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Thank you for entrusting us with your information, we strive to handle it properly. To achieve this, the first step is for you to understand what information we collect, why we collect it, how it’s used, and the options you have regarding your information. This Policy describes our privacy practices in plain language, minimizing legal and technical vocabulary.
EFFECTIVE DATE: February 1, 2023
1. Who we are
If you reside in a European Union country, the person responsible for your information under this Privacy Policy (the «data controller») will be:
Irene Liébana Moradillo
Om Street 6
08860 Castelldefels
Barcelona
2. Where this privacy policy applies
This Privacy Policy applies to Tourly’s websites, apps, events, and other services. To simplify, we refer to all of these as our «services» in this Privacy Policy. For clarity, all relevant services include links to this Privacy Policy.
Some services may require their own privacy policy. If a service has its own privacy policy, that policy will apply (not the Privacy Policy in this document).
3. Information we collect
It goes without saying that to help you navigate the city better, we need some information about you, like your basic profile details and your location. We also collect information generated when you use our services (like session logs), as well as information from third parties, such as accessing our services through a social media account. If you want more information, keep reading.
Information you provide
By using our services, you choose to provide us with certain information. This information includes:
When you create an account, you must at least provide your login credentials, as well as some basic details needed for the service to function, such as your gender and date of birth.
When you complete your profile, you can share more information, like your profile picture or details about your interests. To add certain content, like photos and videos, you may allow us access to your camera or photo album. Some of the information you provide might be considered «special» or «sensitive» in certain jurisdictions. By providing us with this information, you also give us your consent to process it.
When you subscribe to a paid service or make a purchase directly through us (rather than through a platform like iOS or Android), you provide information (to us or our payment service provider) such as your debit or credit card number or other financial data.
When you participate in surveys or discussion groups, you provide your opinion about our products and services, answer our questions, and offer recommendations.
If you choose to participate in our promotions, events, or contests, we collect the information you use to register or enter.
If you contact our customer support team, we collect the information you provide during the interaction. Sometimes we monitor or record these interactions for training and quality assurance purposes.
Information we receive from others
In addition to the information you provide directly, we also receive information about you from third parties, including:
Social networks: You can use your social media login credentials (like your Facebook username and password) to create or log into your Tourly account. This helps you avoid remembering more usernames and passwords and lets you share certain information from your social media account with us.
Other partners: We may receive information about you from our partners. For example, when Tourly ads are displayed on a partner’s websites and platforms (in which case, they might provide us with campaign success data).
Information collected when you use our services
When you use our services, we collect information about the features you’ve used, how you’ve used them, and the devices you use to access our services. Keep reading for more information:
Usage information: We collect information about your activity on our services. For example, how you use them (e.g., date and time of login, features used, searches, clicks, pages viewed, referring website addresses, or ads you clicked on).
Device information: We collect information about the devices you use to access our services. This includes hardware and software information, like IP address, device ID and type, device-specific settings and features, app crashes, ad identifiers (such as Google’s AAID and Apple’s IDFA, random numbers that can be reset in your device’s settings), browser type, version, and language, operating system, time zone, and identifiers associated with cookies or other technologies that can identify your device or browser (e.g., IMEI/UDID and MAC address); information about your connection to Wi-Fi and mobile networks, like your service provider and signal strength; information about device sensors, like accelerometers, gyroscopes, and compasses.
Other information with your consent: With your permission, we may collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth, or Wi-Fi connections. Geolocation information collection happens in the background on the device, even when you’re not using the services, as long as the permission you’ve granted allows such collection. If you don’t give us permission to collect your geolocation data, we won’t collect it. You can also give us consent to collect your photos and videos (e.g., if you want to post a photo, video, or stream on the services).
4. Cookies and other similar data collection technologies
We use, and may allow others to use, cookies and similar technologies (e.g., web beacons or pixels) to recognize you or your devices. You can read our Cookie Policy for more information about their purposes (e.g., for authentication, remembering settings and preferences, analyzing page traffic and trends, running advertising campaigns, measuring their effectiveness, and enabling social features) and how you can control their use through browser settings and other tools.
Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) have a «Do Not Track» («DNT») option that informs websites that the user does not want their online activity to be tracked. If a DNT signal is received by a website that responds to it, the browser may prevent that website from collecting certain information about the user’s browser activity. Not all browsers offer a DNT option, and DNT signals do not work consistently. This is why many companies, including Tourly, do not currently respond to DNT signals.
5. How we use the information
The main reason we use your information is to provide and improve our services. We also use your information to enhance your security and provide you with ads that may interest you. Keep reading for a more detailed explanation of why we use your information, along with practical examples.
Managing your account and providing our services
Creating and managing your account
Offering customer support services and addressing your requests
Facilitating your transactions
Communicating with you about the services, including order management and billing
Helping you find new tours
We analyze your profile, service activity, and preferences to recommend new tours.
Ensuring a consistent experience across all your devices
Linking the various devices you use to provide you with a consistent service experience across them. To achieve this, we link devices and browser data, such as when you log in to your account from different devices, whether you use a full or partial IP address, browser version, and similar device data for identification and linking.
Providing you with new Tourly services
Registering you and displaying your profile in new Tourly features and apps
Managing your account on these new features and apps
Showing you relevant offers and advertisements
Managing sweepstakes, contests, discounts,
and other offers
Developing and presenting customized content and ads tailored to your interests on our services and other websites, and tracking the performance of that content
Communicating with you via email, phone, social media, or mobile devices to inform you about products or services that might interest you
Improving our services and developing new ones
Managing discussion groups and surveys
Researching and analyzing user behavior to enhance our services and content (e.g., changing the appearance and style of a new feature based on user behavior or making substantial modifications based on user feedback)
Developing new features and services (e.g., further developing an interest-based feature based on user requests)
Preventing, detecting, and combating fraud or other illegal or unauthorized activities
Addressing alleged or persistent misconduct, on or off the platform
Conducting analyses of information to better understand and counteract such activities and design more effective countermeasures
Retaining information about fraudulent activities to prevent their recurrence in the future
Ensuring legal compliance
Complying with legal requirements
Assisting law enforcement agencies
Enforcing or exercising our rights, such as our Terms
To process your information as described above, we rely on the following legal bases:
Providing our services: In general, we process your information to fulfill the contract we have with you. For instance, when you use our services to book tours, we use your information to manage your account and profile, make your reviews visible to other users, and recommend other tours to you.
Legitimate interests: We may use your information whenever we have a legitimate interest to do so. For example, we analyze user behavior on our services to continuously improve our offerings, suggest offers we think you might be interested in, and process information for administrative, legal, and fraud detection purposes.
Consent: Occasionally, we might ask for your permission to use your information for specific reasons. You can withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
6. How we share information
Because our aim is to help you explore the city, we share certain user information with service providers and partners who assist us in managing the services and, in some cases, with legal entities. Read on for more details about how we share your information with others.
With other users
You share information with other users when you voluntarily disclose information in the services (including your public profile). Be cautious with your information and ensure that the content you share is something you don’t mind being publicly visible. Remember that neither you nor we can control what others do with your information once you’ve shared it.
If you choose to restrict the audience for all or part of your profile, or certain content or information about you, the visibility will depend on your settings.
With our service providers and partners
We use third parties to help us manage and improve our services. These third parties assist us with various tasks, such as data hosting and maintenance, analytics, customer support, advertising, ads, payment processing, and security operations.
We may also share information with partners who help distribute and advertise our services. For instance, we might share limited information about you (encrypted and in a non-human-readable format) with our advertising partners.
For corporate transactions
We may transfer your information if we participate, wholly or partially, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change in ownership or control.
When required by law
We may disclose your information if it is reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena, search warrant, government investigation/law enforcement request, or other legal requirements; (ii) to prevent and detect criminal activities (as per the relevant laws in each case), or (iii) to safeguard a person’s safety.
To enforce legal rights
We may also share information: (i) if disclosing such information would mitigate our liability in a potential or actual lawsuit; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you, and (iv) to investigate or prevent criminal activities, suspected fraud, or other misconduct, or take any other action as appropriate.
With your consent or at your request
We may ask for your consent to share your information with third parties. In such cases, we will clearly explain the reason for sharing the information.
We may use and share non-personal information (information that does not identify the person by itself, such as device information, general demographic data, general behavioral data, non-identifiable geolocation) and encrypted, non-human-readable personal or non-personal information under any of the above-mentioned circumstances. We may combine this information with additional non-personal or personal, encrypted, and non-human-readable information we have collected from other sources. You can learn more about our use of cookies and similar technologies in our Cookie Policy.
7. Your rights
We want you to have control over your information, so we provide you with the following tools:
Device permissions. Mobile platforms have permission systems for specific types of data and device notifications, like phone book and location services, as well as push notifications. You can change your device settings to consent or object to the collection of corresponding information or the display of corresponding notifications. Of course, doing this might impact the full functionality of certain services.
Deletion. You can delete your account using the corresponding feature directly within the service.
We want you to be aware of your privacy rights. Here are some key points to remember:
Reviewing your information. Applicable privacy laws may grant you the right to review the personal information we have about you (referred to as the right of access, right to portability, or similar variations). You can request a copy of your personal information by contacting us.
Updating your information. If you believe the information we hold about you is inaccurate or no longer permissible to use and you wish to request correction, deletion, or processing restrictions, please contact us.
For your protection and the protection of all our users, we may require you to provide evidence of your identity before addressing the above requests.
Please note that we may decline certain requests for various reasons, such as if the request is illegal or violates trade secrets, intellectual property, or the privacy of other users.
Furthermore, there may be certain processing requests that we cannot fulfill, especially if they prevent us from continuing to provide our services to you. For example, we cannot provide our services if we do not have your email address.
Uninstallation. You can halt all information collection by an app by uninstalling it using your device’s standard uninstallation process. If you uninstall the mobile app from your device, the unique identifier associated with your device will still be stored. If you reinstall the app on the same mobile device, we can reassociate this identifier with your previous transactions and activities.
Accountability. In certain countries, including EU member states, you have the right to file a complaint with the relevant data protection authority if you’re concerned about how we process your personal information. The data protection authority you can file a complaint with may be in your country of residence, your place of work, or the location where we’re established.
8. How we protect your personal information
We work hard to protect you against unauthorized access to your
personal information and against alteration, disclosure, or destruction of the same. Like all technology companies, while we take measures to safeguard your information, we cannot promise and you should not expect, that your personal information will always be secure.
We regularly monitor our systems for possible vulnerabilities and attacks, and we also review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures.
In the event that we suspect or detect a security breach, we may suspend your use of our services in full or in part, without prior notice. If you believe that your account or information is no longer secure, please notify us immediately.
9. How long we retain your information
We only retain your personal information for as long as we need it for our legitimate business purposes (as described in Section 5) and as permitted by applicable laws. To safeguard the security of our users both inside and outside of our services, we have implemented a three-month security retention window from the moment an account is deleted. Account information will be retained during this period, even though the account will no longer appear in the services.
In practice, we erase and anonymize your information once you delete your account (after the security retention period) or after two years of continuous inactivity, unless:
We are required to retain it to comply with applicable laws (e.g., certain «traffic data» is retained for a year to comply with data retention obligations);
We are required to retain it to demonstrate our compliance with applicable laws (e.g., consent records for Terms of Use, Privacy Policy, and similar consents are retained for five years);
There is an outstanding issue, claim, or complaint requiring us to retain the relevant information until the matter is resolved; or
We need to retain the information for our legitimate business interests, such as preventing fraud and improving the security and protection of users. For instance, we may need to retain the information to prevent a user banned for misbehavior or security incidents from opening a new account.
Please note that although our systems are designed to carry out the above guidelines, we cannot guarantee that all data will be deleted before a specific period due to technical difficulties.
10. Children’s privacy
Our services are restricted to users aged 18 and above. We do not allow individuals under 18 to use our platform, and we do not knowingly collect personal information from individuals under 18. If you suspect that a user is under 18, please report it through our reporting mechanism available on the services.
11. Changes to the privacy policy
As we’re always exploring new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any significant changes take effect, so you’ll have time to review them.
12. How to contact us
If you have questions about this Privacy Policy, you can contact us by sending an email to hello.tourly@tourlytheapp.com.
