Updated January 2022
What this policy covers
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
- What information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How to access and control your information
- How we transfer information we collect internationally
- Other important privacy information
When we refer to “TravPRO Mobile,” “we,” or “us” in this policy, we mean TravPRO Mobile LLC, which controls the information TravPRO Mobile collects when you use our programs. TravPRO Mobile offers training and sales enablement programs, available on web and mobile products.
What information we collect about you
We collect information about you when you provide it to us, when you use our programs, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you input it into our programs or otherwise provide it directly to us.
- Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for our programs. For example, you provide your contact information when you register for our programs. You also have the option of adding a profile photo, bio, and other details to your profile in our programs. We keep track of your preferences when you select settings within our programs.
- Content you provide through our products: The programs include the TravPRO Mobile web, desktop and mobile products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Examples of content we collect and store include: your name, email address, zip code, business name.
- Information you provide through our support channels: The programs also include customer support, where you may choose to submit information regarding a problem you are experiencing with a program. Whether you designate yourself as a contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Information we collect automatically when you use our programs
We collect information about you when you use our programs, including browsing our websites and taking certain actions within our programs.
- Your use of our programs: We keep track of certain information about you when you visit and interact with any of our programs. This information includes registration, progress, links you click on; pages you favorite.
- Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access our programs. This device information includes your connection type and settings when you install, access, update, or use our programs. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better experience. How much of this information we collect depends on the type and settings of the device you use to access our programs.
How we use information we collect
How we use the information we collect depends in part on which programs you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
- To provide the programs and personalize your experience: We use information about you to provide the programs to you, including to authenticate you when you log in, provide customer support, and operate and maintain the programs. For example, we use the name and email you provide in your account to identify you. Our programs also include tailored features, like favoriting pages, that personalize your experience, enhance your productivity, and experience. We may use your email domain to infer your affiliation with a particular organization or industry to personalize the content and experience you receive on our websites. Where you use TravPRO owned or operated services, we may combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one service while searching from another or to present relevant product information as you travel across our websites.
- For research and development: We are always looking for ways to make our programs smarter, faster, secure, integrated and useful to you. We use collective learnings about how people use our programs and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the programs. In some cases, we apply these learnings across TravPRO Mobile owned or operated services to improve and develop similar features or to better integrate the services you use. We also test and analyze certain new features with some users before rolling the feature out to all users.
- To communicate with you about the programs: We use your contact information to send communications via email and within the program, including confirming your registration, reminding you of your status, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, and administrative messages. We also send you communications as you onboard to a particular program to help you become more proficient in using that program.
- To market, promote, and drive engagement with the program: We use your contact information and information about how you use the programs to send promotional communications that may be of specific interest to you, including by email and by displaying TravPRO ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the programs, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. You can control whether you receive these communications as described below under “Opt-out of communications.”
- Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the programs.
- For safety and security: We use information about you and your program use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of policies.
- To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
- With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the programs, with your permission.
- Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the programs you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the program, including to operate the program, provide customer support and personalized features and to protect the safety and security of the program;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the program and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the program.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our programs.
- Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
- TravPRO Mobile Partners: We work with third parties who provide consulting, sales, support and technical services to deliver and implement customer solutions around the programs. We may share your information with these third parties in connection with their services, such as to provide localized support, and to provide customizations. We may also share information with these third parties where you have agreed to that sharing, like when you agree to us sharing your information with a TravPRO Expert for support-related questions.
- Links to Third-Party Sites: The programs may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
- With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our websites. With your consent, we may post your name alongside the testimonial.
- Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect TravPRO Mobile, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person. For more information on how we respond to government requests, see our Guidelines for Law Enforcement8 and our Transparency Report.9
How we store and secure information we collect
Information storage and security
We use data hosting service providers located globally via Amazon Web Services, Digital Ocean or HostingXS to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
- Account information: We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our programs. Where we retain information for program improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our programs, not to specifically analyze personal characteristics about you.
- Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the program and using settings available within the program or your account. Where the programs are administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
- Access and update your information: Our programs give you the ability to access and update certain information about you from within the program. For example, you can access your profile information from your account and search for content containing information about you using key word searches in the program. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
- Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a program account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
- Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database.
- Turn off Cookie Controls: Relevant browser-based cookie controls are described in our Cookies & Tracking Notice.
How we transfer information we collect internationally
Privacy Shield Notice
Under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we are responsible for the processing of information about you we receive from the EU and Switzerland and onward transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for such onward transfers and remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such information about you on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
To learn more about the Privacy Shield Program, and to view our certification, please visit our public Privacy Shield listing.
We encourage you to contact us as provided below should you have a Privacy Shield-related (or general privacy-related) complaint. We have also committed to cooperating and complying with the information and advice provided by an informal panel of data protection authorities in the European Economic Area and/or the Swiss Federal Data Protection and Information Commissioner (as applicable) in relation to unresolved complaints (as further described in the Privacy Shield Principles). You may also contact your local data protection authority within the European Economic Area or Switzerland (as applicable) for unresolved complaints.
Under certain conditions, including when other dispute resolution procedures have been exhausted, you may invoke binding arbitration.
We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Other important privacy information
Notice to End Users
Our products are intended for both personal use and use by organizations. Where the programs are made available to you through an organization (e.g. your employer), that organization is the administrator of the program and is responsible for the end-users and/or program sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the programs is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Even if the programs are not currently administered to you by an organization, if you are a member of a team administered by an organization, or if you use an email address provided by an organization (such as your work email address) to access the programs, then the administrator of that team or the owner of the domain associated with your organizational email address (e.g. your employer) may assert administrative control over your account and use of the programs at a later date. You will be notified if this happens.
Please contact your organization or refer to your administrator’s organizational policies for more information.
Our policy towards children
The programs are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
Your information is controlled by TravPRO Mobile. If you have questions or concerns about how your information is handled, please direct your inquiry to TravPRO Mobile as set forth below:
Morristown, NJ 07960