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TrustyLux LLC (the “Company”, "us"; or "Data Controller") supplies helpful information about luxury hotels and services and provides the following information regarding the processing of personal data (“Personal Data” or “Data”) to allow users (“User” or “you”) of the website, www.trustylux.com (“Website”) to know the personal data protection policy applied and understand how personal information is collected and managed while browsing the Website and using the services available on the Website (“Service(s)”) under applicable laws, including Regulation (UE) 2016/679 ("GDPR" or "Regulation").


Applicability

This policy applies to Personal Data we collect:

  • on the Website;
  • in e-mail and electronic messages between you and the Website;
  • when you use the “Ask Charlotte” or “Inquire to Book“ contact form or similar feature on the Website (i.e., when you send e-mails to the e-mail address listed on the Website); and
  • through any other means associated with or relating to the Website.

This policy does not apply to information collected by:

  • the Company through other websites operated by the Company or any third party; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Underage Users

The Website is not intended for people under eighteen (18) years of age.  No one under age eighteen (18) may provide any personal data to the Company through the Website.


Information we collect about you and how we collect it

We may collect several types of Personal Data from and about Users of the Website, including information:

  • such as data that identifies the User directly (e.g., name, surname, address, etc.) or indirectly (e.g., e-mail address, phone number, IP address, device number/ID, geographic location data, etc.);
  • about the Users’ internet connection and service provider, the equipment used to access the Website, Users’ browsing history and other usage and technical details.

We collect this information:

  • directly from the User when provided to the Website;
  • automatically as the User navigates through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies; or
  • from third parties, for example, our business partners.

Information provided according to the Regulation for EU Residents

According to the Regulation (EU Regulation 679/2016 General Data Protection Regulation), we provide you with the following specific information.


  • 1. Data processing Controller

The data controller is identified as TrustyLux LLC, 4300 Biscayne Blvd - Suite 203 - Miami, Florida 33137 e-mail: [email protected].


  • 2. Types of Personal Data Processed

The Data Controller will not use the Personal Data provided for purposes other than those connected to the Services, among those listed below, to which the User has registered.

The Personal Data collected by this Website, independently or through third parties, may include: Email, First Name, Last Name, City, Address, Sex, Date of Birth, Phone Number, Password, Country, State/Province, image, user ID, billing address, shipping address, prefix, language, profile picture, any preferences on hotels or destinations you may provide us with, geographic location, Cookies, usage data and unique identifiers of advertising devices (Google Advertiser ID, Facebook or IDFA identifier, for example).

Full details about each type of data collected are provided in the dedicated sections of this privacy policy.

Personal Data can be freely provided by the User or, in the case of usage data, collected automatically during the use of this Website (e.g., by means of cookies and other technologies).

Unless otherwise specified, the Personal Data collected by this Website is required to provide certain functionality or Services. If you refuse to disclose it, it may be impossible for this Website to provide the Services. Where the Website deems some Personal Data as optional, Users are free to refrain from disclosing such Personal Data, without this having any effect on the availability of the Services or the functionality of the Website. If you have any doubts about which Personal Data is required, you are encouraged to contact the Data Controller at the following address: [email protected] .

The possible use of Cookies - or other tracking tools - by this Website or the data controllers of the third-party services used by this Website, if not otherwise stated, is intended to provide the Services requested by the User, in addition to further purposes described in this document and in the Cookie Policy

The User takes responsibility for the Personal Data obtained, published or shared through this Website, and guarantees that the User has the right to communicate or disseminate it, freeing the Data Controller from any liability to third parties.

When sending e-mails to the addresses on the Website, the User may provide the Company with Personal Data which belong to special categories of personal data (such as Data revealing racial or ethnic origin, religious beliefs, health, etc. - Article 9 of the GDPR). We urge Users not to disclose such data; by providing such data, Users provide their explicit consent to the processing. Nevertheless, the Company will process and store such Personal Data for the purpose to provide the User with the Services requested and, for the time strictly necessary to process such Personal Data.


  • 3. Purposes and legal basis for the Data processing

All Personal Data collection and subsequent processing activities are aimed at the following purposes:


  1. Registration on the Website

    Personal Data provided by completing the registration on the Website will be collected, processed and used to:

    1. create and manage the account of the User on the Website;
    2. provide the Services offered through the Website;
    3. comply with any legal, accounting and tax obligations;
    4. defending the rights of the Company, our Users and third parties.

    The collection, processing and use of your Personal Data is based on the performance of the contractual relationship, the compliance with the law and the protection of our interests (pursuant to Article 6 (1) (b, c, f) of the GDPR).

  2. Leave Reviews

    As registered User, the Website will provide you with the further service of publishing on the Website your reviews of the hotels you visited and/or of the services used. The Personal Data collected for the provision of the abovementioned service will be processed and used to:

    1. provide you with the possibility to publish a review and upload your pictures (i.e. of the hotel you visited);
    2. allow you (as an authorized hotel representative) to read and reply to Users’ reviews.

    The collection, processing and use of your Personal Data is based on the provision of the service “Leave Reviews” (pursuant to Article 6 (1) b) of the GDPR).

  3. “Ask Charlotte” or “Inquire to Book” functions

    User’s Personal Data, provided when filling in the “Ask Charlotte” or “Inquire to Book” form, will be collected, processed and used to:

    1. respond to requests for information made by Users and, where applicable, provide the Services requested by the User;
    2. complete the booking of hotels/ services requested, handle payments (through our third-party processors) and offer the User after-sale services (where applicable).
    3. comply with any legal, accounting and tax obligations (where applicable);
    4. defending rights of the Company, our Users and third parties.

    The collection, processing and use of your Personal Data is based on the performance of the contractual relationship, the compliance with the law and the protection of our interests (pursuant to Article 6 (1) (b, c, f) of the GDPR).

  4. Marketing

    Please note that, this Website may use User’s Personal Data for marketing purposes (i.e. to submit commercial proposals).

    If the Users provide their consent or are notified under applicable law, Personal Data will be processed to:

    • register with the mailing list or newsletter, and sending advertising /information/promotional material (related to our Services or our partners’ services/products) and participating in initiatives and offers aimed at rewarding customers;
    • carry out market research and customer satisfaction surveys (regarding the quality of the Services provided, for example);

    These activities may:

    • include our products and Services, as well as services and products provided by our business partners, sponsors (e.g. hotels, transfer services, flight providers, advertisers etc.);
    • be carried out by e-mail (e.g., newsletter) or regular mailing, if applicable and according to your preferences. We will process Personal Data only on the basis of the Users’ consent or notice as required by law. The consent is optional and may be revoked at any time by contacting the Company at the e-mail address: [email protected] or by following the instructions in the message, without prejudice of the legality of consent-based processing carried out prior to the withdrawal.

  5. Profiling and analysis

    If Users provide their consent, the Company will use Personal Data (e.g., data provided by registering to the Website, previous purchases, interests, etc.) for profiling purposes such as analysing preferences and interests in order to improve our commercial offer and Services or send offers that meet your interest and needs.

    The Company will process Personal Data for such purpose only on the basis of the Users’ consent or notice as required by applicable law. The consent is optional and may be revoked at any time by contacting the Company at the e-mail address: [email protected] or by following the instructions in the message, without prejudice of the legality of consent-based processing carried out prior to the withdrawal.

    This Website makes use of Cookies and targeting technologies. To learn more and to view the detailed information, you can consult the Cookie Policy

  6. Location-based interactions

    This Website can collect, use and share Personal Data related to a User’s geographical location, in order to provide location-based Services.

    Most browsers and devices provide tools by default to deny geo-tracking. If a User has expressly authorized this possibility, this Website may receive information about Users’ geographic location.

    The geographical location of the User takes place in a non-continuous manner, at the specific request of the User or when the User does not specify his location in the field and allows the Website automatic location detection.

  • 4. Recipients of personal data

    For the purpose of Section 3 above, the Data Controller may disclose a User’s Personal Data to third parties, such as those belonging to the following subjects or categories of persons, as data controller or appointed data processors:

    • suppliers of the services requested or purchased, such as hotels, restaurants, tour guides, drivers, transport services, etc.;
    • police, armed forces and other types of public administration, for the fulfilment of obligations under the law, regulations or applicable law;
    • companies, entities or associations (i.e., outsourcers, payment processors, IT service providers, parent companies, subsidiaries or related entities) such as communications made for administrative and/or accounting purposes;
    • consultants and companies who carry out consultancy activities and support for the provision of services provided by the Company (such as developers, event planners, etc.);
    • advertising and analytics providers for purposes of delivering targeted advertisements and content to you; and
    • advisors and other third parties in the event we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, then your Personal Data may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

    The Data Controller ensures the utmost care that the communication of the Personal Data of the User to those recipients is only related to the Personal Data necessary to achieve the specific purposes to which they are intended. A complete list of external data processors appointed by the Company can be obtained by contacting [email protected].

    Your Personal Data is stored in the Data Controller's or its service providers’ databases and will be processed exclusively by authorized personnel. The latter will be provided with instructions on how to treat it. This Personal Data will also not be disclosed to third parties, except where expressly indicated above and, in any case, within the limits indicated.

    Please note that any Personal Data you may publish within your reviews, through the Leave Reviews service, will be uploaded and published on the Website and therefore such data will be disseminated.

  • 5. Processing methods

    The Data Controller takes appropriate security measures to ensure the security of the Website and prevent unauthorized access, disclosure, modification or destruction of Personal Data. However, the Internet is not 100% secure, and you should exercise caution.

    The processing is carried out by computer and/or telematics tools, with organizational methods and with logic closely related to its stated purposes.

    If you provide your consent, your data will be analysed, organized and processed using automated methods based on your preferences, enabling us to know your interests (e.g. by checking your purchase history), adjust our offer and services offer (e.g. introducing new services that may interest out clientele) and send promotional material (e.g. newsletter, mailing,) that can also meet your interests.

    We specify that our analysis of your preferences will always involve the intervention and evaluation of our personnel (and will not be solely automated).

  • 6. Data retention period

    The Personal Data provided to the Company on or through the Website shall be processed for the time period specified below:

    Registration to the Website
    Users’ Personal Data will be processed for the time necessary to manage the registration to the Website and, subsequently, for the fulfilment of all the obligations or the exercise of the rights connected with the registration for the entire duration of your registration. Upon Users’ un-subscription, Personal Data will be processed only according to accounting/financial laws, and then deleted or anonymized. 

    Leave reviews
    Users’ Personal Data will be processed for the time necessary to manage and publish your review on the Website.

    “Ask Charlotte” or “Inquire to Book“ function
    Your Personal Data will be processed for the time necessary to properly handle your request and for the time necessary to properly update your Website registration (where applicable). In any case your data will be deleted or anonymized after 2 years unless otherwise required by law.

    Marketing
    Users’ Personal Data will be processed to send promotional communications and to allow participating in market research until consent is withdrawn.

    Profiling
    Users’ Personal Data will be processed for profiling purposes until their consent is withdrawn; in any case, your shopping history will be processed for a maximum period of 2 years unless required by applicable law. Thereafter, Personal Data will be deleted or anonymized.

    Geolocation
    Your Personal Data will be processed for the time strictly necessary to provide you with the Services requested and, thereafter, the Personal Data will be deleted or anonymized.

  • 7. Data transfer outside the European Union

    To enable the Company to properly manage the Website, Users’ Personal Data will be held in the European Union or transferred to countries outside the European Union.  When doing so, the Company will use reasonable efforts in an attempt to ensure that such transfer occurs in compliance with the guarantees, safeguards and rights provided in the GDPR and other applicable laws.

    The GDPR provides that the specific consent of the Data Subject is not required for the transfer of personal data to third countries when: (i) such transfer is performed in accordance with Article 45 of the GDPR (i.e. if data are transferred to a Country that has been considered by the EU Commission granting an adequate level of protection regarding personal data); or (ii) as permitted pursuant to Article 46 of the GDPR (e.g. the application of standard data protection clauses adopted by the EU Commission, etc.).  The Company endeavors to comply with these Articles. The User may write to [email protected]  to request information on the existence of an adequacy decision or on the safeguards adopted to allow the data to be transferred.


  • 8. Rights of those affected (data subjects)

    By e-mail to be sent to [email protected] trustylux.com, Users may at any time exercise the rights set out in Articles 15 to 22 of the GDPR, such as requesting:

    • confirmation as to whether Personal Data concerning Users is being processed;
    • access to personal data and the information indicated in Article 15 of the GDPR;
    • rectification of inaccurate Personal Data concerning Users or completion of incomplete Personal Data;
    • erasure of Personal Data concerning Users;
    • restriction of processing of Personal Data concerning Users;
    • notification regarding rectification, erasure or restriction of processing of personal data concerning Users;
    • the right to receive the Personal Data concerning Users in a structured, commonly used and machine-readable format; or
    • the right to object at any time, on grounds relating to Users’ particular situation, to processing of Personal Data.

    Users can also:

    • object to the processing of your Personal Data, particularly for marketing purposes or the analysis of your purchasing habits or preferences;
    • withdraw consent to any activity that requires us to have it.

    All such requests will be processed in accordance with the GDPR and applicable law.

  • 9. Where to lodge a complaint

    Should you consider the processing of your Personal Data infringes the GDPR, you may lodge a complaint before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

  • 10. Applicable law

    This Privacy Policy is governed by GDPR, without prejudice to the application of any mandatory law and provision on data protection.

  • 11. Revision clause

    The Company reserves the right to revise, amend or simply update this Privacy Policy, in whole or in part, as its sole discretion, in any manner and/or at any time, without specific notice. As required by law, Users registered to the Website may also be notified of changes and updates to the Privacy Policy by e-mail-. Changes and updates to the Privacy Policy will be published on the homepage of the Website; they will be binding as soon as published and/or communicated. Please access this section regularly for publication of the most recent and updated Privacy Policy or check your e-mail.

  • 12. Links to other websites

    If you access other websites by using a link provided on the Website, please be aware that this Privacy Policy does not apply to collection, processing, transfer or use of your information on such websites.  Please review the privacy policy on those third-party websites to understand the third-party’s privacy policies. The Company does not control and is not responsible for any data collection, usage, sharing or processing activities carried out by third parties. 

    Also, some content or applications, including advertisements, on the Website may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers.  These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use our Website.

    The information they collect may be associated with your Personal Data or they may collect information, including personal data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

    We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly

    To learn more and to view the detailed information on such tracking technologies, you can also consult our Cookie Policy

    Note that, as stated above and in the Cookie Policy, we may use cookies and other tracking technologies to collect information about Users online activities over time and across third-party websites or other online services (behavioural tracking). 

    Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. We honour DNT signals.  Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser's DNT option in your browser's preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings.  If that occurs, the website visited will not recognize you upon return to that website, save passwords or usernames, and some other features of a website may become unavailable or not function properly.