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Overview
This Privacy Policy for ViaWay, operated by Mattia Zappa ("we," "us," or "our"), an individual acting as data controller, describes how and why we may access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you: download and use our mobile application (ViaWay), or any of our other applications that link to this Privacy Policy; or interact with us in other related ways, including any marketing activities or events. Do you have questions or concerns? Reading this Privacy Policy will help you understand your rights and choices regarding privacy. We are responsible for decisions about how your personal data is processed. If you do not agree with our policies and practices, please do not use our Services. For further questions or concerns, contact us at [email protected].
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Summary of Key Points
This summary provides key points from our Privacy Notice. You can find out more details about any of these topics by using the table of contents below to find the section you are looking for. What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information. Do we collect any information from third parties? We do not collect any information from third parties. How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties, including advertising partners like Google AdMob. How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
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1. What Information Do We Collect?
Personal data you provide to us In short: We collect personal data that you voluntarily provide to us. We collect personal data that you voluntarily provide to us when you register for the Services, express interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or when you contact us. Personal Data You Provide. The personal data we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal data we collect may include: email address, username, password, date of birth, first name, last name. Sensitive Information. We do not process sensitive information. Application Data. If you use our applications, we may also collect the following information, if you choose to grant us access or permission: Mobile Device Access. We may request access or permission to certain features of your mobile device, including camera, microphone, storage, and other features. If you wish to change our access or permissions, you may do so in your device settings. Push Notifications. We may request to send you push notifications regarding your account or certain features of the application. If you opt in to receive push notifications, we collect the notification token generated by your device, which is necessary for delivering alerts. If you wish to opt out of this type of communication, you may do so in your device settings. Location Searches. When you search for or enter a place in your itineraries, we collect your search text to provide you with geolocation results through our geocoding service provider. Device and Usage Data. When you use our mobile application, we automatically collect certain information such as your mobile device ID, model, manufacturer, operating system, version information, IP address, and advertising identifiers (such as Google Advertising ID or Apple IDFA). This information is primarily needed to maintain the security and operation of our applications, for troubleshooting, for our internal analytics and reporting activities, and to show relevant advertisements. All personal data that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such data.
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2. How Do We Process Your Information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including: To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
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3. What Legal Bases Do We Rely On?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: - If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way - For investigations and fraud detection and prevention - For business transactions provided certain conditions are met - If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim - For identifying injured, ill, or deceased persons and communicating with next of kin - If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse - If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province - If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records - If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced - If the collection is solely for journalistic, artistic, or literary purposes - If the information is publicly available and is specified by the regulations - We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments
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5. What Is Our Stance on Third-Party Websites?
In short: We are not responsible for the safety of any information that you share with third parties that we may link to or that advertise on our Services, but that are not affiliated with our Services. The Services may contain links to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us, which may link to other websites, services, or applications. Accordingly, we make no guarantees regarding such third parties and will not be liable for any losses or damages caused by the use of such third-party websites, services, or applications. The inclusion of a link to a third-party website, service, or application does not imply endorsement by us. We cannot guarantee the safety and privacy of data you provide to third-party websites. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for the content or the privacy and security practices and policies of any third parties, including other websites, services, or applications that the Services may link to or be linked from. We encourage you to review the policies of such third parties and to contact them directly with any questions.
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6. Do We Offer AI-Based Products?
In short: We offer an AI-based travel itinerary generation feature. Use of AI Technologies We provide this feature through a third-party service provider ("AI Service Provider"): Google, via the Gemini models. Your inputs (such as the travel preferences you indicate) and the related outputs are shared with and processed by this Provider to generate the requested itinerary. You must not use this feature in any way that violates the terms or policies of the AI Service Provider. Our AI Products We use AI exclusively for assisted travel itinerary generation within the App. How We Process Your Data Through AI Personal data processed through this feature is handled in accordance with this Privacy Policy and our agreements with the AI Service Provider.
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7. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than one (1) month past the termination of the user's account. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
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8. How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
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9. Do We Transfer Your Data Internationally?
In short: We may transfer, store, and process your data outside your country of residence, including countries that may not have the same data protection laws as your country. Our service providers (including Google for Gemini and AdMob, and Expo for push notifications) may process your personal data on servers located in the United States or other countries outside the European Economic Area (EEA). If you are located in the EEA, the United Kingdom, or Switzerland, we ensure that such transfers take place on the basis of appropriate legal mechanisms, such as the Standard Contractual Clauses approved by the European Commission, to ensure an adequate level of protection for your personal data.
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10. What Are Your Privacy Rights?
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence. In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in section 14 below. We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in section 14 below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Account Information If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. If you have questions or comments about your privacy rights, you may email us at [email protected].
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11. Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
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12. Do US Residents Have Specific Privacy Rights?
In short: If you reside in California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal data we maintain about you and how we have processed it, to correct inaccuracies, obtain a copy of it, or request its deletion. You may also have the right to withdraw your consent to the processing of your personal data. These rights may be limited in some circumstances by applicable law. Further information is provided below. Categories of Personal Data We Collect The table below shows the categories of personal data collected in the last twelve (12) months: A. Identifiers — Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, IP address, email address, and account name — Collected: YES B. Personal data as defined by the California Customer Records statute — Name, contact information, education, employment, employment history, and financial information — Collected: NO C. Protected classification characteristics under state or federal law — Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data — Collected: YES (limited to date of birth) D. Commercial information — Transaction information, purchase history, financial details, and payment information — Collected: NO E. Biometric data — Fingerprints and voiceprints — Collected: NO F. Internet or other similar network activity — Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements — Collected: YES G. Geolocation data — Approximate device location, inferred from IP address by our advertising partner (Google AdMob) for targeted advertising purposes. We do not collect the precise GPS location of the device. — Collected: YES H. Audio, electronic, sensory, or similar information — Images and audio, video, or call recordings created in connection with our business activities — Collected: NO I. Professional or employment-related information — Business contact details in order to provide you our Services at a business level, job title, work history, and professional qualifications if you apply for a job with us — Collected: NO J. Education information — Student records and directory information — Collected: NO K. Inferences drawn from collected personal data — Inferences drawn from any of the personal data listed above to create a profile or summary about, for example, an individual's preferences and characteristics — Collected: NO L. Sensitive personal data — Collected: NO We may also collect other personal data outside of these categories when you interact with us in person, online, by phone or mail in the context of: receiving help through our customer support channels; participation in customer surveys or contests; and facilitation of the delivery of our Services and to respond to your inquiries. Sources of Personal Data To learn more about the sources of personal data we collect, please refer to the "What Information Do We Collect?" section above. How We Use and Share Personal Data To learn more about how we use your personal data, please refer to the "How Do We Process Your Data?" section above. Will your information be shared with anyone else? We may disclose your personal data with our service providers pursuant to a written contract between us and each service provider. We may use your personal data for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal data. We have not disclosed, sold, or shared any personal data with third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal data belonging to website visitors, users, and other consumers in the future. Your Rights You have rights under certain US state data protection laws. However, these rights are not absolute, and in some cases, we may decline your request as permitted by law. These rights include: - Right to know whether or not we are processing your personal data - Right to access your personal data - Right to correct inaccuracies in your personal data - Right to request deletion of your personal data - Right to obtain a copy of the personal data you previously shared with us - Right to non-discrimination for exercising your rights - Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling") Depending on the state where you live, you may also have the following rights: - Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota law) - Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California, Delaware, and Maryland law) - Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota and Oregon law) - Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including Connecticut law) - Right to review, understand, question, and, depending on your state of residence, correct how personal data has been profiled (as permitted by applicable law, including Connecticut and Minnesota law) - Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California law) - Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida law) How to Exercise Your Rights To exercise these rights, you may contact us by submitting a data subject access request, by emailing us at [email protected], or by referring to the contact details at the bottom of this document. Under certain US state data protection laws, you may designate an authorized agent to submit a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. Verification of Requests Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have the information in our system. We will only use personal data provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide a written and signed permission from you to submit such request on your behalf. Appeals Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state's attorney general. California "Shine The Light" Law California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal data (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in section 14 below.
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13. Do Other Regions Have Specific Privacy Rights?
In Short: You may have additional rights based on the country you reside in. Australia and New Zealand We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act). This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information. If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular: - offer you the products or services that you want - respond to or help with your requests - manage your account with us - confirm your identity and protect your account At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided in section 15 below. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
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14. Do We Make Updates to This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
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15. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may email us at [email protected]. How Can You Review, Update, or Delete the Data We Collect From You? Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request at https://app.termly.io/dsar/69bd8dde-fdba-4c71-a218-2f052a212905.
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16. Social Network Features
Our Services offer social networking features that allow you to interact with other users. Please be aware that any personal data you voluntarily choose to submit in public areas of the Services (such as your public profile or your published trips) will be visible to other users and may be collected and used by third parties. We cannot control who reads your posted content or what other users may do with the information you voluntarily post, so please exercise caution with your personal data.