Last updated: 13 February 2025
This privacy notice for WithU Travel Limited (doing business as TrvlWell) ("we", "us", or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
If you have any questions or concerns, reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. For any further inquiries, please contact us at info@trvlwell.net.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice. For more details on each topic, click the corresponding link below or refer to the Table of Contents.
For the full details, please review the complete privacy notice below.
Please note that in general in the delivery of our services to you we will not process any personal data, meaning that the data we request from you through the App will not allow us to identify you. It may be that you provide us additional information, or contact us in a way that allows us to identify you, in which case we will be processing your personal data.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
A. Personal Information You Disclose to Us
B. Information Automatically Collected
2. HOW DO WE PROCESS YOUR INFORMATION?
Please note that if you are a consumer and download the App through the Apple App Store, or Google Play, then we do not process any payment information, or, in the first instance, your personal details. The Apple/Google system will deal with those directly, and only give us a user ID number that represents your account. Without further identifying information from you directly, this will not be personal data, and any data processed through the App without additional information will therefore not constitute personal data.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
Note: For users in the EU/UK, a version of GDPR applies; for users in Canada, processing may be based on express or implied consent or other legal grounds.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In all cases we will ensure that the contracts we have with third parties that involve the processing of your personal data will bind those third parties to their legal obligations to protect your data. In addition, we will not provide your data to third parties for marketing or advertising purposes without your consent.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
Example: We use Google Analytics. To opt out, visit Google Analytics Opt-out and refer to the Google Privacy & Terms page.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
To exercise these rights, please contact us as outlined in Section 13.
In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 13 below.
We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 13 below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')
Depending upon the state where you live, you may also have the following rights:
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights. To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@trvlwell.co, or by referring to the contact details at the bottom of this document. We will honour your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser. Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.
Request Verification. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@trvlwell.co. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.California 'Shine The Light' LawCalifornia Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.
If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section 13
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
by post at: WithU Travel Limited, Data Protection Officer, The Carriage House, Mill St, Maidstone ME15 6YE, UK
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
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