MT Sobek Privacy Statement
Effective Date: May 25, 2018
Introduction. This Privacy Statement (“Privacy Statement”) is designed to provide information about MT Sobek’s (“Mountain Travel”, “we”, “our” or “us”) privacy and data collection practices for the Mountain Travel website (the “Service”) or any online location that posts a link to this Privacy Statement. This Privacy Statement does not cover any information collected at any other websites, mobile applications, or services (unless specifically stated on the website, mobile application, or service). Please review this Privacy Statement carefully.
Key Points to Know
We fully describe our privacy practices below in this Privacy Statement. This summary highlights some important information regarding our use and sharing of your information.
- We may use the information we collect to provide you with customized trips. We may also use your information internally for product development, customer service, and research purposes.
- We do not sell or share any of your personal information outside our company without your permission unless required by law or in the other limited circumstances spelled out in this Statement.
Active Collection of Personal Information. In order that you may access the Service, we may ask you to provide personal information when you access, communicate with or otherwise interact with the Service. “Personal Information” is information that can be used, whether alone or in combination, to identify a specific individual. Examples of Personal Information we may collect through the Service include, without limitation: first and last name, phone number, email address, home address, billing address, and credit card number.
Passive Collection of Information. In addition to the Personal Information that you actively provide to us, we and our third party service providers may use a variety of technologies to automatically collect certain information about your use of the Service (“Usage Information”). This information may include demographic information, IP address, browser type and operating system characteristics. The methods that we may use to automatically collect such information may include the following:
- Cookies: Cookies are data files that are placed on a computer when it is used to visit a website. These cookies may be used for session management, among other things. You may disable cookies using your browser’s preferences. However, some features of the Service may not function properly or may operate slowly if you disable the cookies.
- Web Beacons: We may include small graphic images called web beacons, also known as “Internet tags” or “clear gifs,” in our web pages. We may use web beacons or similar technologies for a number of purposes, including, without limitation, to count the number of visitors to the Service.
- Data Analytics
Our website uses third-party web analytics services, such as Adobe Analytics and Google Analytics, to help us analyze how visitors use the Service. For further information about Adobe Analytics and how they use analytics data, click here. To go directly to an opt-out tool for Adobe Analytics, click here. To learn more about opting out of data collection through Google Analytics, click here.
Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, click here.
Certain third parties may collect Personal Information about your online activities over time and across different websites when you use the Service. To the extent that we combine Usage Information and Personal Information, we will treat the combined information as Personal Information.
Information We Receive From Third Parties. We may, from time to time, obtain supplemental information about you from third party sources. When we associate information that we obtain from third parties with Personal Information that we have collected under this policy, we will treat the acquired information like the Personal Information that we collected ourselves. We will not share information we obtain from third parties in personally identifiable form. However, we may share aggregated, de-identified, non-Personal Information as described in this policy, including information we obtained from third parties.
Use of Personal Information. We may use the information we obtain about you to better understand user behavior; to determine what the most popular trips are; to optimize searches; facilitate your ability to log in to the Service, and manage your use of the Service; provide products or services to you; send you product or service information; perform administrative functions and complete business processes (including customer support); notify you as may be necessary; operate, evaluate and improve our business and the products and services we offer; protect against and prevent fraud, claims and other liabilities, and manage risk exposure; comply with applicable legal requirements and industry standards and our policies; perform research, surveys, and product analysis and development; tailor the Service and communications to deliver a better or new experience to you; and other purposes described elsewhere in this Privacy Statement or for which we have obtained your consent.
Information Sharing. We do not share or sell your Personal Information with third parties for their own marketing purposes without your consent. We may share non-Personal Information, such as aggregate user statistics, demographic information and Usage Information with third parties. We may also share your Personal Information, Usage Information, or other information with third parties with your consent, as disclosed at the time you provide us with information, or as described below or elsewhere in this Privacy Statement:
- Service Providers. We may share Personal Information with third parties who have been retained to carry out or provide support to our business operations. These service providers are prohibited from using your Personal Information for any purpose other than to provide this assistance and are required to protect Personal Information collected by them on behalf of Mountain Travel or disclosed to them by Mountain Travel and to comply with the general privacy principles described in this Privacy Statement.
- Third Party Data Suppliers. We may share your name and Personal Information with third party data suppliers in order to obtain supplemental information about you for our internal research and product development purposes. We will not use information collected from you directly or received from third party data suppliers for marketing purposes. We also prohibit third party data suppliers from using your Personal Information for their own marketing purposes.
- Administrative and Legal Reasons. We may also disclose your information in response to a subpoena, warrant, or when we believe in good faith that disclosure is required by law; to defend our rights; in response to a request from law enforcement regarding an investigation into criminal activity that may have occurred through or in any way using the Service; to provide information to a claimed owner of intellectual property, and/or to protect the personal safety, rights, property or security of any organization or individual. These disclosures may be carried out without notice to you.
- Business Transitions. We may share information we have collected with any parent company, subsidiaries and affiliates, primarily for business and operational purposes. Mountain Travel reserves the right to disclose and transfer all information related to the Service, including Personal Information, if it goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, or other corporate change, including, without limitation, during the course of any due diligence process or bankruptcy.
Social Features. When you use the Service, certain elements of your Personal Information and certain information about your use of the Service may be accessible to other users of the Service and to the public. Certain functionality on the Service may also permit interactions that you initiate between the Service and a third party website or service (“Social Features”). Examples of Social Features include enabling you to “like” or “share” Service content to other websites or services; and to otherwise connect Service websites to a third party website or service. If you choose to use Social Features, information you post or provide access to may be publicly displayed on the Service or by the provider of the Social Feature that you use. Similarly, if you post information on a third party platform that references the Service, your post may be published on the Service in accordance with the terms of the third party website or service. Also, both Mountain Travel and the third party may have access to certain information about you and your use of the Service and the third party site or service. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your “connections’” web pages, profile pages, or similar pages on a social networking or other third party website or interactive service. The information we collect in connection with Social Features is subject to this Privacy Statement. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website or service.
Children’s Privacy. The Service is not directed at children younger than the age of 13. If we learn that a user is younger than 13 years of age, we will promptly delete any Personal Information that the individual has provided to us.
Security. We take commercially reasonable security measures to help protect your information, both during transmission and once we receive it. However, no method of electronic transmission or method of electronic storage is 100% secure. Therefore, we cannot guarantee the security of any information you submit and you do so at your own initiative and risk.
Consent to Transfer Information. The Service is operated in the United States. By using the Service or providing us with any information through the Service, you consent to this transfer, processing and storage of your information in United States.
Third Party Links. The Service may contain links to websites, features and functionality controlled by third parties,. Those websites and services may automatically collect information about your visit to their sites and may use their own tracking technologies, including cookies. Those websites and services are subject to the privacy policies of the third parties that control those websites, and not this Privacy Statement. We encourage you to check the privacy policies of such third party websites and services before using them or disclosing any Personal Information to them.
Changes to this Statement. Mountain Travel may from time to time and without prior notice revise this Privacy Statement. Any changes will be effective immediately when the revised statement is posted on the Service, unless stated otherwise. If changes are made, we may provide you additional notice, including to your email address.
Notice to EU Data Subjects.
Sensitive Data. Some of the information you provide us may constitute sensitive data as defined in the GDPR, including identification of your race or ethnicity on government-issued identification documents.
Legal Bases for Processing. Mountain Travel is required to collect certain information from its users, including some information that may be considered sensitive data, to comply with its obligations under applicable laws. We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at firstname.lastname@example.org.
|Processing Purpose||Legal Basis|
|To provide our service||Our processing of your personal information is necessary to perform the contract governing our provision of the Mountain Travel service or to take steps that you request prior to signing up for the Service.|
|To communicate with you
To optimize our platform
For compliance, fraud prevention, and safety
|These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||We use your personal information to comply with applicable laws, including requirements for government-issued identification for purposes of international travel.|
|With your consent||Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at email@example.com.|
Retention. We will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information you have provided, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal information (so that it can be no longer associated with you), in which case we may use this information indefinitely without further notice to you.
Your Rights. Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to firstname.lastname@example.org. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at email@example.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Contacting Us. If you have questions, suggestions, or complaints about this Privacy Statement or Mountain Travel’s privacy practices, send an email to firstname.lastname@example.org, or write to:
Mountain Travel Sobek
1266 66th Street, Suite #4
Emeryville, CA 94608