This policy is concerned with the protection of your personal information only. Personal information includes any data that can be used to identify you as an individual, including your name, income, personal opinion, interests, home contact information, identification numbers, user IDs, passwords, ethnic origin, and age. Under Canadian law, in a business context, personal information does not include the name, job title, business address, or business telephone number of any employee in an organization.
This policy describes the following practices:
- Collecting information
- Sharing your personal information
- Maintaining your personal information
NOTE: Tugolo services are not intended for children under the age of 18. We do not knowingly collect or maintain any personal information or non-personally-identifiable information from anyone under the age of 18 nor is any part of our website or service directed to children under the age of 18. We will close any accounts used exclusively by such children and will remove and/or delete any personal information we believe was submitted by any child under the age of 18.
We collect information about you in the following ways:
As part of your use of Tugolo’s services
Whether you are a traveler or a “local friend”, Tugolo will require a certain amount of personal information to enable others to contact you to arrange to share travel experiences. Some of such information can be exchanged through Tugolo’s application. Tugolo also collects certain geo-location information from your mobile device, for the purposes of aggregating statistical data respecting use of the services in order to improve the services.
Additionally, we will require your name, address, telephone number and certain financial account or credit card information, for billing and payment purposes. This information is kept confidential and stored securely by Tugolo and its payment provider. For greater certainty, Tugolo will not provide traveler payment information to any “local friend”.
Tugolo also reserves the right to monitor messages sent by you, or data posted by you, through the services, in order to ensure that your use of the services is appropriate, lawful, and in accordance with Tugolo’s user agreement.
Automatically by Tugolo’s software and services
Tugolo’s software and services contain features that automatically collect information from users, such as usage statistics and other tracking information. Although this information will not identify you personally, it nevertheless provides certain information about you, and we therefore treat it as personal information. Additionally, use of Tugolo’s website and/or software may result in the collection of technical information such as your computer’s IP address, operating system, browser name/version, the referring web page, requested page, date/time, and sometimes a “cookie” (which can be disabled using your browser preferences); such information is used to help us understand the overall usage pattern of our website and software.
You contact Tugolo directly
Customers and business partners often contact us directly. When you contact any Tugolo employee by telephone, e-mail, in person, or through our website, you will be asked to provide consent to the collection of personal information if your personal information will help us deliver the information, products, or services you require.
You respond to communications from Tugolo
From time to time, Tugolo may invite you to provide us with information for specific purposes. We may ask for this information through feedback features on our website or software; we may send out e-mail inviting feedback or offering products and services; or we may ask you for information concerning support of our products or services. Your response to these communications may require you to submit personal information and opinions.
Your information is obtained through a third party
Occasionally, Tugolo will obtain information about you from third parties, such as mailing list providers, third party service providers, ISPs, or third party application or account providers. Third-party providers are responsible for obtaining consent for the release of personal information to us from those individuals identified on mailing lists, surveys, or through other collection methods.
Third party collection of your information
Sharing your personal information
Subject to any exceptions stated above in the collection of information section, should Tugolo collect any of your personal information, we will follow these practices regarding the distribution of that information.
Your personal information is protected
Tugolo uses reasonable precautions to protect your personal information and store it securely. Access to your personal information is restricted to those persons who need it (including “local friends” and travelers, as applicable), and Tugolo takes reasonable steps to prevent the unauthorized use or disclosure of your personal information.
Tugolo only uses and discloses your personal information if it helps us facilitate your needs, improve our products and services, meet legal and regulatory requirements, or — to the limited extent possible — manage our internal business operations. Additionally, if there are any disclosure or use restrictions in your consent to the collection of your personal information, Tugolo will abide by those restrictions (subject to the consent exceptions listed below). For example, your credit card or financial information will only be used to bill you for the services that you have authorized or used, or to pay you for the services performed, as applicable.
Tugolo may combine your information with other information into an aggregate form, so your information no longer personally identifies you. We may then disclose the aggregate information to third parties, so they can obtain an overall picture of Tugolo’s products, services, customer sectors and/or usage patterns.
We only share your information with your consent
Tugolo provides your information to third parties only for purposes to which you have consented, and we require such third parties to keep your information confidential.
In a few situations, Tugolo may be required to disclose your information without your prior consent. For example, Tugolo may disclose your information if we are required to do so by law, or if we believe in good faith that such disclosure is necessary to:
- comply with law or legal process
- protect and defend our rights and property, or the rights and property of a third party
- protect against misuse or unauthorized use of any of Tugolo’s products, services, or other proprietary materials
- protect the personal safety of any person
Tugolo will always try to provide you with prior notice of such disclosure; however, such notice may not always be possible or reasonable given the circumstances.
Additionally, the nature of the services provided requires the routine use of your information in the provision of the services. Your personal information will only be used to the limited extent necessary to provide the services that you have requested, and may include the following uses:
- to allow third party suppliers, vendors, contractors and other parties to provide products and services to us or to you, or to otherwise act on our behalf (this may include, without limitation, our authorization of such third parties to email our users regarding updates, surveys and other inquiries regarding their experience with our service); and
- to allow for audits and surveys to, among other things, validate the size and composition of the users of Tugolo’s services, and understand their experience with Tugolo’s service.
Maintaining your personal information
Tugolo has established the following practices regarding the maintenance of your personal information.
You can request access to your personal information at any time
If, for any reason, you wish to review your personal information that Tugolo has in its possession, you can contact our Privacy Officer, who will be pleased to provide you with all your personal information that Tugolo has on file.
You can request changes to your personal information at any time
Sometimes, it will be necessary for you to update your personal information Tugolo has on file. For example, if you change payment account information, you must update your information in order to keep receiving the services provided by Tugolo. In many cases, you will be able to do so by changing your personal settings on your account.
If you wish to make any changes or corrections to your personal information that cannot be done yourself through your personal settings, please contact our Privacy Officer who will implement the changes. This will help us ensure our records are always up-to-date.
You can opt out of communications at any time
Additionally, you always have the choice of whether you wish to receive information – such as e-mail updates – from Tugolo. In some cases, you may do so simply by changing the preferences in the software application through which Tugolo provides the services.
If you do choose to opt out of communications respecting products and services provided by Tugolo, you may not obtain all the benefits we could otherwise provide, such as updates or warnings. Tugolo will not have any liability to you for your loss of those benefits or any negative effects respecting your use of Tugolo’s products or services.
You can request that your personal information be destroyed at any time
A situation may arise where you desire to have all of your personal information that is contained in Tugolo’s records deleted or destroyed. If this is what you wish, please contact our Privacy Officer, who will take care of removing your personal information from all of Tugolo’s records. However, there may be situations where we are obligated to retain one archival copy of your information to allow us to comply with laws or respond to legal processes. We will inform you of all such situations, and will only use your retained personal information to the limited extent necessary to comply with such laws or respond to legal processes.
We follow general principles consistent with applicable privacy laws
We comply with all applicable privacy laws respecting our processing and storage of any personal information that may be used in conjunction with the Services, and we deal with your data under these general principles:
- Lawfulness, fairness and transparency: We may not reveal the granular details of how we protect your data, because that would compromise its security – but we will let you know why we need it, what we need it for, and process it securely and in accordance with applicable laws. If you have any questions respecting your data and how it’s being used, you need only ask us, and we will answer.
- Minimization of data: We only collect information that we need, and that you choose to give to us. We will not collect personal information gratuitously from you for no reason.
- Accuracy: We make reasonable efforts to keep your data accurate and up to date, based on your input; if you notify us of any changes to your data, we will make sure to change it in our systems in a timely manner.
- Limitation of data retention: We believe in streamlining the way that we handle data so that it minimizes data redundancy and unnecessary retention. We have instituted processes to delete personal information from our systems when it is no longer required.
- Integrity and confidentiality: We process your information using appropriate technical or organizational measures designed to ensure appropriate security of your personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage.
Contacting our Privacy Officer