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?
- How do we collect your data?
- How will we use your data?
- Will you sell my data?
- How do you share my data?
- How do we store your data?
- How do you use my data for marketing?
- What are your data protection rights?
- What are cookies?
- How do we use cookies?
- What can set cookies on my device (Cookie provenance)?
- What types of cookies do we use?
- How can I manage cookies?
- Do you honor Do Not Track signals?
- Privacy policies of other websites
- Changes to our privacy policy
- How to contact us
- Data collection catalog
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 Entity | Categories of Personal Data |
|---|---|
| Booking Engine Providers | Traveler 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 Companies | Traveler Information, Passport Information, Travel Restriction Qualifications, Purchase Details, Personal Tour Data, Emergency Contact Information |
| Hosting Providers | Traveler 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 Firms | Marketing Opt-In Data, Marketing Opt-Out Data, Email Analytics, Online Analytics, Purchase Details |
| Call Center Providers | Traveler 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 Provider | Job Applications, Employment Data |
| Survey and Review Service Providers | Publicly 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 own physical servers and therefore this data is stored on servers provided by (but not limited to): Google Drive, Microsoft Dynamics 365 hosted by Peak15, Active Campaign, Google Cloud, Amazon Web Services, and WPengine.
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.
How do you use my data for marketing?
Our Company would like to send you information about our products and services that we think you might like. If you have agreed to receive marketing communications, you may always opt out at a later date.
You have the right to stop Our Company from contacting you for marketing purposes at any time.
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 wants to ensure 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 copies of your personal data from Our Company. 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 or their legal representatives.
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 can set cookies on my device (Cookie provenance)?
There are two possible sources for cookies when you visit our website:
- First Party – These cookies are set by our smartours.com servers and are only communicated directly between your browser and our server.
- Third Party – These are created by another company whose library we may be using for analytics or advertising purposes. They are sent between your browser and the third party servers directly.
What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
- Functionality Cookies – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. For example these are used to keep you logged into our website. Only first party cookies are used for this purpose and the information is never shared.
- Analytics Cookies – 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. We use first party cookies for our internal analytics, and may occasionally share some limited aspects of this data with third parties. With some partnerships, we need to use third party cookies directly, though we will continue to work to reduce this need where possible.
- Advertising Cookies – We may share online data collected through cookies with our advertising partners. Both first party and third party cookies might be used for this purpose. 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 this 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 some of our website features may not function as a result.
Do you honor 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
Our Company website contains links to other websites. Our privacy policy applies only to our website. If you click on a link to another website, you must refer to the privacy policy on that website. Our Company is not responsible in any way for the Privacy Policy of other websites or for the failure of other companies 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 Oct 19, 2022.
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 category | Traveler Information |
|---|---|
| description | All information needed in order to execute a tour that a data subject has purchased, was purchased for them, or in preparation for a future purchase. |
| uses | To 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 data | name, mailing addresses, email addresses, phone numbers, title, gender, birthday, weight, dietary restrictions, medications, allergies, disabilities, passport information, unique alphanumeric guest identifiers, travel restriction qualifications |
| retention | We 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 streamline bookings and display historical tour information on our website. |
| data category | Passport Information |
|---|---|
| description | Information from customer’s passport. Provided to authorities and third parties, where needed, to enable international travel. |
| uses | To process current and future bookings. To comply with regulatory requirements. |
| specific data | name, nationality, number, place of birth, place of issue, date issued, expiration date |
| retention | We 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 category | Travel Restriction Qualifications |
|---|---|
| description | Any 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. |
| uses | To process current bookings. To comply with regulatory requirements. |
| specific data | vaccine status, medical test results, travel visas |
| retention | We 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 category | Purchase Details |
|---|---|
| description | Details relating to a customer’s purchase of a tour and related products. |
| uses | To process current bookings. To show historical information on a customer’s website profile. For market analysis. For statistical analysis. |
| specific data | date purchased, tour selection, dates of tour, tour options selected, insurance selections, payment history |
| retention | We 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 category | Insurance Selections |
|---|---|
| description | Details involving any purchase of insurance by a traveler for one of our trips. |
| uses | To process current bookings. To show historical information on a customer’s website profile. For market analysis. For statistical analysis. |
| specific data | name, insurance plan choice, cost, state, country, age, date choice made, date of payment |
| retention | We 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 category | Personal Tour Data |
|---|---|
| description | Primarily internal information generated for the execution of each guest’s tour for activities/events throughout it. |
| uses | To process current bookings. |
| specific data | airline tickets, hotel reservation data, additional activity reservation data |
| retention | We 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 category | Payment Data |
|---|---|
| description | In 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. |
| uses | In the process of accepting payments for bookings. |
| specific data | credit 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) |
| retention | Credit Card 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 category | Payment History |
|---|---|
| description | Details about historical payments made towards a booking by customer. |
| uses | To process bookings. To show historical information on a customer’s website profile. For statistical analysis. |
| specific data | transaction 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 |
| retention | This data is stored indefinitely for historical tracking purposes against past bookings. |
| data category | Partner Employee Information |
|---|---|
| description | Any 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. |
| uses | To communicate and collaborate on projects. |
| specific data | name, email, phone number, all communications |
| retention | This 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 category | Emergency Contact Information |
|---|---|
| description | For 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. |
| uses | To reach out in cases of emergencies. To provide to authorities if needed. |
| specific data | contact name, relationship to the customer, phone numbers, email addresses |
| retention | This 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 category | Job Applications |
|---|---|
| description | All 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. |
| uses | To evaluate a candidate for an open job position at smarTours. |
| specific data | name, resume, email, phone, address, work history, education history, salary requirements, salary history, answers to any qualification questions, all communications |
| retention | This data will be kept for 1 year after submission to meet legal requirements then will be deleted. |
| data category | Employment Data |
|---|---|
| description | All information relating to personnel, employment, or contractor records. |
| uses | To process paychecks. To enable all employment and HR processes. |
| specific data | name, email, phone, home address, salary, all communications, payroll records, job evaluations, benefit plans, vaccine status |
| retention | This 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 category | Text Communications |
|---|---|
| description | The 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. |
| uses | To respond to inquiries and feedback. To learn how we can improve our services. To provide training to our staff. |
| specific data | online chat transcripts, email contents, physical mail, SMS messages, fax contents, data submitted via online forms, online surveys, reviews |
| retention | This information is kept for historical reference indefinitely. |
| data category | Phone Call Recordings |
|---|---|
| description | Recorded contents of phone calls to our call center by customers (past, prospective or current), |
| uses | To review for quality assurance. To increase customer satisfaction. For training purposes. |
| specific data | audio recording of phone calls |
| retention | Recordings are kept to review for three months and then deleted. |
| data category | Customer Customization Data |
|---|---|
| description | Any information not specifically about the customer themselves, but that is related to direct use of the website and their interactions with it. |
| uses | To customize the website experience. To facilitate future bookings. For direct marketing. For market analysis. |
| specific data | favorited tours, saved tour customizations |
| retention | This information is kept as long as the customer has a website account with smarTours. |
| data category | Marketing Opt-In Data |
|---|---|
| description | Any information related to explicitly choosing to opt in to our various marketing options that we might choose to provide. |
| uses | For direct marketing. For market analysis. |
| specific data | name, email addresses, email marketing opt-in, phone numbers, SMS opt-in |
| retention | The information is kept as long as the subject wishes to remain on our marketing lists. It will be removed, in piece, as requested by the subject via automated and manual means. |
| data category | Marketing Opt-Out Data |
|---|---|
| description | Information used for direct marketing in the form of physical mailed elements, or for outbound phone call sales. |
| uses | For direct marketing. For market analysis. |
| specific data | name, mailing addresses, physical mailing opt-out, phone numbers, phone call opt-out |
| retention | The information is kept as long as the subject wishes to remain on our marketing lists. It will be removed, in piece, when requested by the subject via automated and manual means. |
| data category | Online Analytics |
|---|---|
| description | Information that is automatically gathered in relation to a subject’s interaction with our online (web or app) properties |
| uses | For direct marketing. For market analysis. For statistical analysis. To improve web/app experience and performance. To customize the subject’s experience. |
| specific data | pages 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 |
| retention | This information is kept for historical use indefinitely. |
| data category | Email Analytics |
|---|---|
| description | Information that is automatically gathered when the subject receives, opens, and clicks on email marketing messages sent to them. |
| uses | For direct marketing. For market analysis. For statistical analysis. For deliverability analysis. For spam/fraud detection. |
| specific data | marketing emails sent, marketing emails opened, dates opened, marketing email links clicked, dates clicked |
| retention | This information is kept for historical use indefinitely. |
| data category | IP Address |
|---|---|
| description | In the course of running web-based services for our customers we must log IP Addresses of people who access the website. |
| uses | To provide a stable platform. To prevent fraud. To prevent abuse. To customize the subject’s experience. |
| specific data | IP address, approximate geolocation |
| retention | This information is kept secure and stored for less than 24 hours before automatic removal. |
| data category | Marketing Overlay |
|---|---|
| description | This 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. |
| uses | To keep information up to date. For direct marketing. For market analysis. |
| specific data | geolocation, updated address, affinity categories, approximate income, age, death records |
| retention | Information is kept on file for as long as a subject is in our marketing or customer databases. |
| data category | Publicly Available |
|---|---|
| description | Any information that a subject, otherwise in our records, might post publicly. |
| uses | To increase customer satisfaction. To respond to public complaints. To protect against slander and libel. For market analysis. For promotional purposes. |
| specific data | reviews on third-party sites, social media posts, blog posts, comments on websites or forums |
| retention | Information, if kept locally, is kept indefinitely. |
