Privacy and Cookies Policy

Effective as of May 25, 2018

GENERAL

In this privacy & cookies policy (“Policy”), we describe the information that we collect about you, that you provide to us, is provided to us by third parties, and will be processed by us, as you use this website (our “Website”) and the services available through this Website, our mobile website. We recommend that you read this policy carefully to understand what Best Places of Interest does with your personal information. Your use of our Website and Services and any dispute over privacy is subject to this Policy and any of our applicable Terms and Conditions for the use of our Services, including their applicable limitations on damages and the resolution of disputes. Our Terms and Conditions for our Services are incorporated by reference into this Policy. By visiting https://bestplacesofinterest.com  you are accepting and consenting to the practices described in this Policy. Regardless of the applicable law set forth in the Best Places of Interest Terms and Conditions for use of our Services, however, please note that any disputes arising under this Policy will be interpreted in accordance with the Governing Law provision set forth below.

EUROPEAN ECONOMIC AREA (“EEA”) CUSTOMERS ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to EEA customers, and can be found in detail below.

HOW, WHEN, AND WHAT WE COLLECT?

How does ‘Best Places of Interest’ collect my information?

We collect information directly from you, about you from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity.

When does Best Places of Interest collect my information?

When you contact us with questions, and you otherwise choose to provide information to us.

We, and our third-party service providers (with consent for EEA users), automatically collect the following information about your use of our Website and our online Services through cookies, web beacons, log files, and other technologies: your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website. If you are a registered user, we also may collect the following information about your use of our Mobile Application:  mobile device ID; device name and model; operating system type, name, and version; your activities within the Mobile Application, the length of time that you are logged into our Mobile Application, and, with your permission, your precise geo-location information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.

What information does Best Places of Interest collect?

The types of information we collect about you depend on your interaction with our Website and our Services, and might include, what was permitted by applicable law:

• Your contact information (e.g., name, email address)

• IP address, geolocation

• Identity validation (e.g., photograph, other information requested to verify your information)

• Details of any transactions carried out using any of the Services

• Any other information that you choose to provide to us (e.g. if you send us an email/otherwise contact us)

• Calls/emails/other correspondence

• Information about your business

• Information through Cookies and other tracking technologies as listed above and as described in the section below entitled “Our Use of Cookies and Other Tracking Mechanisms”

HOW WE USE YOUR INFORMATION?

• To validate your identity.

• To provide our Services to you, to communicate with you about your use of our Services or any changes in our Terms and Conditions that apply to you.

• For the purpose for which you specifically provide the information to us, including, to respond to your inquiries, to provide any information that you request, and to provide customer support.

• To tailor the content and information that we may send or display to you, to offer location customization (where permitted by applicable law), personalized help and instructions, and to otherwise personalize your experiences while using our Website and our Services, such as developing and offering you with new and/or additional services or new and/or additional features to existing services.

• For marketing and promotional purposes, for example, where permitted by law (other than if (where applicable) you opted out by unsubscribing from marketing emails and/or by contacting us as noted in the table below), we may use your information, such as your email address, phone number, or mailing address to send you newsletters, special offers, and promotions, or to otherwise contact you about services or information we think may interest you or to conduct draws for campaigns and the like and deliver prizes and rewards.

• As permitted by applicable law (other than if (where applicable) you opted out), to assist us in advertising our products and services in various mediums including, without limitation, sending you promotional emails, advertising our services on third-party sites and social media platforms, sending you direct mail, and by telemarketing.

• To better understand how users access and use our Website and our Services, both on an aggregated and individualized basis, to administer, monitor, and improve our Website and Services, for our internal purposes, and for other research and analytical purposes. Please see the information below regarding Third Party Analytics.

• To protect us, our customers, employees, or property — for instance, to investigate fraud and prevent fraudulent activity, harassment, or other types of unlawful activities involving us or other companies that we do business with, to enforce this Policy, as well as our Terms and Conditions.

WHERE WE STORE YOUR DATA?

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

OUR USE OF COOKIES AND OTHER TRACKING MECHANISMS

We and our third-party service providers use cookies and other tracking mechanisms (including tracking technologies designed for mobile applications) to track information about your use of our Website and Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).

• Cookies.  Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Website and Service. There are four types of cookies:

• Strictly necessary cookies These are cookies that are required for the operation of our Website. They include, for example, cookies that enable users to log into secure areas of our Website.

• Analytical/performance cookies. These types of cookies allow us to recognize, count the number of visitors, and see how visitors move around our Website when they are using it. This assists us to improve the way in which our Website works, for example, by ensuring that you can find what you are looking for easily.

• Functionality cookies These cookies are used to recognize you when you return to our Website. They enable the personalization of content, recognition of users, and remembering your user preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our Website, the individual pages visited, and the links followed. If the cookie is set by a third party (for example, an advertising network) which also monitors traffic on other websites, this type of cookie may also be used to track your movements across different websites and to create profiles of your general online behavior. Information collected by tracking cookies is commonly used to target online advertising.

The four types of cookies above will be either session cookies or persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website or Services. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Website or Services.

• Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer.  We use persistent cookies to remember your user information, preferences, and activity, to enable us to provide our services to you when you next return to our Website or Services.  We also use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.

• Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Website preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, delete any specific Flash LSO.

• Storage HTML5 Storage.  We may also store your user information and Website preferences locally within your web browser via HTML5.

• Clear GIFs, pixel tags, and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Website or Services to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website and Services usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

• Changing or Disabling your Cookie Settings. Most web browsers automatically accept cookies, but if you prefer you can edit your browser options to block them in the future.  The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.  Visitors to our Website who disable their web browser’s ability to accept cookies will be able to browse the Website; however, most site features will not function if you disable cookies and you will not be able to log in to use our services.

• Do Not Track. Currently, our systems do not honor browser “do-not-track” requests. You may, however, disable certain tracking as discussed above (e.g., by disabling Cookies); you also may opt out of Third Party Analytics or targeted advertising by following the instructions in the Third-Party Ad Networks section below.

THIRD-PARTY ANALYTICS

We use automated devices and applications, such as Google Analytics to evaluate the use of our Website and Services. To opt out of Google Analytics, please go to:  https://tools.google.com/dlpage/gaoptout/. Please note that if you use a new or different computer, install a new browser, or clear your cookies; in that case, you will need to re-opt out through the link above.

We use these tools to help us improve our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. These third parties may collect your device ID, IP address, or other information about your use of the Services as part of the analytics they provide to us.

THIRD-PARTY AD NETWORKS

We use third parties, such as network advertisers and other marketing agents, to display advertisements on our Website, to assist us in displaying advertisements on third-party websites, and to evaluate the success of our advertising campaigns. Network advertisers are third parties that display advertisements based on your visits to our Website and unrelated third-party websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors, and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your use of our Website and our Services, as well as aggregate or non-personally identifiable information about visitors to our Website and users of our Service.

You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”).  For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).

Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Website or other websites. You may continue to receive advertisements, for example, based on the website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or mobile device or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.

CHANGES TO OUR PRIVACY & COOKIES POLICY

This Policy may change from time to time. Any changes in the future will be posted on our Website. Please check back frequently to see any updates or changes to our Policy. We will not materially reduce your rights under this Policy without taking steps to bring such changes to your attention.

GOVERNING LAW & JURISDICTION

Save in relation to EEA customers, this Policy shall be governed by and interpreted in accordance with the laws of the State of Delaware, and any dispute hereunder shall be brought exclusively in the courts of the State of Delaware except where prohibited by US law.

For our EEA customers, this Policy shall be governed by and interpreted in accordance with the laws of Gibraltar, and any dispute hereunder shall be brought exclusively in the courts of Gibraltar.

DISCLAIMER

All content provided on this Website or the Services, including links to other websites, is provided for information purposes only and does not constitute advice, recommendation, or support of such content or website. Best Places of Interest makes every effort to provide true and accurate content on its Website. However, Best Places of Interest provides no warranty, express or implied, of the accuracy, completeness, timeliness, or applicability of such content. Best Places of Interest accepts no responsibility for and excludes all liability in connection with the information provided on the Best Places of Interest website, including but not limited to any liability for errors, inaccuracies, or omissions.

WHEN DO WE SHARE YOUR INFORMATION?

The table headed “How and Why We Share Your Information” in the main part of the Policy under the heading “WHEN DO WE SHARE YOUR INFORMATION” lists who we may share your information with, which includes transfers for reasons of legal compliance and necessity to provide you with our Services.

You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside the EEA.

Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. Best Places of Interest will take various measures to ensure that your data is treated securely, which may include, but not be limited to:

assessing the security measures taken at any place your data is transferred to;

having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions; and having monitoring, reporting, and resolution procedures in place about ongoing security.

LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA

We process your information based on the following legal grounds, as recognized by and in compliance with the applicable data protection laws:

• the processing is necessary to perform our contract with you (i.e. the Terms and Conditions that apply as applicable with respect to Best Places of Interest, for the provision of our Services), or to take steps requested by you before entering into said contract; the processing is in Best Places of Interest or someone else’s legitimate interests, and these interests are not overridden by your interests or rights in the protection of your personal data. This may include processing your data for prevention of fraudulent activity, internal research and analytics assessments, for purposes of communication with you, and informing you about new products and services we are offering or to promote new products and services of other parties which we think may be of interest to you, etc.;

• you have given your consent to the processing of your data;

• the processing is necessary to meet a legal obligation that applies to Best Places of Interest.

• Sometimes we process data about you that the law considers to fall within special categories (see section “What data do we process about you?” for more details), in which case, we use one of the following grounds:

• the processing is necessary for the establishment, exercise, or defense of legal claims;

• you have freely given your informed, specific consent to the processing; or

• the processing is necessary for reasons of substantial public interest, based on applicable law.

WHEN DO WE SHARE YOUR INFORMATION?

The table headed “How and Why We Share Your Information” in the main part of the policy under the heading “WHEN DO WE SHARE YOUR INFORMATION” lists who we may share your information with, which includes transfers for reasons of legal compliance and necessity to provide you with our Services.

You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).

Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. BEST PLACES OF INTEREST will take various measures to ensure that your data is treated securely, which may include, but not be limited to:

• assessing the security measures taken at any place your data is transferred to;
• having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions; and
• having monitoring, reporting, and resolution procedures in place about ongoing security.

EU CUSTOMERS ONLY: YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

EU CUSTOMERS ONLY: ACCESS TO INFORMATION

The Act gives you the right to access information held about you and the right to rectify that data. Your rights of access and rectification can be exercised in accordance with the Act. Any access request may be subject to a fee of GIP£10 to meet our costs in providing you with details of the information we hold about you. We may reject requests for disclosure or rectification of data that are unreasonable or extremely impractical (e.g. because they require disproportionate human or technical effort or require significant changes to our processes and technology and impact our ability to provide our services).

©2018