1. General information
beauVoyage will have appropriate technical and organisational measures in place to safeguard your personal data against loss or any other form of unlawful processing.
The party responsible for processing personal data from the beauVoyage platform is the
beauBateau GmbH Mönchhofstraße 6 69120 Heidelberg Germany e-mail: [email protected]
The beauBateau GmbH is the owner of beauVoyage and hereafter referred to as “beauVoyage”, “we”, “us” or “our”. The beauBateau GmbH is a company registered with the Chamber of Commerce in Germany under the number HRB 12758.
Legal basis for processing personal data
If we obtain consent from you to process personal data, Article 6(1)(a) GDPR serves as the legal basis.
When processing personal data needed to fulfil a contract with you, Article 6(1)(b) GDPR also serves as the legal basis in the individual case. The same applies to processing needed to carry out pre-contractual measures.
If personal data must be processed for complying with a legal obligation, Article 6(1)(c) of the GDPR applies as well.
If interests essential for the life you or that of another natural person necessitate the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.
If processing is necessary to uphold beauVoyage’s legitimate interests or those of a third party and if such interests are not overridden by the interests or fundamental rights and freedoms of you, Article 6(1)(f) GDPR applies as the legal basis. For instance, data processing helps us continuously optimise our online services.
2. Data collection
We collect the information you provide on our web platform. This also comprises data in or about the content you provide (called ‘metadata’), such as the location of a photo or the date a file was created. We also receive and process personal data you give to us during registration and subscription (such as your e-mail address or billing information) in order to create your account, to invoice you, and for the performance of a contract in connection with the use of our services to which you are a party.
When individual pages of our platform are retrieved, we log information on how you use our online offerings; such as which content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the date, time, frequency and duration of your activities. These information include details of the request and destination (log version, HTTP method, referrer, user agent string), name of the file retrieved and amount of data transferred (requested URL and query string, size in bytes), whether the request was successful (HTTP status code), websites from which the user’s system accesses our platform, websites accessed by the user’s system via our platform. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by beauVoyage, namely to facilitate content creation and interaction between users, as well as for our service to operate as optimally as possible.
Our system automatically records data regarding the web-connected device through which our platform is accessed. We combine this information across different devices you employ. Data we obtain from these devices include:
- Device attributes such as the operating system, hardware and software versions, battery level, signal strength, available storage space, type and version of browser or app, file names, types, and plugins.
- Device signals: bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
- Data from device settings: information you allow us to receive through device settings you turn on, such as access to your camera or photos.
- Network and connections: information, such as the name of your mobile operator or Internet service provider, language, time zone, mobile phone number, IP address (anonymised), connection speed.
- Cookie data stored on your device, including cookie IDs and settings. Learn more about how we apply cookies below.
beauVoyage requires this information in order for the service to function as optimally as possible (for example, to display content correctly and to keep the service secure), the processing of these personal data is therefore necessary for the purposes of the legitimate interests pursued by beauVoyage.
You can contact us using the e-mail address [email protected]. The information contained in your message (including any personal data you provide) will be saved and used for the purpose of contact and processing the conversation.
If you opt-in for direct marketing, we may, for instance, inform you about updates to our services via e-mail. You may unsubscribe from such marketing or promotional e-mails at any time in the footer of any marketing or promotional e-mail. Please, note that you cannot opt-out of service or legal notices.
Every Internet browser can show you when cookies have been stored on your computer and what they contain. Most browsers accept cookies by default. However, by changing the settings in your Internet browser, the storage of cookies can be disabled or limited to the duration of the individual Internet connection only. Cookies that have already been stored can be deleted at any time. If cookies are deactivated for our platform, it may no longer be possible to use the full range of functions.
Cookies are employed on the basis of Article 6(1)(a) and (f) GDPR.
Data received from third parties
We may receive data about you from third parties with services that interact with the beauVoyage services or that provide services to us, e.g., websites and applications offered by third party developers that integrate with our API or analytics services. This data may relate to your activity on our platform or on unaffiliated websites and apps, or data received from web browsers or operating systems such as browser types and settings, the operating systems, device models, carriers, location information, IP address, mobile device and advertising identifiers (e.g. Apple IDFA or Google Advertising ID), as well as cookie information, pixel or other similar technology. If you created your account using your Google or Facebook account, we may receive certain information from them, such as your first name, last name, gender, birthday, e-mail address and your Facebook or Google ID.
Further purposes of data collection and processing
We may process your data to operate and maintain the beauVoyage platform, and to understand you better and tailor our services to you. You may use our online offerings when you are not logged into your beauVoyage account. If you subsequently log into your beauVoyage account, we may combine data collected while you were not logged in with your beauVoyage account actions. We may also use your data for research and development, to improve the beauVoyage services, or to offer new products, features and tools.
Furthermore, we may deploy your data to customise our platform to provide you with your own special experience. We do this by inferring your interests and preferences, looking at your travel and search history or allowing you to find and add friends who are also using our services from your device’s contact list or if applicable, your Facebook or Google account if you have opted to connect this account to your beauVoyage account. In these situations, we do not store your contact lists. Based on your travel history and behaviour, we may, for example determine that you prefer hostels instead of hotels and therefore show you more recommendations for hostels. The processing of these personal data is necessary for the purposes of the legitimate interests pursued by beauVoyage, namely to give you recommendations and to personalise your experience while you are using the service.
We may use your data to protect the rights, property or safety of beauVoyage, our services, our users and employees, or any third party. For example, we may need to enforce or apply our Terms and Conditions or other policies.
3. Information sharing
Publicly available data
When you use our services, certain information is public, such as your name, username, profile picture, home town, public trips (including metadata), your social interaction on public trips of other members, your number of followers and the number of people that you follow. These publicly available data may be searchable by search engines and be shared with or disclosed to third parties, including to our partners and customers.
Your content sharing options
When you have signed-up as a ‘public blogger’, the content of the weblog you host on the beauVoyage platform, including your metadata, is shared with the public. Public information can be seen by anyone, including people without an account. Individuals accessing your publicly available data may use it or disclose it to other individuals or entities without our control and without your knowledge. Public information can also be seen, accessed, reshared or downloaded through third party services, such as search engines or APIs. We therefore urge you to think carefully about including any specific information you may deem private in trips, comments, plans or tips or other content that you create on our platform.
When you have subscribed as a ‘private blogger’, you select the audience for your different posts by sending exclusive invitations.
However, any member’s posts may be checked at random via algorithms as well as manually to identify inappropriate content.
The secret link functionality enables you to share your trip with a limited amount of people who can use it to view your journey without having a beauVoyage account. Sharing a secret link implies that more people than the person you initially shared the link with may potentially see your trip. This could happen for example if a person you have shared a link with shares it with a third person, or if a third person opens the link from the history of a browser which is used by multiple people.
Data sharing with third parties
beauVoyage may use service providers, vendors, and contractors to provide or perform services on our behalf. In these cases, we may need to share your personal data with them. Our service providers, vendors, and contractors will be subject to binding contractual obligations to: (i) only process the personal data in accordance with our prior written instructions; and not use the personal data for their own purposes; and (ii) use appropriate measures to protect the confidentiality and security of the personal data; together with any additional requirements under applicable law.
When we partner with a business, we may pass on personal information to them, but only in aggregate and anonymous form, such as de-identified data about visits to places (i.e., not tied to individual members). We may also share or disclose aggregated, pseudonymised, and/or anonymised data to other third parties, including other beauVoyage members, and developers who use our API or SDK, for analytical or other purposes.
We may share your data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganisation, liquidation, or similar business transaction or corporate event.
4. Data erasure and storage period
Your data will be retained until the purpose of storage ceases to apply or until your account is deleted. We delete your personal data ninety (90) days after you have deleted your account. However, if you delete your account, any of your anonymised and pseudonymised data that have already been included in the pool of data used by our data analysis tools will not be deleted.
Furthermore, data may be stored for a longer period if provided for by the European or national legislator in EU regulations, laws or other provisions to which the person responsible is subject. Data will also be made unavailable or erased when a maximum storage period prescribed by the aforementioned standards expires, unless continued storage of the data is necessary for the conclusion or fulfillment of a contract.
5. Your rights
All members can see, edit, or delete their personal information at any time. Pursuant to the General Data Protection Regulation (GDPR), you have the following rights vis-à-vis beauVoyage with respect to personal data concerning you:
Right of access, Article 15 GDPR:
This right gives you comprehensive access to your personal data and to information regarding other key criteria, such as the purpose of processing or the period of storage.
Right to rectification, Article 16 GDPR
This right enables you to have inaccurate or incomplete personal data concerning you to be corrected or completed.
Right to erasure, Article 17 GDPR
You have the right to demand that beauVoyage deletes data concerning you (“right to be forgotten”). However, such data may be deleted only if they are no longer needed, if they were processed unlawfully or if consent covering their processing has been withdrawn. The right to erasure does not apply for data beauVoyage is obliged to keep for administrative, legal, or security purposes.
Right to restriction of processing, Article 18 GDPR
This right enables you, under certain circumstances, to temporarily prevent further processing of your personal data. Such a restriction is used above all when you are examining whether to claim other rights.
Right to object, Article 21 GDPR
This right enables you to object to further processing of personal data concerning you if such processing is justified by legitimate interests of beauVoyage (Article 6(1)(f) GDPR). beauVoyage shall no longer process the personal data, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Where personal data are processed for direct marketing purposes, you always have the right to object to the processing of personal data. In that case, beauVoyage shall no longer process your personal data for marketing.
Right to data portability, Article 20 GDPR
This right enables you to receive the personal data, which you have provided to beauVoyage, in a structured, commonly used and machine-readable format from beauVoyage and to transmit those data to another party when the processing is based on your consent or is necessary for the performance of a contract.
Right to withdraw consent, Articles 13 and 14 GDPR
If the personal data are processed on the basis of consent (Article 6(1)(a) GDPR), you can withdraw your consent at any time for the purpose in question. The lawfulness of processing on the basis of the consent provided remains unaffected until notification has been received that consent has been withdrawn.
6. Embedded content
8. Contact and request policy
You may send your requests and questions regarding the processing of your personal data by mail at beauBateau GmbH, beauVoyage Customer Service, Mönchhofstraße 6, 69120 Heidelberg, Germany, or via e-mail at [email protected].
beauVoyage shall respond to your request without undue delay and in any event within 30 days of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. beauVoyage shall inform you of any such extension within 30 days of receipt of the request, together with the reasons for the delay.
If we do not take action on your request, beauVoyage shall inform you without delay and at the latest within 30 days of receipt of the request of the reasons for not taking action. In that case, you also have the right to lodge a complaint with the supervisory authority and to seek a judicial remedy.