Effective from January 1st, 2021
1. Please read carefully!
2. Personal Information I may collect
To provide you the Services, I must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). I collect Personal Information you provide me, from your use of the Services, and from other sources. Here are the types of Personal Information I collect about you:
Information you provide me. When you register for my Services, use any of my Services; and/or when you contact me directly by any communication channel (e.g., the Website’s contact form, emails), you may provide me Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with me and with other users on my platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
Information I collect when you use the Services. When you visit, download, and/or use any of my Services, I may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
Information I collect from other sources. I may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help me screen out users associated with fraud, ii) advertising and marketing partners in order to monitor, manage and measure my ad campaigns.
3. Why I collect such Personal Information
I use your Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize, expand, and improve my Services, based on Users’ common or personal preferences, experiences and difficulties;
To provide my Users with ongoing customer assistance and technical support;
To be able to contact my Users with general or personalized service-related notices and promotional messages (as further detailed in Section 7 below);
To help me to update, expand and analyze my records to identify new customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
To analyze my performance and marketing activities;
To create aggregated statistical data and other aggregated and/or inferred information, which I or my business partners may use to provide and improve my respective services;
To provide you with professional assistance , only upon your request;
To enhance my data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.
I use your Personal Information for the purposes set out in Section 3 where:
My use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with customer assistance and technical support);
My use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that I have; or
My use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve my Services by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
4. How I may share your Personal Information
I may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
4.1. Third Party Service Providers: My website hosting service, Wix, has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance my own. These include data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and my legal and financial advisors (collectively, “Third Party Service Provider(s)”).
I may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers
commercial information, for example information regarding products or services purchased, obtained, or considered
The Personal Information may be shared solely in accordance with this policy.
4.2. Law Enforcement, Legal Requests and Duties: I may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if I have a good faith belief that the law requires me to do so, with or without notice to you.
4.3. Protecting Rights and Safety: I may share your Personal Information if I believe in good faith that this will help protect the rights, property or personal safety of myself, any of my Users, or any member of the general public, with or without notice to you.
4.4. Social Media Features and Framed Pages: My Services may include certain Social Media features, widgets, and features, such as the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect certain Personal Information such as your IP address or which page you are visiting on my Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on my Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not mine.
In addition, my Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of my Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to me, and such interactions and sharing are governed by those third parties’ policies and not mine.
4.5. Wix App Market Developers: As part of my usage of Wix's hosting services and App Market program, I may use third party developers’ (“Third Party Developer(s)”) applications hosted by the Wix App Market (“Third Party App(s)”).
Each Third Party Developer is bound by the Wix App Market – Partner Program Agreement, which among others, contains restrictions on how they may access, store, share, and use the Personal Information you provide them or me.
4.6. Upon Your Further Direction: I may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.
5. Where do I store your Personal Information?
5.1. Users’ Personal Information may be stored in my computers, and/or Wix's data centers located in the United States of America, Ireland, Japan and Israel. They may use other jurisdictions as necessary for the proper delivery of my Services and/or as may be required by law.
Please note that Wix does not change its practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
7. Communications from The Roaming Kiwi
7.1. Promotional Messages: I may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within my platform, marketing calls and similar forms of communication.
If you do not wish to receive such promotional messages or calls, you may notify me at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
7.2. Service and Billing Messages: I may also contact you with important information regarding my Services, or your use thereof. For example, I may send you a notice (through any of the means available to me) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; or notify you of material changes in my Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a roaming-kiwi.com User (which can be done by deactivating your account).
8. Your rights in relation to your Personal Information
I agree that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, I am taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before fulfilling your request, I may ask you for additional information in order to confirm your identity and for security purposes. I reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but I still recommend that you contact me first).
If you are a roaming-kiwi.com User, and you wish to receive a copy, access and/or request me to make corrections to the Personal Information that you have stored with me, or wish to request a list of what Personal Information (if any) pertaining to you I disclosed to third parties for direct marketing purposes, please contact me. I will make reasonable efforts to honor your request promptly (unless I require further information from you in order to fulfill your request), subject to legal and other permissible considerations.
Please note that permanently deleting your roaming-kiwi.com account erases all of your Personal Information from my databases. After completing this process, you can no longer use any of your roaming-kiwi.com Services, your account and all its data will be removed permanently, and I will not be able to restore your account or retrieve your data in the future.
9. Additional Information for California residents
If you are a California resident using the Services, the California Consumer Privacy Act (“CCPA”) may provide you the right to request access to and deletion of your Personal Information.
In order to exercise the right to request access to and deletion of your Personal Information, please see the information in Section 8, above. I do not discriminate based on the exercise of any privacy rights that you might have under this Section.
I do not sell user Personal Information to third parties for the intents and purposes of the CCPA.
Users of the Services who are California residents and under 18 years of age may request and obtain removal of content they posted by emailing me at email@example.com. All requests must be labeled “California Removal Request” on the email subject line. All requests must provide a description of the content you want removed and information reasonably sufficient to permit me to locate that content. I do not accept California Removal Requests via postal mail, telephone, or facsimile. I are not responsible for notices that are not labeled or sent properly, and I may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party
10. Questions and Complaints
I will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. I take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however I recommend that you contact me first so I can try to resolve it.
11. Data Retention
I may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with my legal obligations, to resolve disputes regarding my Users, prevent fraud and abuse, enforce my agreements and/or protect my legitimate interests.
My hosting service, Wix, has implemented security measures designed to protect the Personal Information you share with me, including physical, electronic and procedural measures. Among other things, I offer HTTPS secure access to most areas on my Services; the transmission of sensitive payment information (such as a credit card number) through my designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and I regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. They also regularly monitor my systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of my Services and protection of my Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by myself and Wix, I cannot and do not guarantee the absolute protection and security of your Personal Information, or any other information you upload, publish or otherwise share with me or anyone else. I encourage you to set strong passwords for your User Account, and avoid providing me or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on my Services may less secure than others, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, I request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of my Services, you are welcome to contact me at firstname.lastname@example.org.
13. Third-Party Websites
14. Public forums and user content
My Services may offer publicly accessible blogs, communities and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from my blogs, communities or forums, feel free to contact me at: email@example.com. In some cases, I may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, I advise against posting any Personal Information (via any means) you don’t wish to publicize.
If you upload any user content to your User Account or post it on the Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
There are adequate security measures in place to protect your Personal Information. However, I cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or I may have used on the Website (including, for instance, password-protected areas of the Website). You understand and acknowledge that, even after its removal by you or me, copies of User Content may remain viewable in cached and archived pages or if any third parties have copied or stored such User Content. To clarify, I advise against uploading or posting any information you do not wish to be public.
15. Updates and interpretation
Any heading, caption or section title contained herein, and any explanation, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of me in any way.
16. Contacting me