January 31, 2023
January 18, 2023
Key, non-exhaustive points about our information practices are summarized below, followed by comprehensive explanations of each subject.
- Collection. We collect information about you, such as identifying information (e.g., name, email address), payment data, and contact information (e.g., e-mail address, telephone number). See below to learn more.
- Use. We use your information as needed to provide our products and services, and improve the quality, safety, and security of our products and services, to develop new products and services, and to develop a business relationship with you. See below to learn more.
- Sharing. We share your information to provide you with products and services, to improve the quality, safety, and security of products and services, to comply with applicable law, to respond to your requests, and for marketing or other purposes, subject to your consent where required. See below to learn more.
- Data Security. We use reasonable administrative, technical and physical security to protect the personal information we retain. See below to learn more.
- Choices. You have choices regarding how we use and share your information for marketing and other purposes. See below to learn more.
- Children’s Privacy. We do not target or knowingly collect any information from children under the age of majority. See below to learn more.
- California Privacy Rights. If you are a California resident, you have additional rights regarding your control and access to the data we collect from you. See below to learn more.
- European Economic Area and UK Privacy Rights. If you are a resident of the European Economic Area ("EEA") or the United Kingdom (“UK”), you have additional rights. See below to learn more.
- Contact Us. Please contact us at (248) 650-3070 or firstname.lastname@example.org if you have any questions or concerns regarding our data handling practices. See below to learn more.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
The personal information we collect depends on how you interact with us, the subscriptions you purchase, and the choices you make. We collect personal information about you from different sources and in various ways.
Information You Provide to Us. Tour Connection collects information you provide directly to us on the Site, through a subscription purchase, via email, or through your communications or interactions with us. This includes the following:
- Identifying and contact information, such as your full name, address, telephone number, and email address.
- Payment information, such as the method you use for purchasing a subscription.
Information We Collect through Automatic Data Collection Technologies.
- Information Automatically Collected via the Site. When you visit the Site, we automatically collect certain technical information from your browser, such as the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other data about your visit to the Site.
- Information Collected Using Analytics Tools. We may use analytics features such as reporting tools to collect data about the daily number of inquiries and who these inquiries were sent to.
OUR USE OF YOUR PERSONAL INFORMATION
We use the information we collect in the following ways:
- To Provide Our Products and Services. We use collected information to facilitate your use of our products and services. For example, we will use your name and address information to register you as a user.
- To Advertise, Market or Send You Promotional Materials. We may use your information to further our marketing activities and send you promotional materials. Promotional materials may include newsletters or other information regarding Tour Connection products. We also use your information to share other services or products that may be of interest to you. Promotional materials may be conveyed in emails. If you no longer wish to receive these materials, you may opt out by following the opt-out instructions included in our emails, texts, or mailings, or by contacting us at (248) 650-3070 or email@example.com.
- To Improve Our Services. We collect information using Cookies (data files created when you visit a website), or analytic tools. We use this information to improve the security, design, and/or function of the Site. We may also use your information to support and develop our products and service offerings.
- To Fulfill or Meet the Reason you Provided the Information. For example, if you share your name and contact information to request information or ask a question about our products or service offerings, we will use that information to respond to your inquiry. We may also save and use your information to market or promote our products and service offerings.
- To Provide Customer Support. We may use your information to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To Maintain Safety and Security. We may use your information to help maintain the safety, security, and integrity of our products, website and services, databases and other technology assets, and business.
- To Further Product Development. We may use your information for testing, research, analysis, and product development to allow us to develop and improve our products and service offerings.
- To Comply with Our Legal Obligations. We may use your information if we are required to respond to a law enforcement request and as required by applicable law, court order, or governmental regulations.
- Other uses:
To present our Site and its content to you.
- To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.
- To notify you about changes to our Site or any products or services we offer or provide through it.
- As described to you separately when collecting your personal information.
OUR SHARING OF YOUR PERSONAL INFORMATION
We share personal information with your consent, when you direct us to share it with others, or as necessary to complete your transactions or provide the products you have requested or authorized. For example, when you provide payment data to us, we will share that data with banks and other entities as necessary for payment processing, fraud prevention, or other related financial services.
We share your information with the following parties:
- Technology and Service Providers. Software, IT and cloud service providers we use to support our business. We may also share your information with our selected partners in order to conduct business, including conducting audits, performing industry analysis, and evaluating the results of marketing efforts. We may also share your information with customer relationship management, consultants, financial, legal and other similar providers we use to support our business. When you provide information as described above, we may also share your information with selected partners (e.g., email newsletter providers) to provide you the requested information.
- Payment Service Providers. System providers and payment processors and related providers to perform functions such as processing, storing, verifying or managing payment card information.
- With Other Third Parties. Other third parties when legally required to do so, such as at the request of governmental authorities conducting an investigation or to verify or enforce compliance with policies governing the Site and applicable laws. In addition, we may disclose user information if we believe disclosure is necessary to protect the rights, property or safety of Tour Connection, or any of our respective affiliates, business partners, customers or others.
- Corporate Transactions Parties in connection with, during, or upon completion of a merger, acquisition, asset sale, or other business transaction that involves some, or all, of Tour Connection’s assets, data you have provided to Tour Connection may be transferred to a successor/purchaser as part of a transaction.
We may share de-identified information in accordance with applicable law without restriction with third parties for advertising, promotional, or other marketing purposes.
Should you have further questions or concerns about our security measures, please contact us using the information below.
CHOICE AND CONTROL OF YOUR PERSONAL INFORMATION
You can control how your information is used in the following ways. For California residents, you have additional rights and means to control your information: see more below.
Information Request. You may request information from Tour Connection regarding the personal information it collects from you and how it shares your personal information with third parties. We will endeavor to provide a copy of this information in a standardized format. You may make such a request by emailing firstname.lastname@example.org or calling us at (248) 650-3070.
Accessing, Correcting, and Deleting your Personal Information You can review, update and request to change your personal information by contacting us at email@example.com or calling us at (248) 650-3070 where you can request access to, correct, or delete any personal information that you have provided to us. We will ask you to verify your identity before we give you access to your information or correct it. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Opting Out of Communications. Our promotional materials include instructions and a link for opting out of receiving further communications. If you no longer wish to receive promotional emails, you may also opt out by contacting us with your request at (248) 650-3070 or firstname.lastname@example.org. Please note that even if you opt out of receiving marketing communications, we may still communicate with you regarding an established business relationship or communicate with you about an order, if one has been established. Please allow a reasonable time after reaching out for us to process your request.
Updating or Cancelling an Account with Tour Connection. If you signed up for an account with Tour Connection, you may update the information associated with your account or cancel your account at any time by contacting us with your request at (248) 650-3070 or email@example.com.
Nevada Privacy Rights. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request by calling (248) 650-3070 or emailing firstname.lastname@example.org.
CHILDREN UNDER THE AGE OF 13
Our services are not designed or intended to collect information from children under the age of 13. Tour Connection does not knowingly collect or maintain any information from children under the age of 13.
CROSS BORDER TRANSFERS
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
If you are a California resident, California law provides you with additional rights regarding our use of your personal information. This Privacy Notice for California Residents applies only to personal information (defined below) concerning individuals who reside in the State of California. We provide this notice in accordance with the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively the "CCPA") and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information"). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA's scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA), or clinical trial data.
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from or about consumers within the last twelve (12) months:
Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Name, signature, address, telephone number, passport number, bank account number, credit card number, debit card number, or any other financial information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of products or services purchased, obtained, or considered.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar electronic network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
L. Sensitive Information
Government identifiers (social security, driver's license, state identification card, or passport number); Complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password); Precise geolocation; Racial or ethnic origin; Religious or philosophical beliefs; Union membership; Genetic data; Mail, email, or text messages contents; Unique identifying biometric information; Health, sex life, or sexual orientation information.
We obtain the categories of personal information above from the following categories of sources:
- Directly from you. For example, when you purchase a product from us, the surveys and forms you complete, or through your direct commercial or business relationship with us.
- Indirectly from you. For example, from observing your actions on our Site, from your use of any other websites affiliated with Tour Connection or from information you post on or submit to our Site.
- From other sources. For example, marketing companies that we use to provide you with information concerning our products, service offerings and other information.
Use of Personal Information.
We may use or disclose the personal information we collect as set forth in the Use of Your Personal Information section referenced above.
Sharing Personal Information.
Disclosures of Personal Information for a Business Purpose.
In the preceding twelve (12) months, Tour Connection has disclosed information in the following categories identified above for a business purpose:
- Category A. Identifiers.
- Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Category D. Commercial information.
- Category F. Internet or other similar electronic network activity.
Sale and Sharing of Personal Information.
California residents may opt out of the “sale” or “sharing” of their personal information. We potentially could be deemed to “sell” or “share” your personal information, as those terms are defined in the CCPA, to third parties to provide you with offers that you may be interested in. Under the CCPA, “sale” is defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising related to the Services. “Sharing” is defined as any disclosure, transfer, or other communication of personal information to third parties for purposes of advertising that is targeted based on a consumer’s activities on third-party and distinctly branded digital platforms, whether or not for monetary gain.
If you would like to opt out of the use of your personal information for such purposes that may be considered a “sale” or “sharing” under California law, you may do so by emailing us at email@example.com. Please note that we do not knowingly sell or share the personal information of minors under 18 years of age.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Your Rights and Choices.
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
1. Access, Use Limitation, and Data Portability Rights.
You have the right to request that we limit the use and disclosure of certain personal information, opt-out of the use of certain personal information, as well as disclose certain information to you about our collection and use of your personal information over the past 12 months. You may request that we:
- Disclose to you the categories of personal information we collected about you.
- Disclose to you the categories of sources for the personal information we collected about you.
- Disclose to you our business or commercial purpose for collecting or selling that personal information.
- Disclose to you the categories of third parties with whom we share that personal information.
- Disclose to you the specific pieces of personal information we collected about you (also called a data portability request).
- Disclose to you if we sold, shared, or otherwise disclosed your personal information for a business purpose, separately disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased;
- Sharing, identifying the personal information categories that we shared with each category of recipient; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Disclose to you if we used automated decision-making technology to evaluate or create a profile of you and provide information about the logic involved in such decision-making processes, including descriptions of the likely outcome.
- Stop using automated decision-making technology to evaluate you, create a profile of you, and make predictions about your future behavior.
- Limit the use and disclosure of your “sensitive personal information,” as that term is defined in the CCPA. At your request, we will use “sensitive personal information” only for purposes necessary to provide the Services.
2. Deletion Request Rights.
You have the right to request that we delete your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your consumer rights request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us, or our service provider(s), to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
3. Correcting Your Personal Information.
You have the right to request that we correct any inaccurate information we hold about you. Upon receipt and verification of your request to correct inaccurate personal information, we will use commercially reasonable efforts to correct your personal information as directed by you, pursuant to the law and applicable regulations.
4. Exercising Access, Use Limitation, Data Portability, Deletion, and Correction Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either calling us at (248) 650-3070 or emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us through the methods noted above. Only the consumer or authorized agent may make a verifiable consumer request related to their personal information. An “authorized agent” is a person (or a business entity registered with the California Secretary of State) that consumers have authorized to act on their behalf or an individual granted authority under a written power of attorney issued pursuant to California Probate Code sections 4000 to 4465.
If you are an authorized agent who wishes to submit a request to know, a request to delete, or a request to opt-out on behalf of another consumer, please submit to us sufficient information to allow us to verify your identity to a reasonably high degree of certainty and either:
- Proof of authorization to submit the request, written and signed by the consumer; or
- A power of attorney pursuant to Probate Code sections 4000 to 4465.
We may deny a request from an authorized agent who does not submit adequate proof that they have been authorized by the consumer to act on the consumer's behalf. We may also contact the consumer directly to confirm their identity and that they provided you permission to submit the request on the consumer's behalf.
You may only make a consumer rights request for deletion, access, or data portability twice within a 12-month period. The consumer rights request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a consumer rights request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a consumer rights request to verify the requestor's identity or authority to make the request.
5. Response Timing and Format.
We endeavor to respond to a consumer rights request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your consumer rights request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California Do Not Track Disclosure.
Do Not Track (“DNT”) is a privacy preference that you can set in your web browsers, which allows you to opt out of tracking by websites and online services. We do not currently recognize or respond to DNT signals. For more information about DNT, please see www.eff.org/issues/do-not-track
California Shine the Light.
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
If you have any questions or comments about this notice, the ways in which Tour Connection collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
- (248) 650-3070
- 511 Olde Towne Road, Box #80220, Rochester, MI 48308
EEA AND UK PRIVACY NOTICE
Tour Connection, Inc. ("Tour Connection") contact information:
- (248) 650-3070
- 511 Olde Towne Road, Box #80220, Rochester, MI 48308
Legal basis and purposes for data processing:
We only process personal information when we have a legal basis for the processing and have your consent. We may also process your personal information for the purposes of our own legitimate interests or for the legitimate interests of others so long as that processing does not outweigh your rights and freedoms. Specifically, we will only process your personal information as follows:
- For the reason you provided it to us, including to provide the services requested.
Automated decision making and profiling:
We do not make automated-decisions about you or engage in data profiling.
Personal information requirements:
To engage with our Site, product, and services, you are required to provide certain information regarding your age. You are not required to provide any other personal information to Tour Connection. If you engage or access our services, you are required to provide certain additional personal information to enable us to perform the services. During your registration for our services, you will be provided with information regarding which data elements are required.
You have choices regarding how we use your personal information. You are entitled to:
- The right to access: You have the right to request copies of your personal information. We may charge you a minor fee for this service.
- The right to rectification: You have the right to request that we correct any information that you believe is inaccurate. You also have the right to request that we complete information that you believe is incomplete.
- The right to erasure: You have the right to request that we erase your personal information under certain conditions.
- The right to object to processing: You have the right to object to our processing of your personal information, under certain conditions.
- The right to data portability: You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
In addition, when Tour Connection provides its services or acts as a data processor, we receive your personal information from third parties as needed to provide services. If Tour Connection is processing your personal information as a data processor, we will refer you to our client for assistance with these requests. We support our clients with responding to requests required by law.
You may also decline our marketing communications.
To exercise these rights, please contact us at the address above. Note that for your protection, we may need to verify your identity before we can process your request.
If you believe that we have violated applicable law in our processing of your personal information, please contact us at firstname.lastname@example.org or contact a supervisory authority.
Your personal information may be transferred to, stored at, or processed in the United States, or other countries that may not have equivalent privacy or data protection laws.
We generally use approved EU and UK Standard Contractual Clauses to assure that Personal Information is adequately protected when it is transferred out of the EEA and UK.
Please contact us via email at email@example.com if you would like more information about cross-border transfers or to obtain a copy of the EU and UK Standard Contractual Clauses.