tTravel Privacy Policy
Last update: June 15, 2021
Published: June 15, 2021
1. Welcome to tTravel! A Few General Words
We offer You to discover new countries and special places with travel diaries, which are easy to
find on tTravel. This Privacy Policy describes the definitions of Personal Information, how it is
collected, used, stored, and shared when You use Our Application and Website.
By providing any Personal Information, as well as using the Services, You acknowledge and agree
that You have read, fully accept, and abide by this Privacy Policy.
This Privacy Policy will be accessible in the Application and on the Website. We can periodically
renew it. Information about the changes to the Privacy Policy will be displayed on the date of the
update of the Privacy Policy. If You don't agree to the terms of this Privacy Policy, the Terms of
Conditions, and the License Agreement (if applicable), please don’t use the Application and
the Website.
In case You have any questions relating to the terms contained in this Privacy Policy, please
days.
2. Definitions
For this Privacy Policy, the following terms have the meanings as mentioned below:
“Company”
— refers to Private Entrepreneur Shambalova Olha Mykhailivna
(record
number:
25560000000019320 dd. May 31, 2005), legal address: Ukraine, Odesa, Balkivska street,
house 40) incorporated
under
the
laws
of
Ukraine (hereinafer
- “Company”, “We”, “Our” or
“Us”).
“tTravel”— a mobile application and all its content and links, which can be used by You for
- “Application”, “tTravel”).
“Website” — means all content and links as well as any other linked pages and online Services
offered by the Company at the page https://ttravel.me that provides information regarding the
Application.
“Automatically-collected information” — information collected about a User automatically
through the Application, Website, or third-party services (“Usage Data”).
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“Account” — means an account required to access and/or use certain areas and features of Our
Application.
“Personal Data”, “Personal Information”— any information that can identify a natural person.
“Cookies”
— means small text files that a Website stores on Your computer or mobile device
when You receive the Services.
“Content”
— the information, Company and/or Users provide via Application, including travel
diaries, photos, video, feedbacks, etc.
“Services” — provision of services by the Company via Application, namely: advising on
placement in the Application and providing free / paid access to travel diaries, as well as other
related services that may be provided by the Company for an additional fee.
“Data Controller” — Our Company determines the purposes and means of the processing of
processing activities.
“Data Processor” — means a natural person or legal entity, which processes Personal Data on
behalf of the Controller, specified in this Privacy Policy.
“User” — the individual using the Application, who has passed the Registration and who, unless
otherwise specified, coincides with the Data Subject (also referred to as “You”, “Your”).
“Third-Party” — a legal person, public authority, agency, or a natural person that under the direct
authority of the Data Controller or Data Processor, is authorized to process Personal Data and/or
Automatically-collected information.
“Processing” - any operation or set of operations that is performed on Personal Data or sets of
Personal Data.
“European Union”, “EU” — unless otherwise specified, all references made within this document
to the European Union include all current member states of the European Union and the European
Economic Area.
“California Consumer Privacy Act” — is a state statute intended to enhance privacy rights and
consumer protection for residents of California, United States (hereinafer — "CCPA"). The full text
“General Data Protection Regulation” — is a regulation of the European Union by which the
European Parliament strengthens and unifies the protection of Personal Data of all persons in the
European Union (hereinafer — “GDPR”). The full text of GDPR is available at https://eur-
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3. Contact Details of the Data Controller
Name of the legal person: Private Entrepreneur Shambalova Olha Mykhailivna.
Legal address: Ukraine, Odesa, Balkivska street, house 40.
DPO is absent.
4. Information We сollect
We collect information directly from Users when they register online and provide Us with the
Personal Data, as well as We collect information automatically when You browse Our Application
or Website.
We also collect information from the User’s Google personal account or Facebook account, but
only if the User registered and/or logged in to the Application via the mentioned services. We
We draw Your attention to the fact that third-party services such as YouTube, Instagram,
Facebook, Google and other websites and/or applications, links to which are available in the
Application, may collect various types of information about You, including cookies. Please read
the privacy policies of third-party services before using them. The Company does not store
information collected about You by these third-party services and/or websites.
4.1. Personal Data
4.1.1. Personal Information You Provide to Us
We collect Personal Data You provide to Us only when You register an Account through tTravel and
with Your consent, the rest of the Data that We collect is the Usage Data.
The following is what We usually collect:
-
email;
-
password;
-
Information contained in Your Google and/or Facebook profile if You signed via Google
(such as email address or other Personal Information that is collected in accordance with
the settings of the services).
Personal Data mentioned above requested by the Company is mandatory, and failure to provide it
may make it impossible for the Company to provide the Services.
You may provide the following Personal Information at Your discretion:
-
Your first name and last name;
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-
Your photo for the main page of the User Account;
-
payment details;
-
links to the User's accounts on Facebook, YouTube, and/or Instagram.
In cases where the Application specifically states that some Personal Data is not mandatory, Users
are free to choose not to share this information without limitation of the functionality of the
Application.
4.1.2. Personal Data Collected Automatically
Some Personal Data is automatically collected when You use Our Services, such as the following:
-
IP address;
-
general location information;
-
device identifiers.
4.2. Automatically-collected Information
Apart from Personal Data, We also collect particular information about You automatically, in an
aggregated way. We collect Usage Data directly when Users browse Our Website and/or
Application. Usage Data helps Us to customize the Website and Application. Receiving the Usage
Data We can improve the Services performance.
We collect the following Usage Data when Users access or use Our Website:
-
browser type;
-
browser version;
-
type of device You are using;
-
language;
-
the pages of Our Website that You visit;
-
the time and date of Your visit;
-
the time spent on those pages;
-
other diagnostic data.
We collect the following Usage Data when Users access or use Our Application:
-
type of device You are using;
-
language;
-
the pages of Our Application that You visit;
-
the time and date of Your visit;
-
the time spent on those pages;
-
other diagnostic data.
4.3. Cookies
The Website can create objects and store them on the User's device.
We generally collect 3 types of Cookies.
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4.3.1. Types of Cookies:
a) Session Cookies: We use Session Cookies to operate Our Website.
A Session Cookie contains information that is stored in a temporary memory location and then
subsequently deleted afer the session is completed or the web browser is closed. These Cookies
store information that the User has inputted and track the movements of the User within the
Website and/or Application.The storage period of data obtained through the Session Cookies
—
User session period.
b) Stored Cookies: provide convenient and rapid access to familiar objects, which enhances
the User experience.
A Stored Cookie is a data file capable of providing Websites with User preferences, settings, and
information for future visits. The storage period of data obtained through the Stored Cookies — 6
(six) calendar months.
c) Third-party Cookies: We use Third-party Cookies for tracking and online-advertising
purposes.
Third-party Cookies are stored under a different domain than User visits by the Third-Party
(YouTube, Google, Facebook, etc.). They are mostly used to track Users between websites and
display more relevant ads. The storage period of data obtained through the Third-party Cookies —
time period set by relevant Third-Party.
4.3.2. Manage of Cookies
You can manage Cookies as You wish. For details, we highly recommend to use the following
You can delete all Cookies that are already on Your device by clearing the browsing history of Your
browser. This will remove all Cookies from all websites You have visited.
You can set Your browser to prevent any Cookies being placed on Your device, but You may then
have to manually adjust some preferences every time You visit the Website and/or Application.
The legal basis for collecting Сookies is Your consent to the use of Cookies on the basis of a
notice displayed on Our Websites. The legality of this data Processing is governed by Art. 6 (1) (a)
European Commission’s General Data Protection Regulation
5. The Legal Basis and Purpose
5.1. The Legal Basis for Data Processing
The lawful basis for the Processing of Your Personal Information will depend on the purposes for
which We process Your information.
A full list of the legal grounds for Processing is specified in Article 6 of GDPR. The legal basis for
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Processing includes consent, contractual necessity, and Our legitimate interests or the legitimate
interest of others, as further described below.
The legal grounds for Our Processing of Your Personal Data are as follows:
-
We process Personal Data based on the consent You expressly grant to us at the time we
collect such Personal Data. You grant consent to the Processing of Your Personal Data at
the time of registration in the Application or use of the Website.
-
We may need to process Your Personal Data to comply with a legal obligation if it is
necessary to protect the vital interests of You or other Data Subjects;
-
To the extent that You have given Us Your permission, We will use Personal Data to provide
You with information about Our Services;
-
For the purposes of legitimate interests pursued by the Data Controller that specified in
par.5.2. of this Privacy Policy;
-
Where this is necessary for the performance of a License Agreement or other contract with
You, or in order to take steps at Your request before entering into a contract with You.
You can object to Processing carried out on the basis of Our legitimate interests at any time by
contacting Us via email referred to in par.3 of this Privacy Policy.
5.2. Purposes of the Personal Data and Usage Data Processing
5.2.1. Why We Process Personal Information
Generally, We use Your Personal Data in order to give You access to the Application and Our
Services. We use Personal Information that We collect for the following purposes:
a) Providing use of the Application and the Website Support
To provide and operate Our Application, Our Website, communicate with You about Your use of
the Application and the Website. We need Your Personal Data to Process, manage, complete
transactions, create and manage Accounts You establish.
b) Responding to Your requests
If We receive Your request, We will reach You within 30 (thirty) days, but We try to respond as soon
as it is practically possible
We want to communicate with You about upcoming features, updates,
and news regarding the Application.
c) To Protect Our Legal Rights
To protect the Application, the Website, and Our business operations. For security and fraud
prevention and to ensure that Our Website and Application are safe, secure, and used in line with
Our Terms and Conditions.
d) To Generate Marketing Analytics
Sometimes for statistical purposes, such as analyzing the performance of Our Website, Application
and to understand how the Users use them.
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5.2.2. Why We Process Usage Data
a) Analytics and Research
Usage Data can be used to establish anonymized statistics about the User experience on Our
Website and/or Application. We or Our Third Parties use Usage Data to determine and measure the
performance of ads and to learn whether You have interacted with Ours and Users' Content.
b) Providing Technical Support
We may use Usage Data to, among other things, help diagnose problems with Our Website and/or
Application, analyze trends, resolve bugs and gather information for aggregate use.
c) To Provide You the Relevant Advertising
Usage Data helps Us to show You relevant advertising, measure the performance of such ads, and
report on it. Similarly, the Third Parties may use Usage Data to determine how ads performed or
provide Us with information about how You interact with ads.
6. How We Process Your Data
6.1. Broader Protection Standards
The Usage and Personal Data are processed at the Controller's operating offices and in any other
places where the parties involved in the processing are located.
While most provisions of this Privacy Policy concern all Users, some provisions expressly apply
only if the Processing of Personal Data is subject to broader protection standards.
Such broader protection standards apply when the Processing:
-
US residents are subject to federal laws on privacy and Children Online Privacy Protection
Act. Residents of California State are also subject to California Consumer Privacy Act;
-
EU residents are subject to General Data Protection Regulation and EU-US Privacy Shield.
All other worldwide Users (third countries) are subject to its domestic Data protection legislation.
6.2. How We Process and Where We Store
As a rule, We use Our database and Amazon Web Services (AWS) provided by Amazon Web
Services, Inc. in order to store Personal Data and Usage Data. Amazon Web Services provides its
services in compliance with General Data
Protection Regulation.
You
can find
Amazon Web
Services’ Privacy
Notice
But We can change the provider of database services at any time without additional notification of
Users.
Usage Data also is collected and stored by third-party servers, namely Google Analytics.
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Google Analytics (Google LLC). Google Analytics is a web analysis service provided by Google LLC
(“Google”). Google utilizes the data collected to track and examine the use of the Website, to
prepare reports on its activities, and to share them with other Google services. Google may use the
Data collected to contextualize and personalize the ads of its advertising network (Usage Data
hl=en . Google Analytics may also place Cookies on Your device.
6.3. Third-Party Disclosure
We do not sell Your Personal Data or transfer it for any other commercial purpose to third parties.
But if necessary, We may share Personal Information with the following categories of Third Parties:
-
Other Users of the Application who can see Your Personal Information in the Application
(in particular but not limited by name and photo).
-
Our accountants, lawyers, or similar advisers when We ask them to provide Us with
professional advice.
-
The Third-party provider(s) provide the following types of services to us: Website hosting,
support, and maintenance of the Website and/or Application.
-
Government and/or regulatory authorities for the purposes of doing what a court,
regulator or government, or crime prevention agency requires Us to do.
No sale of Personal Information. In the preceding twelve months, We have not sold any Personal
Information of User, as those terms are defined under the California Consumer Privacy Act.
6.4. Payment Systems
During the payment transactions, the Company does not receive the User's payment information,
unless it is specified by the User in his Account.
To pay for the Services, the User pre-adds the details of his own bank card to third-party payment
services Apple Pay, Apple ID and/or Google Pay. Afer that, payment for the Services is made inside
the Application using the specified payment services. We kindly recommend You to read the
To receive remuneration for the sale of travel diaries, the User shall provide Us the payment
details in the "My information" section of the Account. The User must specify:
-
User's IBAN;
-
full last name, name and patronymic of the bank account holder;
-
individual tax number of the bank account holder.
We do not sell or transfer Your payment details (except for paying taxes and filing reports with
government authorities). Your bank details are stored at the Controller's operating offices and
database.
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6.5. Links to Other Websites
Our Service may contain links, ads to other sites that are not operated by Us. The Company has no
control over and assumes no responsibility for, the content, privacy policies, or practices of any
third-party websites or services.
7. Terms of Data Storage
We keep Your Personal Information for no longer than is necessary for the purposes for which the
personal information is collected. Otherwise, We securely erase Personal Data once it is no longer
needed.
In case of deletion of an Account, the User will no longer have access to all of the Account Content.
In the event Your account is deleted, the Company deletes Your Personal Data within 6 (six)
months. In case Your Account is inactive (the absence of any use of the Account) for more than 1
(one) year, We will delete Your Account and all its Content.
Usage Data shall be processed and stored for as long as required by the purpose they have been
collected for, but not more than 2 (two) years from the date of collection, unless otherwise derived
from the purpose of Data Processing.
8. Users' Rights
This section explains Your rights concerning Your Personal Information. These rights are not
absolute and can be subject to certain exceptions.
a)
The Right to Be Informed: You have the right to be provided with clear, transparent, and
easily understandable information about how We use Your Personal Information and
Usage Data. This Privacy Policy describes what data of Users is being collected, how it’s
being used, how long it will be kept, and whether it will be shared with any third parties.
b)
The Right to Access Your Personal Data: You have the right to request Us to provide You
with information that We have about You. To ask whether We hold Personal Information
about the User and request copies of such Personal Information and information about
how it is processed.
c)
The Right of Rectification. You are entitled to have Your Personal Information corrected if
it is inaccurate or incomplete.
d)
The Right to Request Deletion of Personal Information that is no longer necessary for
the purposes underlying the Processing.
e)
The Right to Object to the Processing of Personal Information. It means that You can stop
or prevent the Company from using Your Personal Data.
f)
The Right to Request Personal Data: We can provide You with the information We
maintain about You. Generally, this will be within 30 (thirty) days from when We receive Your
request, but if the request is going to take longer to process, We will come back to You and
let you know.
g)
The Right To Lodge a complaint with Us regarding Our practices related to Your Personal
Information.
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h) The Right to Be Forgotten: A User can withdraw personal consent in case of outweighing
Our legitimate interest in continuing the Processing. Within 30 (thirty) days of Your request
for deletion of Personal Information, the Company deletes all information it possesses
about You. If You have any questions, please contact Us at:
9. How Do We Protect Your Personal Information
The security and confidentiality of Your Personal Information are extremely important to Us. The
Company takes appropriate security measures to prevent unauthorized access, disclosure,
modification, or unauthorized destruction of the Personal Data.
We have technical, administrative, and physical security measures in place to:
-
secure Our IT systems, databases and safeguard the Personal Information,
-
protect Your Personal Information from unauthorized access, and
-
follow organizational procedures and modes strictly related to the purposes indicated.
10. Change of Data Controller
We have the right to purchase, sell or transfer Our Company. Your Personal Information, such as
email address, Your first name, and last name, and other User information will likely be among the
items transferred in these types of transactions. We will do Our best to guarantee the same level of
security as We provide to Ourselves.
11. Personal Data Concerning Children
Our Website and Application were developed for individuals who are 18 years and above,
otherwise, We request a parental / guardian express consent for User to continue using Our
Website and Application or by writing to Us via Our e-mails. If Your country of residence has other
minimum age requirements for using the Website and Application, please follow Your country’s
laws.
12. Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of Ukraine and
EU Regulation No 2016/678 of 26.04.2016.
All disputes which may arise while using Our Website and/or Application shall be resolved by the
negotiations between the User and Controller via official email.
All disputes arising out of or in connection with this Privacy Policy shall be finally settled by
arbitration according to the Rules of Arbitration of the Commercial Arbitration Center of the
Ukraine Chamber of Commerce and Industry (Commercial Arbitration Center), by one or more
arbitrator(s) appointed in accordance with the Arbitration Rules. The language of the
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arbitration shall be English. The place of arbitration shall be Kyiv.
13. Warranty
All information and materials provided on this Website and/or Application are "as-is" without
warranty of any kind, either expressed or implied. The Company disclaims all warranties,
expressed or implied, including, without limitation, those of merchantability, fitness for a
particular purpose.
In no event shall Company be liable for any direct, special, incidental, indirect, or
consequential damages or any damages arising out of the use or inability to use the
information or materials on Website and/or Application. No data transmission or storage system can
be guaranteed to be 100% secure. As a result, while We strive to protect Your Personal Data, We cannot
ensure or warrant the security of any information You transmit to Us, and You use the Application and
provide Us with Your information at Your own risk.
14. Change to This Privacy Policy
Our Company reserves the right in its sole discretion, to modify or update this Privacy Policy from
time to time. Please check this page regularly for updates. When We change the Privacy Policy in a
material manner, We will update the “last modified” date at the beginning of this page.
15. Contact Us
For further information regarding Your rights, this Privacy Policy, or to make a complaint please
contact Us:
-
Your question will be responded to within 30 (thirty) days.
This Privacy Policy relates solely to the Application and Website, if not stated otherwise
within this document.
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