Updated May 13, 2020
WHAT PERSONAL INFORMATION DOES SMARTOURS COLLECT?
We collect different types of information about you depending on your contact point with us and how you interact with us and our website. Some information you may provide directly. Other information may be collected automatically. For example, when you make a booking with us, you provide us with information such as your name, address, telephone number, payment information, and passport information. We may also collect personal information you post on any of our social media pages (Facebook, YouTube, Instagram, Yelp, etc.), as well as information about our services that you choose to post online in publicly accessible forums (i.e., reviews). A chart showing the categories of personal information we collect and how we use each category of information is found here.
WHAT TECHNOLOGIES DOES SMARTOURS USE TO COLLECT INFORMATION ABOUT ME?
A cookie is a small amount of data, which often includes a unique identifier that is sent to your browser from a website and stored on your computer’s hard drive. Each website can send its own cookies to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.
In addition to cookies, we and our service providers may collect information about you automatically through the use of tracking pixels, and other similar technological tools.
Tracking Pixels (a/k/a “web beacons”). We and our service providers may use technologies called tracking pixels that communicate information from your Internet browser to a web server. Tracking pixels are small, often-transparent graphic images that can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the tracking pixel, the IP address of your computer, and the URL of the web page from which the tracking pixel was viewed. We use tracking pixels for a variety of purposes, including analyzing the traffic patterns on our website and in conjunction with cookies to provide content and ads that are more relevant to you. Through our service providers, we also use tracking pixels to identify visitors to our website to whom we or our service providers may then send marketing communications related to smarTours.
Removing existing cookies from your browser and turning off the browser’s acceptance of cookies will generally prevent tracking pixels from tracking your activity.
HOW DOES SMARTOURS RESPOND TO “DO NOT TRACK” SIGNALS?
Your browser and other technology may have a “do-not-track” setting that sends signals to websites with the technology to receive them in order to express your preferences regarding online tracking. We do not currently have the technology to respond to such signals. If you are a California resident who wishes to opt out of sharing personal information with us, please see the instructions for submitting such requests, below.
Third-parties, such as our analytics providers, may collect data that relates to you on our website, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
HOW DOES SMARTOURS USE THE PERSONAL INFORMATION IT COLLECTS?
We use the personal information we collect about you primarily to: provide services to you, communicate with you regarding our services, process bookings and payments, and manage and improve our services for you, as permitted by applicable laws. The chart below provides more detailed information for each category of information we collect:
|Category for Personal Information Collected||Purpose(s) for Which We Use This Information|
(Email Address, First/Last Name, Postal Address, Phone Number)
|To contact you about trips you book with us or answer|
questions you may have for us;
To fulfill brochure requests and respond to your requests for information about our tours;
To fulfill future date requests;
To process bookings;
To sign you up for our email list at your request.
|Communications You Send Us By Online Chat, Email, Mail, Phone, Text, or Fax||To assist with bookings;|
To answer questions you may have for us;
To learn how we can improve our services;
To provide customer service and support;
To provide training to our staff.
|Credit Card, Debit Card, and Bank Information|
(e.g., card numbers, expiration
dates, billing addresses, etc.)
|To process bookings.|
(e.g., Birthdate, Birthplace, Nationality, Passport Number, Dates of Issuance and Expiration)
|To process bookings;|
To comply with regulatory requirements;
To contact you in case of an emergency.
|Emergency Contact Information|
(Name, Relationship, Phone Number, Email)
|To contact the person(s) designated by you in case of an emergency.|
|Responses to Surveys, Contests, and Promotions|
(varies depending on the survey or promotion, but may include, for example, name, postal address, phone number, email address, age or date of birth, and nationality, as well as written or multiple-choice responses to survey questions)
|To learn how we can improve our products and services;|
To provide customer service and support;
To provide training to our staff;
To enter you to win prizes.
|Geolocation Data||To show you content relevant to your trip while you are using our app|
To assist you with directions to lodging, restaurants, and points of interest during trips you book with us
|Email Engagement Information|
(e.g., opens and clicks)
|To market our products and services to you;|
To understand how we can better market our services.
|Website Analytics Information Visit|
(IP address, location (country and city), age, gender, pages viewed on our website, search terms leading to our site, duration of visit to our website, pages viewed before and after accessing our website, search terms entered on our website, browser type, and operating system)
|To provide you with appropriate product and service recommendations;|
To help you find relevant products and services more quickly;
To assist us with marketing our products to you by showing you relevant ads when you browse the web, or linking up with email or postal address information to market our products to you;
To improve our search engine optimization;
To improve our website, set default options, and provide you with a better experience on our website;
To protect the security of our website;
To detect and prevent fraud against you and/or us.
|Publicly Available Information|
(e.g., information you post about us in third-party reviews or on social media)
We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with our website and how our website could be improved.
IF I SIGN UP FOR YOUR EMAILS, WILL THE INFORMATION I PROVIDE YOU BE SHARED WITH OTHERS?
From time to time, smarTours sends marketing communications and special offers to its customers by email. Users can sign up for our email notification list from our homepage, by providing their contact information. This information will not be shared with third parties. Recipients can unsubscribe from our email list by contacting us at the phone number or email address provided below. Information on how to unsubscribe is also included at the bottom of every email we send.
WILL MY PERSONAL INFORMATION BE SHARED WITH THIRD PARTIES?
We share cookie and tracking pixel information with service providers who assist us in sending marketing emails or postal mail communications to visitors to our website. These service providers identify website visitors based upon their IP address, and match it to email and/or postal information already contained in smarTours’ database (e.g., because you previously provided us with your contact information) or with preexisting information contained in the service provider’s database. We only send marketing communications to those who have already opted-in to receive marketing emails from us, and our service providers are prohibited from using your personal information for any purpose other than assisting us with our marketing efforts. Recipients can unsubscribe by contacting us at the phone number or email address provided below. Information on how to unsubscribe is also included at the bottom of every marketing email we send.
Service providers also may be involved in payment processing, shipping, web analytics, data processing, marketing, advertising or email distribution, or administering contests or promotions. In some cases, these companies may need to access information about you. Service providers may only use the information we provide them for the purpose of carrying out their services and may not otherwise use or share your information.
The third-party services we use for our website include Google Analytics and HubSpot, which we use to better understand how users interact with our website, and tailor our marketing to their individual interests.
HOW DO I SIGN UP TO RECEIVE TEXT MESSAGES FROM YOU (AND HOW DO I OPT-OUT IF I NO LONGER WANT TO RECEIVE THEM)?
You have the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you have shared with us. To opt-in, please call us at the phone number listed below, and speak with one of our customer service representatives. Once you have opted-in, we may send you text messages (i) regarding your account; (ii) your use of our app (if applicable); (iii) to investigate or prevent fraud; and (iv) to alert you in the event of an emergency. We may send you text messages and alerts using autodialed technology. We will not contact you via text messages or alerts for marketing purposes without your prior express written consent. You do not have to opt-in to text messages and alerts to use and enjoy our website and Services. If you opt-in, standard text messaging charges may apply. For more information regarding our text messaging and alerts, please contact us at the phone number or email address provided below.
You may choose to opt-out from our text messages and alerts at any time using any reasonable means. To directly opt-out, send us a text message from your mobile phone with the word STOP, STOP ALL, END, QUIT, CANCEL or UNSUBSCRIBE, and we will unsubscribe you from text communications. Once you opt-out, you will not receive any additional text messages via your mobile phone. Please keep in mind that if you opt-out of receiving text messages and alerts we may not be able to contact you with important messages regarding your account. However, if there is an emergency or account question, we will make every attempt to contact you in other ways, such as by email or on a landline phone.
HOW DOES SMARTOURS PROTECT THE SECURITY OF MY PERSONAL INFORMATION?
We have commercially reasonable and appropriate security measures in place to protect user information under our company’s control against loss, misuse, or alteration. Access to private and confidential data is limited to those employees with a specific need to retrieve this information. Data is stored on multiple service systems and written to tapes. All server systems are located in a secure facility complete with environmentally controlled conditions. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
IS MY PRIVACY PROTECTED WHEN I LEAVE THROUGH A LINK ON THE SMARTOURS WEBSITE?
WHAT ARE MY CALIFORNIA PRIVACY RIGHTS?
If you are a resident of California, your right to submit certain requests relating to your Personal Information are described below. Please note that when submitting a request, you will be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will need to verify your identity directly with us through the process described below.
a. Right to Opt Out of the Selling of Your Personal Information
We do not sell your personal information to third parties. As such, there is no need to submit a request for us to not sell your personal information. If you have any questions, feel free to contact us at info@smarTours.com or 800.337.7773.
b. Right to Request More Information
A general description of the categories of information we collect and the purposes for which we use that information is provided above. If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:
(1) The categories of personal information we have collected about you in the preceding 12 months.
(2) The categories of sources from which the personal information was collected.
(3) The business or commercial purpose why we collected your personal information.
(4) The categories of third parties with which we share personal information.
(5) The specific pieces of personal information we have collected about you.
(6) The categories of personal information about you that we have shared with third parties for a business purpose in the preceding 12 months, and for each category, the categories of third parties to which we disclosed the information (if any).
You may submit a request for the information above by calling us at 800.337.7773 or emailing us at info@smarTours.com. In connection with submission of your request, we will take steps to verify your identity as outlined below and you will need to verify your identity before action is taken.
c. Right to Request Deletion of Your Personal Information
California residents also have the right to request that we delete your personal information collected or maintained by us. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers with whom we shared your personal information also to delete your personal information from their records. There may be circumstances where we cannot delete your personal information or direct service providers to delete your personal information from their records. For example, if we need to: (1) retain your personal information to complete a transaction or provide goods or services; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug or repair errors; or (5) comply with a legal obligation. You may submit a request to delete your personal information by calling us at 800.337.7773 or emailing us at info@smarTours.com. In connection with submission of your request, we will take steps to verify your identity as outlined below, and you will need to verify your identity before action is taken.
d. Verification of Requests for Further Information or to Delete Personal Information
Upon submission of a request for information or a request to delete information, we will take reasonable steps to confirm that the person submitting the request to know or request to delete is the person to whom the information relates, and to prevent unauthorized access or deletion of information. The specific steps taken to verify the identity of the requesting person may vary based on the nature of the request, including the type, sensitivity and value of the information requested, the risk of harm posed by unauthorized access or deletion, the likelihood that fraudulent or malicious actors may seek the information, the robustness of personal information provided to verify your identity, the nature of our business relationship with you, and available technology for verification.
We will generally try to avoid requesting additional information from you for the purpose of verification, but we may need to do so if we cannot verify your identity based on the information already maintained by us. If we request additional information to verify your identity, it will be for that purpose only, and will be deleted as soon as practical after processing the request, except as otherwise provided by law.
The following generally describes the verification processes we use:
- Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity, but will require re-authentication before disclosing or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
- Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
- For requests to know categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
- For requests to know specific pieces of personal information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request. We will maintain all signed declarations as part of our records.
- For requests to delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.
- If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.
e. Right to Non-Discrimination for the Exercise of Your Privacy Rights
If you choose to exercise any of the privacy rights conferred by the California Consumer Privacy Act of 2018, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing goods or services to you, charge you different prices or provide a different level or quality of goods and services to you unless those differences are related to the value of your Personal Information.
545 Eighth Avenue, Suite 2250
New York, NY 10018
- What personal information does smarTours collect?
This section describes the information we collect, which is generally either information you provide directly to us, or information gathered automatically when you visit our website. There is a chart under “How does smarTours use the personal information it collects?” that lists each category of information collected by us.
- What technologies does smarTours use to collect information about me?
This section describes the technologies we use to identify you when you visit our website. Collecting information about you helps us tailor your experience on our website and remember you and your preferences when you come back to our site, among other uses.
- How does smarTours respond to “Do Not Track” signals?
Although some web browsers have the ability to send “Do Not Track” signals, our website does not have the ability to automatically respond to these signals.
- How does smarTours use the personal information it collects?
This section includes a new chart that clearly describes how we use each category of personal information that we collect.
- If I sign up for your emails, will the information I provide you be shared with others?
Information you provide in order to sign up for our email list is not shared with third parties. This section also describes how you can unsubscribe from our marketing emails.
- Will my personal information be shared with third parties?
This section describes the types of service providers we work with in order to run our business. We use service providers to help us with payment processing, shipping, web analytics, data processing, marketing, advertising, email distribution, and administering contests or promotions.
- How do I sign up to receive text messages from you (and how do I opt-out if I no longer want to receive them)?
This section includes simple instructions on how to opt-in and opt-out of receiving text messages from us.
- How does smarTours protect the security of my personal information?
An updated description of how we keep your data safe.
- Is my privacy protected when I leave through a link on the smarTours website?
Not necessarily. Our site contains links to other sites maintained by third parties, and we cannot control the privacy practices of such other sites.
- What are my California privacy rights?
This section has been updated to describe your rights under the California Consumer Privacy Act of 2018. It includes a description of how California residents can exercise their privacy rights.
Describes how to get in touch with us about privacy questions.