Effective
date: 08/07/2023
1.
Introduction
Welcome to Copilot2trip, Inc.
Copilot2trip,
Inc. (“us”, “we”, or “our”) operates https://copilot2trip.com/ and
Copilot2trip mobile application (hereinafter referred to as “Service”).
Our Privacy Policy governs
your visit to https://copilot2trip.com/ and Copilot2trip mobile
application, and explains how we collect, safeguard and disclose information
that results from your use of our Service.
We use your data to provide
and improve Service. By using Service, you agree to the collection and use of
information in accordance with this policy. Unless otherwise defined in this
Privacy Policy, the terms used in this Privacy Policy have the same meanings as
in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service
and together with the Privacy Policy constitutes your agreement with us (“agreement”).
2. Definitions
SERVICE means
the https://copilot2trip.com/ website and Copilot2trip mobile application operated
by Copilot2trip, Inc.
PERSONAL
DATA means
data about a living individual who can be identified from those data (or from
those and other information either in our possession or likely to come into our
possession).
USAGE
DATA is
data collected automatically either generated by the use of Service or from
Service infrastructure itself (for example, the duration of a page visit).
COOKIES are small files stored
on your device (computer or mobile device).
DATA
CONTROLLER means a natural or legal
person who (either alone or
jointly or in common with
other persons) determines the purposes for which
and the manner
in which any personal data
are, or are
to be, processed.
For the purpose
of this Privacy
Policy, we are a Data Controller
of your data.
DATA PROCESSORS (OR SERVICE
PROVIDERS) means
any natural or legal person
who processes the data on
behalf of the Data Controller.
We may use
the services of various Service
Providers in order to process
your data more effectively.
DATA SUBJECT is any living individual who
is the subject of Personal Data.
THE USER is the individual using our
Service. The User corresponds to the Data Subject, who is the subject of
Personal Data.
3. Information Collection and Use
We collect several different
types of information for various purposes to provide and improve our Service to
you.
4. Types of Data Collected
Personal Data
While using our Service, we may ask you
to provide us with certain personally identifiable information that can be used
to contact or identify you (“Personal
Data”). Personally identifiable information may include, but is not limited
to:
(a)
Email
address
(b)
First
name and last name
(c)
Address,
State, Province, ZIP/Postal code, City
(d)
Cookies
and Usage Data
We may use your Personal Data
to contact you with newsletters, marketing or promotional materials and other
information that may be of interest to you. You may opt out of receiving any,
or all, of these communications from us by following the unsubscribe link.
Usage Data
We may also collect
information that your browser sends whenever you visit our Service or when you
access Service by or through a mobile device (“Usage Data”).
This Usage Data may include
information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages
of our Service that you visit, the time and date of your visit, the time spent
on those pages, unique device identifiers and other diagnostic data.
When you access Service with
a mobile device, this Usage Data may include information such as the type of
mobile device you use, your mobile device unique ID, the IP address of your
mobile device, your mobile operating system, the type of mobile Internet
browser you use, unique device identifiers and other diagnostic data.
Location Data
We may use and store information about
your location if you give us permission to do so (“Location Data”). We use this data to provide features of our
Service, to improve and customize our Service.
You can enable or disable
location services when you use our Service at any time by way of your device
settings.
Tracking Cookies Data
We use cookies and similar
tracking technologies to track the activity on our Service and we hold certain
information.
Cookies are files with a
small amount of data which may include an anonymous unique identifier. Cookies
are sent to your browser from a website and stored on your device. Other
tracking technologies are also used such as beacons, tags and scripts to collect
and track information and to improve and analyze our Service.
You can instruct your browser
to refuse all cookies or to indicate when a cookie is being sent. However, if
you do not accept cookies, you may not be able to use some portions of our
Service.
Examples of Cookies we use:
(a)
Session Cookies: We use Session Cookies
to operate our Service.
(b)
Preference Cookies: We use Preference
Cookies to remember your preferences and various settings.
(c)
Security Cookies: We use Security Cookies
for security purposes.
(d)
Advertising Cookies: Advertising Cookies are
used to serve you with advertisements that may be relevant to you and your
interests.
5.
Use of Data
Copilot2trip, Inc. uses the collected data for various
purposes:
(a)
to
provide and maintain our Service;
(b)
to
notify you about changes to our Service;
(c)
to
allow you to participate in interactive features of our Service when you choose
to do so;
(d)
to
provide customer support;
(e)
to
gather analysis or valuable information so that we can improve our Service;
(f)
to
monitor the usage of our Service;
(g)
to
detect, prevent and address technical issues;
(h)
to
fulfill any other purpose for which you provide it;
(i)
to
carry out our obligations and enforce our rights arising from any contracts
entered into between you and us, including for billing and collection;
(j)
to
provide you with notices about your account and/or subscription, including
expiration and renewal notices, email-instructions, etc.;
(k)
to
provide you with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you
have already purchased or enquired about unless you have opted not to receive
such information;
(l)
in
any other way we may describe when you provide the information;
(m) for any other purpose with
your consent.
6.
Retention of Data
We will retain your Personal
Data only for as long as is necessary for the purposes set out in this Privacy
Policy. We will retain and use your Personal Data to the extent necessary to comply
with our legal obligations (for example, if we are required to retain your data
to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
We will also retain Usage
Data for internal analysis purposes. Usage Data is generally retained for a
shorter period, except when this data is used to strengthen the security or to
improve the functionality of our Service, or we are legally obligated to retain
this data for longer time periods.
7. Transfer of Data
Your information, including
Personal Data, may be transferred to – and maintained on – computers located
outside of your state, province, country or other governmental jurisdiction
where the data protection laws may differ from those of your jurisdiction.
If you are located outside
United States and choose to provide information to us, please note that we
transfer the data, including Personal Data, to United States and process it
there.
Your consent to this Privacy
Policy followed by your submission of such information represents your
agreement to that transfer.
Copilot2trip, Inc. will
take all the steps reasonably necessary to ensure that your data is treated
securely and in accordance with this Privacy Policy and no transfer of your
Personal Data will take place to an organisation or a
country unless there are adequate controls in place including the security of
your data and other personal information.
8. Disclosure of Data
We may disclose personal information
that we collect, or you provide:
(a)
Disclosure for Law
Enforcement.
Under certain circumstances,
we may be required to disclose your Personal Data if required to do so by law
or in response to valid requests by public authorities.
(b)
Business Transaction.
If we or our subsidiaries are
involved in a merger, acquisition or asset sale, your Personal Data may be
transferred.
(c)
Other cases. We may disclose
your information also:
(i)
to
our subsidiaries and affiliates;
(ii)
to
contractors, service providers, and other third parties we use to support our
business;
(iii) to fulfill the purpose for
which you provide it;
(iv) if we believe disclosure is
necessary or appropriate to protect the rights, property, or safety of the
Company, our customers, or others.
9. Security of Data
The security of your data is
important to us but remember that no method of transmission over the Internet
or method of electronic storage is 100% secure. While we strive to use
commercially acceptable means to protect your Personal Data, we cannot
guarantee its absolute security.
10. Your Data Protection Rights Under General Data Protection
Regulation (GDPR)
If you are a resident of the
European Union (EU) and European Economic Area (EEA), you have certain data
protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj
We aim to take reasonable
steps to allow you to correct, amend, delete, or limit the use of your Personal
Data.
If you wish to be informed
what Personal Data we hold about you and if you want
it to be removed from our systems, please email us at [email protected].
In certain circumstances, you have the
following data protection rights:
(a)
the
right to access, update or to delete the information we have on you;
(b)
the
right of rectification. You have the right to have your information rectified
if that information is inaccurate or incomplete;
(c)
the
right to object. You have the right to object to our processing of your
Personal Data;
(d)
the
right of restriction. You have the right to request that we restrict the
processing of your personal information;
(e)
the
right to data portability. You have the right to be provided with a copy of
your Personal Data in a structured, machine-readable and commonly used format;
(f)
the
right to withdraw consent. You also have the right to withdraw your
consent at any time where we rely on your consent to process your personal
information;
Please note that we may ask
you to verify your identity before responding to such requests. Please note, we
may not able to provide Service without some necessary data.
You have the right to
complain to a Data Protection Authority about our collection and use of your
Personal Data. For more information, please contact your local data protection
authority in the European Economic Area (EEA).
11. Your Data Protection Rights under the California Privacy
Protection Act (CalOPPA)
CalOPPA is the first state law in
the nation to require commercial websites and online services to post a privacy
policy. The law’s reach stretches well beyond California to require a person or
company in the United States (and conceivable the world) that operates websites
collecting personally identifiable information from California consumers to
post a conspicuous privacy policy on its website stating exactly the
information being collected and those individuals with whom it is being shared,
and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
According to CalOPPA
we agree to the following:
(a) users can visit our site
anonymously;
(b) our Privacy Policy link
includes the word “Privacy”, and can easily be found on the page specified
above on the home page of our website;
(c) users will be notified of any
privacy policy changes on our Privacy Policy Page;
(d) users are able to change
their personal information by emailing us at [email protected].
Our Policy on “Do Not Track” Signals:
We honor Do Not Track signals and do not track, plant
cookies, or use advertising when a Do Not Track browser mechanism is in place.
Do Not Track is a preference you can set in your web browser to inform websites
that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the
Preferences or Settings page of your web browser.
12. Your Data Protection Rights under the California Consumer
Privacy Act (CCPA)
If you are a California resident, you
are entitled to learn what data we collect about you, ask to delete your data
and not to sell (share) it. To exercise your data protection rights, you can
make certain requests and ask us:
(a) What personal information we
have about you.
If you make this request, we will return to you:
(i)
The
categories of personal information we have collected about you.
(ii)
The
categories of sources from which we collect your personal information.
(iii) The business or commercial
purpose for collecting or selling your personal information.
(iv) The categories of third
parties with whom we share personal information.
(v)
The
specific pieces of personal information we have collected about you.
(vi) A list of categories of
personal information that we have sold, along with the category of any other
company we sold it to. If we have not sold your personal information, we will
inform you of that fact.
(vii)A list of categories of personal
information that we have disclosed for a business purpose, along with the
category of any other company we shared it with.
Please note, you are entitled
to ask us to provide you with this information up to two times in a rolling
twelve-month period. When you make this request, the information provided may
be limited to the personal information we collected about you in the previous
12 months.
(b)
To
delete your personal information. If you make this request, we will delete the personal
information we hold about you as of the date of your request from our records
and direct any service providers to do the same. In some cases, deletion may be
accomplished through de-identification of the information. If you choose to
delete your personal information, you may not be able to use certain functions
that require your personal information to operate.
(c)
To
stop selling your personal information. If you submit a request to stop
selling your personal information, we will stop selling it. If you are a
California resident, to opt-out of the sale of your personal information, click
“Do Not Sell My Personal Information” at the bottom of our home page to submit
your request.
Please note, if you ask us to
delete or stop selling your data, it may impact your experience with us, and
you may not be able to participate in certain programs or membership services
which require the usage of your personal information to function. But in no
circumstances, we will discriminate against you for exercising your rights.
To exercise your California
data protection rights described above, please send your request(s) by one of
the following means:
By email: [email protected]
Your
data protection rights, described above, are covered by the CCPA, short for the
California Consumer Privacy Act. To find out more, visit the official California Legislative Information
website.
The CCPA took effect on 01/01/2020.
13. Service Providers
We may employ third party
companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform
Service-related services or assist us in analysing how our Service is used.
These third parties have
access to your Personal Data only to perform these tasks on our behalf and are
obligated not to disclose or use it for any other purpose.
14. Analytics
We may use third-party Service Providers
to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web
analytics service offered by Google that tracks and reports website traffic.
Google uses the data collected to track and monitor the use of our Service.
This data is shared with other Google services. Google may use the collected
data to contextualise and personalise
the ads of its own advertising network.
For more information on the
privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We also encourage you to
review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
Cloudflare
analytics
Cloudflare
analytics is a web analytics service operated by Cloudflare Inc. Read the
Privacy Policy here: https://www.cloudflare.com/privacypolicy/
Amplitude
analytics
Amplitude
analytics is a web analytics service operated by Amplitude, Inc. Read the
Privacy Policy here: https://amplitude.com/privacy
15. CI/CD tools
We
may use third-party Service Providers to automate the development process of
our Service.
GitLab
CI/CD
GitLab CI/CD is provided by
GitLab, Inc.
GitLab CI (Continuous
Integration) service is a part of GitLab that build and test the software
whenever developer pushes code to application.
GitLab CD (Continuous
Deployment) is a software service that places the changes of every code in the
production which results in every day deployment of production.
For more information on what
data GitLab CI/CD collects for what purpose and how the protection of the data
is ensured, please visit GitLab CI/CD Privacy Policy page: https://about.gitlab.com/privacy/.
16. Advertising
We
may use third-party Service Providers to show advertisements to you to help
support and maintain our Service.
Google AdSense DoubleClick Cookie
Google,
as a third party vendor, uses cookies to serve ads on
our Service. Google's use of the DoubleClick cookie enables it and its partners
to serve ads to our users based on their visit to our Service or other websites
on the Internet.
You
may opt out of the use of the DoubleClick Cookie for interest-based advertising
by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
17.
Behavioral Remarketing
Copilot2trip, Inc. uses
remarketing services to advertise on third party websites to you after you
visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our
Service.
Google Ads (AdWords)
Google
Ads (AdWords) remarketing service is provided by Google Inc.
You
can opt-out of Google Analytics for Display Advertising and customize the
Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google
also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser.
Google Analytics Opt-out Browser Add-on provides visitors with the ability to
prevent their data from being collected and used by Google Analytics.
For
more information on the privacy practices of Google, please visit the Google
Privacy Terms web page: https://policies.google.com/privacy?hl=en
Facebook
Facebook
remarketing service is provided by Facebook Inc.
You
can learn more about interest-based advertising from Facebook by visiting this
page: https://www.facebook.com/help/164968693837950
To
opt-out from Facebook's interest-based ads, follow these instructions from
Facebook: https://www.facebook.com/help/568137493302217
Facebook
adheres to the Self-Regulatory Principles for Online Behavioural
Advertising established by the Digital Advertising Alliance. You can also
opt-out from Facebook and other participating companies through the Digital
Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising
Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive
Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your
mobile device settings.
For
more information on the privacy practices of Facebook, please visit Facebook's
Data Policy: https://www.facebook.com/privacy/explanation
Pinterest
Pinterest
remarketing service is provided by Pinterest Inc.
You
can opt-out from Pinterest's interest-based ads by enabling the “Do Not Track”
functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
You can learn more about the
privacy practices and policies of Pinterest by visiting their Privacy Policy
page: https://about.pinterest.com/en/privacy-policy
18. Payments
We may provide paid products
and/or services within Service. In that case, we use third-party services for
payment processing (e.g. payment processors).
We
will not store or collect your payment card details. That information is
provided directly to our third-party payment processors whose use of your
personal information is governed by their Privacy Policy. These payment processors
adhere to the standards set by PCI-DSS as managed by the PCI Security Standards
Council, which is a joint effort of brands like Visa, Mastercard, American
Express and Discover. PCI-DSS requirements help ensure the secure handling of
payment information.
The payment processors we
work with are:
PayPal or Braintree:
Their Privacy Policy can be
viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Apple Store In-App Payments:
Their Privacy Policy can be
viewed at: https://www.apple.com/legal/privacy/en-ww/ / https://support.apple.com/en-us/HT203027
Google Play In-App Payments:
Their Privacy Policy can be
viewed at: https://policies.google.com/privacy?hl=en&gl=us / https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en
Stripe:
Their Privacy Policy can be
viewed at: https://stripe.com/us/privacy
19. Links to Other Sites
Our Service may contain links
to other sites that are not operated by us. If you click a third
party link, you will be directed to that third party's site. We strongly
advise you to review the Privacy Policy of every site you visit.
We
have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or
services.
20.
Children's Privacy
Our Services
are not intended for use by children under the age of 13 (“Children”).
We do not knowingly collect
personally identifiable information from Children under 13. If you become aware
that a Child has provided us with Personal Data, please contact us. If we
become aware that we have collected Personal Data from Children without verification
of parental consent, we take steps to remove that information from our servers.
21. Changes to This Privacy Policy
We may update our Privacy
Policy from time to time. We will notify you of any changes by posting the new
Privacy Policy on this page.
We will let you know via
email and/or a prominent notice on our Service, prior to the change becoming
effective and update “effective date” at the top of this Privacy Policy.
You are advised to review
this Privacy Policy periodically for any changes. Changes to this Privacy
Policy are effective when they are posted on this page.
22. Contact Us
If you have any questions about this
Privacy Policy, please contact us:
By email:
[email protected].