Our commitment to protecting your personal information
Last revised on April 24, 2018, effective as of May 25, 2018
Our commitments to employees are governed by our internal employment policies.
In all instances we are, committed to transparency with our customers, employees and protecting your data privacy.
Who we are
We are Mavericks Travel Group with travel properties of Mavericks Travel, Riga Guide, Vilnius Guide, Tallinn Guide, Russia Rocks. Our HQ website address is https://maverickstravel.com, further related to Platform.
What personal data we collect and why we collect it
There are three general categories of information we collect.
Information You Give to Us.
Information that is necessary for the use of our Platform.
We ask for and collect the following personal information about you when you use our Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
- Account Information. When you request a booking information or sign up for an Account, we require certain information such as your first name, last name, email address, and phone number.
- Profile and Listing Information. To use certain features of our Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
- Payment Information. To use certain features of our Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via Stripe Payments).
- Communications with Platform and other Partners. When you communicate with us or use our Platform to communicate with other Partners, we collect information about your communication and any information you choose to provide.
The information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using our Platform. This additional information will be processed based on your consent.
- Additional Profile Information. You may choose to provide additional information as part of your profile (such as place of stay, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page and will be publicly visible to others.
- Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Platform.
Information that is necessary for the use of the Payment Services.
The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:
- Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
Information We Automatically Collect from Your Use of our Platform and Payment Services.
When you use our Platform and the Payment Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of our Platform and Payment Services.
- Geo-location Information. When you use certain features of our Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
- Usage Information. We collect information about your interactions with our Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on our Platform.
- Log Data and Device Information. We automatically collect log data and device information when you access and use the Platform, even if you have not created an Account or logged in. That information includes, among other things: details about how you’ve used the Platform (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Platform.
- Payment Transaction Information. Our Payment Facility (Stripe) collects information related to your payment transactions through our Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Stripe and to allow the provision of the Payment Services.
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
After purchasing one of our tours, adventures, and experiences, the personal data we may hold about you will contain the following information: First Name, Last Name, Email Address, Phone/Mobile Number, Address, Company Information in order to order to process the necessary service. You may request the removal of the following personal data on our records at any time by contacting our team.
If you leave a comment on our site you may opt-in to save your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
Under the GDPR, we report as being a Data Controler for Google Analytics ас our core analytics solution with Google being a Data Processor. As the Data Processor, Google has obligations to conform to the EU GDPR. Please consider taking a look at Google’s own Privacy Compliance website for more details on the matter, You can opt out of its analytics tracking by installing a Google Analytics Opt-out Browser Add-on
Who we share your data with
With Your Consent
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Account or when you participate in promotional activities conducted by our partners or third parties.
Sharing between Members
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as a Guest submit a booking request, certain information about you is shared with the Partner (and Co-Partner, if applicable), including your full name, the full name of any additional Guests, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
- When you as a Partner (or Co-Partner, if applicable) have a confirmed booking, certain information is shared with the Guest to coordinate the booking, such as your full name, phone number, and Accommodation or Experience address.
- When you as a Partner invite another Member to become a Co-Partner, you authorize the Co-Partner to access your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation address, and email address.
- When you as a Guest invite additional Guests to a booking, your full name, travel dates, Partner name, Listing details, the Accommodation address, and other related information will be shared with each additional Guest.
- When you as a Guest initiate a Group Payment Booking Request certain information about each participant such as first name, last initial, profile picture as well as the booking details are shared among all participants of the Group Payment Booking Request.
We don’t share your billing and payout information with other Members.
Profiles, Listings, and other Public Information
Our Platform lets you publish listing information, including personal information, that is visible to the general public. For example:
- Parts of your public profile page, such as your address, first name, your description, and city, are publicly visible to others.
- Listing pages are publicly visible and include information such as the Accommodation or Experience’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
- After completing a booking, Guests and Partners may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on our Platform (such as the Listing page).
- If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Platform, that content is publicly visible.
Based on our legitimate interest to promote our Platform we may display parts of our Platform (e.g., your Listing page) on sites operated by our business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
The information you share publicly on our Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
Additional Services by Partners
Partners may need to use third party services available through our platform to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services or lock providers. Partners may use features on our Platform to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third party service providers for the purposes of coordinating the stay, managing the Accommodation, or providing other services.
How long we retain your data
For users that register or place a booking/inquiry request on our website (if any), we also store the personal information they provide in their user profile or booking/inquiry request. All users can see, edit, or delete their personal information in the Account at any time (except they cannot change their username). Website administrators can also see and edit that information. This information is stored indefinitely until a request for removal of this information is recorded
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
We store cookie information for up to 2 years.
What rights you have over your data
If you have an Account, created a listing or requested a booking information on this site or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Managing Your Information
You may access and update some of your information through your Account settings. If you have chosen to connect your Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Account).
Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Platform to you, you can request that we erase your personal information and close your Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that Member from opening a new Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we and Stripe Payments may keep some of your information for tax, legal reporting and auditing obligations.
- The information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Platform, even after your Account is canceled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database but are disassociated from personal identifiers.
- Because we maintain the Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular, where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of us override your own.
Where we send your data
Visitor comments may be checked through an automated spam detection service.
In general, we use the information collected to provide you with a great overall experience interacting with us and when using our website and to help us understand who uses our offerings, for internal operations such as operating and improving our website and our help desk services, to contact you for customer service and billing purposes and to facilitate the delivery of our advertising in some cases, including using your email to send information to you about our services.
We use your information to send you a welcome e-mail after you create an account, when you are invited to us, or when you sign up to receive our newsletter. We also use your information to send other e-mail communication related to our website. We always give you the option to unsubscribe in any email we send you.
If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personal information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. We also use the information collected to send announcements and updates regarding changes to our services and products or when making pricing changes. You will be able to unsubscribe from these announcements and updates.
We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve our services. We may link some of this information to personal information for internal purposes or to improve your experience with our website and our services, in these cases we will obtain your consent.
How we use the information we collect
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Platform, create and maintain a trusted and safer environment and comply with our legal obligations.
Provide, Improve, and Develop the Platform
- Enable you to access and use the Platform.
- Enable you to communicate with other Members.
- Operate, protect, improve, and optimize the Platform and experience, such as by performing analytics and conducting research.
- Provide customer service.
- Send you service or support messages, updates, security alerts, and account notifications.
- If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.
- To operate, protect, improve, and optimize the Platform and experience, and personalize and customize your experience (such as making Listing suggestions or ranking search results), we conduct profiling based on your interactions with the Platform, your search and booking history, your profile information and preferences, and other content you submit to the Platform.
We process this information given our legitimate interest in improving the Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
Create and Maintain a Trusted and Safer Environment
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
- Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
- Comply with our legal obligations.
- Resolve any disputes with any of our Members and enforce our agreements with third parties.
- Enforce our Terms of Service and other policies.
- In connection with the activities above, we may conduct profiling based on your interactions with the Platform, your profile information and other content you submit to the Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Platform if such processes detect a Member or activity that we think poses a safety or other risk to the Platform, other Members, or third parties.
We process this information given our legitimate interest in protecting the Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
Provide, Personalize, Measure, and Improve our Advertising and Marketing
- Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about us or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).
- Personalize, measure, and improve our advertising.
- Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or its third-party partners.
- Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Account.
How the Payments Data Controller uses the Information Collected
- Enable you to access and use the Payment Services.
- Detect and prevent fraud, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Conduct checks against databases and other information sources.
- Comply with legal obligations (such as anti-money laundering regulations).
- Enforce the Payment Terms and other payment policies.
- With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
The Payments Data Controller processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
How we protect your data
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the Contact Us section below.
What third parties we receive data from
Our Platform and Stripe Payments may collect information, including personal information, that others provide about you when they use the Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Third Party Services. If you link, connect, or log in to your Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Your References. If someone has written a reference for you, it will be published on your public profile page with your consent.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Platform through partnerships, or about your experiences and interactions from our partner ad networks.
Whom do I contact if I have any privacy questions?
Our representative in the European Union can be contacted by email.