Date of entry into legal force: 17/09/2018
1. General Provisions
Capitalized terms that are used in this document signify the same concepts as those in the Terms of Services.
2. Information on the person who controls the processing of users’ personal and other data in the Application:
LLC “Ltech” whose registered office is at 2, Naberezhna str, Lutzk, Ukraine, 43025. You can contact Us via firstname.lastname@example.org.
3. Information We Collect
There are three general categories of information we collect.
3.1 Information You Give to Us.
3.1.1. Information that is necessary for the use of the Application.
We ask for and collect the following personal information about you when you use the Application. This information is necessary for the adequate performance of the contract between you and us, for usage of interactive features of the Application. Without it, we may not be able to provide you with all the requested Services.
- Account Information. When you sign up for an Account, we require certain information such as your first name, last name, telephone number. Please note that based on your telephone number we automatically define your country of residence. If you contact us via contact form in the Application, we will ask you to indicate your email address to receive an answer.
- Announcement Information. To use certain features of the Application (such as creating an Announcement), we may ask you to provide additional information, which may include description of your trip (means of transport you are going to use, route, departure and arrival date), photo and contents description of your parcel.
- Communications with us or other users. When you communicate with us or other users of the Application through the Application, for purposes of safety, we collect information about your communication and any information you choose to provide.
3.1.2 Information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience or a higher user rating when utilizing the Application. This additional information will be processed based on your consent. By uploading this information you grant us your consent to process it. You are entitled to recall your consent for processing by deleting certain information from your Account.
- Additional Account Information. You may choose to provide additional information as part of your profile (such as photo, preferred language, currency, email address, and a personal description or short bio). Some of this information as indicated in your Account settings is a part of your public profile page, and will be publicly visible to others.
- Identity Verification Information. To help create and maintain a trusted environment, you may indicate in your Account links to your Facebook or Google account that contains your identity verification information. You may also log in your Account using these social media platforms (“SMP”). We do not receive any additional information about you from Facebook or Google except your profile ID on these SMP; however other users of the Application can see that your TravelPost Account is verified by linking to your external account on SMP.
- Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Application.
3.2 Information We Automatically Collect about Your Use of the Application or our Website.
When you use the Application or visit the Website, we automatically collect information, including personal data, about the Services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest enable us to provide and improve the functionalities of the Application. This data helps us to inform you about our Services, maintain secure environment between users, and evaluate the effectiveness of the advertising messages we send.
- Usage Information. We collect information about your interactions with the Application such as the pages or content you view, your searches for Announcements, Announcements you have made, and other actions on the Application.
- Log Data and Device Information. We automatically collect log data and device information when you access and use the Application or the Website, even if you have not created an Account or logged in. That information includes, among other things: details about IP address, access dates and times, hardware and software information, device information, unique identifiers, and the pages you’ve viewed or engaged with before or after using the Application.
3.3 Information We Collect from Third Parties.
We may collect information, including personal data, that others provide about you when they use the Application, or obtain information from other sources and combine that with information we collect through the Application. We do not control, supervise or respond for how the third parties providing your data process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Reviews about you. If someone has written a review for you, it will be published on your TravelPost public profile page.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as fraud detection information, from third party service providers and/or partners, and combine it with information we have about you.
3.4 Children’s Data.
3.5 How Long Do We Retain Collected Information.
We may retain your personal information so long as your Account is active. We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons. For example, in the event your Account has been suspended or blocked, we will keep your data during life time of the Application in order to avoid any circumvention by you of the rules of the Application.
4. How We Use Information We Collect. Purposes and Basis for the Processing
We use, store, and process information, including personal data, about you to provide, improve, and develop the Application and the Services associated with it; create and maintain a trusted and safer environment; provide, personalize, analyze, and improve our advertising and marketing.
4.1 Provide, Improve, and Develop the Application.
- Enable you to access and use the Application.
- Enable you to communicate with other users of the Application.
- Operate, protect, improve, and optimize the Application and experience, such as by performing analytics and conducting research.
- Send you service or support messages, updates, security alerts, and account notifications.
- If you provide us with your contacts’ information, we may process this information: (1) for fraud detection and prevention; (2) for any purpose you authorize at the time of collection.
- To operate, protect, improve, and optimize the Application and experience, and personalize and customize your experience (such as making Announcements suggestions or ranking search results), we conduct profiling based on your interactions with the Application, your usage history, your profile information, other content you submit to the Application and information we receive about you from third parties.
We process this information given our legitimate interest in improving the Application and our users’ experience with it, and where it is necessary for the adequate performance of the contract with you, or on the basis of your consent.
4.2 Create and Maintain a Trusted and Safer Environment.
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- We process this information given our legitimate interest in protecting our users and the Application, to measure the adequate performance of our contract with you, and to comply with applicable laws.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you.
- Conduct checks against databases and other information sources, to the extent permitted by applicable laws and with your consent where required.
- Comply with our legal obligations.
- Resolve any disputes with any of our users and enforce our agreements with third parties.
- Enforce our Terms of Services and other policies.
In connection with the activities above, we may conduct profiling based on your interactions with the Application, your profile information and other content you submit to us, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Application if such processes detect a user or activity that we think poses a safety or other risk to the Application, other users, or third parties.
4.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
- Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about TravelPost campaigns and Services) and social media advertising through social media platforms such as Facebook or Google).
- Personalize, measure, and improve our advertising.
- Administer surveys, contests, or other promotional activities or events sponsored or managed by TravelPost or its third party partners.
- Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Application and the Website, information obtained from third parties, and your search and usage history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
We will process your personal information for the purposes listed in this section on the basis of our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest, or on the basis of your consent.
You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Account or you device which you use for access to the Application.
5. Your Data Protection Rights
You may exercise any of the rights described in this section by sending us an email to email@example.com. Please note that we may ask you to verify your identity before taking further action on your request. Besides, some of the rights set out below are granted by legislation only of some jurisdictions. That’s why in some cases we will need to check your place of residence to proceed with your request.
5.1 Managing Your Information
You may access and update some of your information through your Account settings. You are responsible for keeping your personal information up-to-date.
5.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal data concerning you (and which you cannot update yourself within your Account settings).
5.3 Data Access and Portability
In some jurisdictions (for example, in European Economic Area), applicable law may entitle you to request copies of your personal data held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
5.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information, you can request that we erase your personal information and close your Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that user from opening a new Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, our Company may keep some of your information for legal reporting and auditing obligations, if any.
- Information you have shared with others (e.g., reviews, postings, chats) may continue to be publicly visible in our Application, even after your Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain the Application to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
5.5 Withdrawing Consent.
Where you have provided your consent to the processing of your personal data by our Company you may withdraw your consent at any time by changing your Account settings or by sending a request to us through Support contact form in the Application specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
5.6 Restriction of Processing.
In some jurisdictions applicable law may give you the right to limit the ways in which we use your personal data, in particular where (1) it has been used improperly but you do not wish us to delete it; (2) it is not relevant any more, but you prefer us to keep it for use in possible legal claims; (3) you have already asked us to stop using your personal data but you are waiting for our confirmation of some legitimate grounds to use your data.
5.7 Objection to Processing.
In some jurisdictions applicable law may entitle you to require us not to process your personal data for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending a request to us through Support contact form in the Application.
5.8 Lodging Complaints.
If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us, you have the right to file a complaint by sending an email to firstname.lastname@example.org. You also have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities in your country.
6. Third-party Disclosure
6.1 Sharing between users.
To help facilitate Announcements or other interactions between users, we may need to share certain information, including personal information, with other users of the Application, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as a Sender publish a parcel delivery request, certain information about you is shared with Travelers, including your full name, the description of your parcel, and other information you agree to share. When your request is confirmed, we will disclose additional information to assist with coordinating interaction between you and the Traveler, like your phone number.
- When you as a Traveler post an Announcement about your Trip, we will show you suggested parcel delivery requests which may match your route. Also certain information about you, including contact details, is shared with the Sender who has chosen you.
6.2 Profiles, Announcements, and other Public Information.
The Application lets you publish information, including personal data, which is visible to the general public. For example:
- Parts of your public profile page, such as your full name, your public profile photo, and your rating are publicly visible to others.
- Announcements are publicly visible.
- After completing a parcel delivery, Travelers and Senders may write reviews for each other.
6.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (1) to comply with our legal obligations, (2) to comply with legal process and to respond to claims asserted against our Company, (3) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (4) to enforce and administer our Terms of Services, or other agreements with users, or (5) to protect the rights, property or personal safety of TravelPost, its employees, its users, or members of the public.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Application secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
Where appropriate, we may notify users about legal requests unless: (1) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (2) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon our property, our users and the Application. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
6.4 Service Providers.
6.5 Business Transfers.
If our Company undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets,
6.6 Transfer of Data to Other Countries
7. Other Important Information
7.1 Analyzing your Communications.
We may review, scan, or analyze your communications on our Application for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask description of parcels with forbidden objects. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
7.2 Linking Third Party Accounts.
You may link your TravelPost Account with your account at a third party SMP. When you create this link, we will receive your profile ID on these SMP, and other users of the Application will see that your TravelPost Account is verified by linking to your external account on SMP.
8. Cookies and Similar Technologies
When you use the Application or visit the Website, our system automatically collects information about your visit, such as your browser type, operating system you use and your IP address. Such information is typically collected using cookies, pixels, beacons, embedded hyperlinks, and similar tools.
Cookies are text files containing small amounts of information, which are downloaded to your device when visiting a website or using an application. Cookies can be recognized by the website (or the app) that downloaded them, or other websites that use the same cookies. This helps websites to know if the device has visited them before. The cookies allow the website to “remember” your actions or preferences over time.
Pixels are tools that allow us to track users’ actions on a website or an application and to gather information about these actions. The data collected from pixels can be used for advertising and marketing campaigns.
See below for the types of cookies and similar technologies we use on the Website and in the Application and their respective purposes:
- Required Cookies: enable the navigation and basic functionality of the Application and the Website, e.g., access to protected area of the Application.
- Functional Cookies: allow us to analyze your Application and Website usage and your selections (e.g. your language preferences, or your country), so we can save these settings and offer you a more personalized experience.
Required and Functional Cookies are First party Cookies, which belong to us and are set by the Website or by the Application. All information these cookies collect is anonymous and is only used to ensure proper functioning and improve Services we offer.
You can choose to have your device warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s help menu to learn the correct way to modify your cookies.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us via email@example.com.