Privacy Policy
- Scope. This policy applies to any users of the services of My-Cierge or its affiliates anywhere in the world, and to anyone else who contacts My-Cierge or otherwise submits information to My-Cierge, unless noted below. This includes those who use My-Cierge or its affiliates’ services to request or receive services (users) and any other user of My-Cierge’s services (including apps, websites and API), and anyone else who contacts My-Cierge or otherwise submits information to My-Cierge, unless subject to a separate privacy policy, notice or agreement. This Privacy Policy describes our global practices regarding the collection, use, and sharing of data about identified or identifiable individuals (“Personal Information”) though the services offered by My-Cierge (“the Services”).
- Data Controller. My-Cierge is a “data controller” for the purposes of the General Data Protection Regulation 2016 which means that we are responsible for, and control the processing of, your Personal Information. By using, the Services you indicate that you acknowledge and understand the policies and practices contained in this Privacy Policy.
- The Information We Collect. My-Cierge collects information that you provide to My-Cierge, when you create your My-Cierge account; information created when you use our services, such as location, usage and device information and information from other sources, such as My-Cierge partners and third parties that use My-Cierge’s API.
- Information you provide – this includes: information submitted when you create or update your My-Cierge account, which depending on your location and the My-Cierge services you use may include your name, email, phone number, login name and password, birth date, and photo; requests for services through the My-Cierge app or website; contacts with My-Cierge, including for customer support; and surveys sent to and received from you by My-Cierge or on behalf of My- Cierge.
- Information created when you use our services – this includes:
- Information from other sources – These may include: users providing feedback, such as ratings or compliments, social media services, or apps or websites who use My-Cierge’s APIs or whose API My-Cierge uses; publicly available sources and marketing service providers.
- How We Use Your Information. We collect and use information to improve the services we offer. We use the information we collect for purposes including:
- Providing services and features – My-Cierge uses the information we collect to provide, personalize, maintain and improve our products and services. This includes using the information to enable services; enable features to personalize your My-Cierge account; perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.
- Safety and security – We use your data to help maintain the safety, security and integrity of our services.
- Customer support – My-Cierge uses the information we collect (including recordings of customer support calls after notice to you and with your consent) to assist you when you contact our customer support services, including to direct your questions to the appropriate customer support person; investigate and address your concerns and monitor and improve our customer support responses.
- Research and development – We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products.
- Legal proceedings and requirements. We may use the information we collect to investigate or address claims or disputes relating to your use of My-Cierge’s services, or as otherwise allowed by applicable law.
- Communications from My-Cierge. My-Cierge may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events. My-Cierge may also use the information to promote and process contests and sweepstakes, fulfill any related awards, and serve you relevant ads and content about our services. We do not share, sell, or lease Personal Information about you to any third parties for their marketing use.
- ARCO Rights. You have the right to request the access to, rectify, cancel and oppose the management of your Personal Information (the “ARCO Rights”). Furthermore, you have the right to request
- Consent. You have the right to revoke your consent to the management of your Personal Information. The procedure, requirements, and contact information needed for you to revoke your consent shall be the same as the procedure needed to exercise your ARCO Rights established above.
- Cookies and Third Party Technologies. My-Cierge and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this policy. Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. My-Cierge uses cookies and similar technologies for purposes such as: authenticating users; remembering user preferences and settings; determining the popularity of content; delivering and measuring the effectiveness of advertising campaigns; analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services. We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services. A cookie notice will provide you with the option to reject the use of cookies. However, if you choose to reject cookies, some features and functions within the platform may be impacted. You can view, update or remove any Personal Information that you
- Information Sharing and Disclosure. We may share your information with our affiliates, subsidiaries and business partners, or for legal reasons or in the event of a dispute. My-Cierge may share the information we collect:
- At your request – This includes sharing your information with My-Cierge business partners at your request. For example, if you requested a service offered by a third party, My-Cierge may share your information with those third parties. This may include, for example, other apps or websites that integrate with our APIs or services, or those with an API or service with which we integrate, or business partners or third parties with whom My-Cierge may collaborate with to deliver to provide you with a service.
- With the general public when you submit content to a public forum – including through public forums such as blogs, social media, and certain features on our network. When you communicate with us through those channels, your communications may be viewable by the public.
- With the owner of My-Cierge accounts that you may use – If you use a profile associated with another party we may share your service information with the owner of that profile. This occurs, for example, for users who receive services arranged by another person.
- With My-Cierge subsidiaries and affiliates – We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, My-Cierge may process or store information on behalf of its subsidiaries and affiliates.
- With My-Cierge service providers and business partners – My-Cierge may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. For example, My-Cierge may provide information to such parties to help facilitate service, to conduct surveys on our behalf, and to process payments for our services.
- For legal reasons or in the event of a dispute – My-Cierge may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request. This includes sharing your information with law enforcement officials, government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect My-Cierge’s rights or property or the rights or property of others, or in the event of a claim or dispute relating to your use of our services. This includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
- With your consent – My-Cierge may share your information other than as described in this policy if we notify you and you consent to the sharing.
- Security of Collected Information. We maintain reasonable physical, administrative, and technical security measures to protect the confidentiality, availability, and integrity of Personal Information. It is important to note that no method of safeguarding information is completely secure. While we try to ensure the protection of your Personal Information, we cannot guarantee (or be accountable/liable) that our safeguards will be effective or sufficient.
- The right to know what Personal Information we maintain about you;
- The right to know with whom we have shared your Personal Information;
- The right to receive a copy of your Personal Information; and
- The right to access, correct, or delete your Personal Information.
- Information Retention And Deletion – My-Cierge retains your information while your account remains active, unless you request deletion of your information or account. Subject to the exceptions described below, My-Cierge deletes or anonymizes your information upon request. My-Cierge may retain information after account deletion, as required by law, if there is an unresolved issue relating to your account, such as an unresolved claim or dispute; if we are required to by applicable law; and/or in aggregated and/or anonymized form. My-Cierge may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if My-Cierge shuts down a user’s account because of unsafe behavior or security incidents, My-Cierge may retain certain information about that account to prevent that user from opening a new My-Cierge account in the future.
- Children. The Services are not intended for children under the age of sixteen (16), and children under the age of sixteen (16) are not permitted to use the Services without written consent from a parent or legal guardian. We may collect information from children under the age of 16 to the extent provided by a parent or guardian, and such information would be associated with the parent or guardian, not the child.
- Email, Opt-Out and Marketing Communications. If you no longer wish to receive email communications from us, you can follow the specific unsubscribe instructions in the email you receive or contact us at the address below. If you do business with us, you may not opt out of certain automated notifications (including confirmation, welcome, and post-departure emails) based on the particular transaction.
- International Use. Your Personal Information may be stored, used, and processed in any country where we have facilities or where we have engaged a Provider, and by your use of the Services you acknowledge that we may transfer information to countries outside of your country of residence, which may have different data protection rules than in your country. All Personal Information held by My-Cierge directly is stored at the applicable site and/or in the United States, which may require transfer of the Personal Information from your location to the property’s location and/or the United States.
- Privacy Statement for Information Subjects Whose Personal Information May Be Collected in the European Union. My-Cierge may have from time to time users who are from the European Economic Area (“EEA”). In order to serve these users, we may transfer Personal Information from individuals (“Data Subjects”) located within the EEA. Personal information that may be collected by us from a Data Subject in the EEA may include: name, phone number, email address, login name and password and birth date. The information that we collect may be transferred outside of the EEA, including to countries, such as the United
- Contacting Us. If you have any questions about this Privacy Policy, our privacy practices, or the processing of Personal Information, please contact us. We welcome your questions and suggestions about our Privacy Policy and will use reasonable efforts to respond in a timely manner. Please feel free to email us at: travelservices@my-cierge.com.
- Choice And Transparency
- Privacy Settings. The Privacy Settings menu in the My-Cierge app gives users the ability to set or update their location and contacts sharing preferences, and their preferences for receiving mobile notifications from My-Cierge.
- Device Permissions. Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the My-Cierge app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the My-Cierge app seeks before you first use the app, and your use of the app constitutes your consent.
- Accessing and Correcting Your Information. You can edit the name, phone number and email address associated with your account through the settings menu in My-Cierge’s app. You can also look up your services, orders and history in My-Cierge app. You may also request access to, correction of, or a copy of your information by contacting My-Cierge.