1. INTRODUCTION
This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the Travel Pala website and the Payment Services. This privacy policy describes our privacy practices for all websites, platforms and services that link to it. Please read the privacy policy on the applicable site.
2. INFORMATION WE COLLECT
2.1 Information You Give to Us.
2.1.1 Information that is necessary for the use of the Travel Pala Platform. We ask for and collect the following personal information about you when you use Travel Pala website. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services. Account Information. When you sign up for a Travel Pala Account, we require certain information such as your first name, last name, email address, and date of birth. Profile and Listing Information. To use certain features of the website (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture. Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information. Payment Information. To use certain features of the Travel Pala (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via Travel Pala Payments).
2.1.2 Information that is necessary for the use of the Payment Services. The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services: Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law. Identity Verification and Other Information. If you are a Host, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.
2.1.3 Information We Automatically Collect from Your Use of the website and Payment Services. When you use the website and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the website and Payment Services. Usage Information. We collect information about your interactions with the website such as, your reservations, and bookings you have made. We may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Payment Transaction Information. Travel Pala Payments collects information related to your payment transactions through the website, including the payment instrument used, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Travel Pala Payments and to allow the provision of the Payment Services.
2.2 Children’s Data. Our websites are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.
3. Create and Maintain a Trusted and Safer Environment.
We may use the personal information to create and maintain a trusted and safer environment such as to: detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, conduct security investigations and risk assessments, verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide), conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required, comply with our legal obligations, Resolve any disputes with any of our Members and enforce our agreements with third parties, enforce our terms of service and other policies, and in connection with the activities above, we may conduct profiling based on your interactions with the website, your profile information and other content you submit to the website, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the website if such processes detect activity that we think poses a safety or other risk to the website, our community, or third parties. If you challenge the decisioning please contact us as provided in the Contact Us section below.
3.1 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to: send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences and social media advertising through social media platforms such as Facebook or Google, personalize, measure, and improve our advertising, Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Travel Pala or its third party partners, Host story, we may use the information provided to reach out to you to invite you to relevant events).
4. SHARING & DISCLOSURE
4.1 Advertising and Social Media; Sharing With Your Consent. Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Travel Pala Account or when you participate in promotional activities conducted by Travel Pala partners or third parties. The social media platforms with which we may share your personal information are controlled or supervised by Travel Pala. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
4.2 Sharing between Members. To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows: When you as a Guest submit a booking request, certain information about you could be shared with the Host (and Co-Host, if applicable), including your profile, full name, the full name of any additional Guests, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number. When you as a Host (or Co-Host, if applicable) have a confirmed booking, certain information could be shared with the Guest (and the additional Guests they may invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Accommodation or Experience address. When you as a Guest initiate a Group Payment Booking Request certain information about each participant such as first name, last initial, profile picture as well as the booking details is shared among all participants of the Group Payment Booking Request. We don’t share your billing and payout information with other Members.
4.3 Profiles, Listings, and other Public Information. The website lets you publish information, including personal information, that won’t be visible to the general public. For example: Parts of your public profile page, such as your first name, national ID, Address, and Listing name, are not publicly visible to others. Listing pages are publicly visible and include information such as the Accommodation or Experience’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share. After completing a booking, Guests and Hosts may write Reviews and rate each other. Reviews and Ratings maybe a part of your public profile page and may also be surfaced elsewhere on the website (such as the Listing page). If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the website, that content is publicly visible. Information you share publicly on the website may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
4.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights. Travel Pala and Travel Pala Payments may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Travel Pala, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability (See more information on Travel Pala’s Law Enforcement Guidelines here), (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Travel Pala, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies. These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the website platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage. Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Travel Pala’s property, its Members and the website Platform. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
5. OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications. We may review, scan, or analyze your communications on the Travel Pala Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We may use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on Travel Pala's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2 Linking Third Party Accounts. You may link your Travel Pala Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link: some of the information you provide to us from the linking of your accounts may be published on your Travel Pala Account profile; your activities on the Travel Pala Platform may be displayed to your Friends on the Travel Pala Platform and/or that third party site; a link to your public profile on that third party social networking service may be included in your Travel Pala public profile; other Travel Pala users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable; other Travel Pala users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service; the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
6. YOUR RIGHTS
Please note that we will verify your identity and request before you could start taking further action on the website.
6.1 Managing Your Information. You may access and update some of your information through your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Travel Pala Account).
6.3 Data Access and Portability. In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure. We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely." Please note that if you request the erasure of your personal information: We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Travel Pala Account for fraud or safety reasons, we may retain certain information from that Travel Pala Account to prevent that Member from opening a new Travel Pala Account in the future. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Travel Pala and Travel Pala Payments may keep some of your information for tax, legal reporting and auditing obligations. Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Travel Pala Platform, even after your Travel Pala Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Because we maintain the Travel Pala Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing. If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to Travel Pala specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Travel Pala override your own.
6.6 Objection to Processing. In some jurisdictions, applicable law may entitle you to require Travel Pala and Travel Pala Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Travel Pala and/or Travel Pala Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Where your personal information is processed for direct marketing purposes, you may, at any time ask Travel Pala to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@travelpala.co.zw.
6.7 Lodging Complaints. You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.
7. SECURITY
We shall keep on continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Travel Pala Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Travel Pala Account, please contact us following the instructions in the Contact Us section below.
8. CHANGES TO THIS PRIVACY POLICY
Travel Pala reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Travel Pala Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Travel Pala Platform will be subject to the revised Privacy Policy.
9. CONTACT US
If you have any questions or complaints about this Privacy Policy or Travel Pala’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at: information@travelpala.net