Privacy Policy

 

Viagem Inc. and its affiliates (“Viagem”, “we”, “our”, “Company”) respect the privacy of its Users and is committed to protect the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you use the Service or interact with us in any manner.

This Privacy Policy describes how we collect, store, use and disclose personal data regarding individuals (“you”) who: (i) visit or otherwise interact with our websites (“Visitors”) or (ii) use our Services.

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.

You are not legally required to provide us with any Personal Data (as defined below), and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with such Personal Data, or to have it processed by us or any of our Service Providers (defined below), please simply do not enter our Site or use our Service. You may also choose not to provide us with “optional” Personal Data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Service.

This Privacy Policy forms part of our Terms of Use available at: https://stayviagem.com/terms-of-use/ (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

  1. Data Collection

We collect various types of personal data regarding our Users as well as data regarding Visitors to our Sites. Such data is typically collected and generated through your interaction with us or our Service, through automatic means, or directly from you, from other Users, from our customers, or from other third parties (including Service Providers, as hereinafter defined).

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “Personal Data“):

User Data received from you: When you contact us or make a Reservation, you may provide us with Personal Data. This includes your name, phone number, email address, billing information (name of card, card number, expiry date, CVV) which is gathered by a payment processor (PCI compliant) and not by us (we do not hold or retain your credit card details ourselves), as well as any other data you choose to provide when you use our Service, or contact us via our Service.

Data automatically collected or generated: When you visit, interact with, or use our Site or Service, we may collect, record or generate certain technical data about you. We do so either independently or with the help of third-party Service Providers (as defined below), including through the use of “cookies” and other tracking technologies (as detailed below).

Such data may consist of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device data (like type, operating system, mobile device id, browser version, locale and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on such device and the recorded activity (sessions, clicks and other interactions) of Visitors and Users in connection with our Service. In addition, phone calls (e.g. with our customer success or product consultants) may be automatically recorded, subject to applicable law, tracked and analyzed, for purposes including analytics, service-, operations-, and business quality control and improvements, and record-keeping purposes.

Data received from other third parties: We may receive Personal Data concerning you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your Personal Data from its organizers. We may also receive your contact details from our business partners or service providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business opportunities, such as Airbnb, booking.com, Guesty and other data sources.

Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and Visitors visit or use the Sites or Service, which pages they visit and when, and which website, ad or e-mail message brought them there.

  1. Data Uses

We use Personal Data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Service, e.g. in understanding how our Service are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Service to you and others; providing customer service and technical support; and protecting and securing our Users, customers, Visitors, ourselves and our Service.

If you reside or are using the Service (i) in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for processing Personal Data (in general, or specifically with respect to the types of Personal Data you choose to share via the Service), your acceptance of our Terms and of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us by email at: contact@stayviagem.com.

Specifically, we use Personal Data for the following purposes:

  1. To facilitate, operate, and provide our Service;
  2. To verify and carry out financial transactions in relation to payments in connection with the Service (through an online service- we do not possess or retain you credit card information);
  3. To authenticate the identity of our Users, and to allow them access to our Service;
  4. To provide our Visitors and Users with assistance and support;
  5. To gain a better understanding on how Visitors and Users evaluate, use and interact with our Service, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Service;
  6. To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Service, and thereby to increase your engagement and overall satisfaction with our Service. This includes contextual, behavioral and interests-based advertising based on the Visitor’s or User’s activity, preferences or other data available to us or to our business partners;
  7. To contact our Visitors and Users (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described below);
  8. To facilitate, sponsor and offer certain events, contests and promotions;
  9. To publish your feedback, user story and submissions;
  10. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  11. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
  12. To comply with applicable laws and regulations.

We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).

  1. Data Location & Retention

Data Location: Our online booking platform is based on the Guesty platform that allow guests or tenants to perform online booking or reservations of properties and rooms from Guesty clients. Your Personal Data is maintained, processed and stored through Guesty (whose privacy policy is available here: https://www.guesty.com/privacy-policy and our authorized Service Providers (defined below) in cloud services in the US and in other countries. the laws in those countries may provide a lesser degree of data protection than the laws of your own country. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by law.

Data Retention: We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Service and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use).

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.

  1. Data Sharing

Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.

Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution, marketing and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and enrichment services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, compliance and financial advisors (collectively, “Service Providers“).

These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes as determined in our agreements with them.

Our Service Providers shall be deemed as ‘Data Processors’ where Viagem assumes the role of ‘Data Controller’.

Our Service Providers may include Guesty and its partners, Lynx keyless solutions, Stripe, Google Analytics and others. Such Service Providers may use your Personal Information detailed above, in accordance with their privacy policy including by sharing information with their partners and retaining it. For more information regarding our Service Providers, please contact us at: contact@stayviagem.com.

Sharing your Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Sites and Service (including other customers). If you wish to remove your public review, please contact us at: contact@stayviagem.com.

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Viagem, any of our Users or any members of the general public.

Viagem Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group, for the purposes described in this Privacy Policy. In addition, should Viagem or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of any of its assets, your Personal Data may be shared with the parties involved in such an event.

For the avoidance of doubt, Viagem may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

  1. Cookies and Tracking Technologies

Our Sites and Service (including some of our Service Providers) utilize “cookies”, anonymous identifiers, container tags and other technologies in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by a User.

Please note that we do not change our 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.

  1. Communications

Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes,  etc. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like billing notices or Reservation related communications).

Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Viagem at any time by sending an e-mail to: contact@stayviagem.com.

  1. Data Security

In order to protect your Personal Data held with us, we are using industry-standard physical, procedural and technical security measures however, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section above.

  1. Data Subject Rights

If you wish to exercise your rights under any applicable law, such as the right to request access to, and rectification or erasure of your Personal Data held with Viagem, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, you can either do this through the Platform or contact us by e-mail at: contact@stayviagem.com.

Please note that once you contact us by e-mail, we may instruct you on how to fulfill your request independently through the Platform; or may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

  1. Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.

Viagem is the “Data Controller” of Personal Data relating to its Visitors’ and Users’ contacts, as well as of data consisting of profile and contact details, and usage, preferences, engagement and analytics data. With respect to such data, we assume the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “Data Processor”.

  1. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Service. The amended version will be effective as of the date it is published. When we make material changes to these Terms, we’ll provide customers with notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending customer an email. Your continued use of the Service after the changes have been implemented will constitute your acceptance of the changes.

External Links: While our Service may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Service for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Service.

Our Service is not designed to attract children under the age of 21: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 21 is using the Service, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at: contact@stayviagem.com.

Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your Personal Data held with us, please contact Viagem’s support at: contact@stayviagem.com. If you are a GDPR-protected individual, you may, to the extant applicable, also have the right to lodge a complaint with an EU supervisory authority.

For any inquiry, please contact contact@stayviagem.com or:

85 Broad Street, Suite 28-088, New York, NY 10004

Effective Date: 15 December, 2020