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This PRIVACY AND COOKIE POLICY (this "Privacy Policy") outlines the type of information we collect, why we collect it, and how we use it. By accessing or using the Victor Emanuel Nature Tours ("VENT") website (www.ventbird.com) (together with its pages and features, the "Site"), you agree to the collection and use of your information in accordance with this Privacy Policy. Topics:
1. "Personal Data" Explained As used in this policy, "Personal Data" means information that would allow someone to specifically identify you or contact you physically or online (e.g., your name, physical address telephone number, email address, social security number, credit card information); and the term "Non-Personal Data" means any information other than personal information that we may collect from you. As described in more detail in section 3 below, the term "Personal Data" as used in this Privacy Policy includes Device Information (defined below) and Order Information (defined below). 2. Our Data Protection and Data Privacy Principles We have implemented security features that are designed to prevent loss, misuse, alteration, or unauthorized release of, or access to, Personal Data provided to us. We have designed the Site to limit the collection and processing of Personal Data. The confidentiality of any communication or material transmitted to or from us on, through, or in relation to the Site (including any instant messaging feature made available or through the Site) or by e-mail or other electronic communication cannot be guaranteed. We are not responsible for the security of information transmitted via the Internet. If you do not want to communicate with us via the Internet, you may contact us by mail at the mailing address set forth in the "Contact" section below (see section 21 below). 3. Types of Personal Data We Collect and How We Use that Data When you visit the Site, we might automatically collect certain information about you or your device, including, for example, information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we might collect information about the individual web pages, products, services, or content that you access, view, or listen to, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as "Device Information". As described in more detail in section 7 below, we might collect Device Information using the following technologies:
Additionally, when you make a purchase or attempt to make a purchase on, through, or in relation to the Site, we collect certain information from you, including, for example, your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as "Order Information". Again, when we talk about "Personal Data" in this Privacy Policy, we are also talking about Device Information and Order Information. We use commercially reasonable efforts to maintain the confidentiality of the Personal Data that you provide to us. 4. How Do We Use Your Personal Data We might use the Order Information that we collect generally to fulfill any orders placed on, through, or in relation to the Site (including, for example, processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we might use this Order Information to:
We might use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize the Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). We might also use the Personal Data in other ways. Examples of those uses might include, for example:
In addition to all of the foregoing, we reserve the right, for us and for those who we might share your personal and/or non-personal information with (including our affiliates and/or third-party travel partners), to use your personal and non-personal information when:
5. Retention of Personal Data We may retain your personal information and non-personal information for as long as it is reasonably needed for a business purpose, as described above. We may also dispose of or delete any such personal information or non-personal information at any time, except as set forth in any other agreement or document executed by both you and us concerning the same or as required by law. 6. Sharing of Personal Data We may share your Personal Data with our employees, agents, administrators, accountants, financial advisors, and legal advisors for use in connection with the work they may perform on our behalf. We may share your Personal Data in the manner set forth in the potential examples listed in Section 4, above. We also reserve the right to share your Personal Data with our affiliates, business partners, third-party travel partners or other third party service providers: (a) acting on our behalf or with our permission to provide you with our content, products, or services; (b) acting on our behalf or with our permission to fulfill your requests; (c) acting on our behalf or with our permission to send you marketing and event materials, newsletters, surveys, polls, e-mails, instant messages, or other communications; (d) supporting our operations through software, system, and platform assistance, cloud hosting, data analytics, payment processing, or the like; and/or (e) acting on our behalf or with our permission to provide, manage, administer, maintain, improve, monitor, distribute, operate, or facilitate the Site or the content, products, and services offered or made available on, through, or in relation to the Site. For example, we work with a number of third-party travel partners in connection with the tours that we provide including, without limitation, ground operators, hotels and lodges, transportation providers (e.g., bus companies, airlines, cruise lines and smaller water craft operators, and railways), governmental agencies, private land owners, and local guides. We may also utilize third party providers to accept payments for the products and services you purchase from the Site. We may share aggregate date on website users' home servers with third parties, such as marketing and data analytics firms. We may also use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative's educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt-out of certain targeted advertising by using the links below:
In certain cases, we are required to disclose Personal Data to investigate, prevent, or take action concerning: (1) legal requests; (2) the enforcement of our Terms of Use or Cancellation & Refund Policy; (3) the protection of our rights, property, or personal safety or the rights, property, or personal safety of our users and the public; (4) our exercise of legal rights; and (5) any other disclosure required by law. 7. Cookies A "cookie" is a small text file that is stored on computers, tablets, mobile phones, and any device used to browse the Internet, capable of storing navigation information for statistical or functional purposes. Some cookies may be used to recognize the user viewing a particular website, make navigation easier, and customize the content. For example, cookies allow us to remember your actions and preferences so that you do not have to re-enter information each time you visit or use the Site or navigate to another page. Cookies also allow us to keep track of items you add to your shopping cart. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. While browsing on the Site, we may collect information about traffic flow and visits to the pages of our domain. This information, obtained through cookies, will be treated in a secure manner. You can set your browser to accept or reject the setting of all or certain cookies, or to request to be notified when a cookie is set. Each browser has specific configuration instructions. However, please be aware that the blocking of cookies may have the effect that you will not be able to use all of the Site's functions. 8. Social Plugins, Social Media Widgets, and Connecting via Social Networks The Site may include different types of "social plugins" and social media widgets. These features may collect your IP address and information on which pages you are visiting on the Site, and they may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy policy of the company providing it. The Site may include social media widgets from Facebook, Instagram, YouTube, Twitter and LinkedIn that use cookies to track users and advertise to them when they visit those platforms. If you do not want to be tracked by social media widgets, log out of all social networks to which you are logged in to before visiting the Site. If you choose to log in to the Site using a social networking service, we may receive and store authentication information from that service to allow you to enable your log in and other information you may choose to share when you connect with those services. 9. Analytics Google Analytics (Functional Cookies). We use Google Analytics, a web analysis service of Google, to improve the user experience. Google Analytics helps us determine the number of visitors to the Site and helps us understand how users find the Site. Google Analytics may record your geographical location, device, internet browser, operating system, and IP address. We are not provided with information allowing us to link an individual to an IP address. More information about Google Analytics can be found at https://marketingplatform.google.com/about/analytics/. Google AdWords (Advertising Cookies). We may use Google AdWords Conversion tracking cookies to measure and optimize the performance and user experience related to our ads in Google Search or selected Google Display Network websites. More information about Google's Privacy Policy can be found at https://policies.google.com/. We may use other web analytics services in the future to help us improve the user experience. 10. Transactions. In connection with setting up your account and/or any transaction that you conduct through the Site, you may be asked to supply certain information relevant to the transaction, including, without limitation, your credit card number and expiration date, your billing address, your shipping address, your phone number and/or your email address. By submitting such information, you grant us without charge the irrevocable, unencumbered, universe-wide and perpetual right to provide such information to third parties (e.g., payment processing companies) for the purpose of facilitating the transaction. All credit card, debit card and other monetary transactions on or through the Site occur through an online payment processing application(s) accessible through the Site. This online payment processing application(s) is provided by our third-party online payment processing vendor. Our relationship with our third-party online payment processing vendor, if any, is merely contractual in nature, as that entity is nothing more than a third-party vendor to us, and is in no way subject to our direction or control; thus, their relationship is not, and should not be construed as, one of fiduciaries, franchisors-franchisees, agents-principals, employers-employees, partners, joint venturers, or the like. 11. Security We implement security measures to help protect the Personal Data collected through the Site. For example, we encrypt the transmission of information through the Site by using secure socket layer (SSL) technology. In addition, we also implement commercially reasonable security measures to protect your Personal Data, including: physical measures (e.g., locked filing cabinets and restricted access to offices); organizational measures (e.g., security clearances and limiting access on a "need-to-know" basis;" and technology measures (e.g., the use of passwords and encryption). Regardless of the foregoing, please observe that "perfect" or "100%" security does not exist on the Internet. Therefore, your access and use of the Site, and your opening of any communications sent through or as a function of the Site, are done at your own risk. 12. Other Websites This Privacy Policy only applies to the Site and any websites of our affiliates which may link to this Privacy Policy. The Site may contain links to other websites. Please be aware that we are not responsible for the privacy practices of those websites. When visiting other websites, you should read those websites' privacy policies. 13. Children Under the Age of 14 The Site is not intended for children. No one under age 14 may provide any Personal Data on the Site. We do not knowingly collect Personal Data from children under 14. If you are under 14, do not use or provide any information on the Site. If we learn we have collected or received Personal Data from a child under 14, we will use reasonable efforts to refrain from further using such Personal Data or maintaining it in retrievable form. If you believe we might have information from or about a child under 14, please contact us at info@ventbird.com. Furthermore, if you are under eighteen (18) years of age, then you (or your parent or legal guardian) may at any time request that we remove content or information about you that is posted on the Site. Please submit any such request ("Request for Removal of Minor Information") to info@ventbird.com, with a subject line of "Removal of Minor Information". For each Request for Removal of Minor Information, please state "Removal of Minor Information" in the e-mail or letter subject line, and clearly state the following in the body:
We are not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled, or incorrectly sent. Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site. Also, please note that we are not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule, or regulation requires us to maintain the content or information; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished, or reposted by the third party); when we anonymize the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information. The foregoing is a description of our voluntary practices concerning the collection of personal information through the Site from certain minors, and is not intended to be an admission that we are subject to the Children's Online Privacy Protection Act, the Federal Trade Commission's Children's Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations 14. Online Tracking We do not respond to "do not track" (DNT) signals. 15. Mergers, Acquisitions, and Other Business Transactions We may decide to sell, buy, merge, or otherwise reorganize our business. If that occurs, you will be notified via email or a prominent notice on the Site of any ownership change and any changes in the use of your Personal Data. These types of transactions may involve the disclosure of Personal Data to prospective or actual purchasers, or receiving it from sellers. We seek appropriate protection for Personal Data in these types of transactions. 16. California Privacy Rights Please note that VENT is not subject to regulation under the California Consumer Privacy Act of 2018 ("CCPA"). Therefore, even if you are a California resident and we may have personal information about you that is the type of the information subject to the CCPA, the CCPA is not applicable to Alita Health. The CCPA is inapplicable to our relationship with you. However, if you are a resident of the State of California and we have an established business relationship with you, then, pursuant to Section 1798.83 of the California Civil Code, you have the right to request the following at any time: (a) information from us free of charge regarding the manner in which we share certain personal information collected through the Site with third parties who use such information for direct marketing purposes; and (b) the discontinuation (or opt-out) of our sharing of such information with such third parties. Please submit any such request ("California Privacy Rights Request") to any one of the following: By mail: VENT, 2525 Wallingwood Drive, Suite 1003, Austin, Texas, 78746, with a subject line of "Your California Privacy Rights". By email: info@ventbird.com, with a subject line of "Your California Privacy Rights". For each California Privacy Rights Request, please state "Your California Privacy Rights" in the email or letter subject line, and clearly state the following in the body:
If you send a California Privacy Rights Request by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking. We will not accept a California Privacy Rights Request via telephone or fax; and are not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled or incorrectly sent. You are solely responsible for the accuracy and content of your personal information, and for keeping your Personal Data current and correct. Finally, as explained further above, we do not authorize third parties to collect your personal information when you use the Site, except as expressly stated in this Privacy Policy. To the fullest extent permitted by law, we are not responsible for, and you hereby release us from, any and all liability which may arise from, such third parties' unauthorized collection of your personal information. 17. Nevada Privacy Rights. For Nevada Residents Only: Effective October 1, 2019, Nevada law gives consumers in Nevada the right to restrict certain businesses from selling certain Personal Information to third parties if those third parties will license or sell such personal information to additional third parties. Please submit any such request ("Nevada Privacy Rights Request") to any one of the following: By mail: VENT, 2525 Wallingwood Drive, Suite 1003, Austin, Texas, 78746, with a subject line of "Your Nevada Privacy Rights". By email: info@ventbird.com, with a subject line of "Your Nevada Privacy Rights". 18. Canada Privacy Rights If you are a Canadian Citizen and we have an established business relationship with you, then, pursuant to Principle 9 of the Model Code for the Protection of Personal Information, you have the right to request the existence, use and disclosure of your Personal Data and be given access to that information. You are further able to challenge the accuracy and completeness of the information and have it amended as appropriate. Specifically, you are entitled to obtain free of charge, information from us regarding whether or not we have any of your Personal Data, an account of the use that has been made of that information, and an account of the third parties to which it has been disclosed. Please submit any such request ("Canada Privacy Rights Request") to any one of the following: By mail: VENT, 2525 Wallingwood Drive, Suite 1003, Austin, Texas, 78746, with a subject line of "Your Canada Privacy Rights". By email: info@ventbird.com, with a subject line of "Your Canada Privacy Rights – Attn. Canada Privacy Agent". For each Canada Privacy Rights Request, please state "Your Canada Privacy Rights" in the email or letter subject line, and clearly state the following in the body:
If you send a Canada Privacy Rights Request by mail, then please do so by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking. We will not accept a Canada Rights Request via telephone or fax; and are not responsible for a Canada Privacy Rights Request that is incomplete, incorrectly labeled or incorrectly sent. Finally, as explained further above, we do not authorize third parties to collect your personal information when you use the Site, except as expressly stated in this Privacy Policy. To the fullest extent permitted by law, we are not responsible for, and you hereby release us from, any and all liability which may arise from, such third parties' unauthorized collection of your personal information. 19. Visiting the Website from Outside the United States of America If you are accessing the Site from outside of the United States of America or otherwise contacting or visiting us from outside of the United States of America and Canada, please be aware that your Personal Data may be transferred to, stored or processed in the United States of America, where our servers are located and our database is operated. The data protection and other laws of the United States of America and other countries might not be as comprehensive as those in the country from which you are accessing the Site. By providing your Personal Data, you understand that it may be transferred to our facilities and to those third parties with whom we share it as described in this Privacy Policy. 20. DISCLAIMER OF HIPAA APPLICABILITY. VENT is not a "covered entity" as defined in the federal medical record privacy statute known as the Health Insurance Portability and Accountability Act of 1996, as amended, and the regulations issued under that law ("HIPAA"). Additionally, with respect to the Personal Information we will obtain about you, we are not a "business associate" under HIPAA. Therefore, even though your personal information contains medical information that is the type of information commonly protected under HIPAA, it is not subject to any of the protections available to you under HIPAA. HIPAA is inapplicable to our relationship with you. 21. Contact Us Should you have any further questions or suggestions regarding the protection of your Personal Data processed in connection with the use of the Site or any concerns about this Privacy and Cookie Policy, please contact us at info@ventbird.com. 22. Changes to Our Privacy Policy This Privacy Policy is effective as of the date set forth at the end of this document. We may regularly review and revise our Privacy Policy as we deem appropriate. We will make changes to the Privacy Policy available on this Site and note that this Privacy Policy has been updated, in which case the updated version of this Privacy Policy is effective immediately after it appears on this Site. This Privacy Policy was last updated on June 29, 2020. |
