LAST UPDATED ON: 05-Dec-22
1 USE AND DISCLOSURE OF INFORMATION
1.1 We are delighted that you have shown interest in the services of Fused Portal Services (“splidu”, “we”, “us”, “our”) which are provided via our Platform, https://www.splidu.com/. This policy applies only to activities splidu engages in on its Platform and does not apply to splidu activities that are offline or unrelated to the Platform.
1.2 Your privacy is important to us, and we respect your privacy regarding any Personal Data that we collect when you make an Account on our Platform or while availing the Platform Services and engaging in transactions thereafter. We treat your Personal Data as confidential and in accordance with the statutory data protection regulations and this Privacy Policy.
1.3 Except as otherwise stated below, we do not sell, trade, or rent your Personal Data collected on the Platform to others. We may collect, hold, use and disclose your Personal Data for the following purposes but it will not be further processed in a manner that is incompatible with these purposes:
1.3.1 to contact or communicate with you;
1.3.2 to process Booking Confirmation and to keep you informed about its status;
1.3.3 to run offers and other additional benefits for you or to notify you of Platform Services or special offers that may be of interest to you;
1.3.4 for advertising and marketing, including but not limited to sending you promotional information about our Platform Services;
1.3.5 to enable you to access and use our Platform;
1.3.6 to enable us to customize or personalize your experience on our Platform;
1.3.7 you give us Consent to do so for a specific purpose;
1.3.8 for analytics, market research and business development, including to operate and improve our Platform;
1.3.9 for statistical purposes to improve our Platform Services;
1.3.10 for internal record keeping and administrative purposes;
1.3.11 to comply with our legal obligations and to resolve any disputes that we may have; and
1.4 All credit/debit cards’ details and Personal Data relating to transactions made for Booking Confirmation will be shared with and stored by our third-party payment processor. We
recommend checking the policies of our payment processor to understand the manner in which your Personal Data will be handled by these payment processors.
1.5 Cookies are small bits of data cached in a Data Subject’s browser. splidu utilizes cookies to determine whether or not you have visited our Platform in the past. splidu may use non-personal Anonymized data to enhance the operation of our Platform, or to analyze interest in the different areas of our Platform.
In this Agreement, (i) capitalised terms defined by inclusion in quotations and/or parenthesis have the meanings so ascribed; and (ii) the following terms have the meanings assigned to them herein below. Terms not defined in this Agreement shall have the same meaning as assigned in the Terms and Conditions published on the Platform.
2.1 “Anonymization” means the Processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific Data Subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person;
2.2 “Consent” means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the Processing of Personal Data relating to them;
2.3 “Data Subject”, “you” and “your” collectively mean any identified or identifiable natural person, including Users and Vendors, whose Personal Data is Processed by us. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
2.4 “Personal Data” means any information relating to a Data Subject; and
2.5 “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
When you visit our Platform, our servers may automatically log the standard data provided by your web browser. It may include but not limited to, your computer’s internet protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and such other details.
3.2 DEVICE DATA
We may collect data about the device the Data Subject uses to access our Platform. This data may include but not limited to, the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
3.3 PERSONAL DATA
We may ask for Personal Data, including but not limited to: (i) name; (ii) e – mail; (iii) social media profiles; (iv) phone/mobile number; (v) home address.
4 LEGAL GROUNDS
4.1 We will Process your Personal Data lawfully, fairly and in a transparent manner. We collect and Process your Personal Data about you only where we have legal bases for doing so.
4.2 Where you Consent to our use of Personal Data for a specific purpose, you have the right to change your mind at any time without having any effect on any Processing that has already taken place.
4.3 We don’t keep your Personal Data for longer than is necessary. When we retain your Personal Data, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. Notwithstanding the foregoing, we understand that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your Personal Data for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
4.4 splidu has implemented numerous technical and organizational measures to ensure the complete protection of Personal Data processed through this Platform. However, internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed.
5 SECURITY
5.1 To protect your Personal Data, we take reasonable precautions and follow best industry practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or
destroyed.
5.2 Data Subjects shall be responsible for maintaining the confidentiality of their Account.
5.3 Our Platform uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential information, including but not limited to, the inquiries you send to us as the Platform operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar.
5.4 When SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
6 THIRD-PARTY SERVICES
6.1 Notwithstanding anything contained in this Privacy Policy, we may provide your Personal Data to third-party, including but not limited to, IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators providers used by us, who will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
6.2 We may also provide your Personal Data to:
6.2.1 our employees, contractors and/or related entities;
6.2.2 sponsors or promoters of any competition we run;
6.2.3 credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
6.2.4 third-parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you; and
6.2.5 third-parties to collect and process data.
6.3 Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
6.4 Once you leave our Platform or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Website’s Terms of Use.
6.5 When you click on links on our Platform, they may direct you away from our Platform. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements before availing the services offered by them. You shall be solely responsible for your activities outside our Platform.
7 DATA COLLECTION BY OUR WEBSITE COOKIES
7.1 The Platform of splidu uses cookies. Cookies are text files that are stored in a computer system via an internet browser.
7.2 Many internet sites and servers use cookies and cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Platform and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited internet sites and servers to differentiate the individual browser of the Data Subject from other internet browsers that contain other cookies.
7.3 A specific internet browser can be recognized and identified using the unique cookie ID.
7.4 Through the use of cookies, splidu can provide the Users of our Platform with more user-friendly services that would not be possible without the cookie setting.
7.5 By means of a cookie, the information and offers on our Platform can be optimized with the User in mind. Cookies allow us, as previously mentioned, to recognize our Platform Users. The purpose of this recognition is to make it easier for Users to utilize our Platform. The Platform User that uses cookies, e.g., does not have to enter access data each time the Platform is accessed, because this is taken over by the Platform, and the cookie is thus stored on the user’s computer system.
7.6 The Data Subject may, at any time, prevent the setting of cookies through our Platform employing a corresponding setting of the internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an internet browser or other software programs. This is possible in all popular internet browsers. If the Data Subject deactivates the setting of cookies in the internet browser used, not all functions of our Platform may be entirely usable.
7.7 We may also such cookies and similar tracking technologies (for example tracking pixels in our marketing emails and website/app advertisements) and analytics services (such as Google Analytics) to collect information about your use of our Platform, Services and your interactions with our marketing emails and advertisements.
7.8 In addition, third-party advertising platforms (for example, Facebook, Google, and LinkedIn) may also use their advertising pixels and other cookies on our website and in our emails with our permission. Their cookies are used to track visitors across websites in order to deliver adverts more relevant to them and their interests. The advertisers may use information about your visit to our website to target advertising to you on other websites.
7.9 We will ask for your Consent to the use of non-essential cookies, including third-party cookies. You can find further information about the cookies used on our Platform and the purposes they are used for by going to https://www.splidu.com.
8 YOUR ELIGIBILITY
8.1 By making an Account on our Platform, you represent that you are at least the age of eighteen
8.2 The Data Subject must retain a copy of transaction records (usually sent by email) and merchant policies and rules.
9 CONSENT
9.1 When you provide us with Personal Data to complete a transaction, verify your credit card or any other mode of payment used by you, make a Confirmed Booking, or cancel a Confirmed Booking, we imply that that you Consent to our collecting it, and using is for that specific reason only.
9.2 If we ask for your Personal Data for a secondary reason, like marketing, we will either ask you directly for your expressed Consent, or provide you with an opportunity to say no.
9.3 Each User shall have the right to withdraw their Consent to the Processing of their Personal Data at any time. If the Data Subject wishes to exercise the right to withdraw their Consent, they may at any time directly contact splidu at info@splidu.com.
10 MODIFICATIONS TO THE PRIVACY POLICY
10.1 splidu reserves the right, at its sole discretion, to modify this Privacy Policy anytime and without prior notice. If we modify this Privacy Policy, we will post the modification on our Platform or provide you with notice of the modification, to keep you informed of the information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. We will also update the “Last Updated Date” at the top of this Privacy Policy. By continuing to access or use our Platform after we have posted a modification on our Platform or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified terms of this Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using our Platform and/or Platform Services.
10.2 If splidu is acquired or merged with another company, your Personal Data may be transferred to the new owners so that we may continue to sell services to you.
If you have any questions about this Privacy Policy, feel free to contact splidu at info@splidu.com.
You acknowledge that you have read, understood, and accepted to be bound by this Privacy Policy. Effective as of 1 December 2022