Travala Privacy Policy

Last Updated: 7 March 2024

Travala Pte Ltd, a company incorporated in Singapore (hereinafter referred to as “Travala”, “we” or “us”) recognises the importance of privacy. In this privacy policy, we describe how we collect, use, and disclose information that we obtain about visitors to our website, www.travala.com, and the services available through our website.

1. Information we collect.

We collect personal information directly from you, from third parties, and automatically through your use of our website. We may combine information automatically collected with other information that we have collected about you. Where applicable, we may also collect “Anonymous Data” from you which means data, including aggregated and de-identified data, that is not associated with or linked to your personal information. Anonymous Data does not, by itself, permit the identification of individual persons.

Personal information means any information that can be used to identify you.

We are the Data Controller for data collected through our website.

If you are in the EU or the UK, the lawful basis when we process your personal information for the provision of our services is pursuant to a contract.

If you are in the EU or the UK, the lawful basis when we process your personal information for marketing is consent.

You may browse and use certain portions of our website without directly providing us with any personal information.

Certain features, however, may only be used by users that are registered or where you provide us with personal information.

Information we collect from you (or someone acting for you):

• contact information, including your name, address, email address, telephone number and other contact details;
• billing or payment information, such as your credit card number, cardholder name, expiration date, authentication code and billing address;
• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• information you provide to us through customer surveys or feedback;
• passport information, including your passport number, passport expiration date, and date of birth
• loyalty program details (such as frequent flyer details);
• information about your health (if disclosed);
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the Website, ad data, IP address and standard web log information;
• any additional information relating to you that you provide to us through your use of our website, in person or through other websites or accounts from which you permit us to collect information;
• any other personal information that may be required in order to facilitate your dealings with us.

Information about you we collect from third parties.

We may receive personal information and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with the use of our website or whose products and/or services may be linked to the services on our website. For example, including and not limited to, information in relation to you from flight carriers, hotel/property operators, travel membership/loyalty program providers, property management service providers and/or activity service providers for the performance of any contract or verification/confirmation purposes, third-party wallet providers that may provide us with your blockchain address, or payment service providers or payment wallet providers who may provide us with your debit/credit card details for payment verification/confirmation and other information you choose to share with those wallets providers. We may add this to the data we have already collected from you to provide the services on our website.

If you apply to work with us, we collect information from you from:

• recruitment consultants;
• your previous employers; and
• other organisations that are authorised to give us information about you

to assist us in deciding the outcome of your application.

Information we collect automatically. We automatically collect information through your use of our website using cookies and other technologies. This information includes your

• domain name, operating system, settings and system configurations,
• IP address,
• the webpages you access within our website,
• the website that led you to our website,
• the website to which you go after leaving our website;
• the dates and times you access our website, and
• web log personal information.

Public information we may record. We may collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.

2. How we use your information.

We use your information for the following purposes:

• Providing our services. Provide accommodation, flights, and experiences booking services on the website, to manage your account, to communicate with you, including via email, about your use of our services, to respond to your inquires, and for similar customer service purposes.
• Marketing. Where you consent, we will provide you with news, special offers, promotions, and information about products we think may interest you; and for other marketing, advertising, and promotional purposes provided that you have not opted-out of receiving such communications.
• Analysing Use of Our Services. To better understand how users access and use our website and services, on an aggregated basis; to respond to user desires and preferences; to improve our website navigation and its service; and for other research and analytical purposes. In addition, we may create Anonymous Data records derived from personal information provided for the aforesaid purposes. We reserve the right to use Anonymous Data for any lawful purpose and to disclose Anonymous Data to third parties lawfully.
• To Protect Rights and Interests. To protect our rights and interests, as well as the rights and interests of our customers, users of our website or services, and any other person.

3. Marketing.

Travala would like to send you information about our products and services that we think you might like. If you have agreed to receive marketing communications, you may always opt out at a later date. You have the right at any time to stop us from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please click the ‘Unsubscribe’ button contained in the footer of each of our emails or contact us at [email protected].

4. How we store your personal information.

We undertake a number of physical, administrative, personnel, and technical measures to protect your personal information and prevent it from misuse, interference and loss, as well as unauthorised access, modification or disclosure. Our data security measures include, but are not limited to: Secure Sockets Layer (SSL) encryption technology, pseudonymisation, internal data access restrictions, and strict physical access controls to buildings & files.

Travala will keep your personal information for the duration that your account is active, and for the requisite period in accordance with applicable law following the deactivation of your account. Once this time period has expired, we will delete your personal information.

5. Security

We take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. For example, we take steps to destroy or permanently de-identify personal information if we no longer need it for any purpose. Please be aware that despite our efforts, no personal information security measures can guarantee 100% security.

If you have an account with us, you should take steps to protect against unauthorised access to your account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorised password activity.

6. How we disclose your information.

We may disclose your information, including personal information, with the following entities:

• Our Group of Companies and Employees. We disclose your required information to our employees, subsidiary, related and/or affiliated companies in order to perform the necessary duties to provide you with our services.
• Service Providers. We disclose your information to our vendors, service providers, or others who perform functions on our behalf. All service providers are required to keep your personal data safe, and process pursuant to a data processing agreement. If the service provider is located outside of the UK or the EU, we put in place measures to ensure that your information has the same level of protection.

We may also disclose your information, including personal information, in the following ways:

• Business Transfers. We may disclose your information to another entity if we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of a similar business transfer.
• Protecting Rights and Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this privacy policy, or as evidence in litigation in which we are involved.
• Cross Border Disclosure of Information. We may disclose your personal information to international third parties, including countries outside the European Economic Area (EEA) (collectively “Cross-border Disclosure”), generally to arrange travel with a travel service provider on your behalf. Whenever we perform Cross-border Disclosures, we will do so in accordance with applicable law and ensure that a similar degree of protection is afforded to it by implementing appropriate safeguards. Cross-border Disclosures outside the EEA will only be made:
  • i. to a country recognised by the European Commission as providing an adequate level of protection; or
  • ii. to a country which does not offer adequate protection, but whose transfer has been governed by the standard contractual clauses of the European Commission, or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

7. Cookies and other tracking mechanisms.

We and our service providers use cookies and other tracking mechanisms to track your use of our website or services. We use these in a range of ways including:

• Keeping you signed in;
• Understanding how you use our website;
• Functionality - Travala uses tracking mechanisms so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer, the currency in which prices are displayed, and the location you are in. A mix of first-party and third-party tracking mechanisms are used; and
• Advertising - Travala uses these tracking mechanisms to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Travala shares some limited aspects of this personal information with third parties for advertising purposes. We also share personal information collected through tracking mechanisms with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

Types of tracking mechanism we use:

• Cookies. We or our service providers use cookies to track visitor activity on our website. A cookie is a text file that a website transfers to your computer's hard drive for record-keeping purposes. We or our service providers may use cookies to track user activities on our website, such as the pages visited and time spent on our website. Most browsers allow users to refuse cookies. The ‘Help’ portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Users who disable cookies may not be able to browse certain areas of the website. Please refer to our Cookie Policy for further information in regards to Cookies used on our website; and
• Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our website to track the activities of visitors to our website, help us manage content, and compile statistics about usage of our website. We or our service providers also use clear GIFs in HTML emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

8. Third-party analytics.

We use service providers, such as Google Analytics demographics and interests reports as well as advertising reporting features, to evaluate the use of our website and our services. We or our service providers use automated devices and applications to evaluate the use of our website and services. We or our service providers use these tools to help us improve our website, services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or Flash LSO, to perform their services. To opt out of Google Analytics, go here. To opt out of Google Analytics for display advertising or customise Google display network ads, you can visit the Google Ads Settings page.

9. Interest-based advertising.

We use third parties such as network advertisers to serve advertisements on our website and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (\"DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (\"NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our website. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.

10. User-generated content.

Note that if you post information in a publicly accessible portion of our website or service, it may be viewed by other users and potentially be further disclosed by those users. Please exercise caution when deciding to disclose such information.

11. Your choices.

We take steps to ensure the personal information that Travala collects, uses or discloses is accurate, complete and up to date.

You may modify your personal information by updating your account on our website or by contacting us at [email protected]. On request, we will give you access to the personal information we hold about you. If any personal information we hold about you is out of date or inaccurate, we encourage you to let us know by contacting us using one of the methods listed above and ask us to correct it.

If you are a registered user, we may send periodic informational emails to you. You may opt out of such communications at any time by following the opt-out instructions contained in the email. Please note that it may take up to five business days for us to process opt-out requests.

If you opt out of receiving emails about recommendations or other information we think may interest you, we will still send you emails about your account or any services you have requested or received from us provided that you have not opted-out of receiving such emails.

12. Your Rights.

In compliance with applicable personal data protection laws, you may have some / all of the following rights:

• Right to access – the right to request access to the personal data we hold about you. We may charge you a fee to cover the cost of processing and fulfilling this request.
• Right to rectification – the right to request the correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure – the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent to our processing of your data.
• Right to restrict processing – the right to request that we restrict the processing of your personal data, under certain conditions.
• Right to personal data portability – the right to request that we transfer the personal data you have provided to us to another organisation where technically feasible, or directly to you, under certain conditions.
• Right to object to processing – the right to object to our processing of your personal data, under certain conditions.
• Right to withdraw consent – where our processing is based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

If you would like to exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month of receiving it. In some cases, we may need to extend this period by an additional two months if the request is complex or numerous. If an extension is necessary, we will inform you within one month of receiving your request and explain the reasons for the delay.

Notwithstanding the above, please be aware that we cannot edit or delete any personal information that is stored on a blockchain, as we do not have custody or control over any blockchains. The information stored on the blockchain may include (but is not limited to) purchases, sales, and transfers related to your blockchain address and/or any metadata that may be attributable to you that can be viewed on the blockchain, such as when you complete or accept a booking on our website, or when you interact with any of our blockchain-based products, including but not limited to the Open Passport NFT.

13. Children.

Our website is not targeted to children under 13 years of age and we do not knowingly collect personal information from children under 13 without parental consent.

If we discover that the personal information of a child under 13 of age is in the system without parental consent, we will promptly delete such personal information from our systems.

We encourage children of all ages to obtain their parent's or guardian's permission before sharing personal information with any website.

14. External links

This website contains links to other websites. We are not responsible for the information handling practices or content of these external websites. Please read the privacy policies of these third parties before using such websites.

15. Third-party payment processors and wallets

In order to use the services offered on our website, you may opt to use payment options which utilize a third party payment processor or a third-party wallet which allows you to engage in transactions on public blockchains. Your interactions with any third-party payment processor or wallet provider are governed by the applicable terms of service and privacy policy of that third party.

16. Contact us

If you have any questions or concerns about the privacy aspects of our website or services or want to make a complaint about an interference with your privacy by Travala, please email us at [email protected]. We will do our best to resolve your complaint as quickly as possible.

You can also contact your local data protection authority to lodge a complaint.

If you are in the EU you can find your Data Protection Authority here.

If you are in the UK you can contact the Information Commissioner’s Office here.

17. Changes to this privacy policy

We may change this privacy policy from time to time, and new versions will be posted on this website, so please check back periodically for updates.

If you are registered with us, we will let you know when we update this privacy policy.