
You
can instruct your browser to refuse all cookies or to indicate when a cookie is
being sent. However, if you do not accept cookies, you may not be able to use
some portions of our Service.
Examples
of Cookies we use:
We
may use other or similar technologies to collect data. For example, we
may use the following technologies:
Use
of Data
SmartNomad Inc. uses the
collected data for various purposes:
Because
we provide a travel-related services, we may share personal data you provide to
us with third parties necessary to provide you with the services. Your personal
information may be shared to help you book your travel and/or vacation, assist
with your travel and/or vacation stay, communicate with you (including when we
send information on products and services or enable you to communicate with
travel providers and/or property owners), and comply with the law.
We
may use your personal information for various purposes described below:
Communications
and Marketing:
Other
Business Purposes and Compliance
Sharing
of Data
We
may share your personal information as described below, and as permitted by
applicable law.
Legal
Basis for Processing Personal Data under the General Data Protection Regulation
(GDPR)
If
you are from the European Economic Area (EEA) or are otherwise subject to the
GDPR, SmartNomad Inc. legal basis for collecting and
using the personal information described in this Privacy Policy depends on the
Personal Data we collect and the specific context in which we collect it.
SmartNomad Inc. may process
your Personal Data because:
Retention
of Data
SmartNomad Inc. will retain
your Personal Data only for as long as is necessary for the purposes set out in
this Privacy Policy. We will retain and use your Personal Data to the extent
necessary to comply with our legal obligations (for example, if we are required
to retain your data to comply with applicable laws), resolve disputes and
enforce our legal agreements and policies.
SmartNomad Inc. will also
retain Usage Data for internal analysis purposes. Usage Data is generally
retained for a shorter period of time, except when this data is used to
strengthen the security or to improve the functionality of our Service, or we
are legally obligated to retain this data for longer periods.
Transfer
of Data
We
store all personal information on protected and encrypted servers in the United
States. Thus, your information, including Personal Data, may be
transferred to - and maintained on - computers located outside of your state,
province, country or other governmental jurisdiction where the data protection
laws may differ from those of your jurisdiction.
If
you are located outside United States and choose to provide information to us,
please note that we transfer the data, including Personal Data, to United
States and process it there.
Your
consent to this Privacy Policy followed by your submission of such information
represents your agreement to that transfer.
SmartNomad Inc. will take all
the steps reasonably necessary to ensure that your data is treated securely and
in accordance with this Privacy Policy and no transfer of your Personal Data
will take place to an organisation or a country unless there are adequate
controls in place including the security of your data and other personal
information.
Disclosure
of Data
Business
Transaction
If
SmartNomad Inc. is involved in a merger, acquisition
or asset sale, your Personal Data may be transferred to an acquiring company.
We will provide notice before your Personal Data is transferred and becomes
subject to a different Privacy Policy.
Disclosure
for Law Enforcement
Under
certain circumstances, SmartNomad Inc. may be
required to disclose your Personal Data if required to do so by law or in
response to valid requests by public authorities (e.g. a court or a government
agency).
Legal
Requirements
SmartNomad Inc. may disclose
your Personal Data in the good faith belief that such action is necessary to:
Security
of Data
The
security of your data is important to us but remember that no method of
transmission over the Internet or method of electronic storage is 100% secure.
While we strive to use commercially acceptable means to protect your Personal
Data, we cannot guarantee its absolute security.
If
you have created a SmartNomad account, access to this
account is only possible after entering your personal password. You agree
to keep your access information confidential.
Our
Policy on "Do Not Track" Signals under the California Online
Protection Act (CalOPPA)
We
do not support Do Not Track ("DNT"). Do Not Track is a preference you
can set in your web browser to inform websites that you do not want to be
tracked.
You
can enable or disable Do Not Track by visiting the Preferences or Settings page
of your web browser.
Your
Data Protection Rights under the General Data Protection Regulation (GDPR)
If
you are a resident of the European Economic Area (EEA), you have certain data
protection rights. SmartNomad Inc. aims to take
reasonable steps to allow you to correct, amend, delete or limit the use of
your Personal Data.
If
you wish to be informed about what Personal Data we hold about you and if you
want it to be removed from our systems, please contact us.
In
certain circumstances, you have the following data protection rights:
Please
note that we may ask you to verify your identity before responding to such
requests.
You
have the right to complain to a Data Protection Authority about our collection
and use of your Personal Data. For more information, please contact your local
data protection authority in the European Economic Area (EEA).
Service
Providers
We
may employ third party companies and individuals to facilitate our Service
(“"Service Providers”"), provide the Service on our behalf, perform
Service-related services or assist us in analyszing
how our Service is used.
These
third parties have access to your Personal Data only to perform these tasks on
our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
Web
analytics and the other named services in this section are used for the
continuous optimization of our website. The tracking provides a record of
the use of our website and to evaluate it for the purpose of optimizing the
Services. From time to time, we employ a variety of data processing
and collection services and tools to help us provide you with the best services
available. Examples of at least some of the data collection and/or processing
services we may use are found in the corresponding list below. Note that
the list may change from time to time and is provided solely as examples of how
we collect data. The legal basis for the data processing described in the
following section is our authorized interest in the needs-based
design and continuous optimization of our website.
Google Analytics
Google
Analytics is a web analytics service offered by Google that tracks and reports
website traffic. Google uses the data collected to track and monitor the use of
our Service. This data is shared with other Google services. Google may use the
collected data to contextualise and personalise the ads of its own advertising
network.
For
more information on the privacy practices of Google, please visit the Google
Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Firebase
Firebase
is an analytics service provided by Google Inc.
You
may opt-out of certain Firebase features through your mobile device settings,
such as your device advertising settings or by following the instructions
provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
We
also encourage you to review the Google's policy for safeguarding your
data: https://support.google.com/analytics/answer/6004245 .
For
more information on what type of information Firebase collects, please visit
the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Piwik
/ Matomo
Piwik or Matomo
is a web analytics service. You can visit their Privacy Policy page here: https://matomo.org/privacy-policy
Clicky
Clicky is a web analytics service. Read the
Privacy Policy for Clicky here: https://clicky.com/terms
Statcounter
Statcounter is a web traffic
analysis tool. You can read the Privacy Policy for Statcounter
here: https://statcounter.com/about/legal/
Flurry Analytics
Flurry
Analytics service is provided by Yahoo! Inc.
You
can opt-out from Flurry Analytics service to prevent Flurry Analytics from
using and sharing your information by visiting the Flurry's Opt-out page: https://developer.yahoo.com/flurry/end-user-opt-out/
For
more information on the privacy practices and policies of Yahoo!, please visit
their Privacy Policy page: https://policies.yahoo.com/xa/en/yahoo/privacy/index.htm
Mixpanel
Mixpanel is provided by Mixpanel Inc.
You
can prevent Mixpanel from using your information for
analytics purposes by opting-out. To opt-out of Mixpanel
service, please visit this page: https://mixpanel.com/optout/
For
more information on what type of information Mixpanel
collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/
Unity Analytics
Unity
Analytics is provided by Unity Technologies.
For
more information on what type of information Unity Analytics collects, please
visit their Privacy Policy page: hhttps://unity3d.com/legal/privacy-policy
Behavioral
Remarketing
SmartNomad Inc. uses
remarketing services to advertise on third party websites to you after you
visited our Service. We and our third-party vendors use cookies to inform, optimizse and serve ads based on your past visits to our
Service.
Google Ads (AdWords)
Google
Ads (AdWords) remarketing service is provided by Google Inc.
You
can opt-out of Google Analytics for Display Advertising and customise the Google
Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google
also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout -
for your web browser. Google Analytics Opt-out Browser Add-on provides visitors
with the ability to prevent their data from being collected and used by Google
Analytics.
For
more information on the privacy practices of Google, please visit the Google
Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Twitter
Twitter
remarketing service is provided by Twitter Inc.
You
can opt-out from Twitter's interest-based ads by following their
instructions: https://support.twitter.com/articles/20170405
You
can learn more about the privacy practices and policies of Twitter by visiting
their Privacy Policy page: https://twitter.com/privacy
Facebook
Facebook
remarketing service is provided by Facebook Inc.
You
can learn more about interest-based advertising from Facebook by visiting this
page: https://www.facebook.com/help/164968693837950
To
opt-out from Facebook's interest-based ads, follow these instructions from
Facebook: https://www.facebook.com/help/568137493302217
Facebook
adheres to the Self-Regulatory Principles for Online Behavioural Advertising
established by the Digital Advertising Alliance. You can also opt-out from
Facebook and other participating companies through the Digital Advertising
Alliance in the USA http://www.aboutads.info/choices/,
the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or
the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your
mobile device settings.
For
more information on the privacy practices of Facebook, please visit Facebook's
Data Policy: https://www.facebook.com/privacy/explanation
Pinterest
Pinterest
remarketing service is provided by Pinterest Inc.
You
can opt-out from Pinterest's interest-based ads by enabling the "Do Not
Track" functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
You
can learn more about the privacy practices and policies of Pinterest by
visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy
AdRoll
AdRoll
remarketing service is provided by Semantic Sugar, Inc.
You
can opt-out of AdRoll remarketing by visiting this AdRoll Advertising
Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false
For
more information on the privacy practices of AdRoll, please visit the AdRoll
Privacy Policy web page: http://www.adroll.com/about/privacy
Payments
We
may provide paid products and/or services within the Service. In that case, we
use third-party services for payment processing (e.g. payment processors).
We
will not store or collect your payment card details. That information is
provided directly to our third-party payment processors whose use of your
personal information is governed by their Privacy Policy. These payment
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
MasterCard, American Express and Discover. PCI-DSS requirements help ensure the
secure handling of payment information.
The
payment processors we work with are:
Stripe
Their
Privacy Policy can be viewed at https://stripe.com/us/privacy
PayPal / Braintree
Their
Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Links
to Other Sites
Our
Service may contain links to other sites that are not operated by us. If you
click a third party link, you will be directed to that third party's site. We
strongly advise you to review the Privacy Policy of every site you visit.
We
have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
Children's
Privacy
Our
Service does not address anyone under the age of 18 ("Children").
We
do not knowingly collect personally identifiable information from anyone under
the age of 18. If you are a parent or guardian and you are aware that your Child
has provided us with Personal Data, please contact us. If we become aware that
we have collected Personal Data from children without verification of parental
consent, we take steps to remove that information from our servers.
CCPA
The
California Consumer Privacy Act (CCPA) places new obligations on organizations
that collect personal information of California consumers. As a result, we’re
updating our Privacy Policy to include a description of additional rights
granted by CCPA and provide California consumers with required disclosures
about the collection of personal information.
Your
California Privacy Rights
This
section provides additional details about the personal information we collect
about California consumers and the rights afforded to them under the California
Consumer Privacy Act or “CCPA.”
For
more details about the personal information we have collected over the last 12
months, including the categories of sources, please see the relevant section
above, along with relevant other sections. We collect this information for the
business and commercial purposes described above. We share this information
with the categories of third parties described above (as such term is defined
in the CCPA) the personal information we collect. We
do not sell your personal information; and will not sell your personal
information without providing you the ability to opt out.
Please note that we do use third-party cookies for our advertising purposes as
further described above.
Subject
to certain limitations, the CCPA provides California consumers the right to
request to know more details about the categories or specific pieces of
personal information we collect (including how we use and disclose this
information), to delete their personal information, to opt out of any “sales”
of their personal information that may be occurring, and to not be
discriminated against for exercising these rights.
California
consumers may make a request pursuant to their rights under the CCPA by
contacting us at
SmartNomad, Inc.
3155_Frontera
Way
Burlingame,
CA
United
States
Email: hello@smartnomad.com
We
will verify your request using the information associated with your account,
including email address. Government identification may be required. Consumers
can also designate an authorized agent to exercise these rights on their
behalf.
Changes
to This Privacy Policy
We
may update our Privacy Policy from time to time. We will notify you of any
changes by posting the new Privacy Policy on this page.
We
will let you know via email and/or a prominent notice on our Service, prior to
the change becoming effective and update the "effective date" at the
top of this Privacy Policy.
You
are advised to review this Privacy Policy periodically for any changes. Changes
to this Privacy Policy are effective when they are posted on this page.
Contact
Us
If
you have any questions about this Privacy Policy, please contact us: