Privacy Policy

Find Your Perfect Tour

Privacy Policy

This privacy policy will explain how Our Company (smarTours, LLC) uses the personal data we collect from you when you use our website.


Topics


What data do we collect?

Our Company collects various categories of personal data on natural persons who use our website or contact us via other means.  For a full description of categories of data we collect, how it is used, and how it is retained , please consult our data collection catalog below.

We do not knowingly collect or disclose personal information from children under the age of 16 without parental or guardian consent. If a child under the age of 16 has provided us with personally identifiable information, we ask that a parent or guardian contact us so that the information can be removed.

How do we collect your data?

You directly provide Our Company with most of the data we collect. We collect data and process data when you:

  • Register for an online account or place an order for any of our products or services.
  • Provide additional information as requested in order for us to execute on your tour.
  • Voluntarily complete a customer survey, tour review, or provide feedback on any message board, email, or phone call.
  • Use, view, and interact with our website via a web browser, providing interaction data and information via your browser’s cookies.
  • Contact us via web form, email, social media, or phone.
  • Fill out a job application for an open position with Our Company.

Our Company may also receive your data indirectly from the following sources:

  • Via our purchase of marketing lists and information overlays, such as national change of address information.
  • By finding public posts of information regarding Our Company on the internet.

How will we use your data?

Our Company collects your data so that we can:

  • Process your order and manage your account.
  • Customize your experience on our website.
  • Provide a quicker experience for future bookings.
  • Email you with special offers on other products and services we think you might like.
  • Send you direct mailings of our catalog or special offers.
  • Conduct market and statistical analysis.
  • Increase customer satisfaction.
  • Respond to public feedback and communicate with customers.
  • Comply with regulatory requirements.
  • Respond in cases of emergencies on tours.
  • Evaluate job candidates.
  • Provide training to our staff.
  • Evaluate quality assurance.
  • Increase website and application experience, stability, and performance.
  • Detect, prevent, and respond to spam, fraud, slander, libel, or other forms of abuse.
  • Keep personal information up to date and accurate.

Will you sell my data?

We do not sell any data to third party companies, nor provide it to partner companies so that they might market products and services directly to you. We do however provide data to partner companies for purposes of expediting the tour and services we provide as described below.

How do you share my data?

We typically disclose the following categories of personal data as defined in our data catalog to the following categories of entities for business purposes:

Category of EntityCategories of Personal Data
Booking Engine ProvidersTraveler Information, Passport Information, Travel Restriction Qualifications, Purchase Details, Insurance Selections, Personal Tour Data, Payment Data, Payment History, Emergency Contact Information, Customer Customization Data, Marketing Opt-In Data, Marketing Opt-Out Data, Online Analytics, Email Analytics
Airlines, Hotels, Tour Operators, and Destination Management CompaniesTraveler Information, Passport Information, Travel Restriction Qualifications, Purchase Details, Personal Tour Data, Emergency Contact Information
Hosting ProvidersTraveler Information, Passport Information, Travel Restriction Qualifications, Purchase Details, Insurance Selections, Personal Tour Data, Payment History, Emergency Contact Information, Customer Customization Data, Marketing Opt-In Data, Marketing Opt-Out Data, Online Analytics, IP Address
Marketing FirmsMarketing Opt-In Data, Marketing Opt-Out Data, Email Analytics, Online Analytics, Purchase Details
Call Center ProvidersTraveler Information, Passport Information, Travel Restriction Qualifications, Purchase Details, Insurance Selections, Personal Tour Data, Payment Data, Payment History, Emergency Contact Information, Customer Customization Data, Marketing Opt-In Data, Marketing Opt-Out Data, Online Analytics, Email Analytics, Text Communications, Phone Call Recordings
HR ProviderJob Applications, Employment Data
Survey and Review Service ProvidersPublicly Available, Text Communications
Data Warehousing Providers(Any possible data as needed)

When Our Company processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

How do we store your data?

Our Company securely stores your data encrypted at rest and during transit.  We do not host our own servers and therefore this data is stored in online servers where it is generated, this includes but is not limited to:  Google Drive, Microsoft Dynamics 365 hosted by Peak15, Constant Contact, and WPengine hosting servers.

Our Company will only keep your data for as long as it is necessary based upon the category of data.  Once this time period has expired, or a request to forget has been issued, we will delete or anonymize the information to ensure that it is no longer trackable as personal data.

Marketing

Our Company would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop Our Company from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, you can unsubscribe from email marketing by editing your user profile, or following directions at the bottom of any marketing email you receive from us. If you wish to opt out of any other forms of marketing, please submit a request to dataprotectionrequest@smartours.com and we will respond promptly.

What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request Our Company for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that Our Company correct any information you believe is inaccurate. You also have the right to request Our Company to complete the information you believe is incomplete.

The right to erasure – You have the right to request that Our Company erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that Our Company restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to Our Company’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that Our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

The right to non-discrimination for exercising privacy rights – If you choose to exercise any of the privacy rights conferred above, you also have the right to not receive any discriminatory treatment by us in the future.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at with the specific details of your request.  We will then take steps to validate your identity using no less than four unique identifiers, reserving the right to require more in exceptional circumstances, to ensure that we are only processing valid requests made by the data subject of their legal representative’s. 

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in
  • Understanding how you use our website
  • Customizing your experience
  • Providing and monitoring advertising and promotional efforts

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

  • Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. Only first-party cookies are used for this purpose
  • Third Party Advertising and Analytics – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser.  You may also reset your choice to accept third-party advertising cookies by clicking here.  However, in a few cases, a few of our website features may not function as a result.

Do not track signals

We do not process or respond to “Do Not Track” signals from your browser or other mechanisms that enable consumer choice regarding the collection of personal information about one’s online activities over time and across third-party websites or online services.

Privacy policies of other websites

The Our Company website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. Our Company is not responsbile in any way for the Privacy Policy of other websites or for the failure of other companies’ failure to have an adequate privacy policy.

Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page.  This may happen without prior notice to you to reflect changes in our information practices or relevant laws.  We will post a notice on the website to notify you of any substantive changes to the way to collect and use information. This privacy policy was last updated on Sep 29, 2021.

How to contact us

If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us by emailing us at dataprotectionrequest@smartours.com.

Data collection catalog

The chart below provides more detailed information for each category of information we collect. In all cases, the retention policy should be considered to include the phrase “or until the data subject requests removal of this data”, unless we are otherwise barred from doing so for legal reasons.

data categoryTraveler Information
descriptionAll information needed in order to execute a tour that a data subject has purchased, has been purchased for them, or in preparation for a future purchase.
usesTo process current and future bookings.  To comply with regulatory requirements.  To customize a user’s website profile.  For direct marketing.  For market analysis.  For statistical analysis.
specific dataname, mailing addresses, email addresses, phone numbers, title, gender, birthday, dietary restrictions, medications, allergies, disabilities, passport information, unique alphanumeric guest identifiers, travel restriction qualifications
retentionWe must keep this information on file from the time we receive it until at least 30 days after the tour has returned.  After that we keep the information on file indefinitely to offer the guest quicker future bookings and historical tour information on our website.
data categoryPassport Information
descriptionInformation from customer’s passport. Will be used to provide to authorities and third parties, where needed, to enable international travel.
usesTo process current and future bookings.  To comply with regulatory requirements.
specific dataname, nationality, number, place of birth, place of issue, date issued, expiration date
retentionWe must keep this information on file from the time we receive it until at least 30 days after the tour has returned.  After that we keep the information on file indefinitely to offer the guest quicker future bookings.
data categoryTravel Restriction Qualifications
descriptionAny additional information needed from a natural subject for us to confirm, allow, or assist that traveler with passing any travel restrictions, entry or return requirements for various countries or political boundaries.
usesTo process current bookings.  To comply with regulatory requirements.
specific datavaccine status, medical test results, travel visas
retentionWe must keep this information on file from the time we receive it until at least 30 days after the tour has returned.  After that we keep the information for historical reference.
data categoryPurchase Details
descriptionDetails relating to a customer’s purchase of a tour and related products.
usesTo process current bookings.  To show historical information on a customer’s website profile.  For market analysis.  For statistical analysis.
specific datadate purchased, tour selection, dates of tour, tour options selected, insurance selections, payment history
retentionWe must keep this information on file until at least 30 days after the tour has returned.  After that we keep the information on file indefinitely to offer the guest historical tour information on our website.
data categoryInsurance Selections
descriptionDetails involving any purchase of insurance by a traveler for one of our trips.
usesTo process current bookings.  To show historical information on a customer’s website profile.  For market analysis.  For statistical analysis.
specific dataname, insurance plan choice, cost, state, country, age, date choice made, date of payment
retentionWe must keep this information on file until at least 30 days after the tour has returned.  After that we keep the information on file indefinitely to offer the guest historical tour information on our website.
data categoryPersonal Tour Data
descriptionPrimarily internal information generated for the execution of each guest’s tour for activities/events throughout it.
usesTo process current bookings.
specific dataairline tickets, hotel reservation data, additional activity reservation data
retentionWe must keep this information on file from the time we receive it until at least 30 days after the tour has returned. After that we keep this information for historical purposes indefinitely.
data categoryPayment Data
descriptionIn the process of making a purchase a customer may need to provide payment information to complete the transaction.  This can take the form of either credit card data, or bank account transfer.
usesIn the process of accepting payments for bookings.
specific datacredit card data     (name on card, credit card number, expiry date, CCV, billing address)
bank account transfer details      (type of account, routing number, account number, name on account)
retentionThis data is never retained, passed through, or processed by smarTours servers.  It is always directly input into a PCI compliant 3rd party payment processor by either the client directly or a call center agent.
data categoryPayment History
descriptionDetails about historical payments made towards a booking by customer.
usesTo process bookings.  To show historical information on a customer’s website profile.  For statistical analysis.
specific datatransaction IDs, name on account, authorization results, status, payment date, payment amount, currency, exchange rate, account expiration, billing address, payment account type, last four digits of account numbers
retentionThis data is stored indefinitely for historical tracking purposes against past bookings.
data categoryPartner Employee Information
descriptionAny personal data relating to employees from any company that we partner with, such as destination management companies (DMC’s), airlines, hotels, and software service providers.
usesTo communicate and collaborate on projects.
specific dataname, email, phone number, all communications
retentionThis information must be kept during the active performance of any partnership, and will be kept purely for historical basis after the close of any partnership, in the form of past emails and phone logs.
data categoryEmergency Contact Information
descriptionFor travelers on our tours we collect emergency contact information.  This information refers to another natural person who we may contact solely for the purpose of emergency situations on behalf of our customer.
usesTo reach out in cases of emergencies.  To provide to authorities if needed.
specific datacontact name, relationship to the customer, phone numbers, email addresses
retentionThis information must be kept until the customer returns from the tour.  We continue to maintain this information for the convenience of the user for future bookings until removal is requested.
data categoryJob Applications
descriptionAll information related to job applications are kept on file to meet federal and state laws, as well as to be used in the hiring process.
usesTo evaluate a candidate for an open job position at smarTours.
specific dataname, resume, email, phone, address, work history, education history, salary requirements, salary history, answers to any qualification questions, all communications
retentionThis data will be kept for 1 year after submission to meet legal requirements then will be deleted.
data categoryEmployment Data
descriptionAll information relating to personnel, employment, or contractor records. 
usesTo process paychecks.  To enable all employment and HR processes.
specific dataname, email, phone, home address, salary, all communications, payroll records, job evaluations, benefit plans, vaccine status
retentionThis data will be kept for 1 year following termination of an employee, 2 years for job evaluations, and 3 years for payroll records, to meet legal requirements, then will be removed.
data categoryText Communications
descriptionThe content of any communications sent to us from customers (past, prospective, or current), or any other natural person who reaches out through any of our contact methods.
usesTo respond to inquiries and feedback.  To learn how we can improve our services.  To provide training to our staff.
specific dataonline chat transcripts, email contents, physical mail, SMS messages, fax contents, data submitted via online forms, online surveys, reviews
retentionThis information is kept for historical reference indefinitely.
data categoryPhone Call Recordings
descriptionRecorded contents of phone calls to our call center by customers (past, prospective or current), 
usesTo review for quality assurance.  To increase customer satisfaction.  For training purposes.
specific dataaudio recording of phone calls
retentionRecordings are kept to review for three months and then deleted.
data categoryCustomer Customization Data
descriptionAny information not specifically about the customer themselves, but that is related to direct use of the website and their interactions with it.
usesTo customize the website experience.  To facilitate future bookings.  For direct marketing.  For market analysis.
specific datafavorited tours, saved tour customizations
retentionThis information is kept as long as the customer has a website account with smarTours.
data categoryMarketing Opt-In Data
descriptionAny information related to explicitly choosing to opt in to our various marketing options that we might choose to provide.
usesFor direct marketing.  For market analysis.
specific dataname, email addresses, email marketing opt-in, phone numbers, SMS opt-in
retentionThe information is kept as long as the subject wishes to remain on our marketing lists.  It will be removed, in piece, as when requested by the subject via automated and manual means.
data categoryMarketing Opt-Out Data
descriptionInformation used for direct marketing in the form of physical mailed elements, or for outbound phone call sales.
usesFor direct marketing.  For market analysis.
specific dataname, mailing addresses, physical mailing opt-out, phone numbers, phone call opt-out
retentionThe information is kept as long as the subject wishes to remain on our marketing lists.  It will be removed, in piece, as when requested by the subject via automated and manual means.
data categoryOnline Analytics
descriptionInformation that is automatically gathered in relation to a subject’s interaction with our online (web or app) properties
usesFor direct marketing.  For market analysis.  For statistical analysis.  To improve web/app experience and performance.  To customize the subject’s experience.
specific datapages visited, links clicked, pointer tracking, scrollbar tracking, time spent on page, pages visited before accessing our website, search terms entered on our website, search terms entered to find our website, browser type, operating system, geolocation data, analytics tracking IDs, advertising click IDs, advertising campaign tracking details
retentionThis information is kept for historical use indefinitely.
data categoryEmail Analytics
descriptionInformation that is automatically gathered when subject receives, opens, and clicks on email marketing messages sent to them.
usesFor direct marketing.  For market analysis.  For statistical analysis.  For deliverability analysis.  For spam/fraud detection.
specific datamarketing emails sent, marketing emails opened, dates opened, marketing email links clicked, dates clicked
retentionThis information is kept for historical use indefinitely.
data categoryIP Address
descriptionIn the course of running web-based services for our customers we must log IP Addresses of people who access the website.
usesTo provide a stable platform.  To prevent fraud.  To prevent abuse.  To customize the subject’s experience.
specific dataIP address, approximate geolocation
retentionThis information is kept secure and stored for less than 24 hours before automatic removal.
data categoryMarketing Overlay
descriptionThis category of data includes any information that we might acquire from third party sources that we would apply to existing records in our marketing database.
usesTo keep information up to date.  For direct marketing.  For market analysis.
specific datageolocation, updated address, affinity categories, approximate income, age, death records
retentionInformation is kept on file for as long as a subject is in our marketing or customer databases.
data categoryPublicly Available
descriptionAny information that a subject, otherwise in our records, might post publicly.
usesTo increase customer satisfaction.  To respond to public complaints.  To protect against slander and libel.  For market analysis.  For promotional purposes.
specific datareviews on third-party sites, social media posts, blog posts, comments on websites or forums
retentionInformation, if kept locally, is kept indefinitely.