Bakpak Travelers Guide Privacy Policy

Last Updated: May 24, 2018

Bakpak Travelers Guide, Inc. ("Bakpak", "we," "our" or "us") is committed to respecting and protecting your privacy. This Privacy Policy (“Privacy Policy”) sets out how we collect, use, disclose and otherwise manage your Personal Information. Our Privacy Policy applies to all who use our website,www.bakpakguide.com, (the “Site”), and any online services, forms, and tools that we own or control (regardless of how you access or use them) (collectively, the “Services”). If you disagree with this Privacy Statement, you should discontinue using our services.

1. Information We Collect

Personal Information will generally be collected directly from you when download our guides, sign up for a newsletter or you rent a vehicle from us, whether through the use of any of our standard forms, our dealings with you over the internet, via email, or through a telephone conversation. The service that you use will determine exactly what information we collect.

1.1 Travel Guide Downloads/Newsletter Sign Ups. We collect information about you when you download a free travel guide or sign up for one of our newsletters. We may ask for your contact information, including items such as first and last name, email address, where you are from, when you will be traveling, the date of form submission and the IP address from which you completed forms on our website. We use consent as our lawful basis for processing your information for the specific purpose(s) you consented to. Please see section 6 for information on your data protection rights.

1.2 Campervan, Camper and RV/Motorhome Rental QUOTE Requests. We collect information about you when you request a quote for a vehicle rental, whether from our website, via direct email to us, via direct message from our chat application or via messages/posts on social media platforms. We may ask for your contact information, including items such as first and last name, age of youngest driver, email address, phone number (optional), country of residence, the date of form or email submission and the IP address from which you completed forms on our website. We may include some of this information in quotes that we email to you. We use contract as our lawful basis for processing your information so that we may send you a quote(s) and communicate with you regarding such quote(s). Please see section 6 for information on your data protection rights.

1.3 Campervan, Camper and RV/Motorhome Rental BOOKING Requests. We collect further information about you when you submit a booking for a vehicle rental on our website. We may ask for your contact information, including items such as first and last name of lead renter and a secondary renter, age of lead and secondary renters, email address, phone number, full address, Instagram account name (optional), the date of form submission and the IP address from which you completed forms on our website. We use contract as our lawful basis for processing your information so that we may process your booking and communicate with you regarding such booking. Please see section 6 for information on your data protection rights.

1.4 Payment Information. When you make a vehicle rental booking or purchase a travel guide directly from our website, payment information is directed to a third-party payment processor (PayPal) who acts as the controller of your data. You can view PayPals' Privacy Policy. We do not store your financial account information (we do not know or see users’ credit card numbers or three digit code); however, we have access to certain payment information through PayPal including the last four digits of your credit card number, expiry date and billing address, which we may access to process refunds, to process cancellation penalties, or to process additional required payments.

With certain vehicle rental bookings, we may collect full payment information directly from you in order to provide to the supplier of your rental vehicle. This includes but is not limited to credit card number, billing address and expiry date. The Terms and Conditions of Rental provided to you prior to booking will include this information if this situation is applicable.

We use contract as our lawful basis for processing your information so that we may process your booking and communicate with you regarding such booking. Please see section 6 for information on your data protection rights.

1.5 Communications. If you contact us directly through email, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

We use contract as our lawful basis for processing your information so that we may process your booking and communicate with you regarding such booking. Please see section 6 for information on your data protection rights.

1.6 Cookies and Other Tracking Technologies. We may gather certain information automatically and store it in log files. We may collect information about your computer, phone, tablet, or other devices you use to access the Services. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, landing page, and referring URL.

1.7 Children's Privacy. We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act). This is a general audience website and does not offer services directed to children. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her personal information.

We do not intend that any portion of our Site or Services will be accessed or used by children under the age of eighteen, and such use is prohibited. Our Site and Services are designed and intended for adults. By using the Site and Services, you represent that you are at least 18 years old and understand that you must be at least 18 years old in order to use our Services. 

2. How We Use Information We Collect

How we use the information we collect depends on which Services you use. Below are the specific purposes for which we use the information we collect about you.

2.1 Travel Guide Downloads/Newsletter Sign Ups. Depending on the consent you give, the information we collect may be used to email you a link to travel guide downloads, and/or to send you emails about deals, specials, and relevant travel information.

2.2 Campervan, Camper and RV/Motorhome Rental Quote and Booking Requests. The information we collect is used to send you relevant quotes and travel information regarding campervan, camper and/or RV/motorhome rentals and travel, to respond to your inquiries and provide you with service and support. It is also used to process booking requests and provide information for your trip.

2.3 Payment Information. Payment information, whether collected by us or that you provide online through our payment processor, PayPal, is collected to process any purchases or rental bookings made with us.

2.4 Other Use of Information. We may also use your information to:

• To personalize your experience (your information helps us to better respond to your individual needs)
• To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
• To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)

2.5 For Compliance Purpose. We may use your information for compliance purposes, including enforcing legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

3. How We Share Information We Collect

We may share the information we collect in various ways, including the following:

3.1 Travel Guide Downloads/Newsletter Sign Ups. We may share information we collect about you when you download a free travel guide or sign up for one of our newsletters through the use of third-party email newsletter software and marketing services.

3.2 Campervan, Camper and RV/Motorhome Rental Bookings. When you book a vehicle rental with us, we provide some or all of your contact information, including items such as first and last name of lead renter and a secondary renter, age of lead and secondary renters, email address, phone number and full address to the supplier of the vehicle rental. In certain instances, we may provide financial information you have provided to us, to the supplier of the vehicle rental to complete a booking transaction. The suppliers of the vehicle rentals act a data controllers under the GDPR, and as such, your information is also protected in accordance with their privacy policies but we are not responsible for the implementation of their policies under the GDPR.

3.3 Vendors and Service Providers. We work with third-party service providers to render our Services, including (but not limited to) web hosting, chat and online messaging services, outgoing email service providers, marketing, maintenance, backup, storage, payment processing, website statistics and analysis and security. If a service provider needs to access information about you to perform services on our behalf, they do so using policies and procedures designed to protect your information.

3.3 Business Transfer. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

3.4 As Required By Law and Similar Disclosures. We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

3.5 With Your Consent. We may share information about you with third parties when you give us consent to do so.
 

4. Security

4.1 Security Practices. We take steps to protect the security of the personally identifiable information we collect, including, for example, physical, electronic, and procedural safeguards.

Although we take appropriate measures to ensure the security of your personal data, no security system is 100% safe. We cannot provide absolute assurances that personally identifiable information we collect may not be disclosed in a manner that is inconsistent with this Privacy Policy.

4.2 Data Locations. Depending on the information we collect, such information may be stored in database servers on the our website, on a local computer with local backups in Los Angeles, USA and backups stored securely online through third-party site(s).

5. Data Retention

How long we keep information we collect about you depends on the type of service provided to you, as described in further detail below. After such time, we will delete your information from all of our servers, including backups.

5.1 Travel Guide Downloads/Newsletter Sign Ups. Information we collect about you when you download a free travel guide or sign up for one of our newsletters is retained for one year after which all information will be deleted, unless 1) you have used other Services that have different retention guidelines and/or 2) you opted in for our newsletter or updates and have not unsubscribed from them.

5.2 Campervan, Camper and RV/Motorhome Rental QUOTE Requests. Information we collect about you when you request a quote for a vehicle rental is retained for one year after which all information will be deleted, unless 1) you have used other Services that have different retention guidelines and/or 2) you opted in for our newsletter or updates and have not unsubscribed from them.

5.3 Campervan, Camper and RV/Motorhome Rental Bookings. Information we collect about you when you make a booking for a vehicle rental with us is retained for up to seven years, subject to US laws on data retention for tax purposes, after which all information will be deleted.

5.4 Payment Information. When you make a vehicle rental booking or purchase a travel guide from our website, payment information retention is subject to the policies of our third-party payment processor, PayPal. Any payment information that we have collected outside of PayPal will be retained until your vehicle rental has been returned to the vehicle supplier, so that we may enforce any terms and conditions of your rental booking.

5.5 Other Data Retention. We may 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 Services.
 

6. Your Data Protection Rights Under The GENERAL DATA PROTECTION REGULATION (GDPR)

If the GDPR regulation applies to you as a data subject, you have the following data protection rights. If you wish to exercise any of these rights, please email info@bakpakguide.com. Your rights are:

The right to be informed

As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy.

The right of access

You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you.

If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or requires unreasonable expense (which you may have to meet), we will inform you.

The right to rectification

When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

The right to erasure (the ‘right to be forgotten’)

Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

The right to restrict processing

You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:

    a) The accuracy of the personal data is contested
    b) Processing of the personal data is unlawful
    c) We no longer need the personal data for processing but the personal data is required for part of a legal process
    d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing

The right to data portability

You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfillment of a contractual obligation.

The right to object

You have the right to object to our processing of your data where

• Processing is based on legitimate interest;
• Processing is for the purpose of direct marketing;
• Processing is for the purposes of scientific or historic research;
• Processing involves automated decision-making and profiling.

You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you.

Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

7. Data Transfers

Personal information that you submit through the Services may be transferred to countries other than where you live.  Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.

The GDPR provides derogations (exemptions) from the general prohibition on transfers of personal data outside the EU for certain specific situations. A transfer, or set of transfers, may be made where the transfer is:

• made with the individual’s informed consent;
• necessary for the performance of a contract between the individual and the organization or for pre-contractual steps taken at the individual’s request;
• necessary for the performance of a contract made in the interests of the individual between the controller and another person;

As such we are exempt from the general prohibition on transfers of personal data outside the EU for these specific situations.

8. Third Party Links

We may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

9. California Online Privacy Protection Act Compliance

We have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent unless needed to complete travel booking transactions.

10. Changes to Our Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this privacy policy, you will need to stop using the Services as outlined above.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact Bakpak Travelers Guide via email using info@bakpakguide.com.

Under the GDPR, you must appoint a Data Protection Office if:

• you are a public authority (except for courts acting in their judicial capacity);
• your core activities require large scale, regular and systematic monitoring of individuals (for example, online behavior tracking); or
• your core activities consist of large scale processing of special categories of data or data relating to criminal convictions and offenses.

Based on this, we are not required to appoint a Date Protection Officer.