Privacy Policy

Privacy Policy

Last Updated: 24 November 2021

1. GENERAL INFORMATION

1.1 About the Privacy Policy. This Travel Verified LLC (dba The 1000 and associated names) Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the websites of Travel Verified LLC (including but not limited to the1000.club), the related software and services (collectively, the “Platform”). The Privacy Policy does not cover any third-party websites, applications, software, products or services that integrate with the Platform or are linked to from the Platform other than those owned and/or operated by the Owner.

1.2 Owner of the Platform. The Platform is owned and operated by Travel Verified LLC having an address at 1000 Brickell Avenue, Suite 715 PMB 5161, Miami, Florida 33131, USA (“we,” “us,” or “our”).

1.3 Your consent. Before you submit any personal data through the Platform, you are encouraged to read this Privacy Policy that is always available on the Platform to understand on what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, you consent may be necessary if: (i) we intend to collect other types of personal data that are not mentioned in this Privacy Policy; (ii) we would like to use your personal data for other purposes that are not specified in this Privacy Policy; or (iii) we would like to transfer your personal data to third parties that are not listed in this Privacy Policy.

1.4 Minors. The Platform is not intended for use by children (i.e., persons who are minors in their country of residence, usually – below the age of 18). Therefore, we do not knowingly collect minors’ personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay. 

1.5 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.6 Amendments. The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT?

2.1 Sources of personal data. We obtain your personal data from the following categories of sources:

• • Directly from you. For example, if you submit certain personal data directly to us when registering your user account or contacting us;
  • Directly or indirectly through your activity on the Platform. When you use the Platform, we automatically collect technical information about your use of the Platform; and
  • From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a lawful basis for disclosing your personal data to us.

2.2 Types of personal data. We respect data minimisation principles. Thus, we collect only a minimal amount of personal data through the Platform that is necessary to ensure the proper provision of the Platform as described below. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases. You can find more information about the legal bases below.

• • Your account. When you register your user account, we collect your name, contact information, mailing address, and business sales Information. We use the said information to register and maintain your user account, enable your access to the Platform, feature your profile, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ‘pursuing our legitimate business interests’ (i.e., operate, analyse, grow, and administer the Platform). We store such data until you amend it or your user account is deleted.
    • Payments. When you make a payment for our products and services, our third-party payment processors (e.g., VISA, MasterCard, or PayPal) collect your personal data, such as name, address, and payment details (e.g., credit card details). We do not have access to your full payment data; only a part of your personal data is made available to us (e.g., your location, 4 digits of your payment card, email address, and name). Your payment data is used to process payments and maintain our accountancy records. The legal bases on which we rely are ‘performing our contractual obligations’ and ‘pursuing our legitimate interests’ (i.e., administer our business). We store such data for the time period prescribed by law.
    • Enquiries. When you contact us by email, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to grow and promote our business) and ‘your consent’ (for optional personal data). We store such data until you stop communicating with us.
  • Cookies. When you browse the Platform, we may collect your cookie-related data. For more information about our use of cookies, please refer to the section “Cookies” at the end of this Privacy Policy. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (i.e., to analyse and promote our business) and ‘your consent’ (for non-essential cookies). We store such data until your cookies expire, you disable cookies, or you withdraw your consent, whichever earlier.

2.3 Sensitive data. We do not collect or have access to any special categories of personal data from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation.   

2.4 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to register your account, use the full functionality of the Platform or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose. 

2.5 Collection of analytics data. When you browse the Platform, we collect or have access to certain technical analytics data collected from you. Such data includes the following information:

• • Your activity on the Platform (time of visit, pages visited, products viewed, time spent on each page, clicks, scroll depth, interaction with widgets);
  • URL addresses from which you access the Platform;
  • Your browser type and version;
  • Your operating system;
  • Your device details;
  • Information about your orders; and
  • Your other online behaviour.

2.6 Purposes of analytics data. We use your analytics data to analyse what kind of users access and use the Platform, measure your engagement with the Platform, see which products are interesting to you, improve our content, develop new products and services, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, some of such data like your IP address may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyse and improve the Platform) and ‘your consent’ bases.

2.7 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).

2.8 Aggregated and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.

3. HOW DO WE COMMUNICATE WITH YOU?

3.1 Newsletters. If we have your email address, we may, from time to time, send you a newsletter informing you about the latest developments related to the Platform and our special offers. You will receive our newsletters in the following instances:

• • If we receive your express (“opt-in”) consent to receive marketing messages; or
  • If you voluntarily subscribe for our newsletter; or
  • If we decide to send you information closely related to services already used by you.

3.2 Opting-out. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.

3.3 Tracking pixels. The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.

3.4 Transactional notices. If necessary, we will send you important informational messages, such as confirmation receipts, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from our transactional notices.

4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

4.1 We store your personal data inour systems only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

4.2 In certain cases, if we are required by law to store your personal data for a certain period of time, we will keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.

5. HOW DO WE SHARE AND DISCLOSE YOUR PERSONAL DATA?

5.1 Disclosure to data processors. From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:

• • Ensuring the proper operation of the Platform;
  • Providing you with the requested information;
  • Pursuing our legitimate business interests;
  • Enforcing our rights, preventing fraud, and security purposes;
  • Carrying out our contractual obligations; or
  • If you provide your prior consent to such a disclosure.

5.2 List of our data processors. We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are:

• • Our hosting, cloud storage, newsletter, analytics, and marketing service providers Amazon located in the United States, Namespro located in Canada, Constant Contact located in the United States, Microsoft located in the United States, and Google located in the United States;
  • Our payment service providers Amazon, Microsoft, Google, PayPal, VISA, MasterCard located in the United States;
  • Our shipping service providers FedEx, UPS, USPS, DHL, Royal Mail, and Canada Post; and
  • Our independent contractors and consultants.

5.3 Legal requests. If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

5.4 Successors. In case the Platform is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes of the data controller.

5.5 Selling personal data. We do not sell your personal data to third parties.

5.6 International transfers. Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.

6. HOW DO WE PROTECT YOUR PERSONAL DATA?

6.1 Our security measures. We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include access control, secured networks, strong passwords, encryption, and carefully selected data processors.

6.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

7. WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?

7.1 The list of your rights. You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

• • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
    • Right to rectification: you can rectify inaccurate personal data that we hold about you;
    • Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
    • Right to restriction: you can ask us to restrict the processing of your personal data;
    • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
    • Right to object: you can ask us to stop processing your personal data;
    • Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your personal data.

7.2 How to exercise your rights? If you would like to exercise any of your rights, please contact us by email or by post (you can find our email address and postal address at the end of this Privacy Policy) and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

7.3 Complaints. If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

7.4 Non-discrimination. We do not discriminate against you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with lower quality services.

8. COOKIES

8.1 We use cookies on the Platform. In this section, we provide information about the types of our cookies, their purposes, and your right to manage cookies.

8.2 About cookies. A cookie is a small piece of data typically consisting of letters and numbers. When you visit a website, the website may send a cookie to your browser. Subsequently, the browser may store the cookie on your computer or mobile device for a certain period of time. Cookies are designed to allow the recognition of your device and collection of certain information about your use of a website. Thus, over time, cookies allow websites to “remember” your actions and preferences. There are several types of cookies, namely, (i) persistent cookies, which remain valid until deleted by you, (ii) cookies that remain valid until their expiration date, and (iii) session cookies that are stored on a web browser and remain valid until the moment the browser is closed. Cookies may also be (i) first-party cookies (set by the website itself) and (ii) third-party cookies (placed by third-party websites).

8.3 The cookie that we use. We may different types of cookies on the Platform, including:

• • Essential technical (strictly necessary) cookies that are essential to ensure the correct functioning of the Platform and to provide the services requested by you;
  • Preference cookies that record information about the choices that you make on the Platform;
  • Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyse the productivity of our marketing campaigns, and offer you personalised advertisement; and
  • Statistics cookies that allow us to generate statistical reports about how you use the Platform.

8.4 Cookie consent.  When you visit the Platform for the first time, we will ask you to provide us with your consent to our use of all cookies via a cookie consent banner. If you do not provide your consent, we will not serve you our non-essential cookies. Please note that we may not be able to provide you with the best possible user experience if not all cookies are enabled.

8.5 Disabling cookies. When we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you would like to refuse our use of non-essential cookies later, you can do it at any time by declining cookies in your browser or device. For more information, you can consult the cookie management instructions of your browser:

• • Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
  • Chrome: https://support.google.com/chrome/answer/95647
  • Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
  • Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/
  • Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

8.6 Google Analytics. We use Google Analytics, a web analytics service provided by Google LLC, registered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google generates statistical information by means of cookies and creates reports about your use of the Platform. The cookies served by Google are anonymous first-party cookies that do not allow us to identify you in any manner. The information generated by cookies will be transmitted to and stored by Google on servers in the United States. To ensure your privacy, your IP address will be anonymised and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en.

8.7 Targeted advertising. You may encounter targeted interest-based advertising based on your use of the Platform and other websites on the Internet. Where necessary, we will seek your consent. You can control how such advertising is shown to you or opt-out from targeted advertising by consulting the guide powered by the Digital Advertising Alliance available at https://youradchoices.com. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org .

9. CONTACT

If you have any questions about this Privacy Policy or our data protection practices, please contact us:

E-mail address: privacy@the1000.club

Mailing address: Travel Verified LLC dba The 1000, 1000 Brickell Avenue, Suite 715 PMB 5161, Miami, Florida 33131, USA