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Privacy Policy

THE “The Chauffeur of Positano” Privacy Policy

Last updated: Dicember 1, 2018

At The Chauffeur of Positano (from now on TCP), we recognize that earning and retaining your trust is one of the most important things we do as a business. Protecting your privacy is a responsibility we take very seriously.

We have prepared this Privacy Policy to help you understand how TCP collects, uses and seeks to safeguard the Personal Information (as defined below) you provide to us on our websites, mobile applications, via email, and through our service providers and distribution partners. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party, including any third-party distribution partners, suppliers and tour operators, and any third party operating any site to which our websites contain a link. By downloading, accessing or using our websites or content, or using a TCP application (“Application”) on a mobile phone, tablet or similar device (“Device”), or providing information to us in connection with our websites, mobile applications or other sites or services, you agree to the terms and conditions of this Privacy Policy.

WHO WE ARE:

TCP is an online service that enables users to research, find, and book travel services in Italy. TCP’s products and services are made available through chauffeurpositano.com and TCP-affiliated websites around Italy.

chauffeurpositano.com (together with other TCP-branded websites) is our flagship website, where we offer our complete range of products and services directly to consumers.

At TCP we also work with affiliates who distribute our products and services to consumers through their individual websites. We typically host our affiliates’ product-information and booking pages, and manage payment and credit card information.

We also work with distributors (as discussed below) who manage the hosting, purchase and payment for our products and services.

If you provide information directly to our affiliates, distributors or suppliers, the terms of their respective privacy policies, and not this Privacy Policy, will apply to such disclosures. You should carefully review the privacy policies of the affiliate partner, distributor or supplier prior to providing information to such third parties. See “Our Affiliates, Distributors and Suppliers” below for additional information.

WHAT INFORMATION DO WE COLLECT?

IN GENERAL

We receive and store any information you enter on our websites or give us in any other way. We collect two types of information from you on our websites, mobile applications, via email, and through our service providers and distribution partners. Personal Information is information that identifies you personally, such as your first and last name, email address, telephone number, postal and email addresses, user name and password, and billing information (such as your credit card number, cardholder name, and card expiration date). We also collect Other Information that does not identify you personally, such as gender, country of residence and other demographic information.

When you register with TCP, we ask for basic information including your name and email address, and Other Information such as your signup location. You can choose not to provide information to us, but in general some information about you is required in order for you to receive relevant offerings from TCP and its partners and enjoy other benefits of being a registered member. For example, in order to purchase products or services, it is necessary for you to disclose Personal Information, including your name, address, email address, phone number, credit card details and other personally identifying information. If you do not provide Personal Information when purchasing one of our supplier’s products or services, we cannot confirm your purchase or facilitate your booking.

In some instances we may also ask for Other Information such as demographic data, including your country of residence, gender, age, travel habits, etc. We also use cookies (as discussed below) to collect information about the performance and usability of our websites.

Information About Others

You may have the opportunity to provide contact and travel-related information for other people through our websites. If you “Refer a Friend” or if you purchase products or services for someone else through TCP, you will need to submit that individual’s personal information. You must obtain the consent of other individuals prior to providing us with their personal information.

Information from Other Sources.

We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources and add it to other information about you. For example, if you visit TCP by “clicking through” from a site operated by one of our business partners, and you have registered with that partner, then information about you that you have provided to that partner may be shared with us, such as contact information and demographic information. As another example, if you access third party services, such as social media services, through our website or before coming to our website, we may collect information such as your user name and other information made available to us through those services. We will work with our existing partners and potential future partners to improve and personalize your use of our website in accordance with the practices outlined in this Privacy Policy.

AUTOMATIC INFORMATION:

When you visit chauffeurpositano.com or any of our affiliates’ web pages that are hosted by us, our web server automatically recognizes and collects your IP address, which is assigned by your Internet Service Provider and does not identify you personally, web browser software, and referring website. To help us analyze the usage of our websites and related services, and to send more relevant communications to you, we also collect and keep track of Other Information about your online activity, such as content viewed, pages visited, and searches and/or reservations facilitated or made. One of our goals in collecting this automatic information is to help us understand the interests and preferences of our users and customize your user experience. For example, if you frequently visit Paris and London, we may send you special notices listing deals and popular products for those destinations. If you are subscribed to any of our email marketing communications – including newsletters and destination alerts, it is necessary for you to disclose Personal Information such as your name and email address and Other Information such as your home country.

PAYMENT INFORMATION:

If you book a tour or excursion with third-party suppliers facilitated by TCP, we will collect payment information from you, including your credit card number, cardholder name, expiration date, authentication code, and billing address.

We may offer members the option to save information related to method and choice of payment on our websites. If you save such payment details on TCP, you will be able to add, delete, or modify that information at any time in your Account Settings.

Location Information and Other Information from Devices

When you use an Application on a Device, we will collect and use information about you in generally similar ways and for similar purposes as when you use the TCP website. In addition, we may collect information about your location if you have instructed your Device to send such information to the Application via the privacy settings on that Device, or if you have uploaded photos tagged with location information. We may use the location information collected from your Device or photos to enhance your use of the Application by providing you with relevant content and contextual advertising. For example, we may use your location to show you tours or excursions near you when you are travelling. You can change the privacy settings of your Device at any time in order to turn off the functionality to share location information with the Application and/or the functionality to tag your photos with location information. Please note that turning off location sharing may affect certain features of our Application. If you have any queries about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.

Your Contributions

You can contribute to the TCP websites in a number of different ways, including writing reviews, uploading photos, filling out your public profile, and rating other users’ contributions. We may store these contributions (your “Content”), publicly display them on our websites and Applications and those of our affiliate partners and distributors, display them to other users, share them with our affiliate partners and distributors, and use them for promotional purposes. Note that if you include Personal Information in your Content, it can be used and viewed by others. We are not responsible for the information you choose to include in your Content.

COOKIES, AND HOW WE USE THEM:

“Cookies” are pieces of information that are stored by your web browser on your computer’s hard disk, for record-keeping purposes. Cookies in and of themselves only identify your computer; they do not personally identify you.

First-Party Cookies: At TCP we make use of cookies to help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was visiting our site, record session information, collect information on how you visit and access our websites and Applications. We also may record your password in a cookie if you checked the box entitled “Save this password for automatic sign-in”. Please note that member IDs, passwords, and any other account-related data included in such cookies are encrypted for security purposes. We also use cookies to help us customize the content, experience, and advertisements provided to you on our websites and Applications and to analyze and measure the effectiveness of our email communications, website features and offerings, and advertisements.

Most web browsers allow you to turn off cookies; however, turning off cookies will limit your use of our websites and Applications. To learn more about changing your browser’s cookie settings, please see the appropriate informational link:

Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Cookies-frequently-asked-questions

Firefox: http://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

Safari: http://support.apple.com/kb/PH5042

Third-Party Cookies: TCP and its affiliated websites are committed to providing you with relevant content and information across our sites. To do this, we may collect information about your searches and other site activities and use third-party advertising companies to serve ads while you are visiting our websites and we permit these companies to place and access their own cookies on your computer in the course of serving advertisements. Such advertisers do not have access to the information we collect through TCP cookies. Other companies’ use of their cookies is subject to their own privacy policies and not ours.

Web Beacons: Our websites also may use Web beacons (also known as clear gifs, pixel tags or Web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a Web page. We use Web beacons to monitor the traffic patterns of users from one page within our sites to another, to deliver or communicate with cookies, to understand whether you have come to our site from an online advertisement displayed on a third-party website, and to improve site performance. We also may allow our service providers to use Web beacons to help us understand which emails have been opened by recipients and to track the visitor traffic and actions on our site. This helps us measure the effectiveness of our content and other offerings.

Data collected by business partners and ad networks to serve you with relevant advertising: Many of the advertisements you see on the TCP family of sites are served by TCP or its service providers; however, we also allow third parties to collect information about your online activities through cookies and other technologies. These third parties include (1) business partners, who collect information when you view or interact with one of their advertisements on our sites, and (2) advertising networks, who collect information about your interests when you view or interact with one of the advertisements they place on many different websites on the Internet. The information gathered by these third parties is used to make predictions about your characteristics, interests or preferences and to display advertisements on our sites and across the Internet tailored to your apparent interests.

Please note that we do not have access to or control over cookies or other technologies these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Policy. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies.

Response to Do Not Track signals: Your web browser may transmit a “Do Not Track” (“DNT”) signal to TCP and other websites. Because of differences in web browsers’ default settings and the manner in which browsers incorporate DNT signals, it is sometimes unclear to site operators whether site visitors have selected the DNT setting themselves, or whether they are aware that they have a choice in determining the setting. TCP does not currently respond to DNT signals. Once the Internet industry has settled on standards related to this issue and TCP recognizes such standards, we may reevaluate this approach.

HOW WE USE AND DISCLOSE YOUR PERSONAL INFORMATION:

We use your personal information in the following ways:

For registration and to manage your account, including to allow your access to and use of our site; to communicate with you in general, including to provide information about TCP and invitations from the TCP family of companies

To provide you with the information you request about our products

To send you email marketing messages and information

To enable our third-party suppliers to fulfill your bookings

To confirm your purchases

To ensure you are correctly billed

To enable us to publish content you submit to us to our family of websites and on our Applications

To measure and track demographic details about our customers

To target content on our website to more closely match your interests and otherwise customize your experience with TCP, including customizing the ads shown to you

To target the appropriate content for email marketing messages to better match your interests

To respond to your questions and comments

To measure interest in and improve our products, services, websites and Applications

To notify you about offers and products or services available from us or our partners that may be of interest to you

To solicit information from you, including through surveys

To resolve disputes or troubleshoot problems

To prevent potentially prohibited or illegal activities

To enforce our Terms of Use

As otherwise described to you at the point of collection

To tailor our products and services to suit your personal interests and the manner in which visitors use our sites, applications and social media assets

To operate, evaluate and improve our business and the products and services we offer

To analyze and enhance our marketing communications and strategies (including by identifying when emails sent to you have been received and read)

To analyze trends and statistics regarding visitors’ use of our sites, mobile applications and social media assets, and the purchases visitors make on our sites

To protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users

We will provide you with choices regarding the use and disclosure of your Personal Information for marketing purposes.

SHARING WITH SOCIAL MEDIA SERVICES:

If you connect to TCP using Facebook, we may show you reviews, photos and tours that your Facebook friends have posted, shared, saved or purchased on TCP. Note that, if you have Facebook friends who are using TCP, they may also share information about you with us through Facebook. If you wish to prevent that sharing, please review your Facebook privacy settings.

You can also choose to access third-party social media websites and services through TCP (such as Facebook and Twitter). When you do so, you are sharing information with those sites, and the information you share is governed by their privacy policies. You may also be able to modify your privacy settings with these third party social media websites.

SHARING WITH SERVICE PROVIDERS:

Some of the Personal Information we collect is shared with our service providers (e.g. tour operators) who are directly involved in fulfilling the purchases you have made from us. We only provide our service providers with your name and your local contact details, if you provide them (e.g., your hotel name for pick-ups and drop-offs, your local phone number, your mobile phone number, your email address, etc.) We do not provide our service providers with any other Personal Information. If you decide to provide any Personal Information directly to a service provider, we recommend that you review the service provider’s privacy policy to determine how such service provider may use or disclose your Personal Information.

Sharing with Third Party Vendors

We also share your Personal Information with third party vendors who provide services or functions on our behalf, including business analytics, payment processing, customer service, marketing, public relations, distribution of surveys or sweepstakes programs, and fraud prevention. We may also authorize third-party vendors to collect information on our behalf, including, for example, as necessary to operate features of our websites or Applications or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.

We currently contract with several third-party online partners to help manage and optimize our Internet business and communications. We use the services of third-party marketing companies to help us measure the effectiveness of our advertising and how visitors use our website. To do this, we use web beacons and cookies provided by such marketing companies in connection with our websites. The information we collect helps us learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. If you do not want to help us learn how to improve our site, products, offers and marketing strategy, you can “opt-out” of our ability to analyze such data.

SHARING WIITH REFERRING WEBSITES:

If you were referred to TCP from another website, we may share your registration information, such as your name, email address, mailing address, telephone number and travel preferences, about you with that referring website. We have not placed limitations on the referring websites’ use of personal information and we encourage you to review the privacy policies of any website that referred you to TCP.

Sharing with Companies within our Corporate Family

We may share your personal information within the TCP group of companies. This sharing enables us to provide you with information about products and services, both travel-related and other, which might interest you. To the extent that our parent company and corporate affiliates have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy. They also will comply with applicable laws governing the transmission of promotional communications and, at a minimum, give you an opportunity in any commercial email they send to choose not to receive such email messages in the future.

OTHER SHARING:

We may also use or disclose Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legitimate and enforceable subpoenas, court orders, or other legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions or otherwise establish or exercise our legal rights; (e) to protect and defend our rights, property or safety or those of any of our affiliates, our customers, or others; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; (h) to investigate, prevent, or take action regarding illegal or suspected illegal activities; (i) in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or (j) as otherwise required by law.

We may use and disclose Other Information for any purpose. In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information, as long as it is so combined.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our website receives or the most popular excursions or tours. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.

EMAIL COMMUNICATIONS YOU CAN EXPECT TO RECEIVE FROM TCP:

We may send to you marketing emails with information about TCP deals, destination and product news, offers, competitions, and other special promotions that we believe that you will find valuable, interesting or informative. We will provide you with choices regarding our use of your Personal Information for marketing purposes. If you are no longer interested in receiving future email marketing communications from TCP, you have several choices for opting out of future mailings:

You may unsubscribe at any time by following the directions and link included in each email marketing message we send.

Please note that, even if you opt-out of receiving future marketing communications from TCP, we will continue to send to you emails regarding your purchases and bookings, and regarding administrative information such as changes to our terms, conditions and policies. If you make a booking or purchase at one of our websites, we may also send you information about new products, or ask your opinion about our websites, etc., so that we may improve our service to you and other consumers.

OUR AFFILIATES, DISTRIBUTORS AND SUPPLIERS:

Tours, activities and experiences advertised on our site are made available through our third-party affiliates, distributors and suppliers. Our affiliates, distributors and suppliers may have privacy policies that differ from TCP’s Privacy Policy.

You should also be aware that some product or tour suppliers and some of our affiliates and distributors may need additional Personal Information or Other Information (such as health or physical fitness information) to determine whether you can participate in an activity. You should read and rely upon the relevant supplier, affiliate or distributor Privacy Policy only (and not TCP’s Privacy Policy), if TCP does not collect this information from you directly.

HOW YOU CAN ACCESS YOUR INFORMATION:

We take reasonable steps to ensure that your information is relevant to its intended use, accurate, and complete. You can access and update your contact information by accessing your account via the Viator website. If you update any of your information, we may keep a copy of the information that you originally provided to us in our archives for uses documented in this policy.

You can also close your TCP account by accessing your account via the TCP website. We will send you an email to confirm your request. Please note that after you close an account, you will not be able to sign in or access any of your Personal Information. However, you can open a new account at any time.

Please also note that we may retain certain Personal Information and Other Information associated with your account in our archives, including for analytical purposes as well as for recordkeeping integrity, fraud prevention, dispute resolution, investigations, and compliance with legal requirements.

YOUR CHOICES:

As discussed above, you can choose not to provide us with any information, although it may be needed to take advantage of certain features offered on TCP. You also can add or update information and close your account as described above. In addition, as described above, you may opt out from receiving e-mail communications from TCP. Please note that we reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating either to your TCP account, without offering you the opportunity to opt out of receiving them. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if you refuse to accept cookies from TCP, you will not be able to access portions of our site.

OUR SECURITY AND STORAGE MEASURES:

At TCP we seek to maintain the integrity and security of your Personal Information.

We use industry-standard encryption protocols when receiving and transferring your Personal Information. In fact, when you send Personal Information to us over the Internet, we first require that a “secure session” be established using Secure Socket Layer (SSL).

We seek to store your Personal Information in secure operating environments that are not accessible to the general public, and to have security measures in place at our physical facilities to protect against the loss, misuse or alteration of your Personal Information by our employees or third parties.

However, no data transmission over the Internet or data storage environment can be guaranteed to be 100% secure, so we cannot give an absolute assurance that the information you provide to us will be secure at all times. TCP will not be held responsible for events arising from unauthorized access to your Personal Information. TCP will rely on you telling us if you experience any unusual events that may indicate a breach in your information security. We will then seek to investigate whether the security breach was related to the data transmissions from or to TCP and let you know what steps can be taken and have been taken to help rectify the problem. Further action, such as reporting incidents to the police or other proper authorities, may also be required.

CHILDREN’S PRIVACY:

TCP is a general audience site and does not offer services directed to children. Should an individual whom we know to be a child under age 13 send personal information to us, we will delete or destroy such information as soon as reasonably possible.

EXTERNAL LINKS:

If any part of any TCP website links you to other websites, those external websites do not operate under this Privacy Policy. We are not responsible for the privacy practices of other sites and we recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.

VISITING OUR WEBSITE FROM OUTSIDE THE UNITED STATE:

If you are visiting any of our websites from outside the United State, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. By becoming a user, you have given us your express and informed consent to transfer the data that you provide to us to the United States and to process it in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that TCP does take steps pursuant to laws in the United States to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

CHANGES TO OUR PRIVACY POLICY:

We know that our business will continue to evolve as we introduce new products, and, as such, from time to time this Privacy Policy may be reviewed and revised.

TCP reserves the right to change this Privacy Policy by posting the changes on its website. You can determine when this Privacy Policy was last updated by reviewing the LAST UPDATED legend above and any revisions will take effect upon posting. We will notify our members of material changes to this Privacy Policy by either sending a notice to the email address you provided to us or by placing a notice on our Website. We encourage you to check this Privacy Policy from time to time to review the most current version. Using our websites or applications after a notice of changes has been sent to you or published on our website shall constitute consent to the changed terms and practices.

CALL RECORDING AND MONITORING:

Please be aware that calls to and from TCP may be recorded. We may use the call recordings to monitor our customer service for quality or compliance purposes, to check the accuracy of the information you provide us, for fraud prevention purposes, or to provide training to our staff. We will retain the call recordings for as long as reasonably necessary to perform such activities and then delete them. Any personal information obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy

CONTACTING US:

For some TCP services you can access and update your registration and Personal Information online.

To correct or update any other Personal Information, or if you have questions about TCP’s Privacy Policy, please email us at [email protected]