Last Updated: November 6, 2018
Thank you for using Adventure IO!
When this policy mentions “Adventure IO,” “we,” “us,” or “our,” it refers to the Adventure IO, Inc. (the “Data Controller”).
There are three general categories of information we collect.
1.1 Information You Give to Us.
1.1.1 Information that is necessary for the use of the Adventure IO Platform.
We ask for and collect the following personal information about you when you use the Adventure IO Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
1.1.2 Information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using Adventure IO Platform. This additional information will be processed based on your consent.
1.1.3 Information that is necessary for the use of the Payment Services.
The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:
1.2 Information We Automatically Collect from Your Use of the Adventure IO Platform and Payment Services.
When you use the Adventure IO Platform and the Payment Services, we automatically collect information, including personal information, 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 in being able to provide and improve the functionalities of the Adventure IO Platform and Payment Services.
1.3 Information We Collect from Third Parties.
Adventure IO and Adventure IO Payments may collect information, including personal information, that others provide about you when they use the Adventure IO Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Adventure IO Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Adventure IO Platform, create and maintain a trusted and safer environment and comply with our legal obligations.
2.1 Provide, Improve, and Develop the Adventure IO Platform.
We process this information given our legitimate interest in improving the Adventure IO Platform and our Users’ experience with it, and where it is necessary for the adequate performance of the contract with you.
2.2 Create and Maintain a Trusted and Safer Environment.
We process this information given our legitimate interest in protecting the Adventure IO Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. 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 Adventure IO Account.
2.4 How the Payments Data Controller uses the Information Collected.
The Payments Data Controller processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
3.1 With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Adventure IO Account or when you participate in promotional activities conducted by Adventure IO partners or third parties.
3.2 Sharing between Users.
To help facilitate bookings or other interactions between Users, we may need to share certain information, including personal information, with other Users, as it is necessary for the adequate performance of the contract between you and us, as follows:
We don’t share your billing and payout information with other Users.
3.3 Profiles, Listings, and other Public Information.
The Adventure IO Platform lets you publish information, including personal information, that is visible to the general public. For example:
Based on our legitimate interest to promote the Adventure IO Platform we may display parts of the Adventure IO Platform (e.g., your Adventure page) on sites operated by Adventure IO’s business partners, using technologies such as widgets or APIs. If your Adventures are displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on the Adventure IO Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.4 Additional Services by Guides.
Guides may need to use third party services available through the Adventure IO Platform to assist with managing their Adventures or providing additional services requested by you. Guides may use features on the Adventure IO Platform to share information about the Participant (like Adventure times and dates, Participant name, Participant phone number) with such third party service providers for the purposes of coordinating the stay, managing the Adventure, or providing other services.
3.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Adventure IO 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: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Adventure IO, (iii) 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, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Users, or (v) to protect the rights, property or personal safety of Adventure IO, its employees, its Users, or members of the public.
Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) 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 Adventure IO’s property, its Users and the Adventure IO Platform. 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.
3.6 Service Providers.
Adventure IO uses a variety of third party service providers to help us provide services related to the Adventure IO Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.
Adventure IO will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
3.7 Corporate Affiliates.
To enable or support us in providing the Adventure IO Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.
3.8 Social Media Platforms.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Adventure IO Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal data are not controlled or supervised by Adventure IO. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask Adventure IO to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com.
3.9 Collection and Remittance of Occupancy Taxes.
In jurisdictions where Adventure IO facilitates the Collection and Remittance of Occupancy Taxes as described in the “Taxes” section of the Terms of Service, Guides and Participants, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Guide’s and Participants’ data and other information relating to them or to their transactions and bookings Taxes to the relevant tax authority, including, but not limited to, the Guide’s or Participant’s name, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Guides from Participants, and contact information.
3.10 Government Registration.
In jurisdictions where Adventure IO facilitates or requires a registration, notification, permit, or license application of a Guide with a local governmental authority through the Adventure IO Platform in accordance with local law, we may share information of participating Guides with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Guide’s full name and contact details, Adventure address, tax identification number, Adventure details, and number of nights booked.
3.11 Guide Information Provided to Adventure IO for Work Customers.
If a booking is designated as being for business purposes and made by a Participant affiliated with a company or other organization enrolled in our Adventure IO for Work Program (either or both an “Enterprise”), we may disclose information related to the booking to the Enterprise, such as the name of the Guide, the Adventure address, pricing, Adventure details, and other related information, to the extent necessary for the adequate performance of the services. At the request of the Enterprise or the Participant, we may also share this information with third parties engaged by the Enterprise to provide travel management, travel planning, financial reporting, personnel management, crisis management, or other services.
3.12 Participant Information Provided to Adventure IO for Work Customers.
If you have linked your Adventure IO Account with an Enterprise, and you are included on a booking designated as being for business purposes, we may disclose information related to the booking to your Enterprise to the extent necessary for the adequate performance of the services. Typically, this includes your name, dates of the booking, number of Participants, pricing, Adventure details, the Adventure address, and other related information. At the request of you or your Enterprise, we may also disclose this information to service providers engaged by it, such as companies that provide travel management, financial reporting, personnel management, crisis management, or other services. In the event of a dispute, emergency, or similar situation involving a booking identified as being for business purposes, Adventure IO may also share additional relevant information it believes is necessary to safely and quickly address the situation.
3.13 Business Transfers.
3.14 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4.1 Analyzing your Communications.
We may review, scan, or analyze your communications on the Adventure IO Platform 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 contact information and references to other websites. 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.
These activities are carried out based on Adventure IO’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2 Linking Third Party Accounts.
You may link your Adventure IO Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
4.3 Google Maps/Earth.
A cookie is a small data file that is transferred to your device (e.g. your phone or your computer). For example, a cookie could allow us to recognize your browser, while another could store your preferences. There are two types of cookies used on the Adventure IO Platform: (1) “session cookies” and (2) “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device after you close your browser, and can be used again the next time you access the Adventure IO Platform.
We use these technologies for a number of purposes, such as:
We may also allow certain business partners to place these technologies on the Adventure IO Platform. These partners use these technologies to (1) help us analyze how you use the Adventure IO Platform, such as by noting the third party services from which you arrived, (2) market and advertise Adventure IO services to you on the Adventure IO Platform and third party websites, (3) help us detect or prevent fraud or conduct risk assessments, or (4) collect information about your activities on the Adventure IO Platform, other sites, and/or the ads you have clicked on. For example, to help us better understand how people use the Adventure IO Platform, we work with a number of analytics partners, including Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here.
Third parties may also use such tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the Adventure IO Platform and on other websites and online services. Targeting and advertising cookies we use may include Google, and other advertising networks and services we use from time to time. For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To the extent advertising technology is integrated into the Adventure IO Platform and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms.
The Adventure IO Platform may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of the Adventure IO Platform. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Adventure IO Platform to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information. If you choose to decline cookies, some parts of the Adventure IO Platform may not work as intended or may not work at all.
The Adventure IO Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Adventure IO doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Adventure IO, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
You may exercise any of the rights described in this section before your applicable Adventure IO Data Controller and Payments Data Controller by sending an email to firstname.lastname@example.org. Please note that we may ask you to verify your identity before taking further action on your request.
6.1 Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your Adventure IO Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Adventure IO Account).
6.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information 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).
6.4 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 to provide the Adventure IO Platform to you, you can request that we erase your personal information and close your Adventure IO Account. Please note that if you request the erasure of your personal information:
6.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by Adventure IO you may withdraw your consent at any time by changing your Account settings or by sending a communication to Adventure IO 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. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Adventure IO override your own.
6.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Adventure IO and Adventure IO Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Adventure IO 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 Adventure IO to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com.
6.7 Lodging Complaints.
You have the right to lodge complaints about the data processing activities carried out by Adventure IO before the competent data protection authorities.
7.1 EU-US & Swiss-US Privacy Shield.
Under the Privacy Shield Framework, Adventure IO and Adventure IO Payments are subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at Adventure IO, Inc., Legal Department, via email. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or Commission or seek assistance from our designated Privacy Shield independent recourse mechanism, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.
7.2 California & Vermont Residents.
Adventure IO will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.
7.3 California Privacy Rights.
California law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact” section for where to send such requests. Adventure IO do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.
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 Adventure IO Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Adventure IO Account, please contact us following the instructions in the Contact Us section below.