TruTravels Privacy Policy

Effective: October 1, 2019

TruTravels is committed to protecting your personal information. We want you to understand our Privacy Policy and what it means to you. If you have any questions about our Privacy Policy, you can contact our Privacy Officer at privacyofficer@gadventures.com or through the contact information posted below.

The Privacy Policy describes the privacy practices of TruTravels Limited (“TruTravels”).

 

What is personal information and how do we use or disclose it?

Personal information is information about an identifiable individual and includes your name, contact information, travel itinerary and other information described below.

 

Booking Travel

TruTravels may collect, use or disclose your personal information, either directly or through our agency and booking partners, for the purposes of offering or booking travel services on your behalf, such as your name, age, gender, address, phone number, e-mail address, emergency contact information, passport information, travel medical information (where required), insurance details, ISIC information (where applicable), nationality, residency, nutrition preferences, trip evaluations, travel and accommodation preferences, comments you provide us, trip destination information, and payment-related information. This personal information enables us to provide you with trip information, book accommodations, process payments, and provide similar travel services.

If you book a TruTravels trip, TruTravels may rely on local service providers. Please be aware that TruTravels may be required to provide certain personal information to our service providers for the purposes of delivering your experience. When you book travel services with us, you consent to the collection, use and disclosure of your personal information by TruTravels—and the corresponding collection and use by the relevant travel partners or suppliers—for the purposes of administering and delivering the travel services you requested.

 

Your personal information may also be used for the purposes of:

• Enabling us to better understand your needs as a customer and determine eligibility for our products and services;
• Informing you about our products and services, or those of our partners that we believe may be of interest to you (provided that we have received valid consent from you if such consent is required);
• Providing ongoing service and support, including resolution of any issues with the services or products you request from TruTravels;
• Ensuring the safety and security of our passengers and products;
• Carrying out internal accounting and administration of our business;
• Complying with laws, regulations, and immigration requirements.

 

Travel Agents and Agencies

TruTravels collects personal information (as described above) from agents and agencies as required to book TruTravels’ trips and be properly credited for such booking. If you are an agent travelling with TruTravels, TruTravels may also collect employment-related information to confirm your eligibility for travel-industry promotions.

 

Contests and Newsletters

We may also collect personal information, including contact information such as name, address, phone number or email address if you elect to enter a contest or sweepstakes with us, subscribe to our newsletter, or request a brochure. We use this personal information for the purposes of administering the contests/sweepstakes or delivering the information you request.

 

Facebook

You can opt to subscribe to our mailing list through our 'sign up' tab on Facebook. This collects personal information such as name, address, phone number or email address. You will be added to our mailing list but can opt-out at any time. We use this personal information for marketing purposes.

 You can also create an account through our log in area using your Facebook credentials.

If you would like to request the deletion of your personal data, you have the right to do so at any time. To make a request, please follow these steps:
Contact Us: Send an email to privacyofficer@gadventures.com  with the subject line “Data Deletion Request.” Include your full name, email address, and any relevant information that will help us locate your data.
Verification Process: Once we receive your request, we will verify your identity to ensure that we are deleting data for the correct individual.
Processing Your Request: After verification, we will process your request and delete your personal data from our systems, unless we are required to retain it by law or for legitimate business purposes (such as completing a transaction or complying with legal obligations)

 

Employment

TruTravels collects personal information from those individuals applying for employment or similar positions at TruTravels to the extent necessary to (i) identify the individual and (ii) evaluate their suitability for the applied-for position. This information may include name, contact information, educational and employment background, criminal record verification, residency and/or citizenship information, and other information necessary for us to screen potential employees and staff.

 

Service Provider Arrangements

In addition to the third party travel suppliers outlined above, TruTravels may transfer your personal information to third parties who provide services on our behalf. For example, we may use service providers to authorize and process payments, host our customer service operations, serve advertisements on our website, send emails or other communications, or run our contests and promotions. Your personal information may be maintained and processed by our service providers in the US or other jurisdictions. For information about the policies or practices of our service providers, please contact us at the email address above. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose your personal information for their own purposes.

 

European Residents: Transfers of Data Outside Europe

Please note that if you are resident in the UK, European Union or European Economic Area (“EEA”) we may hold your personal information outside of the EEA. For instance, your personal information may be held by us in Canada (which has been recognized by the European Commission as having an adequate level of privacy protection).

We may also need to transfer your personal information to travel suppliers and other third parties outside of the EEA, for instance where a supplier is based outside of the EEA. Countries outside of the EEA may not have the same level of privacy laws as exist in the UK, Canada and the EEA. We will take reasonable steps to ensure that your privacy rights are protected.

 

Sale of Business

We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of TruTravels or as part of a corporate reorganization or other change in corporate control.

 

Legal and Compliance

TruTravels and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

 

Essential Services

TruTravels uses essential services including Live Chat, Response IQ and TradeDoubler to collect information including but not limited to, full name, email address, phone number, IP address, and location. These services are essential to TruTravels and are used regardless of whether users accept cookies.

Response IQ

Response IQ is a data controller for the purposes of the General Data Protection Regulation EU 2016/679. This service is essential to TruTravels as it enables us to gather essential information in order to contact you. To use this service, you input your phone number and request a call back - at this point, you have given your permission to be contacted.

Pure Chat/Live Chat

LiveChat, Inc. participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Pure Chat, Inc. a Delaware corporation and includes live chat, visitor tracking and any other additional services. These services are essential to TruTravels as it allows us to chat with users with their permission.

Facebook and Google Account

Heads up! We use your email and public profile information from your Facebook or Google account to provide login functionality to our website so you can see your future trips and bucket list destinations specific to you. Please note We use this data to create an account under your email address, with your first and last name prefilled automatically from this data.

Any security vulnerabilities found on www.trutravels.com should be disclosed to privacyofficer@gadventures.com via email as soon as they are found.

How is your personal information protected?

We have implemented measures designed to help protect personal information in our custody and control. We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. Unfortunately, no collection or transmission of information over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure, and therefore, we cannot ensure or warrant the security of any such information. We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

 

Can I access my information and whom do I contact for more information?

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may access, update, and/or correct much of your personal information through your account on the TruTravels website, or you may request access, updates and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Attn: Privacy Officer

TruTravels Limited, c/o G Adventures

19 Charlotte Street

Toronto, Ontario M5V 2H5

Tel: (416) 260 0999

E-Mail: privacyofficer@gadventures.com

As well as a right to access, update and correct information we hold about you, if you are resident in the UK, European Union or European Economic Area then you have the following additional rights:

• To be told how long your personal information will be retained by us or the basis on which we make decisions about how long we retain your personal information;
• To require that your personal information is deleted by us, subject to any necessary legal requirements we may have to retain the information;
• To object to our processing of your personal information or to restrict processing of your personal information (but we may be unable to provide certain services to you without processing this information);
• To receive a copy of any personal information we hold about you in a portable format;
• To lodge a complaint with relevant supervising authority (for example the Information Commissioner’s Office in the UK).

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