EBMV LLP (“we,” “Our” or “us”) cares about your privacy and wants you to be familiar with how we collect, use, and disclose data. This Privacy Statement covers the collection, use, and disclosure of data collected via www.travelfreeby.com (“Site”). This Privacy Statement also describes your legal rights in relation to such data.
Please note that this Privacy Statement addresses the data collection and handling practices associated with this Site only. Other websites, including those provided by members/subscribers/users are governed by their own privacy statements. Additionally, our products and services may be subject to their own statements specific to the product or service. We encourage you to review these privacy statements to understand how our products and services use data.
By using this Site, you are subject to the terms and conditions of this Privacy Statement.
1. DATA COLLECTION
We collect or obtain data relating to you in a variety of ways, as described below. Such data may include personal data, i.e., information that alone or in combination with other information identifies you as an individual or can be reasonably linked to your identity.
1.1 Data You Provide: When you submit questions, request information, or give us feedback via this Site, we may ask you for data, like your name, postal address, telephone number, and email address so we can respond or follow up. We may also ask you to provide other data relevant to your question, request, or feedback, such as your geographical location, industry, and preferred contact method.
You may also make requests through this Site to exercise your individual rights under applicable privacy laws. We will collect and maintain data related to such requests in order to respond to you and for our audit and legal compliance purposes.
We generally do not seek data that may be considered “special” or “sensitive” personal data (e.g., government-issued identification numbers or information related to an individual’s racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or trade union membership) from visitors of this Site, and we ask that you do not provide such data. If we specifically require “special” or “sensitive” personal data in connection with one or more of the uses described below, we will request your consent to use the data in accordance with this Privacy Statement and/or in the ways described at the point where you were asked to disclose the data. If you voluntarily share with us or post/upload any “special” or “sensitive” personal data to this Site for any other reason, you consent that we may use such data in accordance with applicable law and this Privacy Statement.
Please note that any information or materials you post or disclose on this Site via message boards, chats, profile pages, blogs, and other services (including social media services) are publicly available and will be seen by other visitors to this Site. You should consider this when deciding to disclose any personal data or any other information on this Site.
1.2 Data Collected from your Use of this Site: We automatically receive certain data about the computer or device you are using when you visit this Site, including: your Internet Protocol (IP) address; information about the browser or type of device you are using; data collected through cookies, pixel tags, and other similar; the date and time of your visit; and the web page you visited immediately prior to visiting this Site. We also collect data about videos or other content you view on this Site, like the type and name of the content and the time viewed.
2. DATA USE
We use data about you for the purpose(s) for which it was collected or provided to us (as stated at the point of collection) or as otherwise obvious from the context of collection. We may also use data to:
Note that you may unsubscribe from a our mailing list at any time by clicking on the ‘unsubscribe’ link in any of our marketing communications to you. After you unsubscribe, we will not send you further marketing communications, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.
We will never use your personal data to advertise, promote, or market third-party goods or services to you. Additionally, we will not license or publish any of your personal data. We do not and will not sell any personal data to third parties for their own commercial use.
3. BASIS FOR PROCESSING PERSONAL DATA
Applicable law in certain countries requires us to set out in this Privacy Statement the legal basis upon which we rely in order to process personal data.
3.1 Consent: We may rely on the consent that you provide us at the point of data collection or disclosure to us to process such data for the purposes outlined herein.
3.2 Legitimate interests: We may rely on our legitimate interests to process your personal data, provided that our interests are not overridden by your interests, fundamental rights, or freedoms. In particular, we may process your personal data in reliance on a legitimate interest in the effective and lawful operation of this Site and our businesses, as well as the effective delivery of information and services to you. We may have other legitimate interests and, if so, we will make clear what those interests are at the relevant point in time.
3.3 Compliance with legal obligations: We may process your personal data if necessary for us to comply with a legal obligation arising under an applicable law to which we are subject.
To the extent that we process any “special” or “sensitive” categories of personal data relating to you, we will do so because either: (i) you have given us your explicit consent to carry out such processing; (ii) the processing is necessary for the establishment, exercise, or defense of legal claims; or (iii) you have made the data manifestly public.
4. DISCLOSURES OF PERSONAL DATA
In connection with one or more of the purposes outlined in the “Data Use” section above, we may disclose your data to:
The disclosures described in this section may result in the transfer of your data to countries or regions with data protection laws that differ from those in your country of residence. By providing us with your data and using this Site, you are acknowledging that your data may be transferred to countries outside of your country of residence.
In cases where your data is transferred outside of your country of residence, we take steps to ensure that appropriate safeguards are in place to protect such data. If you are based in the EU/EEA, such safeguards may include a data transfer agreement with the data recipient based on standard contractual clauses or such other mechanism as is approved by the European Commission for transfers of personal data to third countries.
5. COOKIES AND OTHER INTERNET TECHNOLOGIES
5.1 Other third party cookies and technologies. We also enable third-party cookies and other similar technologies to collect or receive data from this Site and elsewhere for use in advertising, including for the purposes of serving advertisements targeted to users’ interests, retargeting visitors to this Site, conversion tracking (i.e., tracking the actions users take after viewing or engaging with our advertisements), measuring ad effectiveness, and ensuring that you do not see the same ad repeatedly. These cookies and similar technologies collect data about your browsing habits and online behavior, including across different browsers and devices used by you, in order to serve advertisements that may be of interest to you
Third parties may also use data about your use of this Site to help target advertisements based on your online behavior and/or interests in general. Data collected generally includes actions you take on this Site (e.g., URL, previous website visited), device and browser data (e.g., IP address, operating system, browser type), timestamp, and events (e.g., page views). In some cases, this data is connected to your social network ID. Please note that we are not responsible for practices by such third parties, and those practices are subject to those companies’ own policies.
6. THIRD-PARTY WEBSITES
This Privacy Statement does not address, and we are not responsible for, the privacy practices of any third parties, including those that operate websites to which this Site links. The inclusion of a link on this Site does not imply that we or our affiliates endorse the practices of the linked website.
7. DATA SECURITY
We use reasonable organizational, technical, and administrative measures to protect data under our control. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you feel that the security of any data that we hold about you has been compromised, please immediately notify us of the problem by contacting us.
8. EXERCISING YOUR RIGHTS
You have choices about how your personal data is handled, and we are committed to providing you with reasonable access to your personal data and the ability to review and limit the use of such data in accordance with applicable law.
If you no longer want to receive electronic newsletters you signed up to receive or other marketing communications from us, you can click on the ‘unsubscribe’ link at the bottom of such communications.
Depending on your country of residence, you may also have the right to:
Please note that we may require proof of your identity before we can give effect to these rights.
We will not discriminate against you if you decide to exercise your rights under applicable law.
Because we want to avoid taking action regarding your personal data at the direction of someone other than you, only you or an “Authorized Agent” permitted to act on your behalf may submit a request. An “Authorized Agent” means a natural person or a business entity you have authorized to act on your behalf by providing your written permission. Please note, we may deny a request from an Authorized Agent if they do not submit proof that they have been authorized by you to act on your behalf.
Your request must:
We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data we maintain relates to you. To verify your identity, we will seek to match any personal data you provide when you (or an Authorized Agent) submit your request to any personal data we already maintain. If we are unable to verify your identity based on the data we maintain, we will let you know.
Special Notice to California Residents
If you are a resident of the state of California, you are entitled to request information regarding the disclosure of your personal data to third parties for direct marketing purposes. Please note that we do not share your personal data with non-affiliated third parties for such purposes.
9. DO NOT TRACK SIGNALS
10. DATA RETENTION
We will retain your personal data only for those periods necessary to fulfill the various purposes outlined in this Privacy Statement, unless a longer retention period is required or allowed by law.
11. USE OF THIS SITE BY MINORS
We understand the importance of protecting the privacy of minors, especially in the online environment. This Site is not designed for or intentionally targeted at minors under the age of 18, and we request that minors not use this Site. We do not knowingly collect data from minors on this Site. If we become aware that we have received data from a person under the age of 18, we will take reasonable steps to delete such data from our records.
12. UPDATES TO THIS PRIVACY STATEMENT
We may make changes to this Privacy Statement from time to time. Any changes will become effective when we post a revised version of this Privacy Statement on this Site. Your use of this Site is subject to the terms in the version of this Privacy Statement that is posted on this Site at the time of your visit. We encourage you to review this Privacy Statement periodically to remain informed about how we are protecting your data.
13. CONTACT US
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