Last updated on October 1st, 2020
travlerz.com (“Travlerz”, “we” or “us”) is an online magazine provided to you by Kueez Entertainment Ltd (the “Services”).
We respect the privacy of our readers (“you” or “your”) and are strongly committed to making our practices regarding your personal data more transparent and fairer.
1. Data Collection
2. Data Uses
3. Data Location and Retention
4. Data Sharing
5. Cookies and Tracking Technologies
7. Security Measures
8. Data Subjects Rights
9. Children’s Privacy
10. Data Controller/Processor
11. Additional Notices
1. Data CollectionWe collect two main types of personal data – i.e. data which may relate to an identified or identifiable individual:
- Data Automatically Collected or Generated: When you visit, interact with or use our Services, we may collect or generate technical data about you. We collect or generate such data either independently or with the help of Service Providers (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as detailed in Section 5 below).
Such data mainly consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) in connection with the Services. Such data does not enable us to learn about a person's true identity or contact details, but mostly to gain a better understanding on how people typically use our Services and how we can improve them. The use of such technical data also helps us and our Service Providers (as detailed in Section 5 below) to deliver contextual or otherwise more effective advertisements and content, to optimize our ad management and our readers’ viewing experience, and to improve the overall user experience and functionality of our Services.
- Data Received from you: You may provide us with personal data voluntarily, such as your name, e-mail address and your location when you contact us. The Services are not intended to serve as a platform for collection of sensitive information, and we urge you not to share any such sensitive data when communicating with us. If you still choose to provide us with sensitive data, we may remove it from our records at any time without notice
2. Data UsesWe use personal data as necessary for the performance and provision of our Services; for complying with applicable law; and to support our legitimate interests in maintaining and improving our Services, understanding how our Services are used, optimizing our marketing and advertising efforts and serving advertisements on our Services, improving our support operations, as well as protecting and securing our readers, ourselves and our Services.
If you reside or are using the Services (i) in a territory governed by privacy laws which determine that "consent" is the only legal basis for the processing of personal data (in general, or specifically with respect to the types of personal data you choose to share via the Services) or (ii) in the EEA and provide us with personal data, the processing of which requires “consent” under applicable law (e.g. ‘special categories’ under the GDPR), your acceptance of our Terms of Service and of this Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at firstname.lastname@example.org
Specifically, we use personal data for the following purposes:
- To facilitate, operate, and provide our Services;
- To further develop, customize and improve our services and general user experience, based on common or personal preferences, experiences and difficulties;
- To create audience-related insights for optimizing marketing campaigns;
- To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners and advertisers (see Section 5 below), including for re-targeting purposes;
- To provide you with assistance and support;
- To contact you with general or personalized messages and communications, as further described in Section 6 below;
- To facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our affiliates or Service Providers may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
3. Data Retention and LocationData Location: Your personal data may be maintained, processed and stored by“Travlerz”, our affiliates and Service Providers (as defined in Section 4 below) in the United States and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
“Travlerz” is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the personal data of EU Member State residents.
While privacy laws may vary between jurisdictions, “Travlerz” has taken reasonable steps to ensure that your personal data is treated by our affiliates and Service Providers (as further defined below) in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
Data Retention: We may retain your personal data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use).
- Legal Compliance: We may disclose or allow government and law enforcement officials access to certain personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Service Providers and Advertisers: We may engage selected third party, business partners, companies and individuals to perform services complementary to our own (such as hosting and content delivery services, data analytics services, e-mail distribution and monitoring services, and our business, legal, financial and compliance advisors), or to serve advertisements via our Services (collectively - “Service Providers”). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating our Services, and may only use it for such purposes.
- Protecting Rights and Safety: We may share your personal data with others, if we believe in good faith that this will help protect the rights, property or personal safety of “Travlerz”, or such rights and safety of our readers (including yourself) or any members of the general public.
- Change of Control or Ownership: Should “Travlerz” any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of any or substantially all of its assets, your personal data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or a prominent notice on our Services.
- Further Sharing of personal data: For the avoidance of doubt, we may share your personal data in additional manners, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may also disclose your personal data upon your explicit consent. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies and Tracking TechnologiesOur Services and some of our Service Providers utilize “cookies”, anonymous identifiers, pixels and other tracking technologies which help us provide, secure and improve our Services, personalize your experience, serve advertisements and monitor the performance of our Services.
A cookie is a small text file that is placed, for example, to collect data about activity on our Services. Some cookies and other similar technologies serve to recall personal data, such as an IP address, that was previously indicated by the person using our Services.
6. CommunicationsIf you have provided us with your e-mail address, for example whilst signing-up to our newsletter or updates, we may use it to send you our newsletter and other service or promotional communications.
If you wish not to receive such messages, you may notify us at any time by contacting us by filling out the electronic form below, or by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions in the communications you receive.
8. Data Subject RightsIf you wish to exercise your rights under any applicable law, including the GDPR or the CCPA, such as the right to request access to, rectification or erasure of your personal data held with “Travlerz”, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at email@example.com.
To opt-out of the sale of your personal data, please visit https://travlerz.com/ccpa.
9. Children’s PrivacyOur Services are directed towards and designed for use by persons aged 16 and older. We do not solicit or knowingly collect personal data from children under the age of 16 nor do we provide any Services to children. If we nevertheless receive personal data from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 16 we will delete such information from our database.
10. Data Controller/Data ProcessorCertain data protection laws and regulations such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA the “business”) who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA the “service provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Where our Service Providers only process personal data on Travlerz’s behalf, they will be deemed as “Data Processors”. However, on certain occasions, i.e. when personal data is being shared with our advertisers, as listed in Section 5 above, such advertiser shall be deemed as the “Data Controller” of your personal data and will process such data as an independent “Data Controller”. The advertiser will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
11. Additional NoticesLinks to Third Party Sites: The Services may contain links to other sites or services. While we try to link only to sites that share our respect for privacy, please be aware that Travlerz is not responsible for the privacy practices or the content of other sites (including our Service Providers). Domains that are accessible by hyperlinks from the Services may use “cookies.” (see under Section 5 above). We encourage you to read the privacy statements provided by other sites and Service Providers.
DPO: Travlerz’s operator, Kueez Entertainment Ltd., has appointed the privacy experts of PrivacyTeam as our Data Protection Officer, for monitoring and advising on our ongoing privacy compliance efforts, and serving as a point of contact on privacy matters for data subjects and supervisory authorities. PrivacyTeam may be reached at firstname.lastname@example.org.
EU Representative: Kueez Entertainment Ltd. has designated Dr. Andreas Mätzler as its representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. Inquiries regarding Travlerz’s EU privacy practices may be sent to Dr. Mätzler at Schellinggasse 3/10, Vienna 1010, Austria, or by e-mail to email@example.com (please add the following subject to all correspondences: 14102729). If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
Effective Date: October 1st , 2020