INTRODUCTION
Travel Miles With Us, (“Travel Miles With Us)”, “Company,” “Us” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Notice and Policy (hereafter the “Policy”) describes the types of information we may collect from you or that you may provide when you visit or use www.travelmileswithus.com and the Company’s mobile website, its mobile and tablet applications (collectively herein the “App”), or use any content, functionality, and services offered on or through travelmileswithus.com, as well as our practices for collecting, using, maintaining, protecting, sharing, and disclosing that information.
This Policy applies to information we collect:
– When you visit the Website, App, and/or use our online services;
– In email, text, and other electronic messages between you and this Website or App; and
– When you interact with our advertising and applications available on third-party websites and services if those applications or advertising include links to this Policy.
This Policy does not apply to information collected by:
– Us offline or through any other means, including on any other website operated by the Company or any third party; or
– Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. This Policy may change from time to time (see “Changes to Our Privacy Policy). Please check the Policy periodically for updates.
Children Under the Age of 13
Our Website is not intended for, intentionally targeted to, or designed for use by children under 13 years of age. We do not knowingly or intentionally collect personal information from children under 13. If you are under 13, do not use or provide any information on or through this Website, the App, or any of their features; do not register on the Website, make any purchases through the Website/App, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [email protected] INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of our Website, including:
– Information by which you may be personally identified, such as name, residential address, postal address, e-mail address, telephone number, credit card numbers or other payment information, or any other identifier by which you may be contacted online or offline (“personal information”);
– Information that is about you but does not individually identify you;
– Information about your internet connection and IP address, the equipment you use to access our Website, the browser type and language, and access dates/times, referring website addresses, and other usage details;
– Information you provide on our Website to assist you with travel arrangements for yourself or another person, for example, your username, password, location, zip/postal code, mailing address, email address, driver’s license, passport or other government-issued identification numbers, date of birth, gender, arrival and departure locations and times, airline, hotel, or car rental loyalty program numbers and other travel-related information;
– Financial information, including the budget for travel arrangements;
We collect this information:
– Directly from you when you provide it to us;
– Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, operating systems, browsers, and information collected through cookies (small text files stored in a user’s web browser), web beacons (electronic images that allow us to count users who have accessed particular content including certain cookies), and other tracking technologies;
– From third parties, for example, our business partners;
– From third party social media services, such as Google, Facebook, Twitter, Instagram, etc. that you may use to interact with our Website or that allow you to share information;
– Unaffiliated parties, such as analytics companies, advertising networks, affiliates, and other third parties that may provide us with information so we can better understand you and provide you with information that may be of interest to you.
Information You Provide to Us
The information we collect on or through our Website may include:
– Information that you provide by filling in forms on our Website. This includes information provided when registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
– Records and copies of your correspondence (including email addresses) if you contact us.
– Your responses to surveys that we might ask you to complete for research purposes.
– Details of transactions you carry out through our Website and of the fulfilment of your travel reservations and purchases. You may be required to provide financial information before completing a booking through our Website.
– Your search queries on the Website.
You also may provide information to be published, displayed (hereinafter, “posted”) or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted, displayed, and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
– Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
– Information about your computer and internet connection, including your IP address, operating system, and browser type.
– Information about your use of our Services, how you interact with our Services and advertisements, and information about data or files that have been uploaded to our Services. This information may include things like buttons you click, mouse movements, key strokes, page visits, dates and times of access, web beacons, and cookie or pixel tag information. See below for additional information about cookies, pixel tags, web beacons, and analytic technologies.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). The information we collect automatically is statistical data and may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. We may use third-party vendors to assist with monitoring and analysing site activity, including but not limited to Hotjar, Google Analytics & Mix Panel. It helps us to improve our Website and deliver a better and more personalized service, including by enabling us to:
– Estimate our audience size and usage patterns.
– Store information about your preferences, allowing us to customize our Website according to your individual interests.
– Speed up your searches.
– Recognize you when you return to our Website.
We may use cookies and other similar technology for automatic data collection. Cookies are small pieces of text sent as files to your computer or mobile device when you visit most websites. Cookies are either session cookies or persistent cookies. Session cookies enable sites to recognize and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognize you as an existing user and these cookies are stored on your system or device until they expire or are deleted.
You can manage your cookies by setting or amending your web browser controls to accept or refuse cookies whenever you like, but if you do choose to reject certain cookies, your access to some features and functionality of our website may be restricted. Certain cookies are required or “essential” for our site to function as intended. These essential cookies are necessary for you to use certain features of our site such as accessing your account and managing your reservations. You are not able to opt out of or reject essential cookies.
The technologies we use for this automatic data collection may include:
– Cookies (or browser or mobile cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
– Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
– Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We use cookies for several reasons including to:
– Help us improve your experience when visiting our site.
– Fulfil transactions and ensure our site performs as intended.
– Remember your preferences each time you visit our site.
– Provide you with relevant advertising and analyse performance of those ads.
– Enable you to return to previous searches you performed on our site.
– Identify errors on our site.
– Help us protect your data and potentially detect and investigate malicious and/or fraudulent activity.
– Help us understand traffic to our site and analyse how well our site is performing.
Third-Party Use of Cookies and Other Tracking Technologies
Some content, applications, and features, including without limitation advertisements, ticket issuance, and payment processing, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, analytics companies, payment processors, your mobile device manufacturer, your mobile service provider, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from any providers, see “Choices About How We Use and Disclose Your Information” below.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
– To present our Website and its contents to you;
– To fulfil your travel reservations, bookings, and purchases, to communicate with you regarding your reservations, bookings, and purchases, and to otherwise provide you with information, products, or services that you request from us;
– To fulfil any other purpose for which you provide it;
– To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for payment processing, billing, and collection of amounts to be paid under any such contracts;
– To notify you about changes to our Website, App, or any products or services we offer or provide though it;
– To promote our products and services by sending you marketing and advertising communications that we develop and believe may be of interest to you;
– To create, maintain, and update user accounts on our Website and authenticate you as a user
– To allow you to participate in interactive features on our Website;
– To respond to your questions, requests for information, and process information choices;
– To contact you to provide information like travel booking confirmations and updates;
– In any other way we may describe when you provide the information;
– For any other purpose with your consent.
We may use the information we have collected from you to contact you about goods and services that may be of interest to you. For information about how you can opt out of receiving information about goods and services, see “Choices About How We Use and Disclose Your Information” below.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any specific individual for business purposes, without restriction where permissible under applicable laws and regulations.
We may disclose personal data and information that we collect, or you provide as described in this Policy:
– To our subsidiaries and affiliates;
– To contractors, service providers, and other third parties we use to support our business, including but not limited to, but only to the extent such parties are necessary for the fulfilment of your travel arrangements. Generally, it will be necessary for us to process personal data via a third party, including, but not limited to, airlines, hotel vendors, car rental companies, and entry visa or passport companies, in the course of completing your purchases of travel;
– To other third party suppliers we work with in connection with our business and the provision of our services to you. This includes for example, marketing agencies and/or companies that run our marketing campaigns, IT developers, service providers and hosting providers, third parties that manage promotions we may run, third party software companies, advertising providers and networks, and site analytics providers.
– To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred;
– To fulfil the purpose for which you provide it;
– For any other purpose disclosed by us when you provide the information;
– With your consent.
We may also disclose your personal information to fulfil our legal obligations:
– To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
– To enforce or apply our terms of use and other agreements, including for billing and collection purposes;
– If we in good faith believe disclosure is necessary or appropriate to protect your safety or the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
– Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or mobile cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may be inaccessible or not function properly.
– Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request at [email protected] or you can unsubscribe here.
– Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request [email protected] or you can unsubscribe here.. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, licensing subscription, product service experience, or other transaction.
– Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request at [email protected] or you can unsubscribe here. For this opt-out to function, you must have your browser or smartphone set to accept browser cookies.
We might rely on third parties, to help manage our marketing communications. They may collect personal information when you interact with its digital property, including IP addresses, digital identifiers, information about your web browsing and application usage and how you interact with its properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes.
ACCESSING AND CORRECTING YOUR INFORMATION
If you have signed up for an account on our Website, you can review and change your personal information by logging into your account and visiting your account profile page. You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms and Conditions. Residents of certain states within the United States may have additional personal information rights and choices. Please see the section on your specific state’s privacy rights, if applicable.
DATA SECURITY
We take the security and protection of your information very seriously. We have implemented industry-standard measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
Unfortunately, the transmission of information via the internet is never completely secure. Although we take all reasonable security measures to protect your personal information, we cannot guarantee or warrant the security of your personal information transmitted to us online. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. If we learn that your personal information is compromised, we may notify you by email to the last known email address provided in the most expedient time reasonable under the circumstances, or as otherwise required by applicable law, provided however, we may delay notification as may be necessary while we determine the scope of the breach, attempt to restore reasonable integrity to our system, and cooperate with law enforcement.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.
RETENTION OF YOUR INFORMATION
We will retain your personal information in accordance with all applicable laws, and only for as long as necessary to fulfil the purposes set forth in this Policy. We will deidentify, aggregate, or otherwise anonymize your personal information prior to using it for analytical purposes or trend analysis beyond the standard retention period. When we delete your personal information, we use industry standard methods to ensure that recovery or retrieval of your information is impossible. We may keep residual copies of your personal information in backup systems to protect our systems from malicious loss. This data is inaccessible unless restored, and upon restoration, all unnecessary information will be deleted.
The criteria we use to determine our retention periods include:
– The duration of our relationship with you, including open user accounts, or recent bookings or other transactions you have made through us;
– Applicable laws requiring us to keep records of your transactions with us for a specific period of time;
– Current and relevant legal obligations governing how long we retain your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations;
– Whether the information is needed for secure backups of our systems.
PROCESSING YOUR INFORMATION
Information that you provide may be transferred to, accessed, stored, and processed in the United States and other countries. The data protection and other laws and standards of such countries might not be as comprehensive as those in your country. By using the Website, you acknowledge and agree that your information may be transferred to such countries, including without limitation to our facilities and those third parties with whom we share it as described in this Policy in such countries.
We restrict data transfers to those that are legally binding or essential for the provision of our business obligations.
INTERNATIONAL DATA TRANSFER
The personal information we process may be accessed from, processed or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country.
The servers for our platform are located in the United Kingdom, and Travel Miles With Us and its third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries. Our employees may access your personal information from various countries around the world. The transferees of your personal data may also be located in countries other than the country in which you reside.
We have taken appropriate steps and put safeguards in place to help ensure that any access, processing and/or transfer of your personal information remains protected in accordance with this Policy and in compliance with applicable data protection law. Such measures provide your personal information with a standard of protection that is at least comparable to that under the equivalent local law in your country, no matter where your data is accessed from, processed, and/or transferred to.
Such measures include the following:
– Adequacy decisions of the European Commission confirming an adequate level of data protection in respective non-EEA countries.
– Ensuring that the third-party partners, vendors and service providers to whom data transfers are made have appropriate mechanisms in place to protect your personal information. For instance, our agreements signed with our third-party partners, vendors and service providers incorporate strict data transfer terms (including, where applicable, the European Commission’s Standard Contractual Clauses issued by the European Commission and/or United Kingdom, for transfers from the EEA/UK), and require all contracting parties to protect the personal information they process in accordance with applicable data protection law.
– Carrying out periodic risk assessments and implementing various technological and organizational measures to ensure compliance with relevant laws on data transfer.
NOTICE OF RIGHTS TO RESIDENTS OF SPECIFIC GEOGRAPHIC LOCATIONS
This Section supplements the information contained in the rest of this Privacy Policy and applies solely to visitors, users, and others who reside in the countries and states specified within the following “Notice of Rights” Subsections.
Notice of Rights of Individuals located within the EU
Notice to individuals located within the territorial confines of the European Economic Area (“EEA”): This Policy and the notices contained herein are intended to comply with the EU General Data Protection Regulation (Regulation (EU) 2016/679) of the European Parliament and of the Council of 27 April 2016 (the “GDPR”) and provide appropriate protection and care with respect to the treatment of your user information in accordance with the GDPR.
We limit our collection, retention, and use of such information to that which is necessary to provide you with our goods and/or services and is compliant with applicable data retention laws. As a “Data Subject” within the meaning of GDPR, under applicable law you have certain rights that you may exercise to protect your personal data, which you can exercise at any time. These Data Subject rights are:
– Right to be informed � you have the right to inquire about what personal data (about you) we process and the rationale for such processing.
– Right of access to information � you have the right to request a copy of the personal data that we collect and process for you. If we refuse your request under your right of access, we will provide you with a reason as to why and you will have the right to complain to a relevant data protection supervisory authority about our processing of your personally identifiable information.
– Right of rectification � you have a right to correct any inaccurate or incomplete data that we collect and process for you.
– Right to restriction of processing � where applicable, such as when there is a pending legal dispute or the data is being corrected, you have a right to temporarily restrict the processing of your data.
– Right to be forgotten (right to erasure) � in certain circumstances you can ask for the data we collect about you to be erased from our records.
– Right of portability � you have the right to have the data we collect about you to be transferred to another organization and for such data to be provided in a commonly used, structured, and machine-readable format.
– Right to withdraw consent � you have the right to withdraw a previously given consent for processing of your personal data for a specific purpose.
– Right to object � you have the right to object to certain types of processing, such as using your personal data for direct marketing and advertising. This also applies to profiling, where appropriate, insofar as it is associated with such direct marketing and advertising.
– Right to lodge complaint � you have the right make a complaint with a local supervisory authority using any method acceptable to them.
The Data Subject may exercise these rights at any time by contacting the responsible party. The responsible party, according to Article 4 (7) of the GDPR, is Travel Miles With Us, Office 210, Stanmore Business Centre, Howard Road, Stanmore, London HA7 1GB, Attn: Information Security Coordinator, telephone: +441582240900, E-mail: [email protected]
Under applicable law, we will not process and/or disclose your personal data without a lawful basis to do so, as such bases are defined in Article 6 of the GDPR. In general, at least one of the following must apply whenever personal data is processed:
– Consent. The individual has given clear consent for the processing of their personal data for a specific purpose.
– Contract. The processing is necessary for the performance of a contract.
– Legal Obligation. The processing is necessary to comply with the law.
– Vital Interests. The processing is necessary to protect someone’s life.
– Public Task. The processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
– Legitimate Interests. The processing is necessary for legitimate interests of the data controller, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
To exercise one or more of your rights, or appeal a denial of a request, contact us at: [email protected]
We may be required to modify our privacy and data protection notices due to changes in our services, changes to applicable laws and regulations, or for a myriad of other reasons. We therefore reserve the right to change this Policy at any time. It is our policy to post any changes we make to our privacy policy on this page. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.
You can find the date the policy was last updated at the top of the page. Any changes to this Policy will become effective when posted unless indicated otherwise.
CONTACT INFORMATION
To ask questions or submit comments about our Privacy Policy and our privacy practices, or to reach the data protection coordinator, contact us at:
By Email: [email protected]
By Mail: Office 210, Stanmore Business Centre, Howard Road, Stanmore, London HA7 1GB
By Phone: +441582240900
Please ensure that the subject line of any correspondence contains the word, “PRIVACY”, so we can ensure that your correspondence is routed in a timely and efficient manner.