This document contains a section dedicated to California consumers and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
This Privacy Notice applies to the websites, including the online store (collectively, “Websites”), owned and operated by Monos Travel Ltd. (“Monos,” “we,” “us”). This notice describes how we may collect, use, and share personal information from visitors to our Websites (“you,” “your”). It also describes your choices regarding your personal information.
PERSONAL INFORMATION WE COLLECT
When we refer to Personal Information, we mean information that identifies or reasonably relates to a specific person or household, or that is otherwise defined as personal information or personal data under applicable laws.
Personal Information You Provide:
You may choose to provide us with your Personal Information when you engage with certain features of our Websites. For example, when you create an account, sign up for email alerts or subscribe to receive a newsletter, participate in our promotions or surveys, contact us with questions or for support, or make a purchase, you may be asked to provide us with certain Personal Information so that we may fulfill your request.
Depending on the use case, the Personal Information you provide may include your first and last name, email address, user name, and password. If you choose to make a purchase, we will collect payment card information such as your card’s payment account number and expiration date, billing address and shipping address (we refer to this as “Order Information”). We may also ask for your phone number and email address, which we use to notify you about the status of your order and send you additional updates and promotions should you opt in to receive those.
Information We Collect Automatically:
When you visit our Websites, our servers automatically collect certain information about your device, including information about your web browser, IP address, time zone, operating system of your device, language, country, and some of the cookies that are installed on your device. Additionally, as you browse the Websites, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Websites, and information about how you interact with the Websites, including how much time you spend on the Websites and the pages you visit most frequently and when. We refer to this automatically-collected information as “Usage Information.”
We analyze Usage Information to help us better understand trends about how our Websites are used, to help us improve our Websites, and to help us measure the efficacy of our advertising and marketing.
We use the following technologies to help us collect Usage Information:
“Cookies” are data files that are placed on your device or computer. Cookies store information related to your browser to allow us to recognize the browser on return visits to our Websites. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
“Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Websites and to understand what links are clicked. When we send you emails, these files also allow us to track which emails are opened.
When Usage Information is processed in a format that would be considered Personal Information, we treat it in accordance with this Privacy Notice.
THIRD PARTY COOKIES AND TRACKING
In addition, when you use the Internet, we and our third parties, as well as unaffiliated third parties, including ad networks, analytics companies, and social networking platforms, may use tracking technologies such as those described above to collect information about your online activities over time and across our and other websites. We and they may use this information to measure the effectiveness of our marketing and to serve you targeted advertisements and marketing that we believe may be of interest to you. Please note that we do not honor “do not track” signals transmitted by web browsers as there is no industry standard for implementing such programs.
For more information about third party advertisers and how to prevent them from using your information, visit the NAI’s consumer website at http://www.networkadvertising.org/choices or http://www.aboutads.info/choices/, or http://www.youronlinechoices.com/uk/. If you want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Chrome, Edge, Firefox, Safari or others) that you use on each device. Note that DNT is different than the Global Privacy Control (GPC), which we do respond to in certain territories, such as Europe and California. To find out more about GPC, please visit https://globalprivacycontrol.org/.
HOW DO WE USE YOUR PERSONAL INFORMATION?
Our purposes for processing your Personal Information are described below. We have also explained the lawful basis for that processing under applicable laws.
We generally collect, use, and disclose your Personal Information for the following reasons:
Fulfilling orders placed through the Websites (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).
Administering our Websites, including to ensure the security of our Websites, provide support, and services.
Communicating with you, including to respond to your requests, resolve a support issue, and notify you about changes to the Websites.
In the event of a reorganization, merger, sale, assignment, bankruptcy, or similar business change, in which case we may need to transfer your Personal information to a successor entity for them to use in accordance with this Privacy Notice.
Where applicable, our lawful basis for the above is fulfillment of our legitimate interests and performance of a contract. For example, the processing is necessary for us to provide you with access to our Websites, to communicate with you about issues or changes related to the Websites, to change or operate our business, and to enable us to perform our obligations and provide you with access to our Websites. These activities are reasonably expected by you and do not unduly and negatively affect your privacy rights.
Addressing our legal or regulatory obligations, including as necessary to protect our rights or the rights and safety of our users, or as necessary in the event of a court order, regulatory inquiry or other lawful request. However, unless legally prohibited, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Our legal bases for these above are to fulfill our legal obligations such as to allow us to ensure the legality of our Websites and to fulfill our legitimate interests, such as providing the Websites and protecting our legal rights. These activities are reasonably expected by you and these activities do not unduly and negatively affect your privacy rights.
When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services or request your feedback. At any time, you may unsubscribe or opt out of further communication on any electronic marketing communication by using the link labeled “unsubscribe” available in each email communication or by contacting us at [email protected].
Our legal basis for the above where required by applicable law is your consent.
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us deliver our Websites and to provide certain features on our behalf, such as data hosting, analytics, content delivery, maintenance, email and marketing management, advertising, order fulfillment, security, fraud prevention, and similar functions. These third parties may require certain information, including Personal Information, in order to provide their services.
We may also use and share aggregated demographic information that is not linked or linkable to Personal Information with these third parties.
HOW YOU MAY MODIFY YOUR PERSONAL INFORMATION
If you would like to review, correct, update or request that we delete Personal Information you have provided to us, please contact us at [email protected] and specify what you would like to review, correct, update or have deleted.
LINKS AND SOCIAL MEDIA
Our Websites contain links to third party websites, including social networking websites. The fact that we link to a website is not an endorsement or representation of an affiliation with that website. We do not control third party websites or their privacy practices. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We encourage you to read their privacy policies and the privacy policies of any websites you may visit.
We aim to protect the confidentiality, integrity and availability of your Personal Information through the use of physical, administrative, and technical safeguards. We host Personal Information in cloud-based environments that use firewalls, encryption and other industry-standard technologies in an effort to prevent interference or access from outside intruders. The Internet, however, is not perfectly secure and we are not responsible for security breaches not reasonably within our control.
We retain Personal Information for as long as is necessary to provide you with access to our Websites or as long as is permissible under applicable law, including as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, comply with applicable industry standards, and protect the security of our Websites
When you place an order through the Website, we will maintain your Order Information for our records unless and until you ask us to delete this information. You may request deletion of your Order Information by contacting us at [email protected].
We may send you emails with information about our products that we believe may be of interest. You may opt out of receiving these email messages from us by clicking on the “unsubscribe” link found at the bottom of every email that we send, or by contacting us at [email protected].
NOTICE FOR CALIFORNIA RESIDENTS
California residents have certain rights with respect to their Personal Information, as described below. Before we may fulfill your requests, we are required by law to verify your identity in order to prevent unauthorized access to your data. In order to do this, we may ask you to verify certain information previously provided by you, request that you log into your account if you have created one, or request that you provide other information.
Right to Know and Access Personal Information: You may request to access Personal Information we maintain about you using the methods provided below. If we are able to grant your request, we will provide you with a copy of the Personal Information we maintain about you in the ordinary course of business. However, we may not fulfill some or all of your request for access as permitted by applicable law.
Right to Deletion of Personal Information: You may request that we delete your Personal Information. Depending on the scope of your request, we may not be able to fulfill it in the entirety, as permitted by applicable law. For example, we may be legally required to retain your Personal Information in our business records. You may submit a deletion request using the methods provided below.
Right to Opt Out of “Sale” or “Sharing” of Personal Information: You may opt out of what California law considers to be the “sale” of your Personal Information. For our Websites, this typically means transfer of your Personal Information to certain third parties for their or for others’ commercial purposes, including advertising and marketing purposes. You may opt out of this practice by clicking on the “Do Not Sell My Personal Information” link available on the footer of our Websites and follow the instructions.
Authorized Agent: California residents may use an authorized agent to exercise a privacy right on their behalf. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their device to exercise these rights digitally. Please contact us using the contact information below with supporting verification information, which includes a valid Power of Attorney in the State of California, proof that you have access to the consumer’s interface, and proof of your own identify.
To Exercise Your Rights
Please note that your exercise of the above rights is subject to certain exemptions to safeguard the public interest (for example, to prevent or detect crime) and our interests (for example, our ability to maintain legal privilege). We will try to comply with your request as soon as reasonably practicable, in compliance with time frames set forth in applicable laws. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and of any reasons why we are unable to fulfill your request.
Categories of Personal Information We Collect:
Online identifier, Internet Protocol address;
Personal information including your name, email address, phone number, account name, mailing address, billing address, and credit card number if provided, under subdivision (e) of California Business and Professions Code Section 1798.80;
Commercial information, including records of products purchased, obtained, or considered, or other purchasing or consuming history tendencies;
Internet or other electronic network activity information related to your use of our Websites and interactions with our advertisements;
Inferences drawn from the information we have collected to create a profile reflecting your preferences;
Categories of sources from which the Personal Information is collected:
We collect the Personal Information directly from you including during the time you spend on the Websites.
Business or commercial purpose for collecting or selling Personal Information. We collect your Personal Information to operate the Websites, respond to your requests and for the following business purposes:
Maintaining or servicing the Websites and providing customer service;
Auditing purchase transactions;
Preventing, detecting and responding to security incidents, malicious, deceptive, fraudulent, or illegal activity;
Debugging to identify and repair errors that impair existing intended functionality;
Sending you marketing communications;
Inferences drawn from your use of our Websites are used by us and our third parties to support our marketing and remarketing efforts, and by third parties for their or others commercial interests, including to enable interest-based advertising.
Categories of third parties with whom we share Personal Information:
We may share your Personal Information – specifically your IP address, device ID or similar online identifier, with certain third parties, such as social networks and advertising networks. This information may be used to inform the advertising you see after you’ve visited our Websites.
We may also share your Personal Information with our advisors, including lawyers, accountants, and other professionals for our lawful business purposes.
Specific pieces of Personal Information we have collected:
If you chose to provide it, we will have collected your first and last name, email address, phone number, mailing address, billing address, account name and password, and credit card number;
Internet Protocol address, device ID.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our Websites;
Products purchased and considered.
California “Shine the Light” Rights
If you are a resident of California, you may request certain information regarding our disclosure of Personal Information for marketing purposes. To make such a request, please contact us at [email protected].
ADDITIONAL INFORMATION FOR USERS FROM THE EUROPEAN UNION, UNITED KINGDOM, AND EEA
If you are located outside of the United States, please be aware that your information will be transferred to, processed, and stored in the United States and Canada.
When you access our Websites, we function as a “data controller” under the General Data Protection Regulation (“GDPR”). In some cases, we will ask for your consent so that we may process your Personal Information. In other circumstances, we may rely on a different lawful basis, as explained in the section, “How we Use and Disclose Your Personal Information.”
By submitting your Personal Information, you acknowledge that we may transfer, process and store your Personal Information as described in this Privacy Notice. Wherever the information is, it will be treated in accordance with applicable privacy laws of the Canada. These laws may be different from the privacy laws in your country. However, this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure of your Personal Information. Where required, we will implement Standard Contractual Clauses with our third parties or rely on such other transfer mechanism to ensure that the transfer of your Personal Information outside of the European Union, United Kingdom or the EEA is lawful. You may request details of the transfer mechanisms that we rely on to transfer Personal Information outside of the European Union, United Kingdom or EEA by emailing us at [email protected].
Additional Data Rights
Please note that the rules in your country may provide you with additional rights or may limit these rights. In all cases, we will respect your rights and respond to your rights requests in compliance with applicable laws.
For example, if you are based in the European Union, United Kingdom, or EEA, you may have the right to access, update or correct your Personal Information, request deletion of your Personal Information, object to certain processing, including that related to marketing, receive a machine-readable copy of your Personal Information that you provided to us, or – in certain circumstances - ask us to transfer your Personal Information to an applicable third party.
In addition, where you provided your consent for our processing of your Personal Information, you may withdraw your consent by contacting us using the details provided in the “Contact” section. You may also restrict how we use your Personal Information while a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (for example, to prevent or detect crime) and our interests (for example, maintaining our legal privilege).
We may update this Privacy Notice from time to time. We will alert you to changes by providing notice within the Website or otherwise as required by law. The “last updated” note at the top of this policy indicates when it was last revised, and updates will become effective when they are posted.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:
Monos Travel Ltd.
[Re: Privacy Compliance Officer]