Dated: May 5, 2020
This Privacy Statement applies to any visitor to the GloboLoko website, and any other service we provide, and explains the information we collect, what we do with it and the third-parties we work with. We will not, without your consent, supply your personal information to any third party for their or any other third party’s direct marketing. The data collected here is only used for the purposes specified in this Privacy Statement. If you do not agree to this privacy statement you may not access or use this website or any service it provides.
2. Who we are
GloboLoko is an independently owned travel website that expresses opinions about products and services related to travel. Our website address is: https://www.globoloko.com.
3. Personal information we collect
We collect different types of information for various purposes to provide and improve our Service. While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- Your name;
- Your email address;
- Information contained in any communications that you send to us by email or through the forms on our website;
- Any other information you voluntarily share with us
We may also collect information that your browser sends whenever you visit our website. This Usage Data may include information such as your IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, geographical location, operating system, referral source, page views, click events, website navigation paths and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
4. How we collect and use personal data
4.1 When you give us information
You sometimes give us information like your name and email address. For example, when you sign up to receive our newsletter, contact us through our contact forms or by email, or create a user profile on our website or mobile apps.
4.1.1 Newsletters and marketing materials
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link in any email we send or by contacting us.
4.1.2 Contact through contact forms or by email
GloboLoko has embedded forms to enable communication between visitors and the website owners. These include contact forms managed by “Contact Form 7” WordPress plugin. You may need to provide your contact information to us, including, but not limited to, your email address, in order for us to get back in contact with you regarding a personal or business request. By doing this, you expressly consent to receive communications from us that allows us to send information that you have requested or to send information about other products or services developed or provided by us.
Where you contact us to ask for help to resolve an issue on our websites or mobile applications we may ask for your name, your email address and any information you choose to give us as part of servicing your request, including a description of your issue, and screenshots of the issue you may be seeing. We use this information to receive and reply to feedback and queries from you.
4.1.3 Create a user profile
GloboLoko has embedded a login and registration system for visitors to create a user account. These functionalities are managed by “UserPro” WordPress plugin. By creating a user account, visitors can build their travel plan and leave comments and reviews. When creating a user account, we may ask for your name, surname, email address, links to your personal website and social media, a biography and profile picture.
4.2 When you post or share content
We also collect and use personal information when you post or share content through your user account or share it directly with us, including personal data in photographs and Travel Stories.
To submit a comment in an article, you may need to enter valid personal information, such as name and valid email address. This is done exclusively for safety reasons, namely to prevent spam commenting. Your data will pass through our spam filter (Akismet plugin) before submission and won’t be shared with any third-parties. We use these personal data to allow you to share your experiences with fellow travellers on our web forums, mobile applications, and social media sites.
4.3 When we receive your information automatically
We sometimes collect personal data automatically when you view our sites or applications on your phone or computer. When you view our Website on your devices, we collect technical information like: IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, geographical location, operating system, referral source, page views, click events, website navigation paths and other diagnostic data. We consider this necessary either to process and administer your contractual use of our sites and applications, or for our legitimate interests in operating and improving them (including personalising your user experience).
We may also use this information to show you advertising that we think will be more relevant to you (see our “Cookies Statement” for more information, including how to opt-out of receiving cookies). This data will only be shared with third parties who assist us to provide these services to you. This data may be cached on your device for short periods of time in order to improve user experience and make our applications and websites more responsive.
We also use this automatically gathered information about you to understand how our websites and applications are used by our community and to make sure any technical problems are reported to us. We use Google Analytics to gather and process this data. For details about the information Google Analytics collects and how Google Analytics treats that information please visit their Terms of Service.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
We may provide third parties with statistical information about our visitors that we then aggregate and use to generate traffic metrics and insights and help improve our website. This can include, but is not limited to, demographic and geographic information.
We allow third-party companies to serve ads and/or collect certain anonymous information when you visit our web site. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. No personal information is shared. These third-parties typically use a cookie or third party web beacon to collect this information.
Non-identifiable aggregated information about the general use of our website may be shared by us for any purposes permitted by law, provided that such information shall not specifically identify you in any way.
This may include, but is not limited to, sharing overall statistics and metrics about GloboLoko as a website on trusted social media, advertising and analytics partners in order to customize content and advertising.
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
The Website and App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or apps and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website or app you visit.
Some of these third party websites are linked to through affiliate links. These might entail a small commission should you click them or start a transaction with some partner companies. There’s absolutely no additional cost to you, as a visitor. An affiliate link is a specific URL that contains the affiliate’s ID or username. In affiliate programs, advertisers use affiliate links to record the traffic that is sent to the advertiser’s website. This action is all part of an affiliate program.
As part of this affiliate program, some third-parties may enable a dashboard or separate tool or app to allow GloboLoko to have more information about the transactions that occurred with origin in our website. The data shown there is anonymised and in compliance with the third-parties’ privacy policies. The types of cookies used by these third parties and how they use the information generated by them will be governed by those companies’ privacy policies.
4.5 When you do business with us or work for us
We may also collect the above sorts of information in relation to businesses we work with and the people who work in them. This falls within our core function as a media and publishing organisation providing journalistic content. This is so we can prepare listings and reviews in our publications. Our writers may collect personal information in the course of gathering material for inclusion in our products, this could include things like the name of an individual who runs a hotel, restaurant or tour company.
If you work for GloboLoko (as an employee or as a freelancer) we keep information about you in the context of that employment or contractual relationship.
5. Who we share your data with
GloboLoko does not, and will not, sell information about you to anyone. We only use your information as set out in this notice and we will only share your information with third parties for commercial purposes such as marketing or promotions if we have your consent to do so; or where we’ve engaged a company outside GloboLoko to provide a service for us (which might involve them handling your information, but this is only when we have proper safeguards in place); or where we’re obliged by law to share information with authorities.
We may have to share your personal data with Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where relevant, we might provide your information to businesses and individuals that we engage to assist us to provide our products and services to you (for example, our printers, software developers, and international language partners, travel writers, photographers, and editors). However, their use of your data will always be limited to acting on our instructions and regulated under a contract that adequately protects your data.
We also use third party services to help us provide some of our services (eg: web hosting, data storage, communication, maintenance, development and insights etc). These third parties will only have access to data relevant for the service they provide and they are obligated to not share with others or use your data for any other purposes.
Our servers are maintained in the BIT datacenter in Ede, Netherlands. By using GloboLoko, you freely and specifically give us your consent to export your personally identifiable information to the Netherlands and to store and use it in the Netherlands as specified in this Privacy Statement.
6. How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will only retain your personal data for as long as we have a lawful reason to do so, linked to the purposes set out in this Privacy Notice (including arts and journalism). This is subject to any reasonable requests by you which will be considered as above.
GloboLoko will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. What rights you have over your data
Request access – you can ask us what information we hold about you and check that we are complying with the laws that apply to the way we use your information. We won’t charge you a fee for this, unless you ask for excessive information or you repeatedly contact us or you don’t have a proper reason to contact us.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process itFor example if we no longer need your information for the purpose that we collected it, if we asked you for consent to use your information, but you want to withdraw that consent, if you object to our use of your personal information and there is no legitimate business interest for us to keep using it, where we’re using your information against the law or where there is a legal obligation that means your information has to be erased
Object to processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
When we receive any objection to processing on these grounds, we will generally restrict access to the information you’ve contacted us about while we assess whether our legitimate interests are lawful and override your objection. If we can demonstrate that our lawful reasons override your objection or that we need to keep your information for legal claims, we are allowed to continue to process your personal information. Otherwise we will either restrict processing of your information or stop processing it altogether.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent – if we have asked you for your consent to process particular items of your personal information, you are entitled to withdraw that consent at any time. If you wish to do so please send an email to firstname.lastname@example.org. Alternatively, if you would like to unsubscribe from one of our emails, you can simply go to the Ünsubscribe” link in the footer of any email to remove yourself from our list.
As stated above, none of these rights are absolute and we may have lawful reasons to continue processing, whether or not linked to our core public interest activity as a publisher of journalism and travel writing.
Exercising your rights
If you wish to exercise any of the rights set out above, please contact us by emailing email@example.com. We will do our best to respond to any request within one month of receiving it, but if your request is complex it may take longer.
We aren’t always obliged to say yes to every request: if our answer to your request is no, we’ll explain to you why that is. If your complaints are not addressed through these channels, you have other options if you are from the EU region, such as EU Data Protection Authorities. We would, however, appreciate the chance to deal with your concerns before you approach the EU Data Protection Authorities so please contact us in the first instance.
8. Additional information
8.1 How we protect your data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Our website includes hyperlinks to, and details of, third party websites. We have no control over, and are not responsible for, the content nor the privacy policies and practices of such third parties.
We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Statement at any time. However, if at any time in the future we plan to use personally identifiable information in a way that materially differs from this Privacy Statement, including sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses.
Your continued use of this website and our services following the posting of any changes to this Privacy Statement means you accept such changes.
8.3 Contact information
If you have any questions, complaints, or need clarification on this privacy statement, you can contact us here.