Effective Date: March 5, 2017
HELLOGBYE PRIVACY STATEMENT
This Privacy Statement describes how HelloGbye, LLC and HelloGbye Canada LP (we, our, us, * or *HelloGbye) collect, use and disclose personal information. This Privacy Statement applies to the personal information we collect from our members and users and visitors (you and your) when you use or visit our websites and any related sites, online and mobile applications, and content , and services that display or link to this Privacy Statement (any, a "Site," and collectively, the “Sites”). When we provide our products or products or services to you, we may also give you specific additional details about how we use your personal information or the personal information provided by you. Your use of a Site indicates your acceptance of this Privacy Statement Policy and your consent as to the collection, uses, sharing and other practices set forth herein. IF YOU DO NOT AGREE TO THIS PRIVACY STATEMENT POLICY, PLEASE DO NOT USE THE SITES OR ANY SERVICES AVAILABLE ON OR ACCESSED THROUGH THE SITES. THIS PRIVACY STATEMENT IS NOT A CONTRACT AND DOES NOT CREATE ANY LEGAL RIGHTS OR OBLIGATIONS.
*Information We Collect *
When you register on or access our Site, view or click on our notices or other online content, interact with us through social media websites and other websites and applications, or when you contact us, you may give us certain information that can be used to identify you as an individual or any other person (collectively, personal information), including without limitation, your identity and contact information, travel documentation/details, habits and preferences, frequent traveller and loyalty program numbers, and payment or billing information.
In addition, when you visit our Site, we collect certain information by automated means, as described below under the heading Usage Information. When you download or use one of our online or mobile applications, or access one of our mobile-optimized sites, we may receive information about your precise se and geolocation and your mobile device, including a unique identifier for your device.
Third party providers of travel related services, in-city content or services, and those persons who assist us in providing our products and services to you are referred to as Third Party Providers.
*Using Information We Collect *
We use and store your personal information to:
communicate with you about our products, services, collaborations and partnerships, including for marketing, service review solicitation, and promotional purposes;
deliver our services to you, including as follows:
recognize you and verify your identity when you return to our Sites;
provide search results and other personalized content, including information about services offered by Third Party Providers;
facilitate the processing of your requests of us ored transactions with Third Party Providers in accordance with your authorizations;
communicate with you about your transactions, requests, any travel related services includingor in-city content and/or services;
learn more about you and your preferences so that we can customize your experience;
respond to your requests and inquiries;
update you about new features and benefits;
use the location of your mobile device for location-based services that you may request or be interested in;
obtain your feedback on products and services, including Third Party Providers;
send or provide you with promotions and offers, and analyze whether our promotions and offers are effective, including determining whether you may be interested in new products or services;
reward you as part of any reward or recognition program;
resolve or attempt to resolve disputes and collect fees for our services and other amounts owing to us;
meet our legal, regulatory, risk management, fraud prevention and security requirements;
maintain our business and transaction records for reasonable periods;
address problems with, and improve our Sites and services;
respond to your inquiries and to send you administrative communications;
analyze user and visitor member behaviour and activity;
conduct research and measurement activities;
send you personalized emails or secure electronic messages;
meet insurance, audit, and processing requirements;
manage fraud and security risk; and
otherwise with your consent or as permitted or required by law.
In addition, we may de-identify and/or aggregate any personal information we collect, so that the information is no longer personally identifiable or attributable to you. We may use and share such information without restriction.
Information We Disclose
We may disclose your personal information to our subsidiaries, affiliates, parent companies and to unaffiliated third parties (including Third Party Providers) in connection with the purposes described in this Privacy Statement as follows:
Providing Services. In order to process transactions that you request, we will disclose your personal information to Third Party Providers in accordance with your transaction authorizations.
Service Providers. We may transfer personal information to service providers third party service providers that perform services on our behalf, for example marketing, feedback/review, information technology and/or data hosting, analytics, travel fulfilment services or processing services. Some of these service providers service providers or affiliates may be located in Canada, and the United States, but we may also use service providers service providers that are located outside of Canada and the United States. Your personal information may be collected, used, disclosed, stored and processed outside of Canada and the United States for the purposes described in this Privacy Statement. We take reasonable measures to ensure that personal information that may be processed by these service providers on our behalf is protected and not used or disclosed for purposes other than as directed by us, subject to legal requirements in Canada, the United States and other foreign countries applicable to our affiliates, agents and service providers (for example lawful requirements to disclose personal information to government authorities in those countries). Our service providers are required to limit their use of your personal information for the purposes and in the manner we have instructed them. We also require them to commit to keep your personal information confidential and to secure it in a manner that is consistent with this Privacy Statement.
Business Transactions. We may use your personal information and disclose it to parties connected with the contemplated or actual financing, securitization, insurance, sale, lease, merger, amalgamation, assignment or any other type of acquisition, financing, disposal or transfer of all or part of our business, assets or shares or those of our corporate subsidiaries, affiliates or parent companies, for purposes related to the evaluation and performance of these transactions, including: (i) permitting such parties to evaluate and determine whether to proceed or continue with the transaction, and (ii) fulfilling reporting, inspection or audit requirements or obligations to such parties. Successors and assigns of HelloGbye our company and/or our business or assets may use and disclose your personal information for similar purposes as described in this Privacy Statement.
Legal and Regulatory Requirements. We may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law. This may include lawful requirements to disclose personal information to government authorities in Canada, the United States and in foreign countries. Government authorities in Canada, the United States and in foreign countries may, without your consent (or our consent), communicate information to other authorities, including the police forces. Please note that the U.S. Transportation Security Administration (TSA) requires that you to provide your full name, date of birth, and gender. You may also provide your Redress Number, if available. Failure to provide your full name, date of birth, and gender may result in denial of transport or denial of authority to enter the boarding area. TSA may share information you provide with law enforcement or intelligence agencies or others subject to its own policies and practices. For more information on TSA privacy policies, please see the TSA website of www.tsa.gov. As well, please note that Public Safety Canada and Transport Canada have similar requirements.
Special cases. We may disclose your personal information as necessary to respond to an emergency or otherwise protect the safety, rights, property or security of HelloGbye, users of our Sites, third parties, and the public, such as in response to a physical threat to you or others.
Your Consent
By providing your personal information to us, you consent to our collection, use, storage, and disclosure of your personal information in accordance with this Privacy Statement. In addition, from time to time and where appropriate, we may request your specific authorization or consent for the collection, use, storage, and disclosure of your personal information for the purposes specified in our request.
You may withdraw your consent to our collection, use, storage, and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. However, if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Please be aware that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to Canadian and foreign government entities as required to comply with laws). Subject to the above limitation, you may withdraw your consent by contacting us as described under the heading Your Choices.
We may also be required or permitted under statute or regulation to collect, use, store, or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
Your Choices
If you wish to withdraw your consent as described above under the heading Your Consent, you may do so by contacting us at legalprivacy@hellogbye.com. In addition, you may unsubscribe from receiving promotional emails from us at any time by simply clicking the "unsubscribe" link provided at the bottom of every promotional email from us. Please allow 10 business days for your updated preferences to take effect. In addition, you may be able to exercise choice with respect to the use of your personal information for purposes of targeted advertising as described under the heading Online Advertising.
*Usage Information *
We and our service providers may use browser tracking cookies (or cookies), log files, web beacons, and other similar mechanisms to passively collect information about your use of our Sites. Cookies are small text files that are placed on the hard disk of a computer by a website. Cookies are uniquely assigned to you, and can only be read by a website or web server that issued the cookie to you. "Log files" record certain information when you visit a Site (which may include your internet protocol (IP) address and type of operating system and web browser). “Web beacons” are transparent electronic images placed in the web code that collect non-personal data while visiting a web site. We may use similar technologies in connection with our mobile applications.
With your consent and in order to improve your experience on our Sites, we use cookies, web beacons, log files, and similar technologies to: recognize you when you return to our Sites; keep track of activity on our Sites and remember what items you have clicked on or viewed; study and analyze how you navigate through our Sites so that we can improve the design, content and function of our Sites; and customize the message, content and delivery of online advertisements and e-mails that reflect how you navigate to and through our Sites based on your online behaviour. We may hire third-party service providers to assist us in the collection and analysis of this information, but we do not disclose your personal information to these third party service providers.
You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your internet browser. If you decide to turn off or block cookies, our website might not function correctly.
Online Advertising
We, our service providers and our business partners may collect information about your activities on our Sites for use in providing you with content and advertising tailored to you on our Sites and elsewhere online. Some of our service providers and business partners may collect information about your online activities over time and across third-party websites and mobile applications for these purposes. The information collected for these purposes may include details about the particular content you view and actions you take on our Sites. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track ("DNT") mechanisms, we do not respond to web browser-based DNT signals at this time. However, some of our service providers and business partners that collect information about your activities on our Sites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behaviour for purposes of targeted advertising. For example, you may opt out of receiving targeted advertising through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Canadian users may opt out of receiving targeted advertising through members of the Digital Advertising Alliance of Canada by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
*Security *
We aim to provide you with a safe experience. We have in place certain physical, electronic, technological, and organizational safeguards designed to assist us in protecting the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying use or modification. However, while we try to create a secure and reliable Sites for users and visitors, the confidentiality of any communication or material transmitted to or from the Sites, or via e-mail cannot be guaranteed.
Links to Other Sites and Online Content
We may provide links to other websites or online content that are operated by third parties we think you will enjoy. These third parties operate independently of us and may have established their own privacy and security policies. Any personal information you provide to these third parties typically is subject to that third party’s privacy policy. We strongly encourage you to review these policies before providing any personal information to a third party. This Privacy Statement does not apply to such third-party websites or online content, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.
*Children’s Online Privacy Protection *
If you are under the age of majority in the state or province where you reside, please do not submit any personal information through our Sites without the express consent and participation of your parent or guardian. We do not knowingly solicit data online from, or market online to children.
Access and Correction
We may establish and maintain a file of your personal information for the purposes described in this Privacy Statement, which will be located at our administrative offices located at 25 York Street, Suite 608, Toronto, Ontario Canada M5J 2V5.
If you wish to request access or correction of your personal information in our custody or control, you may modify your account on-line or you may write to the mailing address provided above, attention Privacy Officer. Your right to access or correct your personal information is subject to applicable legal restrictions. To protect your privacy and security, we may require additional information to verify your identity when requesting access or correction.
We will retain your personal information as long as your HelloGbye account is active, or needed to provide you services or is necessary to fulfill the purposes of this Privacy Statement. At any time you can delete your HelloGbye account, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to HelloGbye. We will also retain your personal information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
Changes
We may make changes to this Privacy Statement and if we do so, we will post an updated version on our website at www.hellogbye.com and www.hellogbye.ca , and within our mobile application. We recommend that you review the current version of our privacy statement from time to time. IF WE MAKE CHANGES TO THIS PRIVACY STATEMENT, INCLUDING MATERIAL CHANGES, WE WILL UPDATE THE EFFECTIVE DATE THAT APPEARS AT THE TOP OF THIS PAGE.
Questions
If you have any questions about this Privacy Statement or our privacy practices generally, please feel free to contact us at legal@hellogbye.com. If you contact us about your personal information, we will respond to your request within a reasonable time and at no cost to you.
