Privacy Policy

Read the Privacy Policy below

I. Data of the Personal Data Administrator

We would like to inform you that the administrator of your personal data is Travpack LLC, 810 Pony Express Rd Cheyenne, WY 82009 USA st., hereinafter referred to as the "Administrator". Contact with the Administrator regarding the protection of personal data is possible

using the following e-mail address: support@travpack.us

 

II. Purpose and basis of personal data processing

 

In order to provide services in accordance with the activity profile, the Administrator processes your personal data as our client - for various purposes, but always in accordance with the law. Below you will find specific purposes for the processing of personal data along with the legal basis. In order to set up a Customer's account, we process personal data such as: username (login), e-mail address, date of registration.

 

The legal basis for such data processing is art.6 par.1(b) GDPR, which allows personal data to be processed, if it is necessary to perform the contract or take steps to conclude the contract. In order to conclude and perform the contract for the provision of services in the use of the Platform and Application, we process such personal data as:

*first name and last name;

*username (login);

*company name;

*headquarters address;

*NIP;

*Business Registration Number;

*e-mail address;

*phone number.


I allow the Service Provider to record, distribute and use my image for the purpose of creating a photo, which will then be posted by the Service Provider on my application profile in order to identify me to increase the safety of persons and property in connection with contracts for the carriage of goods concluded via the Application. At the same time, I declare that:

1) I have given this permission in a conscious and voluntary manner;

2) this permit has been granted free of charge, i.e. I am not entitled to any remuneration for posing or other similar claims in this respect;

3) dissemination of the said photograph may take place through the Application;

4) The service provider may allow third parties to record, disseminate and use the image, if the need for such permission is connected with the implementation of the objectives set out above;

5. this authorization covers the entire world and is granted without a time limit;

6) I know that at any time I can withdraw the permission to fix and disseminate the image, but in the event of withdrawal of the license, I will not be able to conclude transport contracts through the Application.


The personal data administrator is Travpack LLC, 810 Pony Express Rd Cheyenne, WY 82009 USA, Filing ID 2017-000752633, e-mail: support@travpack.us. Personal data is processed to ensure the safety of persons and property on the basis of art. 6 par. 1 lit. f RODO. You have the right to request the administrator to access personal data, rectify it, delete or limit processing, object to processing, the right to transfer data, as well as the right to file a complaint to the supervisory body. More information on the processing of personal data can be found in the Privacy Policy available here.

 

The legal basis for such data processing is art.6 par.1(b) GDPR, which allows personal data to be processed, if it is necessary to perform the contract or take steps to conclude the contract. In order to handle requests (eg in the case of breakdowns, errors, etc.), we process personal data such as: first name and last name;

*username (login);

*company name;

*e-mail address;

*phone number.

 

The legal basis for such data processing is art.6 par.1(b) GDPR, which allows personal data to be processed, if it is necessary to perform the contract or take steps to conclude the contract. In order to process a complaint, we process personal data such as:

*first name and last name;

*username (login);

*company name;

*headquarters address;

*e-mail address;

*phone number;

*history of Services;

*IP address.

 

The legal basis for such data processing is art.6 par.1(b) GDPR, which allows personal data to be processed, if it is necessary to perform the contract or take steps to conclude the contract. In order to send e-mail notifications, we process personal data such as:

*first name and last name;

*username (login);

*e-mail address.

 

The legal basis for such data processing is art.6 par.1(f) GDPR, which allows personal data to be processed, if, in this way, the Personal Data Administrator performs its legitimate interest (in this case, the Administrator's interest is to inform the client about activities related to the provision of services in order to increase the comfort of using the services); In order to issue an invoice and fulfill other obligations resulting from tax law regulations, such as storing accounting records for 5 years, we process personal data such as:

 

*first name and last name;

*username (login);

*company name;

*headquarters address;

*NIP;

*Business Registration Number;

*history of Services;

*other data if required by tax law.

 

The legal basis for such data processing is art.6 par.1(c) GDPR, which allows personal data to be processed, if such processing is necessary for the Personal Data Administrator to fulfill its obligations under the law;

 

In order to fulfill the obligations related to the GDPR, in particular through the creation of registers and records, e.g. the register of clients who raised objections in accordance with the GDPR, we process personal data such as:

 

*username (login);

*first name and last name;

*e-mail address;

 

because, firstly, the provisions of the GDPR impose certain documentation obligations on us to demonstrate compliance and accountability, and secondly, if you object to the processing of your personal data, for example for marketing purposes, we must know who we should not use direct marketing for. The legal basis for such data processing is, firstly, art.6 par.1(c) GDPR, which allows personal data to be processed, if such processing is necessary for the

 

Personal Data Administrator to fulfill its obligations under the law; secondly, art.6 par.1(f) GDPR, which allows personal data to be processed, if in this way the Personal Data Administrator performs its legitimate interest (in this case, the Administrator's interest is to have

knowledge about people who, for example, exercise their rights resulting from the GDPR).In order to establish, investigate or defend against claims, we process personal data such as:

*first name and last name;

*username (login);

*company name;

*headquarters address;

*NIP;

*Business Registration Number;

*e-mail address;

*Phone number;

*history of Services;

*IP address.

 

The legal basis for such data processing is art.6 par.1(f) GDPR, which allows personal data to be processed, if, in this way, the Personal Data Administrator performs its legitimate interest (in this case, the Administrator's interest is to have personal data that can identify, assert or defend against claims from customers and third parties).

For archival and evidential purposes, we process personal data such as:

*first name and last name;

*username (login);

*company name;

*headquarters address;

*NIP;

*Business Registration Number;

*e-mail address;

*phone number;

*history of Services;

*IP address;

*for the purpose of securing information that may serve to demonstrate facts of legal significance.

 

The legal basis for such data processing is art.6 par.1(f) GDPR, which allows personal data to be processed, if in this way the Personal Data Administrator performs its legitimate interest (in this case, the Administrator's interest is to have personal data that will prove

certain facts related to the provision of services, for example when a state authority requests it) ;

 

For analytical purposes, i.e. research and analysis of the activity on the website belonging to the Administrator, we process personal data such as: date and time of the website visit, type of operating system, approximate location, type of web browser used to view the website,

time spent on the website, visited subpage, subpage where the form has been filled out. The legal basis for such data processing is art.6 par.1(f) GDPR, which allows personal data to be processed, if, in this way, the Personal Data Administrator performs its legitimate interest (in this case, the Administrator's interest is to know the clients' activity on the website);

 

In order to use cookies on the website, we process such text information (cookies will be described in a separate section). The legal basis for such processing is art.6 par.1(a) GDPR, which allows personal data to be processed on the basis of a voluntary consent (the first time you access a website, you will be asked for consent to use cookies);

 

In order to administer the website, we process such personal data as: IP address, server date and time, information about the web browser, information about the operating system - these data are automatically saved in the so-called server logs, each time a page belonging to the Administrator is used. It would not be possible to administer the website without using the server and without this automatic saving. 

 

The legal basis for such data processing is art. art.6 par.1(f) GDPR, which allows personal data to be processed, if in this way the Personal Data Administrator performs its legitimate interest (in this case, the Administrator's interest is to administer the website).

 

 

 

 

III. Cookies

 

The administrator on his website, like other entities, uses the so-called cookies, i.e. short text information, saved on a computer, phone, tablet or other user device. They can be read by our system, as well as by systems belonging to other entities, whose services we use (eg Google, Microsoft). Cookies perform a lot of functions on the website, most often useful, which we will try to describe below (if the information is insufficient, please contact us): ensuring security - cookies are used to authenticate users and prevent unauthorized use of the client's account. 

 

They are therefore used to protect the user's personal data against unauthorized access; impact on the processes and efficiency of using the website - cookies are used to ensure that the website works efficiently and that you can use the features available on it, which is possible, inter alia, by remembering the settings between subsequent visits on the site. Thanks to them, you can efficiently navigate the website and individual subpages; state of the session - cookies often contain information about how visitors use the website, for example which subpages are displayed most often. They also enable identification of errors displayed on some subpages. Cookies used to save the so-called "Session state" help to improve services and increase the comfort of browsing; maintaining session status - if the client logs in to his account, cookies allow the session to be sustained. This means that after switching to another subpage, you do not have to enter the username and password again, which contributes to the comfort of using the website; creating statistics - cookies are used to analyze how users use the website (how many users open the website, how long they stay on that website, which content arouses the most interest,etc.). 

 

Thanks to this, we can constantly improve the website and adapt its operation to the preferences of users. In order to track activity and create statistics, we use Google tools, such as Google Analytics; in addition to reporting website usage statistics, the Google Analytics

Pixel can also serve, along with some of the cookies described above, to help display more relevant content to the user on Google services (e.g. Google search engine) and across the entire web;

 

Your web browser by default allows cookies to be used on your device, so when you first visit, please agree to the use of cookies. However, if you do not wish to use cookies while browsing the website, you can change the settings in the web browser - completely block the automatic support for cookies or request notification whenever cookies are saved on the device.

 

Settings can be changed at any time. While respecting the autonomy of all people using the website, we feel, however, that we must notify you that disabling or limiting the use of cookies may cause quite serious difficulties in using the website, for example in the form of having to log in to any subpage, a longer period of page loading, restrictions in the use of functionality, etc.

 

IV. The right to withdraw consent

 

If the processing of personal data takes place on the basis of consent, you can withdraw your consent at any time - at its sole discretion. If you would like to withdraw your consent to the processing of personal data, it is enough to send an email directly to the Administrator at the e-mail address support@travpack.us. If the processing of your personal data was based on consent, its withdrawal does not mean that the processing of personal data up to this point was illegal. In other words, until the withdrawal of consent, we have the right to process your personal data and its revocation does not affect the legality of the current processing.

 

V. The requirement to provide personal data.

 

Providing any personal data is voluntary and depends on your decision. However, in some cases, providing specific personal information is necessary to meet your expectations for the use of services. To use the services under the Application, it is necessary to provide your name, surname, company name, registered office, tax identification number, e-mail address and telephone number - without this we are not

contracting for the provision of services. In order to be able to receive an invoice for services, it is necessary to provide all data required by tax law, i.e. your name or company name, registered address, tax identification number - without this we are unable to properly issue an invoice.

 

VI. Providing personal data when using services

 

In order to comply with the rules regarding the processing of as little personal data as possible, please do not give us more personal data when using the Application than is indicated in relation to objective needs. If you are in possession of any other personal data, i.e. personal data that does not directly concern you, we kindly ask you not to provide it in a larger quantity than is necessary for proper use of the Application. In a situation where you will contact us, e.g. by electronic means, and therefore you must send us certain documents, we ask for anonymised unnecessary data. We reserve the right to delete or destroy personal data, which in our opinion are redundant and in the light of applicable law, we have no grounds to process it.

 

VII. Automated decision making and profiling

 

We would like to inform you that we do not carry out automated decision-making, including profiling. Price of services, the method of consideration of the request, etc. are not in any way the result of the evaluation performed by any IT system, nor do they depend on the

amount of given data, choice of variants, etc.

 

VIII. Recipients of personal data

 

Like most entrepreneurs, we use the help of other entities in our operations, which often involves the necessity to provide personal data. Therefore, if necessary, we provide your personal data to lawyers cooperating with us, software suppliers (IT companies), hosting companies, courier companies.

 

Please be advised that the Applications use Microsoft Azure cloud software, therefore it is necessary to transfer your personal data to this entity. In addition, it may happen that, for example, on the basis of the appropriate law or decision of the competent authority, we will have to pass your personal data to other entities, whether public or private. That is why it is extremely difficult for us to predict who may apply for the disclosure of personal data. Nevertheless, we assure you that every request to disclose your personal data is analyzed very carefully, so that we do not inadvertently inform the unauthorized person.

 

IX. Transfer of personal data to third countries

 

Like most entrepreneurs, we use various popular services and technologies offered by entities such as Microsoft and Google. These companies are based in countries outside the European Union, and therefore in the light of the provisions of the GDPR, these countries are

treated as third countries.

 

The GDPR imposes certain limitations on the transfer of personal data to third countries, since, as it does not apply, as a general rule, European legislation, the protection of personal data of European Union citizens may unfortunately be insufficient. Therefore, each personal data administrator is required to establish the legal basis for such transmission. For our part, we assure you that when using services and technologies, we only transfer personal data to entities in the United States and only those who have joined the Privacy Shield, based on the decision of the European Commission of July 12, 2016 - read more on this subject at the European Commission website https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_pl. 

 

Entities that have joined the Privacy Shield guarantee that they will comply with the high standards of personal data protection that are in force in the European Union, therefore the use of their services and technologies offered in the processing of personal data is legal. At any time, we will give you additional explanations regarding the transfer of personal data, in particular when this issue raises your concern. You have the right to obtain a copy of your personal data transferred to a third country at anytime.

 

X. Period of processing personal data

 

In accordance with applicable law, we do not process your personal information "infinitely," but for the time that is needed to achieve the goal. After this period, your personal data will be irretrievably deleted or destroyed. Regarding individual periods of personal data processing, we kindly inform you that we process personal data for the period of:

 

providing services - in relation to personal data processed in order to use the services offered; 3 years - in relation to personal data processed in order to establish, investigate or defend claims; 5 years from the end of the calendar year - in relation to personal data related to the fulfillment of obligations under tax law; until the consent is withdrawn or the purpose of processing has been reached - in relation to personal data processed on the basis of consent;

until the moment of effective filing of objections or achieving the purpose of processing - in relation to personal data processed on the basis of the legitimate interest of the Data Controller; until the time of becoming obsolete or losing its usefulness, however, not longer than for 2 years - in relation to personal data processed mainly for analytical purposes, the use of cookies and the administration of the website.

 

We count the periods in years from the end of the year in which we began to process personal data to improve the process of removing or destroying personal data. Separate calculation of the deadline for each service would entail significant organizational and technical difficulties, as well as significant financial outlay, therefore establishing one date of removing or destroying personal data allows us to manage this process more efficiently. Of course, if you use the right to be forgotten, such situations are considered individually.

 

XI. Data subjects' rights

 

We kindly inform you that you have the right to:

access your personal data;

correct personal data;

delete personal data;

restrict the processing of personal data;

oppose to the processing of personal data;

transfer of personal data.

We respect your rights under the provisions on the protection of personal data and we strive to facilitate their implementation to the highest possible extent. We point out that these rights are not absolute, and therefore we may legally refuse you to comply in some cases. However, if we refuse to accept your request, it is only after careful consideration and only if the refusal to accept your request is absolutely necessary.

 

Regarding the right to object, we explain that you have the right to oppose the processing of your personal data at any time on the basis of the legitimate interest of the Data Controller (these are listed in point II) in relation to your particular situation. However, you must remember that in accordance with the law, we may refuse to take into account objections if we prove that: there are legitimate grounds for processing that override your interests, rights and freedoms or there are grounds for establishing, investigating or defending claims. In addition, you may object to the processing of your personal data for marketing purposes at any time. In this situation, after receiving the objection, we will stop processing your data for this purpose. You can exercise your rights by sending an email to support@travpack.us

 

XII. Right to lodge a complaint


If you believe that your personal data is processed contrary to the law in force, you can file a complaint to the President of the Office of Personal Data Protection.

 

XIII. Final Provisions

 

The cases not covered by this Privacy Policy are regulated by the current personal data protection regulations. You will be notified of any changes made to this Privacy Policy via e-mail. This Privacy Policy applies from January 1, 2019.



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