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Privacy Policy

Effective: September 4th, 2024 

Bokun is an online booking software service that provides users with access to a day-to-day management and sales system, including booking engines for the facilitation of tours and activities bookings. The Bokun website (including any mobile properties and related applications) and services (collectively, our “Services”) are owned and provided by Tripadvisor LLC (“Tripadvisor”, “we”, “our”, “us”). 

By accessing and utilising our Services, you acknowledge that you have read and understood this Privacy Policy and the information collection and handling practices outlined in it.

We may change this Privacy Policy from time to time so please check back regularly to keep informed of any updates.

Overview

This Privacy Policy describes in detail our policy and practices regarding our collection, use and disclosure of your personal data.

We understand that providing information online involves a great deal of trust on your part. We take this trust very seriously and make it a high priority to ensure the security and confidentiality of the personal data you provide us when you use our Services.

  1. Collection of your personal data
  2. How we use your personal data
  3. With whom we share your personal data
  4. How long we keep your personal data
  5. Cookies and other web technologies
  6. Your rights
  7. How we protect your personal data
  8. Information concerning minors
  9. External links
  10. International transfers
  11. Changes to this Privacy Policy
  12. How you can contact us

Notice at Collection of Personal Information

We collect personal information from and about you as detailed in this Notice at Collection of Personal Information (“Notice”) and in the Privacy Policy.

What categories of personal information do we collect and why?

  • Biographical information & identifiers: This may include your name; phone number, postal, billing, and email address; other information about yourself that you have voluntarily disclosed; unique personal identifier; online identifier; IP address; account username and password; and other similar identifiers.
  • Personal information categories listed in the California customer records statute: This may include your billing and payment card information and certain information that you provide to support our facilitation of the Services.
  • Commercial Information: This may include information related to products or services that you have purchased or obtained, including details of your relationship with Bokun.
  • Internet or other Electronic Network Activity Information: This may include information related to your browsing history (including pages you have visited, content reviewed, and apps reviewed), search history, and access to and use of our Services (including automatic collection of information as described in more detail in this Privacy Policy).
  • Visual and Audio Information: This may include photos you provide and any communications we have received when you contact our customer service team, including inbound and outbound calls. 
  • Inferences Drawn from the Above: We may generate inferences based on the above categories of personal information.
  • Sensitive Personal Information: The following categories are considered “sensitive personal information” under certain privacy laws: precise geolocation data, race, ethnicity, sexual orientation, religion, driver’s license number, or passport number. To the extent that we use or disclose any “sensitive personal information” or “sensitive data”, as those terms are defined in applicable privacy laws, we do not use or disclose the sensitive personal information for the purpose of inferring characteristics about you or for any purpose other than limited permissible purposes, such as providing our Services and verifying, maintaining the quality of, and improving our Services.

We collect and use each category of personal information for the following business and commercial purposes described in more detail in Section 2 of this Privacy Policy: registration, to improve the Services, personalization and customization, communication, and legal compliance.

We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in the Privacy Policy, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise, or defend any legal rights.

What categories of personal information do we “sell” or “share” to third parties?

Though the terms “sell” and “share” are broadly defined in certain U.S. privacy laws, we do not engage in the sale or sharing of personal information. As such, we do not offer an opt out from the sale or sharing of personal information. 

1. Collection of your personal data

Personal data means any information about an individual from which that person can be directly or indirectly identified. It does not include data where the identity has been removed or otherwise anonymized (anonymous data).

In the course of our business, we collect and process personal data in different ways. We may collect personal data you give us directly but we also collect data by logging how you interact with our services. For example by using cookies on our websites. We also receive personal data from third party businesses who use our Services.

The personal data we collect about you may include, but is not limited to: your name, email address, postal address, phone number, payment information, survey responses, booking details and other information you may provide about yourself through use of our Services, and your IP address and web browser software.

You can choose not to provide us with your personal data. However, in general you need to provide us with certain information about you in order to take advantage of many features of the Services. We also collect personal data for security purposes.

Information that you provide us: as described below, we may receive and store any information you enter on our website or give us in any other way.

Information about Others: You may provide contact and travel-related information for other people through our Services. If you book for someone else through the Services, you will need to submit that individual’s personal data. You must obtain the consent of other individuals prior to providing us with their personal data.

Information from Other Sources: We also may obtain information about you from affiliated entities, business partners, Bokun suppliers and resellers, and other independent third-party sources.

Automatic Collection of Information: We may automatically collect some information from your computer or mobile device when you visit our website. For example, session data, including your IP address, the navigation software used and the reference site. We may also collect information about your online activity, such as reviewed content, pages visited and searches. We automatically collect this type of information to try to better understand your interests and preferences and potentially to personalise your experience. We also collect personal data in order to help protect our site and other users from misuse.

Location Information and Other Information from Devices: When you use our website on a device, we may collect certain 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. 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.

Call Recording and Monitoring: Please be aware that calls to and from us 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 data obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.

2. How we use your personal data

We use the personal data that we collect only for specific purposes. This includes, but is not limited to, offer our Services, to manage your registration and account, including your access to and use of our Services, to manage and facilitate booking enquiries and bookings processed via our Services, to communicate with you about your account or use of our Services, to respond to, or follow up on, your comments and questions and otherwise provide customer service, notify you about changes to our terms or privacy policy, ask you to leave a review or take a survey, operate and improve our Services, personalise your experience on our websites, measure interest in and improve our Services, notify you about promotions and special offers, to invite you to partake in a prize draw or competition, to protect, investigate and deter against fraudulent or illicit activity, unauthorised or illegal activity, administer and protect our business and to resolve disputes or troubleshoot problems.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • With your consent.
  • Where we need to comply with a legal or regulatory obligation.
  • Marketing
  • You may receive marketing messages from us if you have given your consent, if you have requested to receive them, or if you have purchased goods or services from us and if you have not opted out of receiving marketing messages.

Each time you receive an email of this type, you will be able to tell us if you no longer wish to receive them by clicking on the unsubscribe link that you will find at the bottom of each communication you receive from us, or by e-mailing info@bokun.is with your request.

Please note that we may continue to send you service communications, such as service and administrative messages about your account or transactional messages related to your bookings. It is not possible to unsubscribe from these service communications.

3. With whom we share your personal data

Tripadvisor may make available your information with other parties, including other group companies and the types of third parties listed below. For instance, if we sell or divest our business or any part of it, and your personal data relates to such sold or divested part of our business, or if we merge with another business, we will share your personal data with the new owner of the business or our merger partner, respectively.

Separately, if we are legally obliged to do so, we will share personal data to protect our customers, the site, as well as our company and our rights and property.

  • Suppliers and resellers of services, including but not limited to tours, activities, attractions, accommodation, car hire or transport who fulfil travel bookings using our Services.
  • Third-party service providers 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 authorise third-party service providers to collect information on our behalf, including, for example, as necessary to operate features of our Services or to facilitate the delivery of online advertising tailored to your interests. Third-party service providers 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.
  • Business partners with whom we may offer products or services in conjunction. If you choose to access these optional services, we may share information about you, including your personal data, with those partners. Please note that we do not control the privacy practices of these third-party business partners.
  • Affiliated Websites. If you were referred to our website from another website, we may share your registration information, such as your name, email address, mailing address, telephone number and travel preferences with that referring website. We encourage you to review the privacy policies of any website that referred you to our website.
  • Companies belonging to our group. We may share your personal data within the Tripadvisor group of companies, as well as with our parent companies and domestic and international corporate affiliate companies and websites. This sharing enables us to provide you with information about products and services 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.

We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:

  • to comply with legitimate and enforceable subpoenas, court orders or other legal process; to establish or exercise our legal rights; to defend against legal claims or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
  • to investigate, prevent or take action regarding illegal or suspected illegal activities; to protect and defend our rights, property or safety of , our customers or others and in connection with our Terms of Service and other agreements or
  • in connection with a corporate transaction, such as a divestiture, merger, consolidation or asset sale or in the unlikely event of bankruptcy.

Other than as set out above, you will be notified when personal data about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

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. This information does not contain any personal data and is used to develop content and services we hope you will find of interest.

4. How long we keep your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or statutory reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure or your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

We may retain certain information subsequent to the closing of your account with us, for example if it is necessary to fulfil our legal obligations or to exercise, to maintain security, to prevent fraud and abuse and to defend or enforce our rights.

5. Cookies and other web technologies

We may collect information via cookies and other similar technologies (such as web beacons). Cookies are small text files that are automatically placed on your computer or mobile device when you visit a website. They are stored by your internet browser. Cookies contain basic information about your use of the internet. Your browser sends these cookies back to our website every time you visit it, so it can recognise your computer or mobile device and personalise and enhance your browsing experience.

You can find out more information about cookies in general, including how to see what cookies are installed on your (mobile) device and how to manage and delete them at websites such as www.allaboutcookies.org and www.youronlinechoices.com/uk.

6. Your rights

In accordance with applicable law, you may have the right of access, the right of rectification, the right to erasure, the right to restrict processing, the right to data portability and the right to object. Please find below more details and information on how and when you can exercise your rights. We will respond to your request within one month but have the right to extend this period with two months.

Your Privacy Rights Under GDPR

You have certain rights regarding your personal information. Your rights with respect to your own personal data include the following:

  • The right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • The right to request to correct your personal data if it is inaccurate. You may also supplement any incomplete personal data we have, taking into account the purposes of the processing.
  • The right to request deletion of your personal data if:
    • your personal data is no longer necessary for the purposes for which we collected or processed them; or
    • you withdraw your consent if the processing of your personal data is based on consent and no other legal ground exists; or
    • you object to the processing of your personal data and we do not have an overriding legitimate ground for processing; or
    • your personal data is unlawfully processed; or
    • your personal data has to be deleted for compliance with a legal obligation.
  • The right to object to the processing of your personal data. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
  • The right to restrict the processing of personal data, if:
    • the accuracy of your personal data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
    • the processing is unlawful and you oppose the deletion of your personal data and request restriction; or
    • we no longer need your personal data for the purposes of processing, but your personal data is required by you for legal claims; or
    • you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
  • The right to data portability. You may request us to receive the personal data that concern you. You may also request us to send this personal data to a third party, where feasible. You only have this right if it regards personal data you have provided us, the processing is based on consent or necessary for the performance of a contract between you and us, and the processing is done by automated means.

To exercise any of the aforementioned rights, you can e-mail info@bokun.is.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights described in this Privacy Policy). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request.

Your U.S. State Privacy Rights

Depending on your U.S. state of residence, you may have certain rights in relation to your personal information that we collect, use, or disclose in accordance with this Privacy Policy, including:

  • Right to know. You may have the right to request that we disclose to you the categories and specific pieces of personal information that we have collected about you; the categories of sources from which we collected your personal information; our business or commercial purpose for collecting or sharing your personal information; the categories of personal information that we have disclosed for a business purpose, and the categories of third parties with whom we have disclosed your personal information, if applicable. You may have the right to request your personal information in a portable format. 
  • Deletion. You may request that we delete your personal information that we maintain about you, subject to certain exceptions. As described in more detail in our Privacy Policy, there are some reasons for which we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation. You can also access, update, and remove your information.
  • Correction. You can request that we correct inaccurate personal information that we maintain about you.
  • Do Not Sell or Share My Personal Information. We do not offer an opt-out from the sale of personal information because we do not engage in the sale or share of personal information as contemplated by applicable law. As noted elsewhere in this Privacy Policy, we share personal information with other our companies in our group and other third parties for a variety of reasons. 

To take advantage of any of these rights, please contact us in writing by e-mailing info@bokun or contact us toll-free at tel:+18339305755. You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent. We may need to verify your identity or elements of the request to enable us to process your request. We will take reasonable steps to verify your identity when you submit a right to know, delete, or correct request; these verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. We value your privacy and will not discriminate against you in response to your exercise of privacy rights. 

Additionally, you can opt out of certain uses of cookies for advertising purposes by visiting www.aboutads.info/choices. For more information, please see the “Cookies” section above. Your opt-out of cookie-based tracking for advertising purposes is specific to the device, website, and browser you are using; it is deleted whenever you clear your cookies or your browser’s cache.

We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. Depending on your U.S. state or residence, you have the right to submit an appeal if you are not satisfied with the outcome of your request by e-mailing info@bokun.is.

Notice of Financial Incentives

We may collect your personal information in connection with certain special offers, discounts, sweepstakes, contests, or other promotions (collectively, “promotions”) that we may make available to you. For example, we may collect your biographical information/identifiers (e.g. name, contact details, etc), commercial information, internet or other electronic network activity information, characteristics of protected classifications under California or U.S Federal law, visual and audio information, or inferences drawn from the above. Because these promotions may involve the collection of personal information, they may be interpreted as a “financial incentive” under California law or a “bona fide loyalty program” under Colorado law. We use the personal information that we collect as described in the Notice and in Section 2 of the Privacy Policy.

When you sign up for a promotion, we will provide you with relevant terms that apply to your participation in the promotion. To stop receiving promotions by email, you may unsubscribe by clicking the “unsubscribe” button at the bottom of any email. If you decline to provide your personal information or ask us to delete your personal information, we may not be able to provide you with access to these promotions.

The value of any financial incentive or bona fide loyalty program we offer is reasonably related to the value of any personal information that you provide to us. We estimate the value of your personal information by considering, without limitation, the expenses we incur from collecting your personal information and/or providing the promotions to you, and/or the revenue generated through the promotions.

7. How we protect your personal data

We want you to feel confident about using our Services, and we are committed to protecting the personal data we collect. While no website can guarantee perfect security, we have implemented and maintain appropriate physical, administrative, technical, and organisational measures to protect the personal data you provide us against unauthorised or unlawful access, use of disclosure and against accidental loss, damage, alteration or destruction.

For example, only authorised employees are permitted to access personal data, and they may do so for permitted business functions. In addition, we use encryption when transmitting your personal data between your system and ours, and between our system and those of the parties with whom we share sensitive information, and we employ firewalls and intrusion detection systems to help prevent unauthorised persons from gaining access to your personal data.

8. Information concerning minors

Bokun is a general audience site. 

Our Services are not intended for children, which we consider to be: (i) individuals that are 13 years of age or under, or the age of privacy consent in your jurisdiction; or (ii) when processing data on the basis of a contract, the age of legal capacity to enter into the agreement. 

We will only collect or process information belonging to children under very limited circumstances. We might need to process personal information belonging to children as part of our Service if, for example, the personal information is required as part of a travel-related reservation. We will only collect personal information belonging to children if it is provided by and with consent of a parent or guardian. We do not knowingly collect data relating to minors. If we become aware that we have processed the personal information of a child without the valid consent of a parent or guardian, we will delete the personal information.

9. External links

Our website may include links to third party websites, plug-ins and applications. If you access other websites from the links provided on our website, the operators of those websites may collect or share information about you. This information will be used by them in accordance with their privacy policy, which may differ from our Privacy Policy. We do not control these third-party websites and recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using and disclosing personal data.
 

10. International transfers

Your personal data may be stored or transferred to countries outside the European Economic Area for the purposes described in this Privacy Policy. When we store or transfer your personal data outside the European Economic Area, we take the following precautions to ensure that your personal data is properly protected.

Whenever we store or transfer your personal data outside the European Economic Area, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal data are made:

  • to a country recognised by the European Commission as providing an adequate level of protection; or
  • to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

By using our services, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

11. Changes to this Privacy Policy

We may change or modify this Privacy Policy from time to time. We will note the date that revisions were last made to this Privacy Policy at the first page of this Privacy Policy, 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 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.
 

12. How you can contact us

To exercise your other rights you can file a request by e-mailing info@bokun.is You may also have the right to lodge a complaint to the supervisory authority about the way we process your personal data. We would, however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.

Our full details are:

Tripadvisor LLC
400 1st Avenue
Needham, MA 02494, USA
 
Attn: Privacy Officer/Legal Department
Email: info@bokun.is

In accordance with applicable data privacy law, we have appointed a representative within the European Union and the United Kingdom. 

The contact details of our European Union representative are:

Tripadvisor Ireland Limited
C/O Matheson
70 Sir John Rogerson’s Quay, Dublin 2
D02 R296
Ireland
Attn: Privacy Officer

The contact details of our United Kingdom representative are:

Tripadvisor Limited
7 Soho Square
London
W1D 3QB
United Kingdom
Attn: Privacy Officer
Email: info@bokun.is 

Tripadvisor Ireland Limited and Tripadvisor Limited’s roles in this respect are limited solely to being a contact person for questions on data protection from EU citizens and data protection supervisory authorities. For the avoidance of doubt, neither Tripadvisor Ireland Limited and Tripadvisor Limited can field other communications or legal process on behalf of Tripadvisor LLC.