This document forms part of the Terms & Conditions of Use and terms used herein are consistent with those used therein unless otherwise specified herein.
Thelma & Louise Club Limited ("we", "our" and "us") respects the privacy of its members and this policy explains what information we collect about you, how we process it and why, and the steps that we take to protect it and keep it secure.
This policy is required by data protection law. References in this policy to "data protection law" mean (as applicable) the General Data Protection Regulation (Regulation (EU) 2016/679) and all related or successor data protection legislation having effect in the United Kingdom from time to time.
Under this policy, the data controller is Thelma and Louise Club Limited, a company registered in England with company number 04863137 and having its registered office at 73 Cornhill, London, EC3V 3QQ.
Our data protection officer is Ana Roxburgh who can be contacted at firstname.lastname@example.org
WHAT WE DO
Thelma and Louise Club works on behalf of women from all over the world, its members, to inspire them to travel and connect them with the aim to find travel buddies. Members register free of charge to our website at www.thelmandlouise.com (the "site") and receive weekly newsletters which contain information about the latest trips, stories and things that happen on the site. Members are also able to create content on the site (such as trip ideas, meetups, and postcards), communicate with each other through comments and private messages and use a matching tool to find a travel buddy according to their preferences.
To connect members, to help them find travel buddies and to keep them informed about the things happening on the site, Thelma & Louise Club needs to keep contact details and personal information about its members.
PRACTICAL TIPS TO PROTECT YOUR PRIVACY AND SAFETY ON THE SITE
On our site you have access to an onsite “inbox” for private messages. This allows you to communicate directly with individual members without the need to share your personal email address.
You should adopt a common sense approach and take sensible precautions to protect your privacy when using the site, including but not limited to, the following:
- If your trip idea involves a house swap or sharing arrangement, you should not include your home address or identify your specific address or location within the trip idea. You can include the country/city and area description but specific details should be managed through your private messages following voice/video conversations and, if possible, face to face meetings in a safe public venue to validate the identity and suitability of member candidates;
- Events are public and you should not post personal or family events on the site (such as birthday parties, anniversaries, etc.). Meet-ups are for events, festivals or similar type activities that you feel are useful to share with all members. You should not disclose any private information, including your home address, phone number, etc. within the events section;
- Remember to close your browser window when you have finished what you have being doing on the site; this is to ensure that others cannot access your personal information and correspondence if your computer is accessible to others or if you share your computer with someone else or are using a computer in a public place like a library or an internet cafe; and
- As a general rule do not post anything on the site that you would not mind the entire world being able to see, read or share.
WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect personal data in different ways depending on how you choose to connect with our services. We collect personal data when you sign up to our newsletter as a non-member, when you register to use our the site by creating an account and when you complete a profile to share with potential travel companions.
Signing up to our newsletter. If you sign up to our newsletter we collect your name and email address.
Creating an account and profile. If you create an account and a profile on the site, then the personal data we collect includes your name, the town and country where you live, year of your birth, your email address, a profile picture, travel preferences and any other information that you choose to share with the other members by adding it to your profile. You will also be asked to create a user name, which does not have to be your real name (this helps to protect your privacy online). Other members will be able to see your profile information, but not your email addresses or real name (unless you choose to use your real name as your username). Non-members do not have full access to the site content or to members’ information. Additionally, users are able to follow topics and members of interest when they update their profile.
We ask that you do not enter certain personal information into your Edit Profile or Edit Account areas (e.g. do not use your address or password as your username, or include your password or address in your written responses), because if you do then it may be posted publicly on the site. Please note that nowhere on the site do we knowingly collect personal information from children under the age of 18, as we require that all members represent and warrant to us that they are at least 18 years old.
Activities on our site. Our site also stores the content your activities on the site after you have created an account, including transaction history information, browsing history information, searching history information, registration history information, creating trips or meetups, sharing postcards, adding comments or messages and the content of communications between you and other members through the site. This can include information in or about the content you provide, such as the location of your next trip or the details you write in a postcard. We also collect information about how you use our website, such as the types of content you view and engage with and the frequency and duration of your activities on our site.
Device information. We collect information from or about the computers, phones, or other devices where you install or access our website. We may associate the information we collect from these different devices, which helps us provide consistent services across all devices. Here are some examples of the device information we collect: operating system, browser type, time zone and IP address.
HOW WE USE YOUR PERSONAL INFORMATION
We are passionate about creating engaging experiences for our members, inspiring them and helping them to find travel buddies. Our members are the only ones who benefit from us collecting the data, because the data that we require aids in the search process for our members. We collect your personal information for the following purposes:
Communicating with you. If you have subscribed to our newsletter or to receive other marketing communications, we use your contact details to send you newsletters and/or marketing communications. We also use your contact details to communicate with you about our services and let you know about our policies and terms. We also use your information to respond to you when you contact us.
Finding travel buddies. The personal information you give us on via site, particularly your profile information, is used to display your profile in the members' area of the site and to help you find travel companions with interests or travelling objectives similar to your own. We profile members in the sense that we collect your personal information and then use that in the ‘Find a travel buddy’ tool. This data is not used to evaluate, analyse or predict behaviour, location or movements. Its purpose is to personalise the service and make it more useful for you and other members. When we have location information, we use it to tailor our services for you and others, like helping you find other members in your area, organising a meetup or meeting up with local members when you travel to a place.
Improve and develop services. The information we collect about website usage enables us to understand how our website is used, which in turn enables us to deliver our services more efficiently, personalise content, and make suggestions for our members. We also test features in development, and analyse the information we have to evaluate and improve services, develop new products or features, and conduct audits and troubleshooting activities.
Show and measure ads and services. We use Google AdWords for our advertising and measuring system so we can show you relevant advertisements on and off our services and measure the effectiveness and reach of advertisements and services. Learn more about advertising on our services and how you can control how information about you is used to personalize the ads you see.
Promote safety and security. We use the information we have to help verify accounts and activity, and to promote safety and security on and off of our services, such as by investigating suspicious activity or violations of our terms or policies. We work hard to protect your account using password, two factor authentication, automated security updates, local firewall, technical support engineers and advanced technology such as encryption.
OUR THE LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL INFORMATION
Under data protection laws we must have a legal ground to process your personal information.
Where you have subscribed to our mailing list or to receive marketing emails, we process your contact details for this purpose on the ground that you have consented to receive such communications.
Where you have created an account on the site and provided information in your profile, you have agreed to our terms and conditions, and we process your information in so far as it is necessary for the performance of the contract between you and us relating to your use of the site.
In some cases we also process your personal information because we have a legitimate interest in communicating with you to promote, improve and operate our site. In accordance with our obligations under data protection law, we have carefully weighed up your interests and fundamental rights and freedoms against our interest to process your information for these purposes and we are satisfied that we are justified in processing your information for this purpose.
In some cases we may process your information because it is necessary for us to comply with our legal obligations, such as where we are required to remove defamatory content.
WHO IS YOUR PERSONAL INFORMATION SHARED WITH?
Here at Thelma and Louise Club we take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us. Save as described below, we will never pass our members’ personal data to a third party without consent.
Third party suppliers. We work with third party companies, such as MailChimp for communication with our members. We also work with a third party to host and maintain our website. These third parties will process information only in accordance with our instructions and are bound by obligations of confidentiality.
Advertising, Measurement and Analytics Services (Non-Personally Identifiable Information Only). We sell advertising space on the site as this makes it possible o provide our services for free. We want the advertisements you see on the site to be as interesting and useful to you as possible. With this in mind, we use Google AdWords to deliver the ads and Google Analytics for measurement services. While we share all of the information we have about you to show you relevant ads, we do not share information that personally identifies you (personally identifiable information is information like name or email address that can by itself be used to contact you or identifies who you are) with advertising, measurement or analytics partners unless you give us permission. We may provide these partners with information about the reach and effectiveness of their advertising without providing information that personally identifies you, or if we have aggregated the information so that it does not personally identify you. For example, we may tell an advertiser how its ads performed, or how many people viewed their ads, or provide non-personally identifying demographic information (such as 25 year old female, in London who wants to travel to India) to these partners to help them understand their audience or customers.
To opt out of online interest-based ads on the web, visit the European Interactive Digital Advertising Alliance. You'll need to opt out separately with each browser you use.
If you allow online interest-based ads:
• You'll see ads that are more interesting and relevant to you.
If you don't allow online interest-based ads:
• You'll still see ads, but they won't be as relevant to you.
• You may still see ads for other reasons, such as:
• Your age, gender or location.
• The content in the app or website you're using.
Corporate and legal requirements. Your personal information may be passed on to a third party in the event of a transfer of ownership or assets, or a liquidation or bankruptcy. We may also disclose personal information or financial information when we determine that such disclosure is necessary to comply with applicable law, to cooperate with law enforcement or to protect the interests or safety of ourselves or other members or visitors to the site. We also may disclose your personal information or financial information to our subsidiary and parent companies and businesses, and other associated legal entities and businesses with which we are under common corporate control.
International transfers. Information that you add to your profile will be made public to other members that enrol to use our site. Some of these users may be based outside the European Economic Area ("EEA"). This requires a justification under data protection laws. When you create your account, you are required to agree to our terms and conditions, which creates a contract between you and us. The publication of your information to other members, some of whom may be outside the EEA, is necessary for the performance of the contract between you us for the provision of the service provided by the site and this is the legal justification for making it available to members who may be located outside the EEA.
If you subscribe to our newsletter or join one of our mailing lists, we will provide your email address to a third party to automate the sending of emails to you. The automation service is provided by an American company, The Rocket Science Group LLC d/b/a MailChimp and your email address may be transferred outside the EEA by them. The Rocket Science Group LLC d/b/a MailChimp have signed up to the US Privacy Shield, which offers safeguards in respect of you personal data. For more information, you can visit the US Privacy Shield website at www.privacyshield.gov/welcome.
Save as described above, to the best of our knowledge, understanding and belief, your information will not be transferred outside of the EEA or to any country which is not approved by the European Commission. If this changes then we will let you know.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION AND HOW TO DELETE YOUR ACCOUNT
If you have subscribed to our newsletters, we retain your contact details until you unsubscribe or tell us that you no longer wish to receive newsletters or other marketing communications from us.
If you create an account and a profile on the site, we store data for as long as it is necessary to provide products and services to you and others, including those described above. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services.
You can manage your profile and account information by editing and amending your account and your_profile.
You can delete your account any time by sending us an email at email@example.com and requesting this. When we remove your account from our website, we delete all your content, things you have posted, such as trips, meetups, trips reviews, comments and photos. If you do not want to delete your account, but want to temporarily stop using our services, you do not need to do anything. Keep in mind that information that others have shared about you is not part of your account and will not be deleted when we delete your account.
Under data protection law you have the following rights:
- if we are processing your data on the basis of your consent then you have the right to withdraw that consent at any time. Consent can be withdrawn by notifying us using the details set out in section 11 below. The lawfulness of our historic processing based on your consent will not be retrospectively affected by your withdrawal of consent;
- the right to access a copy of your information which we hold. This is called a 'subject access request'. Additional details on how to exercise this right are set out in section 7, below;
- the right to prevent us processing your information for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by [checking certain boxes on the forms we use to collect your data]. You can also exercise the right at any time by contacting us using the details set out in section 11, below;
- the right to object to decisions being made about you by automated means. We will inform you if your information is subject to automated processing; We do not make automated decisions about you based on your information.
- the right to object to us processing your personal information in certain other situations;
- the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate;
- the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law; and
- in certain circumstances, the right to request the information we hold on you in a machine readable format so that you can transfer it to other services.
You also have the general right to complain to us (in the first instance) and to the Information Commissioner's Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out below. The Information Commissioner's Office website is www.ico.org.uk.
For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (www.citizensadvice.org.uk) or the Information Commissioner's Office (www.ico.org.uk).
ACCESS TO INFORMATION
Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you. You must send us proof of your identity, or proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to us using the contact details below.
You will not have to pay a fee unless you are requesting copies of documents you already possess, in which case we may charge our reasonable administrative costs. We will also be allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you if your request is clearly unfounded or excessive. In very limited circumstances, we are also entitled to refuse to comply with your request if it is particularly onerous.
Version date: 23 May 2018
Copyright © 2018 Thelma and Louise Club Limited. ALL RIGHTS RESERVED.