At The Roman Guy, Inc. dba The Tour Guy ('The Tour Guy'), we appreciate the trust you place in us when you choose to visit our websites, https://thetourguy.com, https://theromanguy.com (the 'Website'), and social media pages, and we are committed to protecting your privacy. This Privacy Policy (the 'Privacy Policy') describes the types of personal information we collect, why and how we collect it, how we use it, and when we share it with third parties. Our Privacy Policy also describes the choices you can make about how we collect and use your personal information.
In this Privacy Policy, 'we' and 'our' means The Tour Guy and 'you' or 'user' means any person who visits our Website or social media accounts, calls us on the phone, texts us, or emails us.
Privacy Policy of The Tour Guy
Welcome to the privacy policy of The Tour Guy. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
Latest update: March 17, 2026
Summary
Data we collect automatically
We automatically collect data from you for example when you visit The Tour Guy.
Interaction with data collection platforms and other third parties
Registration and authentication
Registration and authentication provided directly by The Tour Guy
Managing contacts and sending messages
Analytics
Owner and Data Controller
The Roman Guy INC 1200 Brickell Avenue, Suite 1950, Miami, Florida 33131, USA
Owner contact email: privacy@thetourguy.com
Type of Data we collect
Among the types of Personal Data that The Tour Guy collects, by itself or through third parties, there are:
Trackers
Usage Data
IP address
browser information
device information
page views
clicks
number of Users
session statistics
city
ZIP/Postal code
state
province
country
county
latitude (of city)
longitude (of city)
metro area
geography/region
app information
device logs
operating systems
language
launches
number of sessions
session duration
scroll-to-page interactions
mouse movements
scroll position
keypress events
motion sensor events
touch events
video views
browsing history
search history
interaction events
page events
custom events
Application opens
first name
last name
email address
payment info
User ID
Universally unique identifier (UUID)
phone number
username
physical address
various types of Data
Email
password
picture
answers to questions
purchase history
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using The Tour Guy. Unless specified otherwise, all Data requested by The Tour Guy is mandatory and failure to provide this Data may make it impossible for The Tour Guy to provide its services. In cases where The Tour Guy specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by The Tour Guy or by the owners of third-party services used by The Tour Guy serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through The Tour Guy.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of The Tour Guy (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Hosting and backend infrastructure
Advertising
Analytics
Remarketing and behavioral targeting
Collection of privacy-related preferences
Commercial affiliation
Spam and bots protection
Traffic optimization and distribution
User database management
Handling payments
Interaction with external social networks and platforms
Displaying content from external platforms
Content performance and features testing (A/B testing)
Registration and authentication provided directly by The Tour Guy
Handling activity data
Registration and authentication
Interaction with data collection platforms and other third parties
Contacting the User
Content commenting
Handling activities related to compliance
Tag management
Managing contacts and sending messages
Detailed information on the processing of Personal Data
Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on The Tour Guy, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside The Tour Guy.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
WordAds
Company: Automattic Inc.
Place of processing: United States
Personal Data processed: browser information +6
WordAds is an ad monetization service for WordPress sites provided by Automattic Inc.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
a Sharing in California
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Meta ads conversion tracking (Meta pixel)
Company: Meta Platforms, Inc. +1
Place of processing: United States +1
Personal Data processed: Trackers +1
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on The Tour Guy. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
a Sharing in California
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Pinterest Conversion Tag
Company: Pinterest, Inc.
Place of processing: United States
Personal Data processed: device information +2
Pinterest Conversion Tag is an analytics service provided by Pinterest, Inc. that connects data from the Pinterest advertising network with actions performed on The Tour Guy.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
a Sharing in California
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Pinterest Ads
Company: Pinterest, Inc.
Place of processing: United States
Personal Data processed: Trackers +1
Pinterest Ads is an advertising service provided by Pinterest, Inc. that allows the Owner to run advertising campaigns on the Pinterest advertising network.
Users may opt out of behavioral advertising features through their device settings, their Pinterest personalization settings.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
a Sharing in California
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics 4
Company: Google LLC
Place of processing: United States
Personal Data processed: number of Users +3
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of The Tour Guy, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Cloudflare Web Analytics
Company: Cloudflare, Inc.
Place of processing: United States
Personal Data processed: device information +2
Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare, Inc. that gives the Owner insight into the use of The Tour Guy by Users without needing to identify them. Further information may be found here and within the service's privacy policy.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
inferences drawn from other personal information
Meta Events Manager
Company: Meta Platforms Ireland Limited +1
Place of processing: Ireland +1
Personal Data processed: browsing history +5
Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited or by Meta Platforms, Inc., depending on how the Owner manages the Data processing. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on The Tour Guy.
Category of Personal Information collected according to the CCPA
commercial information
internet or other electronic network activity information
Collection of privacy-related preferences
This type of service allows The Tour Guy to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Privacy Controls and Cookie Solution
Company: iubenda srl
Place of processing: Italy
Personal Data processed: IP address +1
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on The Tour Guy.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Commercial affiliation
This type of service allows The Tour Guy to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with The Tour Guy.
For details of which data are collected, please refer to the privacy policy of each service.
Booking.com Affiliate Partner Programme
Company: Booking.com B.V.
Place of processing: Netherlands
Personal Data processed: Trackers +1
Booking.com Affiliate Partner Programme is a commercial affiliation service provided by Booking.com B.V., part of the Priceline.com group.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Contacting the User
Contact form
Company: The Tour Guy
Personal Data processed: email address +1
By completing the contact form with their information, the User authorizes The Tour Guy to use these details to respond to the inquiries (like quotes, and any other requests).
Personal Data processed:
email address
Usage Data
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Mailing list or newsletter
Personal Data processed: email address +2
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning The Tour Guy. Your email address might also be added to this list as a result of signing up to The Tour Guy or after making a purchase.
Personal Data processed:
email address
Trackers
Usage Data
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Phone contact
Personal Data processed: phone number
Users that provided their phone number might be contacted for commercial or promotional purposes related to The Tour Guy, as well as for fulfilling support requests.
Personal Data processed:
phone number
Category of Personal Information collected according to the CCPA
identifiers
Content commenting
Content commenting services allow Users to make and publish their comments on the contents of The Tour Guy.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly
Personal Data processed: email address +5
The Tour Guy has its own internal content comment system.
Personal Data processed:
email address
first name
last name
Trackers
Usage Data
username
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of The Tour Guy.
VWO - Testing
Company: Wingify Software Pvt. Ltd.
Place of processing: India
Personal Data processed: device information +3
VWO - Testing is a content performance and features performance testing service provided by Wingify Software Pvt. Ltd.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Browser Layout Info
Company: The Tour Guy
Personal Data processed: Trackers
Store browser viewport width for proper layout rendering
Personal Data processed:
Trackers
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of The Tour Guy and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube IFrame Player
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: device information +3
YouTube IFrame Player is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows The Tour Guy to incorporate content of this kind on its pages.
Through this Service, The Tour Guy may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Google Maps Widget
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Trackers +1
Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows The Tour Guy to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Google Fonts
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Trackers +1
Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows The Tour Guy to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Handling activity data
This type of service allows the Owner to use the activity or biometric data collected by your device in order for The Tour Guy to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
Depending on what is described below, third parties may be involved in the activity tracking.
Most devices allow for the User to control which Data is accessed or stored.
Consent Preferences Storage
Personal Data processed: Trackers
Store cookie consent preferences
Personal Data processed:
Trackers
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Handling payments
Unless otherwise specified, The Tour Guy processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. The Tour Guy isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
PayPal
Company: PayPal Inc.
Place of processing: See the PayPal privacy policy
Personal Data processed: email address +3
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
Braintree
Company: PayPal Inc. +5
Place of processing: See the Braintree privacy policy +5
Personal Data processed: first name +5
Braintree is a payment service provided by Braintree, a division of PayPal Inc., PayPal (Europe) S.a.r.l. et Cie, S.C.A., PayPal Australia Pty Limited, PayPal Canada Co., PayPal Hong Kong Limited or by PayPal Pte. Ltd., depending on how the Owner manages the Data processing.
Personal Data processed:
first name
last name
payment info
Trackers
Usage Data
various types of Data as specified in the privacy policy of the service
PayPal (Europe) S.a.r.l. et Cie, S.C.A. (See the Braintree privacy policy)
–
Privacy Policy
PayPal Australia Pty Limited (See the Braintree privacy policy)
–
Privacy Policy
PayPal Canada Co. (See the Braintree privacy policy)
–
Privacy Policy
PayPal Hong Kong Limited (See the Braintree privacy policy)
–
Privacy Policy
PayPal Pte. Ltd. (See the Braintree privacy policy)
–
Privacy Policy
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
Google Pay
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: email address +5
Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows users to make online payments using their Google credentials.
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
Payment by bank transfer
Company: The Tour Guy
Personal Data processed: first name +3
In the event that the chosen payment method is a direct bank transfer to the current account indicated by The Tour Guy, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data processed:
first name
last name
payment info
physical address
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
identifiers
commercial information
Venmo Business
Company: PayPal Inc.
Place of processing: United States
Personal Data processed: payment info +2
Venmo Business is a payment service provided by PayPal Inc, which allows Users to make payments using their mobile phones.
Category of Personal Information collected according to the CCPA
commercial information
internet or other electronic network activity information
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable The Tour Guy to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of The Tour Guy.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS)
Company: Amazon Web Services, Inc.
Place of processing: United States +17
Personal Data processed: various types of Data as specified in the privacy policy of the service
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of The Tour Guy for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Third-party Analytics Identifier
Personal Data processed: Trackers
Identify users for analytics / personalization by mountain.com
Personal Data processed:
Trackers
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Direct marketing via popups
Company: The Tour Guy
Personal Data processed: Email +2
The Tour Guy uses popups to interact with the User to propose services and products which may be provided by third parties or that are unrelated to the product or services provided by The Tour Guy.
Personal Data processed:
Email
Trackers
various types of Data
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Mailchimp Widget
Company: Intuit Inc.
Place of processing: United States
Personal Data processed: email address +2
The Mailchimp Widget is a service for interacting with the Mailchimp email address management and message sending service provided by Intuit Inc.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of The Tour Guy.
The interaction and information obtained through The Tour Guy are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on The Tour Guy isn’t being connected back to the User’s profile.
Pinterest “Pin it” Button and Social Widgets
Company: Pinterest, Inc.
Place of processing: United States
Personal Data processed: Trackers +1
The Pinterest “Pin it” Button and Social Widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Klaviyo
Company: Klaviyo Inc.
Place of processing: United States
Personal Data processed: email address +5
Klaviyo is an email address management and message sending service provided by Klaviyo Inc.
To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Registration and authentication
By registering or authenticating, Users allow The Tour Guy to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, The Tour Guy will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Authentication Redirect
Company: The Tour Guy
Personal Data processed: Trackers
Authentication / redirect after login
Personal Data processed:
Trackers
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Secure Session Identifier
Personal Data processed: Trackers
Authentication / session identifier for user sessions
Personal Data processed:
Trackers
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Auth0
Company: Auth0, Inc
Place of processing: United States +1
Personal Data processed: email address +6
Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process, Auth0 can make use of third-party identity providers and save the information on its platform.
Personal Data processed:
email address
first name
last name
password
picture
Trackers
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
audio, electronic, visual, thermal, olfactory, or similar information
Google OAuth
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Trackers +2
Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.
Personal Data processed:
Trackers
Usage Data
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Direct registration and profiling
Company: The Tour Guy
Personal Data processed: email address +4
By registering or authenticating directly through The Tour Guy, Users allow The Tour Guy to identify them and give them access to dedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profiling purposes; to find out more, Users can contact the Owner using the contact details provided in this document.
Personal Data processed:
email address
first name
last name
password
Trackers
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Registration and authentication provided directly by The Tour Guy
By registering or authenticating, Users allow The Tour Guy to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Customer Session
Company: The Tour Guy
Personal Data processed: Trackers
Session management for logged-in users
Personal Data processed:
Trackers
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Direct registration
Personal Data processed: email address +5
The User registers by filling out the registration form and providing the Personal Data directly to The Tour Guy.
Personal Data processed:
email address
first name
last name
password
Trackers
Usage Data
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Remarketing and behavioral targeting
This type of service allows The Tour Guy and its partners to inform, optimize and serve advertising based on past use of The Tour Guy by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Google Ads Remarketing
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Trackers +1
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of The Tour Guy with the Google Ads advertising network and the DoubleClick Cookie.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
a Sharing in California
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Remarketing with Google Analytics
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Trackers +1
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sale in the United States
a Sharing in California
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Spam and bots protection
This type of service analyzes the traffic of The Tour Guy, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.
Cloudflare Bot Management
Company: Cloudflare, Inc.
Place of processing: United States
Personal Data processed: app information +37
Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare, Inc.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
geolocation data
inferences drawn from other personal information
CSRF Protection Token
Company: The Tour Guy
Personal Data processed: Trackers
Security / CSRF protection
Personal Data processed:
Trackers
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Google reCAPTCHA
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: answers to questions +8
Google reCAPTCHA is a spam protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
inferences drawn from other personal information
Tag management
This type of service helps the Owner to manage the tags or scripts needed on The Tour Guy in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Trackers +1
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Traffic optimization and distribution
This type of service allows The Tour Guy to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between The Tour Guy and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare
Company: Cloudflare, Inc.
Place of processing: United States
Personal Data processed: Trackers +1
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through The Tour Guy, i.e., communication between The Tour Guy and the User's browser, while also allowing analytical data from The Tour Guy to be collected.
Personal Data processed:
Trackers
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to The Tour Guy, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving The Tour Guy.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on The Tour Guy.
Klaviyo CRM
Company: Klaviyo Inc.
Place of processing: United States
Personal Data processed: email address +4
Klaviyo CRM is a User database management service provided by Klaviyo Inc.
Klaviyo CRM can also be used as a medium for communications, either through email, or through messages within The Tour Guy.
To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
User Identification UUID
Company: The Tour Guy
Personal Data processed: Trackers
User identification / preferences for personalization
Personal Data processed:
Trackers
Service provided by:
The Tour Guy
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
This processing constitutes:
a Sharing in California
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
localStorage
localStorage allows The Tour Guy to store and access data right in the User's browser with no expiration date.
sessionStorage
sessionStorage allows The Tour Guy to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by The Tour Guy depends on the payment system used.
Cookie Policy
The Tour Guy uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running The Tour Guy and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running The Tour Guy and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
Identifiers
Sold or Shared
Targeted Advertising
Personal Data processed: Various types of data as specified in the privacy policy of the service; City; Zip/postal code; State + 46
Personal Information collected or disclosed:
various types of Data as specified in the privacy policy of the service
city
ZIP/Postal code
state
province
country
county
latitude (of city)
longitude (of city)
metro area
geography/region
Usage Data
Trackers
IP address
device information
app information
device logs
operating systems
browser information
language
launches
number of sessions
session duration
scroll-to-page interactions
mouse movements
scroll position
keypress events
motion sensor events
touch events
video views
clicks
browsing history
search history
session statistics
page views
interaction events
page events
custom events
Application opens
first name
last name
email address
User ID
Universally unique identifier (UUID)
phone number
physical address
various types of Data
Email
picture
purchase history
Sensitive Personal Information collected or disclosed
payment info, username, password
Purposes:
Hosting and backend infrastructure
Spam and bots protection
Traffic optimization and distribution
User database management
Handling payments
Displaying content from external platforms
Content performance and features testing (A/B testing)
Contacting the User
Content commenting
Further information about Personal Data
Interaction with data collection platforms and other third parties
Registration and authentication
Registration and authentication provided directly by The Tour Guy
Managing contacts and sending messages
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
Klaviyo Inc., PayPal Inc., Google LLC, Wingify Software Pvt. Ltd., Salesforce, Inc., Intuit Inc., SAS Mailjet
Service providers or contractors:
Amazon Web Services, Inc., Cloudflare, Inc., The Tour Guy, PayPal Inc., Google LLC, Microsoft Corporation, Auth0, Inc
Internet or other electronic network activity information
Sold or Shared
Targeted Advertising
Personal Data processed: Trackers; Usage data; Ip address; Browser information + 46
Personal Information collected or disclosed:
Trackers
Usage Data
IP address
browser information
device information
page views
clicks
number of Users
session statistics
city
ZIP/Postal code
state
province
country
county
latitude (of city)
longitude (of city)
metro area
geography/region
app information
device logs
operating systems
language
launches
number of sessions
session duration
scroll-to-page interactions
mouse movements
scroll position
keypress events
motion sensor events
touch events
video views
browsing history
search history
interaction events
page events
custom events
Application opens
various types of Data as specified in the privacy policy of the service
first name
last name
email address
User ID
Universally unique identifier (UUID)
various types of Data
Email
picture
answers to questions
purchase history
Sensitive Personal Information collected or disclosed
payment info, username, password
Purposes:
Advertising
Analytics
Remarketing and behavioral targeting
Collection of privacy-related preferences
Commercial affiliation
Spam and bots protection
Traffic optimization and distribution
User database management
Handling payments
Interaction with external social networks and platforms
Displaying content from external platforms
Content performance and features testing (A/B testing)
Registration and authentication provided directly by The Tour Guy
Handling activity data
Registration and authentication
Interaction with data collection platforms and other third parties
Further information about Personal Data
Contacting the User
Content commenting
Handling activities related to compliance
Tag management
Managing contacts and sending messages
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
Automattic Inc., Adform A/S, Google LLC, Booking.com B.V., Cloudflare, Inc., Meta Platforms, Inc., Klaviyo Inc., PayPal Inc., Pinterest, Inc., Spotify AB, Wingify Software Pvt. Ltd., Salesforce, Inc., The Tour Guy, TrustedSite, LLC, Liveintent Inc., Meta Platforms Ireland Limited, Microsoft Corporation, Intuit Inc., SAS Mailjet, AWIN AG
Service providers or contractors:
Google LLC, iubenda srl, Cloudflare, Inc., The Tour Guy, PayPal Inc., Apple Inc., Auth0, Inc
Geolocation data
Sold or Shared
Targeted Advertising
Personal Data processed: City; Zip/postal code; State; Province + 34
Personal Information collected or disclosed:
city
ZIP/Postal code
state
province
country
county
latitude (of city)
longitude (of city)
metro area
geography/region
Usage Data
Trackers
IP address
device information
app information
device logs
operating systems
browser information
language
launches
number of sessions
session duration
scroll-to-page interactions
mouse movements
scroll position
keypress events
motion sensor events
touch events
video views
clicks
browsing history
search history
session statistics
page views
interaction events
page events
custom events
Application opens
Purposes:
Spam and bots protection
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Service providers or contractors:
Cloudflare, Inc.
Inferences drawn from other personal information
Sold or Shared
Targeted Advertising
Personal Data processed: City; Zip/postal code; State; Province + 35
Personal Information collected or disclosed:
city
ZIP/Postal code
state
province
country
county
latitude (of city)
longitude (of city)
metro area
geography/region
Usage Data
Trackers
IP address
device information
app information
device logs
operating systems
browser information
language
launches
number of sessions
session duration
scroll-to-page interactions
mouse movements
scroll position
keypress events
motion sensor events
touch events
video views
clicks
browsing history
search history
session statistics
page views
interaction events
page events
custom events
Application opens
answers to questions
Purposes:
Spam and bots protection
Analytics
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
Cloudflare, Inc.
Service providers or contractors:
Cloudflare, Inc., Google LLC
Commercial information
Sold or Shared
Targeted Advertising
Personal Data processed: Trackers; Usage data; Email address; Various types of data as specified in the privacy policy of the service + 7
Personal Information collected or disclosed:
Trackers
Usage Data
email address
various types of Data as specified in the privacy policy of the service
first name
last name
physical address
purchase history
browsing history
clicks
page views
Sensitive Personal Information collected or disclosed
payment info
Purposes:
Handling payments
Managing contacts and sending messages
Analytics
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
Yes
Targeted Advertising:
Yes
Third-parties:
PayPal Inc., Klaviyo Inc., Meta Platforms Ireland Limited
Service providers or contractors:
PayPal Inc., Google LLC, The Tour Guy, Apple Inc.
Audio, electronic, visual, thermal, olfactory, or similar information
Sold or Shared
Targeted Advertising
Personal Data processed: Email address; First name; Last name; Various types of data as specified in the privacy policy of the service + 2
Personal Information collected or disclosed:
email address
first name
last name
various types of Data as specified in the privacy policy of the service
picture
Trackers
Sensitive Personal Information collected or disclosed
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use The Tour Guy.
For example, you directly provide your Personal Information when you submit requests via any forms on The Tour Guy. You also provide Personal Information indirectly when you navigate The Tour Guy, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of The Tour Guy and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
The right to question the results of the profiling;
The right to be informed of the reason that the profiling resulted in the decision; if feasible
The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
The right to review personal data used in the profiling;
If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on The Tour Guy.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information for Users in the United States
Collection of Personal Information about California consumers aged 13 to 16
We collect Personal Information of consumers between the age of 13 and 16 and won't Sell or Share their Personal Information unless those consumers have opted in.
Collection of Personal Information about California consumers below the age of 13
We collect Personal Information of consumers below the age of 13 and won't Sell or Share their Personal Information unless their parents or guardians have opted in on behalf of those minors.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of The Tour Guy or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, The Tour Guy may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, The Tour Guy and any third-party services may collect files that record interaction with The Tour Guy (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within The Tour Guy and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through The Tour Guy (or third-party services employed in The Tour Guy), which can include: the IP addresses or domain names of the computers utilized by the Users who use The Tour Guy, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using The Tour Guy who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of The Tour Guy. The Data Controller, unless otherwise specified, is the Owner of The Tour Guy.
The Tour Guy (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by The Tour Guy as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Email
Provides access to the User's primary email address.
Legal information
This policy has been prepared based on provisions of multiple legislations.
This policy relates solely to The Tour Guy, if not stated otherwise within this document.
