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Privacy Policy

Trip Ninja Inc. (“Trip Ninja”, “we”, “us”, “our”) is committed to respecting and preserving the privacy of those who engage with us through our website (the “Site”) or who use the other services we provide and in doing so, we endeavour to meet or exceed standards set by law.  This privacy policy (the “Privacy Policy”) applies to information that we gather from you as you use the Services.  

As part of our regular review of all of our policies and procedures, we may change this Privacy Policy from time to time without notice to you.  A current version of this Privacy Policy will be accessible on our Site(s) and Application(s) at all times.  Please also carefully read our Website Terms of Use prior to using the Services.

By accessing and using our Services you agree that you have read and understand this Privacy Policy.  Your use of the Services represents your implied consent for the collection, use and disclosure of any Information that you provide to us, or that we gather from you, through your use of the Site or otherwise, in accordance with the terms of this Privacy Policy. 

Definitions

Content: means any information that is submitted to Trip Ninja, publicly or privately, including but not limited to – Information, images, videos, graphics, sounds, texts and e-mails.

Information: includes both Personal Information and Non-identifiable Information.

Non-identifiable Information: means information that we gather from you that is not personally identifiable to you including, but not limited to, your IP address or browser software.

Personal Information: means information about an identifiable individual including, but not limited to, the User’s billing address and credit card payment information.

Services: means the services provided by Trip Ninja including, but not limited to, use of the Site, travel planning tools/APIs, or White Label solutions.

Site: means the Trip Ninja website hosted at www.tripninja.io. 

User (variously, “you” or “your”): an individual who accesses and uses the Services.

Minors

If you are under the age of majority in your jurisdiction of residence, be sure to obtain your parent or guardian's permission before you send any Personal Information to us, or anyone else. We encourage parents to get involved with their children's online usage and to be aware of the activities in which they are participating. 

Collection of your Information

We only collect Information that we believe is reasonably necessary for a legitimate purpose, as further described below.  In offering you the Services, we may collect Personal Information that you, or another, provides directly to us by filling in forms, and Non-identifiable Information that we collect from cookies or tracking software we utilize. In addition to Information collected while you use the Services, we may also collect Information in other ways such as over the phone, via email and through location tracking devices as further described below.

To the extent that Trip Ninja holds information about you due to your use of our services, Trip Ninja is the controller and is responsible for your personal information. In the cases where we process personal information on your or another’s behalf in providing our services to you, we act as data processor. You may review our Data Processing Addendum here.

The choice to provide us with Personal Information is yours.  In certain cases, your decision to withhold Information may limit the Services that we can provide to you.

Retention of your information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax and other legally required purposes. In some circumstances you can ask us to delete your information.

Further, in some circumstances we may anonymize your personal information (in which case it can no longer be associated with you) for research or statistical purposes; in this case we may use this information indefinitely without further notice to you.

Use of your Information

We will only disclose your Information for purposes identified in this Privacy Policy, or if required by law.  The Information that we collect and store is primarily used for the following purposes:

  1. to provide you with the Services;
  2. to provide you with information relating to our Services;
  3. to follow up on client or User comments and suggestions;
  4. to manage and develop our business systems and operations; 
  5. to monitor and conduct an analysis of our website traffic and usage patterns; 
  6. to post customer testimonials, comments or reviews; 
  7. to protect our rights and property; or
  8. to lessen a serious threat to personal safety, health or security.

We will not sell, share, trade or otherwise distribute your Personal Information to third parties, except in accordance with this Privacy Policy.  However, we reserve the right to use Non-identifiable Information for any commercial purpose in our sole discretion.  Such commercial purpose may include, but is not limited to, sale to third parties to allow them to send targeted advertising messages.

We reserve the right to share any Information collected from you with affiliates, or to transfer such Information to a successor entity or to an entity which purchases substantially all of the assets of Trip Ninja.

We sometimes contract with outside organizations to perform specialized services such as hosting the Site. Our suppliers may at times receive, process or handle some of your Information. Only the Information necessary to perform the services under the contract is given to the supplier. Under their contracts with us, our suppliers may use such Information only to carry out the contracted service and must not store or use the Information for any other purpose. Our contracts with suppliers require that they provide a level of protection for your Information that is comparable to our own. 

Security

To ensure that your Personal Information is secure, we have put in place commercially suitable procedures to safeguard the Information we collect against unauthorized use, disclosure, or modification.  Nonetheless, transmission of information on the internet is not completely secure. Therefore, we cannot guarantee the security of data sent to us electronically on our Site, by email or otherwise and transmission of such data is therefore entirely at your own risk. Likewise, the storage of information is not completely secure and we cannot guarantee the security of data stored on our system and storage of such data is therefore entirely at your own risk.

GDPR Compliance

If you are based in the European Union (EU), please note that the data protection law in the EU changed on May 25, 2018. For more information on how GDPR is handled at Trip Ninja, please visit our GDPR Statement page here.

If you are based in the European Union, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator - please contact us at contact@tripninja.io.

International Transfers

We share your personal information within our company. This will involve, if you are based in the European Union, transferring your data outside the European Economic Area (EEA). Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.

If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Updating your Information and Correcting Errors

You have the right to access, verify and amend all of your Personal Information.  Since we use your Personal Information to provide services to you and others, it is important that the information be accurate and up-to-date. If any of your Personal Information changes, is inaccurate, or is incomplete, please inform us so that we can make any necessary changes.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. You have the rights to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at contact@tripninja.io.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third Party Website and Interaction

By accessing third party websites or applications through our Site, you are consenting to the terms and privacy policies of those websites.  We do not accept any responsibility or liability for their policies. You should read the individual privacy policies of such websites, and make an informed decision whether or not to use those websites based upon their privacy practices and your discretion.

Contact Us:

If you have any questions, concerns or suggestions regarding this Privacy Policy, please contact us at

Email: contact@tripninja.io

This Privacy Policy last updated on February 19, 2019.

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Trip Ninja is a division of Webjet Limited (ASX: WEB) – an ASX 200 listed company.  For more information, visit www.webjetlimited.com