Traveling Coaches Privacy Notice

Effective Date: March 13, 2020

Welcome to the Traveling Coaches, Inc. Privacy Notice.

Traveling Coaches, Inc. (“Traveling Coaches,” “us,” “we,” or “our”) knows that you care about your privacy and protecting your Personal Data (defined below). This Privacy Notice explains how we collect, store, process, share and transfer your Personal Data when you visit our website, found at www.travelingcoaches.com (together with all sub-domains, and any successor website(s) thereto) (the “Site”). Supplemental information may be found in our Cookie Policy. By using our Site, you are accepting the practices described in this Privacy Notice.

For purposes of this Privacy Notice, “Personal Data” means any data that could reasonably be used to identify a person. Generally, we’ll refer to data “processing” when we talk about any operation or set of operations performed on Personal Data, such as the collection, use, sharing, disclosure, retention, and deletion of Personal Data.

We encourage you to read this Privacy Notice fully as outlined in the sections below:

What information do we collect?

On the Site, we may collect different kinds of Personal Data including, but not limited to:

• Identity Data includes first name, last name, title, and firm or company name.
• Contact Data includes firm or company name, email address, telephone numbers, and physical business address.
• Technical Data includes internet protocol (IP) address, browser type and version, time, date and use of the Site, location data, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
• Profile Data includes your interests and preferences.
• Site Use Data includes information about how you use our Site, and services.

Like many organizations, we place a “cookie” (a small data file) on your computer when you connect to our Site. This allows us to recognize your computer’s IP address on return visits, helps us understand traffic patterns on our Site and improve our Site. For more information about cookies and guidance about how to refuse cookies, see below, “How we use cookies and similar technologies” and our Cookie Policy.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Site Use Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How do we collect your Personal Data?

We use different methods to collect Personal Data from and about you including through:

• Direct interactions with you. You give us your Identity, Contact and Profile Data by filling in forms available on our Site. This includes Personal Data you provide when you:
  • Complete the “Contact Us” form on our Site; or
  • Subscribe to “Sign Me Up!” on our Site; or
  • Sign up to “Feed Your Read” on our Site.
• Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Please see below, “How we use cookies and similar technologies” and our Cookie Policy for further details.
• Third parties or publicly available sources. We may receive Personal Data about you from analytics providers such as Google based outside the European Union (“EU”). For more information about cookies and guidance about how to refuse cookies, see below “How we use cookies and similar technologies” and our Cookie Policy.

How do we use cookies and similar technologies?

Cookies: When you visit our Site, we may send a cookie to your computer. A cookie is a small data file stored by your computer to help improve functionality or tailor information to provide visitors with more relevant information. We also analyze Site traffic to identify what visitors visit so we can tailor our Site accordingly. For details about the cookies we use, please see our Cookie Policy, which is part of this Privacy Notice.

Other tracking technologies: We and our third-party service providers may use other, similar technologies from time to time, like web beacons, pixels (or “clear gifs”) and other tracking technologies. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Site or, in the case of web beacons, opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Site to another and to improve Site performance. While you may not have the ability to specifically reject or disable these tracking technologies, in many instances, these technologies are reliant on cookies to function properly; thus, in those instances, declining such cookies will impair functioning of these technologies.

How do we use your personal data?

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in circumstances including:

• Where it is necessary to administer customer service and relations;
• Where it is necessary for marketing or analytical purposes;
• Where we need to administer, maintain and secure our Site;
• Where we have a legitimate interest (for running our business, providing administration and IT services, network security, preventing fraud and in the context of a business reorganization or group restructuring exercise);
• Where it is necessary for us to perform our contractual obligations; and
• Where we need to comply with a legal or regulatory obligation.

Do we share your personal data?

Yes, we will share the Personal Data we collect as described in this section of the Privacy Notice. We may share this data as follows:

• With employees, contractors and agents that provide services to us: We may share the Personal Data that we collect with our employees, contractors and agents, including third-party service providers, that perform services and functions at our direction and on our behalf, but their use of such data shall be limited to the performance of their duties and is consistent with our purposes for using such information.
• With our third-party service providers:
  • Squarespace, Inc.;
  • Salesforce;
  • The Rocket Science Group LLC d/b/a MailChimp; and
  • 123FormBuilder S.R.L.
  • Manzama Inc.
• With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including: (a) to comply with a law, legal process or regulations; (b) responding to or cooperating with law enforcement authorities, other government officials or other third parties pursuant to a subpoena, a court order or other legal process; (c) to protect our property, services and legal rights; (d) with a potential buyer and its agents and advisors in case of a sale, merger, consolidation, liquidation, reorganization, or acquisition (in that event, any acquirer will be subject to our obligations under this Privacy Notice); (e) with any other person with your consent; and (f) to support our audit, compliance and governance functions.

How do we protect your Personal Data?

We maintain suitable physical, technical and administrative safeguards for our Site designed to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information we collect through our Site. When we share your Personal Data with third-party service providers, we put in place a written agreement which commits our third-party service providers to keep your Personal Data confidential, and to put in place appropriate security measures to keep your Personal Data secure. However, the transmission of Personal Data to our Site may not be completely secure and any transmission is at your own risk. If you have any questions about the security of our Personal Data, please contact us at privacy@travelingcoaches.com.

What are your legal rights?

Some jurisdictions (state, federal, national and international), such as California, Canada, and the European Economic Area (under the General Data Protection Regulation (“GDPR”)), provide individuals with certain rights regarding their Personal Data. To exercise any rights your jurisdiction may provide, contact us at privacy@travelingcoaches.com. Also, you may click on this link to find out more about these rights under the GDPR: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.

International transfer of Personal Data

This paragraph is intended only for those of you in the EEA.

Though we do not seek actively to transfer Personal Data of EU residents outside the EU, some of the external third parties we deal with are based outside the EU or process Personal Data outside the EU, so their processing of your Personal Data will involve a transfer of data outside the EU.

Whenever we transfer Personal Data of EU residents out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: “Adequacy of the protection of personal data in non-EU countries.”

Where we use certain service providers, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: “Model contracts for the transfer of personal data to third countries.”

In all such cases, Traveling Coaches is the controller and responsible for your Personal Data.

Other Privacy Issues:

Children’s information: Our Site is not directed at children under the age of eighteen (18) and we do not knowingly collect Personal Data from children under the age of eighteen (18).

Data Retention and Disposal: Personal Data will be stored as long as the information is required to fulfil our legitimate business needs or the purpose for which the information was collected, or for as long as is required by law. Our retention policies will vary depending on the type of data involved. Generally, we will refer to the following criteria to determine retention period:

• Whether the data is necessary to provide our services; or
• Whether we have a legal or contractual need to store the data.

Disclaimer of linked websites: The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.

“Do Not Track” Signals: We do not track our Portal’s visitors over time and across third party websites to provide targeted advertising, and therefore we do not respond to Do Not Track (DNT) signals at this time. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, you can learn more about “Do Not Track” by visiting www.allaboutdnt.com.

Automated decision-making: We do not use automated decision-making without human intervention, including profiling, in connection with the Portal.

How you opt-in to and opt-out of marketing materials: If you have opted-in to our newsletters, but no longer want to be contacted by us, you can opt-out of receiving our newsletters at any time by clicking the “unsubscribe” link at the bottom of our newsletter or contact us directly at privacy@travelingcoaches.com.

Updates to this Privacy Notice

We may update or change this Privacy Notice. The effective date at the top of this page states when this Privacy Notice was last revised. Any change to this Privacy Notice will become effective when we post the revised Privacy Notice on our Site.

If any change will materially and negatively affect the privacy of your Personal Data, we will use reasonable efforts to notify you in advance and give you a reasonable time to object to any changes.

We encourage you to periodically review this Privacy Notice to stay informed about how we process your Personal Data.

How you may contact us

Use the contact information below if you (a) would like to exercise any individual rights you may have about your Personal Information, (b) have questions, concerns or complaints about this Privacy Notice or our privacy practices or (c) would like additional information about Traveling Coaches privacy practices.

You may email us at privacy@travelingcoaches.com, or contact us at:

Chad Johnston
Director of Operations
5345 Towne Square Drive Suite 200
Plano, Texas 75024
cjohnston@travelingcoaches.com

Thank you for reading Traveling Coaches Privacy Notice.