Terms
Last update of this document: 2022-11-23
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and our system users that used the signup process of our website to access additional features.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and system users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and account services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via your Trip with Toddler account settings.
1.5 In this policy, “we”, “us” and “our” refer to Trip with Toddler or UAB Factura. For more information about us and contact details, see Section 19.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data are our analytics tracking systems such as Google Analytics, and similar analytics and tracking services. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We collect required information about you when you sign up to our website in order to provide our core service to you. These information include your name, email address and location. You can adjust these information within your account settings at any time. We may process your account data (“account data“). The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is to be able to provide our services you signed up for to you. The data collected in this step is the minimum in order to provide you with a smooth and running operation of our services.
2.4 We may process your information included in your business profile on our website (“profile data“). The profile data may include your personal name, mailing address, telephone number, email address, and any further data necessary to provide our core services. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper running and administration of our website and services.
2.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your personal data, your social media profiles and additional data, that you have entered into our system in order to use our service. The source of the service data is you, or the user that has set up the account. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is to enable the proper operation and use of our services.
2.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is to enable proper operation of the system and services.
2.7 We may process information contained in any enquiry you submit to us via email, our contact form or our support widgets and tools (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and providing relevant services and offers. The legal basis for this processing is consent.
2.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your social media details, your contact details, and information contained in communications between us and you or your company. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent.
2.9 We may process information relating to transactions, including purchases of our services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or product and special offer newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.11 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms and/or support widget tools. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Automated decision-making
3.1 We reserve the right to use your personal data for the purposes of automated decision-making in relation to automatically analyzing your usage data in order to offer better deals and services to you and improve our overall service experience.
3.2 This automated decision-making may involve any of the above mentioned data we collect on you.
3.3 The significance and possible consequences of this automated decision-making may be that we will automatically contact you via our in-app notification, email or other means of communication in order to provide you with automated offers and customer support.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies, this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose some of your personal data, such as your IP address, your Trip with Toddler account identification (account ID), your email address, your location, your browser name and/or version and your internet service provider (ISP) to our suppliers or subcontractors, such as Google, Facebook, Twitter, LinkedIn, Pinterest, Microsoft and others, insofar as reasonably necessary for tracking services and customer support services in order to improve our website and services. You can find their privacy policies and practices at: Google (https://policies.google.com/privacy); Facebook (https://www.facebook.com/about/privacy/update); Twitter (https://twitter.com/privacy); LinkedIn (https://www.linkedin.com/legal/privacy-policy); Pinterest (https://policy.pinterest.com/en/privacy-policy); Microsoft (https://privacy.microsoft.com/en-gb/privacystatement).
4.4 Financial transactions relating to our website and services are handled by our payment services providers, Stripe and PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at: Stripe (https://stripe.com/us/privacy/); PayPal (https://www.paypal.com/en/webapps/mpp/ua/privacy-full).
4.5 By using some of our functionalities and our email capabilities, we may disclose some of your personal data, including your business data, to our suppliers or subcontractors, such as Amazon Web Services and others, insofar as reasonably necessary for providing our core services. You can find their privacy policies and practices at: Amazon Web Services (https://aws.amazon.com/privacy/).
4.6 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
4.7 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We and our other group companies have offices and facilities in the United Kingdom and Lithuania. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European.
5.3 The hosting facilities for our website and services are situated in the United Kingdom, Ireland and the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. Our hosting partners privacy policy statements can be found here: Digital Ocean (https://www.digitalocean.com/legal/privacy/); Amazon Web Services (https://aws.amazon.com/privacy/).
5.4 Our payment providers are situated within the EU and in the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
All personal data about you, service providers, services in general or related data that has been stored in our system will be kept for as long as you remain a user of our service.
You can edit this data any time by logging into our system and adjusting information in the account settings or the system itself.
You can request a deletion by contacting us directly or by logging into our system and going to the account settings.
Due to safety measurements we keep backups of all our data for up to 30 days. This means that your data may still exist within our data backups for up to 30 days on our dedicated backup system at which point in time it gets deleted.
Some of your personal data, such as log files including your IP addresses and usage history may be deleted on a more frequent basis, before you cancel our service or request a deletion.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store all your personal data on secure servers, personal computers and mobile devices.
7.3 All you data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
7.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of significant changes to this policy by email or through the in-app notification system on our website.
9. Your rights
9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by logging into your account within our service. You can request a copy of your personal data by contacting us via our contact form, our support widget or email.
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured and commonly used format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 9.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 13.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. About cookies
13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
14. Cookies that we use
14.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;
(b) status – we use cookies to help us to determine if you are logged into our website;
(d) personalisation – we use cookies to store information about your preferences and to personalise our website for you;
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: Facebook, Google Adwords, Twitter, Linkedin, Pinterest);
(f) analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: Google Analytics); and
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
15. Cookies used by our service providers
15.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
15.2 We use Google Analytics to analyse the use of our website and services. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
15.3 We use the Pixel tracking and Like/Share features of Facebook, Twitter, LinkedIn and Pinterest to track website visitors and provide social integrations on our website and services. These services use cookies for tracking user behaviour and providing social integration services. You can view the privacy policy of these service providers at https://www.facebook.com/about/privacy/update; https://twitter.com/privacy; https://www.linkedin.com/legal/privacy-policy; https://policy.pinterest.com/en/privacy-policy.
16. Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Our details
17.1 This website is owned and operated by UAB Factura.
17.2 We are registered in Lithuania under registration number 305600621, and our registered office is at Svitrigailos g. 11K-109, LT-03228 Vilnius, Lithuania (EU).
17.3 You can contact us:
(a) by post, to the registered office address given above;
(b) by email, using [email protected].
18. Data protection officer
18.1 Our data protection officer’s contact details are: [email protected].