Privacy Policy TCP APP
TERMS AND DEFINITIONS
Terms and definitions used in this Privacy Policy shall correspond to the terms set in Terms of Use except if otherwise set herein:
Term |
Definition |
App User Authorized User “you” “your” |
An authorised user of Trevolution internal communication systems employed / engaged by one of our companies who access those systems through Mobile App in order to perform their duties in accordance with our internal procedures and instructions. |
Channels |
Internal communication channels of Trevolution Group companies for example emails chats messengers etc. Each App User is assigned specific access to the internal workspace and current Channels based on their authorisation level. |
Dyninno |
A group of entities including Trevolution developing and implementing innovations and technology in its products – dyninno.com |
End-Client |
A customer purchasing from one of Trevolution’s brands |
Mobile App TCPApp |
A Trevolution Group companies internal mobile application “Communication Portal” (or similar name) which main function is to display information from Channels on “one screen” as well as to ensure App Users can quickly respond in each of Channels using single interface. |
Personal data |
Any information related to the identifiable or identified App User. The term “Personal information” shall have the same meaning as Personal data. |
Privacy Policy |
A legal statement explaining how Trevolution collects handles processes and respects App Users’ Personal data. |
Service Provider |
A person that processes Personal data on behalf of Trevolution and that receives from or on behalf of Trevolution App Users’ Personal data for purposes set in service contracts. A Service Provider is prohibited from:
- Selling Personal data for monetary or other valuable consideration;
- Sharing Personal data with third parties for cross-context behavioral advertising;
- Retaining using or disclosing Personal data for any purpose other than for those specified in the contract;
|
Trevolution “we” “our” “us” |
A group of companies selling travel product and services to End-Clients – trevolution.group |
ABOUT THIS PRIVACY POLICY
Privacy of App Users is of significance to Trevolution! We are committed to maximally avoiding risky processing of Personal data. We process only as much data as it would be necessary for achievement of our purposes taking into consideration the proportionality principle. We regret that if there is any information in this Privacy Notice with which you disagree your only recourse is to leave our Mobile App immediately.
This Privacy policy:
- Applies to your Personal data processed during you are performing your duties – communication within Channels including installing and using of Mobile App
- Aims to give you information on how we process your Personal data
- Is instrumental in our data protection system.
We process Personal data in material compliance with the following principal provisions:
- Respecting requirements of the applicable data protection legislation;
- Being fair and transparent with you;
- Processing by default only a Personal data which:
- Is necessary to achieve the current purpose;
- Is accurate and where necessary kept up to date;
- Upon achievement of purposes we are either deleting Personal data or anonymizing it so it is impossible to identify App Users; we might keep processing Personal data where it is required for another purpose set herein or compatible with the initial one (for example after the end of our relations we might need to keep some data to comply with the requirements of the tax legislation or in order to protect our legal claims);
- When Personal data is being processed for security statistical and analytical purposes we are applying anonymization or additional safeguards preventing any undue impact on your person (functional separation);
- We apply organizational and technical measures safeguarding Personal data from any accidental or unlawful destruction loss alteration unauthorized disclosure of or access to the data;
- We train staff training on a regular basis regarding data protection matters.
This Privacy Policy does not relate to Personal data which concerns legal persons (Trevolution and Dyninno companies) meaning that work-related data identifying your person might be related and directed solely to the interests of Trevolution and/ or Dyninno. By using Mobile App you acknowledge that we process your Personal data in accordance with this privacy policy.
This privacy policy was last updated on 23rd of July. We keep the Privacy policy under regular review. We might make minor amendments to this Privacy policy which shall not adversely affect your privacy except if laws set otherwise. In case of material changes we will publish amendments and amended policy on our internal network and in Mobile App available for App Users. Amendments shall enter into force on the Effective Date (date when last updates were made). The actual version of the Privacy policy is published on app stores.
THE CATEGORIES OF PERSONAL DATA WE PROCESS
We may process different kinds of Personal data which we have grouped together as follows:
- Identifiers or Identity Data such as a first/ middle/ last name alias (nickname or username) postal address unique personal identifier (cookie) online identifier Internet Protocol address or other similar identifiers.
- Contact Data includes email address and telephone numbers.
- Network Activity Information including but not limited to Technical Data (your login data including e-Evidence about login fact browser type and version browsing history search history time zone setting and location browser plug-in types and versions operating system and device type other technology on the devices you use to access the Mobile App) and information regarding your interaction with the Mobile App (Usage Data).
- Geolocation data (country state or city).
- Security and Maintenance related data: where we reasonably suspect fraud or face bugs/errors – details of such offences bugs or errors to fix and/ or prevent it in the future.
We also might process Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal data but is not considered Personal data in law as this data will not directly or indirectly reveal your identity.
Customer support. If you choose to contact our customer support we will collect any inquiries complaint or other information that you may submit to our support team.
We do NOT specifically process:
- Special categories of Personal data (sensitive data); this includes details about your race or ethnicity religious or philosophical beliefs sex life sexual orientation political opinions trade union membership information about your health and genetic and biometric data;
- Personal data about children except in cases where it might be indirectly implied by nature of services (e.g. the air ticket booked with one of Suppliers for a passenger who is a child);
- Personal data about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we collect Personal data required by law or under the terms of a contract (for example employment) and you fail to provide that data when requested we may not be able to accept you as an App User. In this case we may have to refuse you to install the Mobile App but we will notify you if this is the case at that time.
WHY DO WE PROCESS PERSONAL DATA?
We process Personal data for the following purposes:
Purpose |
Activity |
To create and manage an account in our internal workspace and in Mobile App based on contractual relations |
(a) Identify you
(b) provide access to certain communication channels
(c) to avoid duplicate access |
To enable you to be in touch with other App Users through Channels based on legitimate interests and employment agreement |
(a) Identify you in the communication
(b) to provide you possibility to chat, send and receive messages and to store those communication records
(c) contact other users |
To manage our relationship with you based on legitimate interest and employment agreement |
(a) Notify you about updates of this privacy policy
(b) ask you to leave a review
(c) provide you support when you ask for it
(d) provide you work-related information including, but not limited to, operational alerts, work schedule and tasks, organizational news etc. |
To administer and protect our business and Mobile App based on legitimate interests |
(a) Detect errors, fraud or illegal activities
(b) keep our App updated and relevant
(c) monitor its performance
(d) analyze its performance |
To deliver relevant Mobile App experience and content to you based on legitimate interests |
(a) Understand how you use the App and use this information to improve it |
DISCLOSURES OF YOUR PERSONAL DATA
We may share your Personal data with the parties set out below for the purposes set out in the table above.
Party |
Disclosure |
Trevolution Group companies |
Your personal data may be shared between our companies in order to provide you with the relevant work information and enable you to perform your job duties effectively. |
Service Providers |
Third-party service providers who provide IT and system administration services, data storage, maintenance, and support. |
Professional advisers |
Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services. |
Regulators |
Regulatory bodies that require reporting of processing activities in certain circumstances. |
We require all third parties to respect the security of your Personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal data for their own purposes and only permit them to process your Personal data for specified purposes and in accordance with our instructions.
DATA SECURITY
We have put in place appropriate security measures to prevent your Personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
We will only retain your Personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal data, we consider the amount, nature, and sensitivity of the Personal data, the potential risk of harm from unauthorized use or disclosure of your Personal data, the purposes for which we process your Personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal data:
- Request access to your Personal data (commonly known as a “data subject access request”).
- Request correction of the Personal data that we hold about you.
- Request erasure of your Personal data.
- Object to processing of your Personal data where we are relying on a legitimate interest.
- Request restriction of processing of your Personal data.
- Request the transfer of your Personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your Personal data.
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal data is not disclosed to any person who has no right to receive it. We may also contact you (via email, phone or messenger) to ask you for further information in relation to your request to speed up our response.
TERMS: We try to respond to all legitimate requests within one month. Sometimes it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. The maximum response time shall not exceed 90 days.
SHARED REQUESTS: If Personal data is shared with other Trevolution/ Dyninno companies and later you exercise any of the rights set herein, we will perform our part, but regarding the rest we will inform the relevant company and they should contact you separately. At the same time, if it does not contravene laws or general policies of Trevolution/ Dyninno, we will perform your request in full.
CONTACTS: you can submit your complaint/ request at privacy@dyninno.com
TERMS OF USE FOR COMMUNICATION PORTAL
23rd of July
SIA “DYNATECH”, registration number 40203110019, legal address Jeruzalemes iela 1, Riga, LV-1010, together with its subsidiaries and affiliates, all of which are Dyninno Group companies, including Trevolution Group companies (“Trevolution”, “we”, “our” or “us”) provides you the access and use of our internal communication and information channels via Communication Portal Mobile application (“Mobile App” or “TCPApp”). Even though you are signing onto an existing workspace, please read out these Terms of Use carefully.
These Terms of Use, in combination with the Privacy Policy and Acceptable Use Policy and any other terms and information we brought to your attention, govern your access and use of TCPApp and apply to you as the user of TCPApp. You agree to these Terms of Use (“Terms”) by installing, accessing or / and using TCPApp.
THESE TERMS ARE LEGALLY BINDING.
These Terms constitute a binding agreement between you and us. You also agree to comply with our Acceptable Use Policy which is incorporated by reference into these Terms. We reserve the right to change, modify, delete, or add provisions to these Terms and Acceptable Use Policy without prior notice. Updated versions of the Terms and Acceptable Use Policy will be posted in TCPApp and are effective immediately on posting. Please check frequently to see the changes. Your access or use TCPApp, or continuance of accessing or using TCPApp after any changes to the Terms and Acceptable Use Policy, constitutes and confirms that you have read, understand and agree to be bound by the latest version of the Terms and Acceptable Use Policy. If you do not understand or agree to these Terms, do not click to accept the Terms and do not use TCPApp otherwise.
AUTHORIZED USER. ELIGIBILITY
We offer access to and use of TCPApp, which main function is to display information from different channels on “one screen”, as well as to ensure you can quickly respond in each channel using single interface, to Authorized users only. For the purposes of these Terms, we consider you as an Authorized User if you meet all of the following criteria:
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You are an individual who reached the age of majority in your country, and that you can form a legally binding contract.
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You are currently employed / engaged or affiliated with us.
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You were invited, permitted or caused to have access and join a workspace controlled by us by receiving a unique username and password, and you are able to log into our internal workspace.
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You were invited by us to download and use TCPApp and
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You agree to use TCPApp solely for our business purposes as instructed by us and not for your own personal gains.
As an Authorized User you must comply with our Acceptable Use Policy and any applicable policies issued by us from time to time. If you see inappropriate behavior or content, you must contact us immediately and report this issue.
You are solely responsible for maintaining the security of your account and account credentials, and you must promptly notify us if you discover or suspect that someone has accessed your account without your permission. You cannot permit others to access your account using your credentials.
These Terms remain effective until your access to our workspace and, consequently, to TCPApp has been terminated by us. Please contact us if you at any time, including due to a disagreement with any changes or updates to these Terms or Acceptable Use Policy, want to terminate your access to workspace or TCPApp.
We reserve the right to investigate and, if appropriate, suspend or terminate your access to TCPApp at any time if we believe that you have violated these Terms, misused TCPApp, or behaved in a way we regard as inappropriate or unlawful. We reserve the right to make use of any personal, technological, legal or other means available to enforce Terms, at any time without liability and without the obligation to give you prior notice.
We reserve the right to pursue any legal remedies available to us, including seeking damages, in the event of a violation of these Terms. This may include reporting your actions to law enforcement authorities if they constitute illegal activities.
You may be liable for any costs, expenses, or damages incurred by us as a result of your violation of these Terms. This includes, but is not limited to, legal fees, costs of investigation, and any compensation paid to third parties.
PROPER USE OF TCPAPP
The key goal of providing you access to TCPApp is to assist and promote our cooperation. In case we reveal that your activities or performance on TCPApp is conducted in the interest of any person and/or entity that may be treated as our competitor, we may immediately terminate our Agreement with you, your right to use the TCPApp will be revoked, and your account will be closed. We also may initiate any legal or other proceedings or investigation that will be appropriate against you or the respective competitor. This Section applies in addition to Section “Intellectual Property” and shall not limit its scope in any part.
FEES
We do not charge Authorized Users any fees. The access to TCPApp is provided by us on a free of charge basis.
LIMITATION OF LIABILITY
To the fullest extent permitted by law, we are not liable, and you agree not to hold us responsible, for any damages or losses arising out of or in connection with these Terms, including, but not limited to: (i) your use of or your inability to use TCPApp; (ii) delays or disruptions in TCPApp; (iii) viruses or other malicious software obtained by accessing, or linking to, TCPApp; (iv) glitches, bugs, errors, or inaccuracies of any kind on TCPApp; (v) damage to your hardware device from the use of TCPApp; (vi) the content, actions, or inactions of third parties’ use of TCPApp; (vii) a suspension or other action taken with respect to your access to TCCApp; and (viii) your need to modify practices, content, or behavior or your loss of or inability to do business, as a result of changes to these Terms and Acceptable Use Policy.
Additionally, in no event will we, our licensors, or our third-party service providers be liable for any special, consequential, incidental, punitive, exemplary, or indirect costs or damages, including, but not limited to, litigation costs, installation and removal costs, or loss of data, production, profit, reputation, or business opportunities. Our liability, or liability of our licensors, and our third-party service providers to any Authorized User for any claim arising out of or in connection with these Terms will not exceed 500 US dollars.
NO WARRANTIES
TO THE EXTENT PERMITTED BY LAW, AND WITHOUT LIMITING THE GENERALITY OF ANY DISCLAIMERS SET FORTH HEREIN, WE MAKE NO WARRANTY OF ANY KIND REGARDING THE TCPAPP, AS IT IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. WE DO NOT WARRANT THE ACCURACY, COMPLETENESS, OR RELIABILITY OF ANY OF THE CONTENT, DATA, OR INFORMATION FOUND ON OR THROUGH THE TCPAPP, AND WE DISCLAIM ALL WARRANTIES AND CONDITIONS, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT, AND THOSE ARISING BY STATUTE OR OTHERWISE IN LAW OR FROM A COURSE OF DEALING OR USAGE OF TRADE. SOME STATES OR COUNTRIES DO NOT ALLOW THE DISCLAIMER OF IMPLIED WARRANTIES, SO THE FOREGOING DISCLAIMER MAY NOT APPLY TO YOU.
PRIVACY POLICY
Please review our Privacy Policy for more information on how we collect, treat, process, use and respect your Personal data.
INDEMNITY
You will indemnify, defend, and hold us harmless, as well as our respective directors, officers, employees, representatives, and agents (each an “Indemnified Party”) for all Indemnified Claims (defined below) and Indemnified Liabilities (defined below) relating to or arising out of: (a) your use of the TCPApp; (b) any result of your actions or your content related to your use of the TCPApp; (c) your failure to comply with these Terms; (d) your failure to comply with applicable law; (e) negligence, willful misconduct, or fraud by you; and (f) your violation of any third-party right, including without limitation any right of privacy (unauthorized disclosure, alteration or blocking of personal data of others), publicity rights or Intellectual Property Rights.
“Indemnified Claim” means any and all claims, damages, liabilities, costs, losses, and expenses (including attorneys’ fees) arising from or relating to any claim, suit, proceeding, demand, or action brought by you or a third party or other user against an Indemnified Party.
“Indemnified Liability” means any and all claims, damages, liabilities, costs, losses, and expenses (including reasonable attorneys’ fees and all related costs and expenses) arising from or relating to any claim, suit, proceeding, demand, or action brought by an Indemnified Party against you or a third party or other user.
INTELLECTUAL PROPERTY
We retain all rights, titles, and interests in and to TCPApp, its content and improvements thereto together with any materials, specifications, guidelines, and instructions provided by us to Authorized Users, as well as all Intellectual Property Rights. You will not remove, copy, distribute, modify, create derivative works based on and otherwise use any content provided to you in or through the TCPApp. For the purposes of these Terms “Intellectual Property Rights” means all patent rights, copyright rights, mask work rights, moral rights, rights of publicity, trademark, trade dress and service mark rights, goodwill, trade secret rights and other intellectual property rights as may now exist or hereafter come into existence, and all applications therefore and registrations, renewals and extensions thereof, in each case, under the laws of any state, country, territory or other jurisdiction.
GOVERNING LAW
These Terms shall be governed by and construed and enforced in accordance with the laws of England and Wales, without regard to conflict of law principles or rules that would cause the application of the laws of any jurisdiction. English courts shall have the exclusive jurisdiction to determine any disputes arising in relation to, or under, these Terms. You agree to submit to the jurisdiction of the courts in England and agree to waive any and all objections to the exercise of jurisdiction over the parties by such courts and to venue in such courts.
SURVIVAL
Upon termination or expiration of these Terms that expressly or by their nature contemplate performance after the Terms terminate or expire will survive and continue in full force and effect. For example, the provisions related to intellectual property, limitations of liability and survival.
SEVERABILITY
If any part of these Terms is found to be invalid, illegal, or unenforceable by court of competent jurisdiction for any reason whatsoever, (a) the validity, legality, and enforceability of the remaining provisions, in whole or in part, shall not be affected or impaired; (b) to the fullest extent possible, the unenforceable, illegal, or invalid provision will be deemed modified and replaced by a provision that approximates the intent and economic effect of the unenforceable, illegal, or invalid provision and these Terms will be deemed amended accordingly.
WAIVER
These Terms constitute the entire agreement between you and us relating to your access to and use of TCPApp. Enforcement of these Terms is at our own discretion, and our failure or delay in exercising or enforcing our right or provision of these Terms will not constitute a waiver of such right.
COMPLIANCE WITH LOCAL REGULATIONS
We cannot guarantee or provide any representations that TCPApp is appropriate or available for use in your location. Authorized Users who access or use TCPApp from their jurisdictions do so at their own risk and are entirely responsible for compliance with all applicable laws and regulations.
In order to access or use TCPApp, you must and hereby represent that you are not a citizen or resident of a geographic area in which access to or use of TCPApp is prohibited by applicable law, decree, regulation, treaty, or administrative act. You agree that if your country of residence or other circumstances change such that the above representations are no longer accurate, that you will immediately cease using TCPApp.