Data Travel, LLC (Hapi)
Privacy Statement
Updated Date: August 1, 2018
Data Travel, LLC, operators of the Hapi platform, ("Hapi", "we," "our," or "us") understand that privacy is important to visitors to our websites (our "Sites") and users of our products and services (our "Service" or "Services"). This Privacy Statement explains how we collect, use, and share your personal information when you use the Sites and Services that link to this Privacy Statement.

This Statement does not apply where Hapi processes the data of our customers on their behalf; our collection and processing of such data is governed by our Terms of Use and individual agreements with those customers.
PERSONAL INFORMATION WE COLLECT
Information you provide directly. We collect and store personal information that you directly provide us through our Site, when using our Services, and other ways, such as through a customer support request, through interactions on social media, participation in a survey or promotion, application for a job, and at events. Information we collect includes, for example, your name, job title, company name, email address, phone number, mailing address, billing address, city and country, and any data you enter into any 'free text' boxes on our forms. We may collect credit card numbers and other payment information if you purchase Services, such as cloud services, or software subscriptions.

Information collected automatically. As further described in the "Our Use of Cookies and Other Technologies" section below, we and our third-party partners automatically collect certain types of usage information when you use our Sites or Services. For example, when you visit our Site, your device's operating system, device identifier and other device information, user agent string, Internet Protocol (IP) address, access times, browser type, and log data detailing your interactions with our Site (e.g., number of clicks, pages viewed, information searched for), and the website you visited before and after coming to our Site (i.e., referer header) are logged automatically. When you submit a support ticket, we receive data from the user agent string of your browser, which includes device information, browser information, OS information, city, state, country, and IP address.

Information collected through social media and other platforms. We receive information about you when you engage with us through various third-party platforms, for example, by joining our Slack community, liking us on Facebook, connecting on LinkedIn, GitHub, or Meetup, following us on Twitter or Instagram, registering for training, or sharing content from our Site on Facebook, Twitter, or LinkedIn. The data we exchange with these third-party platforms may depend upon your privacy settings with these platforms. You should review and consider adjusting your privacy settings on third-party websites and services before engaging. Do not provide us with any sensitive personal data through these platforms. We are not responsible for the data protection and use practices of these third-party platforms. Please see their privacy statements to learn how they use your information.

Third-party sources. We may occasionally receive your personal information from third party sources including our affiliates, marketing and research partners, and companies such as FullContact and LinkedIn. Users of our Services may also provide your personal information when they identify you as a billing, support, or technical contact, or when inviting you to use our Services or attend our events. If you integrate or link a third-party service with our Sites or Services we may receive personal information about you from that third-party service based upon the settings and permissions you've established with such third party service, and that third party service's privacy practices.

The types of information we collect from third parties may include name, company name, title, role, zip code, city, country, telephone number, and social media engagement. We use this information to maintain and improve the accuracy of the records we hold about you, identify new customers, and provide a more tailored advertising experience. We may combine this information with other information we collect about you through our Sites and Services.

When you are asked to provide personal information, you may decline. But if you choose not to provide information that is necessary to provide certain Services, those Services may not be available or function correctly.
OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES
Our Sites and related online services use cookies and similar technologies to enable certain functionality and help collect information about your visit. Please refer to our Cookie Notice for information about our usage of cookies and similar technologies.
OUR USE OF PERSONAL INFORMATION
In general, we collect and process personal information about you with your consent, as necessary to provide the Services you use, operate our Sites and business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests as described in this Privacy Statement and in our notices to you.

For example, we may use your information to:

  • Operate, maintain and improve our internal operations, systems, Sites, and Services
  • Understand you and your preferences to enhance your experience and enjoyment using our Sites and Services, to provide recommendations, and to better market and advertise to you
  • Monitor and analyze user interactions with our Sites and Services to identify trends, usage, and activity patterns
  • Respond to your comments and questions and provide technical support or customer service
  • Provide and deliver the Services you request
  • Comply with applicable laws, rules, or regulations and cooperate and defend legal claims and audits
  • Communicate with you about promotions, upcoming events, and other news about products and services offered by Hapi and our partners
  • Plan and host corporate events
  • Protect the Site and Services, and investigate and deter against fraudulent, unauthorized, or illegal activity.
SHARING OF PERSONAL INFORMATION
We may share your personal information with your consent. We may also share your personal information:

  • Among our affiliates, which include companies owned by or under common ownership of Hapi such as Aquiva Labs LLC, all of which will be required to use your personal information as described in this Privacy Statement
  • With our partners and other third parties, such as our sponsors and co-sponsors of events, whose information we believe may be relevant to you (subject to applicable laws)
  • With third-party vendors and other service providers that we use to provide payment processing, reselling services, support ticket portals, secure transfer software, cloud hosting, video conference services, marketing automation platforms, project management tools, registration services, learning management services, collaboration and communication tools, data backup services, and professional services
  • With other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business or assets by another company or third party, or in the event of a bankruptcy, dissolution, or related or similar proceedings
  • As required by law or subpoena or if we reasonably believe that such action is necessary to comply with the law or the reasonable requests of law enforcement, to enforce our Terms of Use or other agreements or to protect the security or integrity of our Sites and Services, and/or to exercise or protect the rights, property, or personal safety of Hapi, our customers, users, or others.

We may also share aggregated or de-identified data with third parties (subject to applicable laws).
YOUR CHOICES ABOUT PERSONAL INFORMATION
Access, correction, or deletion. If you wish to request access, correction, or deletion of any of your personal information held by us or a change in the way we use your information (for which we reserve the right to charge you a fee, as permitted by applicable law), please contact us at the information below. However, we may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.

How to control your communications preferences. You can stop receiving promotional emails from us by clicking on the "unsubscribe link" provided in such emails or by contacting us at the contact details set forth below. We make every effort to promptly process all unsubscribe requests. If you opt out, we may still send you transactional communications (e.g., non-promotional emails such as emails about training and events you registered to attend and technical or security notices).

Cookies. Most Web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove cookies and to reject cookies. If you choose to remove reject cookies, this could affect certain features or services of our Site or other Services. Other choices related to information collected through the use of cookies and similar technologies are described in the "Cookies" section above. For specific opt-out links and to manage your preferences in relation to first and third party cookies please see our Cookie Notice.

Analytics and online advertising. Our third-party analytics and advertising partners may provide you with options to opt-out of certain information collection. For more information about the applicable choices they provide you, please see the "Cookies" section above and our Cookie Notice.
HOW WE STORE AND PROTECT PERSONAL INFORMATION
Storage and processing. Your information collected through the Sites and our Services may be stored and processed in any country in which Hapi or its subsidiaries, affiliates, or service providers maintain facilities. Our processing locations are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps designed to ensure that the data we collect under this Privacy Statement is processed according to the provisions of this Privacy Statement and applicable law wherever the data is located.

International data transfers. When we transfer personal information from the European Economic Area (including the United Kingdom) and from Switzerland to the United States or other countries which have not been determined by the European Commission to have laws that provide an adequate level of data protection, we use legal mechanisms, including contracts, designed to help ensure your rights and protections. Specifically, our website servers are located in the United States and our affiliates, partners, third parties and service providers operate in the United States, European Economic Area, Latin America, and Eastern Europe. This means when we collect your personal information we may process it in any of these countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Statement. The safeguard Hapi primarily relies upon is the European Commission-approved standard contractual data protection clauses. For more information about these mechanisms, please contact us using the contact details provided in the "How to contact us" section below.

Keeping your information safe. Hapi cares about the security of your information and takes reasonable and appropriate technical and organizational measures designed to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction of personal information. However, no security system is impenetrable, and we cannot guarantee the security of our systems or your information.

Lawful basis for processing personal information (EEA only). If you are located in the European Economic Area (EEA), Data Travel, LLC, is the data controller of your information.

Our legal basis for collecting and using the personal information above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will indicate this at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as the possible consequences, if any, if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of a third party), we will indicate to you at the relevant time what those legitimate interests are.

If you have questions about the legal basis for processing or want to find out more please contact us using the details at the end of this Privacy Statement.

Retention. We retain personal information for as long as we have an ongoing legitimate business need to do so. For example, we retain your account information for as long as your account is active or as needed to provide you with Services you have requested or authorized, including maintaining and improving the performance of the Services and protecting system security. We also retain personal data as needed to maintain appropriate business and financial records, protect our legal interests, resolve disputes, or comply with legal or regulatory requirements. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will store your personal information using appropriate security measures and take appropriate steps designed to isolate it from any further processing until deletion is possible.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

  • You may request access to, and correction or erasure of, personal information.
  • If automated processing of your personal data is based on a contract with you or your consent, you have certain rights to data portability.
  • If the processing of personal information is based on your consent, you have a right to withdraw consent at any time for future processing.
  • You have a right to object to, or obtain a restriction of, the processing of personal information under certain circumstances.
To make such requests, contact us by email at the address below. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
CHANGES TO OUR PRIVACY STATEMENT
Hapi may modify or update this Privacy Statement from time to time to reflect the changes in our business and practices, and so you should review this page periodically. If we make any changes to this Privacy Statement, we will notify you by changing the "Last Updated" date above. If we make any material changes, we will provide you with additional notice or obtain consent as may be required by applicable law.
HOW TO CONTACT US
If you have any questions, complaints, or concerns about how your information is handled, please email us at [email protected] Our main address is 7380 W. Sand Lake Road, Suite 500, Orlando, FL 32819 USA.