Progressive Traveller (we, us, or Progressive Traveller) recognises and values the protection of your personal information.
This policy applies only to information that Progressive Traveller collects via this website.
INFORMATION WE COLLECT AND HOLD
Wherever possible, you can elect to remain anonymous or use a pseudonym in interacting with us e.g. when making an enquiry.
From time to time, we may ask you to supply personal information such as your name, address, date of birth, telephone number or e-mail address.
For example, we ask for your contact information when you sign up for a free eproduct, an email offer, participate in community forums, join us on social media, take part in training and events, contact us with questions or request support.
If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our website or services.
Under no circumstances will we request any information from you that may disclose your:
• political, religious or philosophical opinions, beliefs, associations or affiliations;
• health and sexuality;
• racial or ethnic origin;
• membership of a trade union, or a professional or trade association; or
• criminal records.
We may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the types and quality of services offered to you, and the manner in which those services are offered to you.
How we collect, store, use and secure personal data is in line with Europe’s new General Data Protection Regulation (GDPR)
PERSONAL INFORMATION VIA THE WEBSITE
We collect some information about you automatically when you visit our website or use our services, like your IP address and device type. We also collect information when you navigate through our website and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our website and services so that we can continue to provide the best experience possible (e.g. by personalising the content you see).
Some of this information is collected automatically by cookies or similar tracking technologies. ‘Cookies’ are pieces of information that website send to the browser and are stored in the computer hard-drive. Cookies make using the website easier by storing information about your preferences on the website.
This allows the website to be tailored to you for any of your return visits. Cookies will not identify you personally.
We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.
If you would prefer not to receive cookies, you can alter your security settings on your web browser to disable cookies or to warn you when cookies are being used. However, by disabling the cookie function in your web browser you may impede your ability to use parts of the website.
When you leave a comment on this website, you are giving implied consent for this comment and your information to appear on our website. In leaving a comment, your name and email address will not be shared with any third party. We may use your email address solely to respond to your comment. However, we are not liable or responsible for the actions of other individuals and the unauthorised use by such information that you voluntarily share.
We have public social media accounts and social sharing options on our website. If you choose to interact on social media with us or our accounts, you are advised that any interactions on those accounts are publicly available.
If you choose to share a testimonial on this website, we will first obtain your written permission via email before including your name and testimonial on our website.
YOUR OPTION NOT TO PROVIDE YOUR PERSONAL INFORMATION
We may from time to time run competitions or offer additional benefits to you and we may ask you to provide us with your personal details for these purposes. Providing us with this information is optional to you. However, if you do not provide your personal information to us, we may not be able to contact you or give you access to the additional benefits.
You may opt out of these additional communications at any time. Please contact our Privacy Officer at email@example.com
USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
When we hold your personal information, it will be used for the following primary purposes:
1. to ensure the proper functioning of the website;
2. to ensure the proper functioning of the Progressive Traveller business and
3. to assist Progressive Traveller with our auditing, marketing, planning, billing, product development and research requirements.
First and foremost, we use your personal data to operate our website and provide you with any services you’ve requested, and to manage our relationship with you. We also use your personal data for other purposes, which may include the following:
To communicate with you.
This may include:
• providing you with the information you have requested from us (like training or education materials) or information we are required to send to you for operational communications, like changes to our website and services, security updates, or assistance with using our website and services
• marketing communications (about Progressive Travel or another product or service we think you might be interested in) in accordance with your marketing preferences
• asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).
To support you:
This may include assisting with the resolution of technical support issues or other issues relating to the website or services, whether by email, in-app support or otherwise.
To enhance our website and services and develop new ones:
For example, by tracking and monitoring your use of our website and services so we can keep improving, or by carrying out technical analysis of our website and services so that we can optimise your user experience and provide you with more efficient tools.
To market to you:
In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own website and services or through third-party website and their platforms.
To analyse, aggregate and report:
We may use the personal data, we collect about you and other users of our website and services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties.
We will not use or disclose (or permit the use or disclosure of) information that could be used to identify an individual member in any circumstances except:
• to ensure the proper functioning of our business and the website;
• to communicate promotional offers and special events to you;
• to allow our trusted third parties, including our advertising partners, to communicate promotional and special offers to you;
• where the law requires us, or authorises us, or a company holding data on our behalf, to do so; or
• where you have given express consent to us for a prescribed purpose.
We will not sell, distribute, rent, licence, disclose, share or pass your personal information onto any third parties, other than those who are contracted to us to keep the information confidential whether subject to a statute or a scheme regarding the handling of personal information.
Should a third-party approach us with a demand to access your personal information, we will take reasonable steps to redirect the third party to request the information directly from you, wherever it is lawful and reasonable for us to do so.
If we are compelled to disclose your personal information, to a third party we will take reasonable steps to notify you of this in advance, wherever it is lawful and reasonable for us to do so.
Our trusted third-party partners comply with Europe’s new General Data Protection Regulation (GDPR)
Third Party Partners
Our Third-Party Partners who may place cookies and tracking technology on your computer or device include:
• Google Analytics – providing traffic analytics and demographics
• Mail Chimp – help us collect information for email subscribers so we can tailor our messaging to more personal preferences.
• Amazon – tracks products we promote via affiliate links on our site
• Commission Junction – tracks products we promote via affiliate links on our site
• Facebook – user analytics and advertising tracking
• Twitter – user analytics and advertising tracking
SECURITY OF PERSONAL INFORMATION
In our business, personal information may be stored both electronically and in hard-copy form. We are committed to keeping your personal information secure regardless of the format in which we hold it and we take all reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, modification or disclosure. However, you use the website at your own risk, and we accept no responsibility whether we are deemed to have been negligent or not, in the event of a security that affects your privacy.
Note that no information transmitted over the Internet can be guaranteed to be completely secure. However, we will endeavour to protect your personal information as best as possible, but we cannot guarantee the security of any information that you transmit to us or receive from us. The transmission and exchange of information is carried out at your own risk.
ACCURACY AND QUALITY OF PERSONAL INFORMATION
We will take all such steps as are reasonable in the circumstances to ensure that:
• all information collected from you is kept accurate, up to date, and complete; and
• the personal information that we use or disclose is having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.
ACCESS TO YOUR PERSONAL INFORMATION
In most cases, you have the right to access the personal information that we hold about you. If you wish to access your personal information, please contact our Privacy Officer at firstname.lastname@example.org
We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information which is not currently in use, may require further time before a response can be given.
We may charge you a reasonable fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.
Whenever a fee will be applied, you will be notified of how that fee will be calculated, or where possible, the total amount that will be charged. You will then have the option to decide whether to proceed with your access request.
In some cases, we will refuse to give you access to personal information we hold about you. This includes, but is not limited to, circumstances where denying access is required or authorised by or under USA law or a court/tribunal order or where giving you access would: be unlawful; have an unreasonable impact on other people’s privacy; prejudice an investigation of unlawful activity; reveal our intentions in relation to negotiations with you so as to prejudice those negotiations; prejudice enforcement related activities conducted by, or on behalf of, an enforcement body; reveal evaluative information generated within the Progressive Traveller business in connection with a commercially sensitive decision-making process.
We will also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings. Further, we will refuse access where your request is frivolous or vexatious, and where we reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; unlawful activity, or misconduct of a serious nature, is being or may be engaged in against Progressive Traveller and giving access would be likely to prejudice the taking of appropriate action in relation to that matter.
If we refuse to give you access, we will provide you with reasons for our refusal, unless doing so would be unreasonable in the circumstances. We will also take reasonable steps to give you access in a way that meets your needs without giving rise to the reasons of our refusal. Further, we will provide details of how you may make a complaint about our decision.
These mechanisms for accessing your personal information operate alongside, and do not replace, other informal or legal procedures by which you may be provided with access to your personal information.
CORRECTION OF YOUR PERSONAL INFORMATION
The accuracy of the personal information we have requested from you is important to us. Should you suspect, or become aware of, that your personal information we hold is inaccurate, out of date, incomplete or misleading, please contact our Privacy Officer at email@example.com
We will deal with all requests for correction of personal information as quickly as possible. Requests relating to a large amount of information, or information which is not currently in use, may require further time before a response can be given.
If we refuse to change the personal information as you request, we will provide you with reasons for our refusal, unless doing so would be unreasonable in the circumstances. We will also provide details of how you may make a complaint about our decision. Further, in case of our refusal, you may request that we take reasonable steps to associate, with the relevant information, a statement that you view it as inaccurate, out of date, incomplete or misleading.
In the case we have corrected personal information about you, you may request that we take reasonable steps to give notice of the correction to any third party to which we have disclosed the inaccurate, out of date, incomplete or misleading personal information.
These mechanisms for correcting your personal information operate alongside, and do not replace, other informal or legal procedures by which you may be provided correction of your personal information.
CONCERNS AND COMPLAINTS ABOUT BREACHES
If you have concerns about how we handle your personal information, it is important that you notify us as soon as possible, so that we can address your concerns appropriately as the circumstances require. Any concern or complaint should be made in writing. Please send it to our Privacy Officer at firstname.lastname@example.org, and will respond as soon as reasonably possible.
DISPOSAL OF PERSONAL INFORMATION NOT REQUIRED
If we hold personal information about you, and we do not need that information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy or de-identify that information unless we are prevented from doing so by law.
UNSUBSCRIBING FROM OUR E-MAIL DATABASE
To unsubscribe from our e-mail database, please use the unsubscribe option, which is located on our Home page and within your login account or send us an e-mail to email@example.com with “UNSUBSCRIBE” typed into the subject line of the e-mail.
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