Travtus Privacy Policy

Effective as of May 20, 2021

1. APPLICABILITY OF THIS PRIVACY POLICY

Thank you for visiting the privacy page. Travtus Workforce, Inc., including any affiliates and subsidiaries (“Travtus,” “we,” “us,” or “our”) values the trust you place in us when you use our products, services or affiliated websites. This Privacy Policy describes our collection, use, disclosure, and retention of information we collect from or about you through our products, services, and websites directly or from our customers that use our products and services as well as what your rights are. This Privacy Policy applies to our customer contracts and our products, services and websites that post or link to it, regardless of how you access or use them, including through mobile devices.

BY USING OUR PRODUCTS, SERVICES AND WEBSITES, YOU ARE ACCEPTING THE TERMS OF THIS PRIVACY POLICY AND YOU ARE CONSENTING TO OUR COLLECTION, USE, DISCLOSURE, AND RETENTION OF INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, THEIR CHOICE IS NOT TO USE OUR PRODUCTS OR WEBSITES.

Information We Collect on Behalf of Our Customers

In many cases, we provide property management services to our customers, who are third party businesses and other entities. If you have a relationship with one of our customers, it may be that Travtus’ hardware, software or plugins are integrated with that customer’s websites, applications or services. In those instances Travtus’ technology may collect certain personal data about you on behalf of our customers. We use any personal data in accordance with our contractual obligations to customers, which may include (1) providing services to customers; and (2) generating anonymized, de-identified or otherwise aggregated data that does not identify individual users (“Customer-Generated Data”). Where permissible either contractually or under the law, we may also use such Customer-Generated Data in a non-anonymized manner for purposes of conducting research and analytics relating to our business, benchmarking, improving security for our other users and customers, and enhancing the quality of our products, services and websites.  For information about how we use information that we collect from you, please see the “How We Use Information We Collect From Or About You” section below. 

IF YOU HAVE A CONTRACTUAL RELATIONSHIP WITH OUR CUSTOMER AND THAT CUSTOMER COLLECTS YOUR DATA UTILIZING TRAVTUS TECHNOLOGY, THE COLLECTION AND USE OF YOUR DATA MAY BE GOVERNED BY THE AGREEMENTS AND/OR PRIVACY POLICIES THAT YOU ENTER INTO WITH SUCH CUSTOMER AND NOT BY THE TERMS OF THIS PRIVACY POLICY. 

If you use our Websites outside of the United States, you understand and consent to the transfer of information we collect from or about you to, and the collection, processing, and storage of information about you in, the United States and elsewhere. The laws in the U.S. and these countries may be different than the laws of your country.

Under the EU General Data Protection Regulation (“GDPR”) and other similar laws, Travtus may be considered a “controller” of certain personal data it has collected data because Travtus is responsible for determining how that personal data will be handled. This Privacy Policy is applicable to Travtus’ handling of personal data as a “controller.”

Further, this Privacy Policy also applies to personal data that Travtus receives in the context of providing its services to its customers.  For many of the services that it offers, Travtus acts only as a “processor” (not a controller), which just means that Travtus handles the personal data solely pursuant to the relevant customer’s instructions, unless legally required to do otherwise. In instances where we act as a processor, not a controller, you should refer to any agreement or privacy policy you have entered into with the customer for whom we are processing data. 

Your rights: You have the right to know what we know about you. You can make a request via email to: contact@travtus.com. Make sure you include your name, phone number, email address in question and your home address. We will confirm your identity and get back to you.

This Privacy Policy applies to the personal data we collect about you in connection with:

  • Management of our customer relationships and the provision of our services including through any accounts set up with Travtus or the services that we offer.

  • Sales, including our sale of products through partners, and third-party marketplaces.

  • Our marketing and advertising programs.

  • Investor relations.

  • In connection with the use of our website, software and any other related applications by you, or if you are a Travtus customer, by your end users, end customers or tenants.

  • In email, text, and other electronic messages between you and Travtus.

  • When you or your customers provide us information over the phone, including with respect to calls facilitated by Travtus’ proprietary artificial-intelligence-driven communications feature (known as “Adam”) which can communicate with you (or, if you are a Travtus customer, with your authorized users on behalf of you) as well as recommend third party products and services sourced by Travtus customers and/or Travtus to those users.

  • Management of our websites and apps in relation to any of the above.

2. TYPES OF PERSONAL DATA WE COLLECT

We collect several types of information from and about users of our services, including information:

·       By which you may be personally identified, such as your: name, postal address, e-mail address, telephone number, job title, employer name, or any other identifier by which you may be contacted online or offline and which is defined as person or personally-identifiable information under an applicable law. This includes any personally identifiable information you disclose on our social media platforms and sites when you browse or interact with our products and services.

·       About you or your customers’ experiences with Travtus’ products and services, including with our website and mobile services.

·       About your accounts with us including user names, passwords, your feedback and survey responses.

·       If you have a contractual relationship (including, but not limited to, a landlord/tenant relationship) with one of our customers, that customer may provide Travtus with information about you.

·       Concerning the interactions between you and our customers online properties, including any usage and security-related data such as information about authorized or unauthorized log-in attempts

·       Unique identifiers such as the IP address or operating system which are assigned to a device that is being used to access our website or the website of our customer with which you interact.  

·       When you, your customers or visitors to your online properties navigate through and interact with the websites, platforms, mobile apps, plugins, software, hardware and other platforms that comprise our services and products or through which we offer our services and products, we may use automatic data collection technologies such as cookies, web beacons and JavaScript and other computer code to collect certain information about your equipment, browsing actions, and patterns. Please see below for more details on these automated means.

·       From customer networks, websites, customer applications that have integrated Travtus’ hardware, software or plugins and any associated customer logs that are generated in response.

·       From third parties and offline sources, such as our partners, vendors, data brokers, marketing and analytics providers, referral information that may have been provided from our other customers.

·       From publicly available sources.

When necessary to meet our obligations under applicable law, we may also collect personal data and in turn may notify our customers to do the same.

AS PERMITTED BY LAW WE MAY ALSO DE-IDENTIFY, AGGREGATE OR OTHERWISE ANONYMIZE PERSONAL DATA ABOUT YOU IN WHICH CASE THE DATA WILL NO LONGER IDENTIFY YOU OR BE LINKED TO YOU (“ANONYMIZED DATA”). ANONYMIZED DATA NO LONGER CONSTITUTES PERSONAL DATA AND IS NOT SUBJECT TO THIS PRIVACY POLICY.  TRAVTUS MAY USE OR DISCLOSE ANONYMIZED DATA FOR ANY LAWFUL PURPOSE. 

3.   HOW WE USE INFORMATION WE COLLECT FROM OR ABOUT YOU

Travtus may use and share personal data for the following types of purposes:

·       To provide, review and improve Travtus’ products, services and websites and operations, including for the customization of our products and services. 

·       To provide your with information, products, or services that you requests from us, or which might be of interest to you based on specific requests, including third party products and services. By way of example, if you requests plumbing services, Travtus software or services may suggest local plumbers and offer to schedule an appointment on your behalf. In such instance information about the appointment (such as time, location and your name) will be shared with the third party service provider once you have indicated that they wish to make an appointment.

·       To provide users with information, products or services of our customers. By way of example if one of our customers enables our software to receive calls regarding property rentals and a user calls inquiring about renting a particular unit, the software may provide information about that unit or other similar units being listed by our customer.

·       For enhancing our understanding of our current and prospective customers’ needs and interests. 

·       Responding to requests for information.

·       Analyzing and compiling trends and statistics, including performing market research and conducting surveys.

  • For security, IT management, and related research, including for the collective defense of fraud prevention, fraud detection and cybersecurity threats.

·       To facilitate the processing of payments.

  • For internal business purposes and to facilitate our relationships with our customers, partners, and vendors.

  • To market, advertise and promote Travtus’ services and to contact users for research, informational or marketing purposes.

  • To provide business continuity, manage our operations or improve our security.

·       To comply with any law, court order, legal process or legal terms, or based on our good-faith belief that it is necessary to conform or comply with any law,  court order, legal process or legal terms; to cooperate with police and other governmental authorities; or to protect the rights, property or safety of our customers and visitors to our websites, applications and other platforms through which our services and products are offered to the public.

  • To process or engage in a sale of all or part of our business, or if we go through a reorganization, merger or a comparable event.

  • For communicating with you.

  • To prevent activities that may violate our policies or be fraudulent or illegal

·       For any other purpose with your consent or to fulfill any other purpose requested by you.

In using and sharing any personal data, we may use personal data that we have gathered from one type of service or product or one portion of our website and use it in combination with other services and products we offer or on other parts of our website. We may also use or combine the personal data with information that we collect offline or we collect or receive from third-party sources for any number of reasons, including to enhance, expand, and check the accuracy of our records. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.

Data Retention: We may retain information we collect from or about you for as long as reasonably required to satisfy the purposes for which we have collected the information, or as contractually obligated, or as required by law, whichever is longer. This means we will retain information about you both while you are an active user of our products, services, or websites and after you cease to be an active user.

4.   HOW WE SHARE INFORMATION WE COLLECT FROM OR ABOUT YOU

We may share personal data with, for example: 

  • Our affiliates.

  • Our customers with whom you have an existing business or contractual relationship. We may share information that personally identifies you with entities that use our service. By way of example, if you place a call to Adam inquiring about a real estate listing from a Travtus customer and request a viewing, Travtus may disclose your personal information to our customer in order to schedule a viewing.

  • To third party vendors and service providers where a you have specifically requested that we communicate with such vendor or service provider on the your behalf. By way of example, if our services suggests that you may want to retain the services of a third party plumbing service and you indicate you would like to retain those services, Travtus will disclose personal information (such as the your name, address and contact information) in order to facilitate an appointment on the your behalf.

  • Third party service providers, including our subcontractors. We engage third-party service providers to perform functions on our behalf such as hosting, content syndication, content management, technical integration, marketing, analytics, customer service, and payment processing. These third parties may have access to information about you when needed to perform their functions.

  • Contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

  • Joint marketing partners.

  • Governmental entities

·       Law enforcement or other entities involved in legal processes: we may use or disclose information we collect from or about you if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or in connection with our products, services and websites; (b) protect and defend our rights or property, our products, services and websites, or our users; (c) respond to a third party that alleges that you or any of customers have infringed their intellectual property rights; or (d) act to protect the personal safety of us, users of our products, services and websites, or for the welfare of the public.

  • Entities related to sales of our business, assignments or changes of control. We may change our ownership or corporate organization while providing our products, services and websites. We may transfer some or all information about you in connection with any merger, acquisition, sale of assets, or any line of business, change in ownership control, or financing transaction. Under such circumstances, we will request the acquiring party to follow the practices described in this Privacy Policy with respect to previously collected information. Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat information about you in the same way as described in this Privacy Policy.

Our uses and disclosures of your personal data are also subject to our contractual obligations.

For information about how to manage information about you and the choices you have, see the Your Choices section below.

5. OUR LEGAL BASIS FOR THE COLLECTION, USE AND SHARING OF PERSONAL DATA

The laws in many jurisdictions, particularly in the EU, require data controllers, such as Travtus, to inform you about the legal grounds that allow them to use or disclose your personal data. To the extent any such laws apply to Travtus’ handling, use or sharing of personal data, Travtus’ lawful basis of processing is as follows:

  • Legitimate interests: We handle personal data because it furthers the legitimate interests of Travtus, its customers, business partners, and its third party vendors in business activities such as the ones listed below:

    • Fraud prevention and detection

    • By allowing us to enhance our customers’ cybersecurity and the cybersecurity of their online properties and other information technology assets

    • To protect our customers, their business activities and/or their customers

    • Providing customer service

    • To keep our records updated

    • To improve our promotional and marketing initiatives

    • To analyze trends and conduct research about improving Travtus’ services and products

    • Identifying business and legal risks and conducting assessments of the same

    • To contact users and customers about our products, Customer and third party products and services that a user has specifically requested, or responding to users’ general requests

We do not believe that our handling of data unduly impact your interests, rights, and freedoms.

  • Contractual Obligations: In many instances, our handling of personal data is necessary to meet our contractual obligations, or because we are planning to enter into a contract.

  • Consent: When required by law, we will seek and obtain your consent. On other occasions, we may obtain your consent even when not required by law. For example, you may provide us with consent on our website to contact you for the purpose of providing more marketing information about our products and services or for other direct marketing. Sometimes, even if we do not seek your explicit consent, it may be permissible under the law for Travtus to infer your consent from the circumstances. Additionally if you have a contractual or business relationship with one of our customers, our customer may obtain your consent for the processing of personal data described in this Privacy Policy.

  • Legal compliance: Disclosure and use of personal data may be required to ensure our compliance with our legal obligations under applicable laws.

  • Legal claims: Disclosure and use of personal data may be required to investigate claims (including claims of fraud), and/or legal actions, violations of law or agreements, including this Privacy Policy.  

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 a 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.

6.  COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many comparable products, services and websites, we use tracking technologies such as cookies, web beacons, JavaScript and similar technologies to record your preferences, track the use of our products, services and websites, and measure exposure to our online advertisements. We may also use these technologies to monitor traffic, improve or develop our products, services and websites, and make it easier to use and more relevant. Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the applicable product, service or website may not work or may not work as designed.

We use third-party analytics services to support our products and services and on our websites, including Google Analytics. These analytics service providers use cookies or other tracking technologies to help us analyze how users interact with and use our products, services and websites, compile reports about activity concerning our products, services and websites, and provide us other services. The technologies may collect information such as your IP address, time of visit, whether you are a return visitor, any referring website, and other information. We do not use these analytics service providers to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.

We work with third-party companies who also use these technologies to provide advertisements on third-party websites. These third parties may use these technologies to collect information about you when you use our products, services or websites. They may collect information about your online activities over time and across different websites and other online services. They may also use persistent identifiers to track your Internet usage across other websites in their networks beyond our products, services and websites. They may use this information to provide you with interest-based advertising or other targeted content. While we do not knowingly provide these entities with information that personally identifies you, such third parties may, with sufficient data from other sources, be able to personally identify you, unbeknownst to us.

Some content, applications, and advertisements on our websites or displayed during our services may be served by unaffiliated third parties. We do not control these third parties’ tracking technologies or how they may be used. We are not responsible for the content or privacy practices of any product, service or website not owned, licensed, otherwise operated by us to which our product, service, or websites link or that links to our products, services or websites.

Your browser or device may include “Do Not Track” functionality. Our information collection, disclosure practices, and the choices that we provide, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

7. YOUR CHOICES ABOUT HOW INFORMATION ABOUT YOU IS USED AND SHARED

In many instances, you have choices about the information you provide and how we use that information. These choices are described below. In addition, you may have certain choices with those businesses that use our services.

Marketing Emails: By providing us with an e-mail address, you acknowledge that we may use your e-mail address to communicate with you. While you cannot opt-out of receiving notifications and other service-related communications regarding your account or your transactions, you can opt-out of receiving promotional and other marketing emails from us by using the “unsubscribe” feature in our marketing e-mails.

Interest-Based Advertising Choices: You also have choices related to interest-based advertising. Many browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.

Many of the third-party advertisers that place tracking tools on our websites or through a service that we are offering are members of programs that offer you additional choices regarding the use of information about you for advertising. You can learn more about the options available to limit these third parties’ use of your information by visiting the websites for the Network Advertising Initiative and the Digital Advertising Alliance.

Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings, see the support information for Apple, Android or Windows devices.

Please note that opting-out of participating advertising networks services does not mean that you will not receive advertising while using our products, services or websites or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these industry programs.

8. INFORMATION FOR RESIDENTS OF CALIFORNIA

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. If a User is a California resident, that User’s CCPA rights are described below. If Users have any questions about whether any of the following applies to them, they can email us at contact@travtus.com. Because Users have a direct relationship with Customer and Travtus acts as a processor on behalf of Customer, Users who wish to exercise their rights under the CCPA should contact Customer at which point Customer can make the request to Travtus.

Categories of Personal Information Collected and Disclosed

During the 12 months leading up to the effective date of this Privacy Policy, we collected or may have collected the information described below from and about California residents. We may use any and all of the information for any of the purposes described in this policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.  We may disclose this data to third parties as described in this Privacy Policy

Category

Examples

Collected by Travtus

Disclosed by  Travtus for Business Purposes

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name

Yes

Yes

Audio and Video Recordings or Photos with your likeness (e.g. as collected in video interviews or digital diaries)

Yes

Yes

Social Security number, driver's license number, passport number, or other similar identifiers.

Yes

Yes

B. Customer records information (as described in Cal. Civ. Code § 1798.80(e))

A name, signature, address, telephone number, education

Yes

Yes

Social Security number, physical characteristics or description, passport number, driver's license or state identification card number, insurance policy number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Yes

Yes

C. Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

Yes

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

Yes

Information about an individual’s interests and interactions with Travtus, our partners, or our customers, including transaction data

Yes

Yes

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

No

F. Internet or other network or device activity

Browsing history, search history, IP addresses, unique device identifiers and metadata

Yes

Yes

G. Geolocation data

Information about an individual’s location which may include GPS, Wi-Fi and compass data,

No

No

H. Audio, electronic, visual, thermal, olfactory, or similar information

Audio or visual recordings and images

Yes

Yes

I. Professional or Employment-Related Data

Information about an individual’s employment or career history

Yes

Yes

J. Education Information

Non-public information about an individual’s education history or record

No

No

K. Inferences

Inferences about an individual that could be used to create a profile about the individual such as preferences, attitudes, behaviors and characteristics

Yes

Yes

 

Your Rights And Choices under the CCPA

i.           Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collected about you.

  • The categories of sources for the Personal Information we collected about   you.

  • Our business or commercial purpose for collecting or selling that Personal information.

  • The categories of third parties with whom we share that Personal Information.

  • The specific pieces of Personal Information we collected about you (also called a data portability request).

  • The categories of third parties to whom the consumer’s Personal Information has been sold and the specific categories of Personal Information sold to each category of third party.

ii.          Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

iii.         Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Sending an email to contact@travtus.com.

  • Submit a request through your community.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the Personal Information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you are registered customer, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your Personal Information, we will only complete your request where we are satisfied that we have verified your identity to a reasonably degree of certainty.

iv.         Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

v.          Non-Discrimination

We will not discriminate against you for exercising any of your applicable CCPA rights. Unless permitted by the CCPA, we will not:

·       Deny you goods or services.

·       Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

·       Provide you a different level or quality of goods or services.

·       Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

vi.         Opt Out of the ‘Sale’ of Your Personal Information

If we have sold our users’ personal information over the past 12 months, we will identify the categories of personal information purchased by each category of third-party recipient. AT THIS TIME TRAVTUS DOES NOT SELL ANY PERSONAL INFORMATION AND HAS NOT SOLD ANY SUCH INFORMATION IN THE LAST TWELVE (12) MONTHS.

9.     INFORMATION FOR INDIVIDUALS LOCATED IN THE EU AND SWITZERLAND

This section applies to our processing of personal data that we collect through the Website and from our clients when we provide our services to them, as described above. We process personal data on the following legal bases: with your consent, to comply with laws applicable to us, and as necessary for our legitimate interests where those interests do not override your fundamental rights and freedoms related to data privacy. Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates, subcontractors, or clients maintain facilities.

Individuals that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

If you are a resident of the EEA or Switzerland, you are entitled to certain rights. Please note: In order to verify your identity, we may require you to provide us with personal data prior to accessing any records containing information about you. These rights include the ability:

  • to request from us access to personal data held about you;

  • to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;

  • to ask for data to be erased if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing; and

  • to request that we restrict our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

To submit a request to exercise your rights, please contact us at contact@travtus.com. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

10.   OTHER IMPORTANT INFORMATION

Users Under Thirteen (13): Our products, services and websites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on our websites or through our services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through any of Travtus’ products, services or websites, make any purchases, use any of the interactive or public comment features of Travtus’ products, services or websites, or provide any information about yourself to us, including your name, email address, telephone number, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at contact@travtus.com.

Changes to Our Privacy Policy:  It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated the main Travtus website. If we make material changes to how we treat our users’ personal information, we will notify you by email to the extent you have provided us with an email address (such as by submitting an information request). The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Travtus website and this privacy policy to check for any changes.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information Users provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on actions that you take. Where we have given you a password for access to certain parts of our website or services, you is responsible for keeping this password confidential. You should not share passwords with any third parties.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we can neither guarantee the security of your personal information transmitted to the our website or software nor can we guarantee that such information will not become publicly available. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the our website, software or other applications. You can reduce these risks by using common-sense security practices such as choosing a strong password, using different passwords for different services, and using up-to-date antivirus software on your electronic devices.

Users may provide information to be transmitted to other users of Travtus’ software, website or related application, or to other third parties (collectively, “User Contributions”). By way of example, if  a user provides information regarding scheduling an appointment for maintenance services (such as a name, time and location), such User Contributions will be shared the Travtus customer with which that user has a relationship and/or the third party services provider selected to provide such maintenance services.  YOU ACKNOWLEDGE THAT TRAVTUS CANNOT CONTROL THE ACTIONS OF OTHER USERS OF THE TRAVTUS WEBSITE OR SOFTWARE, OR THIRD PARTY SERVICE PROVIDERS WITH WHOM YOU MAY CHOOSE TO SHARE YOUR USER CONTRIBUTIONS. THEREFORE, WE CANNOT AND DO NOT GUARANTEE THAT YOUR USER CONTRIBUTIONS WILL NOT BE VIEWED BY UNAUTHORIZED PERSONS.

 

 For questions about our Privacy Policy, you can contact us at contact@travtus.com or contact us at:

Travtus,

P.O. Box 4668 # 70057

New York, New York 10163-4668