Privacy Policy and File description of the Ventoura Application user register

Last Updated: [21/03/2015]

Ventoura Oy [business ID 2616676-2) of Vuorimiehenkatu 11 A 4, 00140, Helsinki ("Ventoura", "we" or "us") provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of our application for mobile devices (the "Application"). This Privacy Policy applies only to information that you provide to us through the Application. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service (http://www.ventoura.com/terms).

This Privacy Policy may be updated from time to time. We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your Ventoura Account) or by means of a notice on the Application prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. By continuous use of the Application, you accept these changes to the Privacy Policy.

What Personal Information Do We Collect and How Do We Use It

Our primary goals in collecting information are to provide and improve our Site, Application, services, features and content, to administer your use of the Application and to enable users to enjoy and easily navigate the Application. We use your Personal Information to provide the Service and administer your inquiries as well as to complete your transactions.

Personal data which we collect about you is information including, but is not limited to, your name, phone number, email address, and home postal address, but does not include your credit card number or billing information (”Identity Information”). In order to process some of your transactions through the Application, we may also ask for your credit card number and other billing information ("Billing Information") (Identity Information and Billing Information together, "Personal Information").

If you decide to register by logging into a third party social media service account via our Application, we will obtain the Personal Information you have provided to the applicable third party social network service (“SNS”) (such as your "real" name, email address, profile picture, names of SNS friends, names of SNS groups to which you belong, other information you make publicly available via the applicable SNS and/or other information you authorize Ventoura to access by authorizing the SNS to provide such information) from your Third Party Accounts and use that information to create your Ventoura Account and Ventoura Account profile page and you will become a Member.

Depending on the SNS you choose and subject to the privacy settings that you have set in such SNS, you understand that by granting us access to your SNS accounts, we will access, make available and store (if applicable and as permitted by the SNS and authorized by you) the information in your SNS accounts so that it is available on and through your Ventoura Account on the Application. If there is information about your "friends" or people with whom you are associated in your SNS account, the information we obtain about those "friends" or people with whom you are associated, may also depend on the privacy settings such people have with the applicable SNS.

When you create a Ventoura Account, we will set up a Ventoura Account profile page for you. Your Ventoura Account profile page will include your first name and a profile picture. You can select the other items of Personal Information that you wish to be included in your Ventoura Account profile page including, but not limited to, a biography and links to your Listings, if applicable (together, your "Profile Information"). We will display your Profile Information in your Ventoura Account profile page publicly via the Application, and, with your prior permission, on third party sites. Any information you choose to provide as part of your Profile Information will be publicly visible to all Ventoura Users.

We may use information provided by you via, (i) a SNS, or (ii) directly through the Application, including, Age, Gender, SNS “Friends”, SNS Images, SNS email address, Itinerary, Tour history, Ratings, Matches, User type, Application usage history, Payment information and Conversation data. In addition, when you provide a Service through the Application, we may publish that Service publicly via the Application and may enable third parties to publish your Service on their websites through the use of a HTML "widget". You can review and revise your Profile Information at any time.

We also use your Personal Information to contact you with Ventoura newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your "Notifications" information. See "Changing or Deleting Information" below.

Log Data and Anonymised Data

Our servers automatically record information that your device sends whenever you visit the Application ("Log Data"). This Log Data may include information such as your device's Internet Protocol ("IP") address, browser type or the webpage you were visiting before you came to our Application, pages of our Application that you visit, the time spent on those pages, information you search for on our Application, access times and dates, and other statistics. We use this information to monitor and analyze use of the Application and for the Application's technical administration, to increase our Application's functionality and user-friendliness, and to better tailor our Application to our visitors' needs. We also use this information to verify that visitors to the Application meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated below regarding other Non-Identifying Information.

We also collect the other information that you provide as part of registration and the administration and personalization of your Ventoura Account profile (e.g., without limitation, zip code (on its own) and individual preferences or demographic information) ("Non-Identifying Information").We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Ventoura Users to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Application is used. We may also use the combined information without aggregating it to serve you specifically, for instance to advertise or deliver a product or service to you according to your preferences or restrictions.

We may share aggregated, anonymised information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Any data provided by you to Ventoura can be stored on any Ventoura server or on a third-party server located anywhere in the world.

Disclosure and Transfer of Personal Data

Ventoura is not in the business of selling your Personal Information to third parties.

Personal Information may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy. Additionally, Ventoura may disclose personal data to its parent companies and its subsidiaries in accordance with this Privacy Policy. In particular, Billing Information submitted via the Application is processed by a third party provider in accordance with security protocols set out in the “Security” section of this Privacy Policy.

Ventoura may hire agents and contractors to collect and process personal data on Ventoura’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Ventoura. Ventoura may use third party service providers such as credit card processors, e-mail service providers, shipping agents, data analyzers and business intelligence providers. Ventoura has the right to share your personal data as necessary for the aforementioned third parties to provide their services for Ventoura. Ventoura is not liable for the acts and omissions of these third parties, except as provided by mandatory law.

We may also provide Personal Information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you. You can, at any time, opt out of receiving such communications.

Ventoura may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Ventoura to legal liability.

Ventoura may also disclose your personal data to third parties when Ventoura has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Ventoura’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Ventoura believes that such disclosure is necessary to protect Ventoura’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Ventoura. If you request to make a booking via the Application, Ventoura will share the following information about you with the applicable Member: (i) your first name, and (ii) a link to your Ventoura Account profile page. In addition, subject to your authorization, Ventoura may share (iii) the names of any members of an SNS with whom you are "friends" or associated on the SNS if such individuals are also "friends" or associated with the Host on such SNS, and (iv) an indication that the name that you provided to Ventoura when you became a Member matches the name that you provided to the SNSs to which you have linked your Ventoura Account. All of this information will enable the Local to decide whether to confirm or reject your booking.

Sessions & Cookies

Like many mobile applications, we use "Sessions" to collect information. We use sessions for two purposes. First, we utilize sessions to save your login information for future logins to the Application. Second, we utilize sessions to enable certain features of the Application, to better understand how you interact with the Application and to monitor aggregate usage by Ventoura Users and web traffic routing on the Application.

Third party advertisers on the Application may place or read cookies on your device. A cookie is a small data file that is transferred to your device for record-keeping purposes. You can instruct your device, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Application or all functionality of the Application.

Third party vendors, including Google, use cookies to serve ads based on a Ventoura User's prior visits to Ventoura. You can disable these specific cookies that track prior visits for the sake of follow-up advertising by opting out at http://www.google.com/privacy_ads.html

Web Beacons

Our Application may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Application is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

Changing or Deleting Your Information

All Members may review, update, correct or delete the Personal Information in their registration profile by contacting us at feedback@ventoura.com or editing the relevant part of their profile. If you would like us to cancel your Ventoura Account, please contact us (feedback@ventoura.com) and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your Ventoura Account. Please note that, if you cancel your Ventoura Account, any reviews you have posted via the Application will remain publicly viewable via the Application. Please see below for privacy contact information.

Security and Phishing

Ventoura is very concerned with safeguarding your information. When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We do not and will not, at any time, request your credit card information, your Ventoura Account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. By using the Application, you assume this risk. If you have any questions about security on our Application, you can contact us.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Application in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Our Policy Toward Children

The Site and Application are not directed to individuals under 18. We do not knowingly collect personally identifiable information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we become aware that a child under 18 has provided us with Personal Information, we will delete such information from our files.

Contacting Us

If you have any questions about this Privacy Policy, please visit our FAQ (http://www.ventoura.com/faq) page.