Welcome to buzzy’s privacy notice
Culture Trip respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit and use our websites (theculturetrip.com and our related websites) (“Website”) or our Culture Trip branded app (“App”) and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Culture Trip collects and processes your personal data through your use of our Website or App, including any data you may provide through our Website or App when you sign up to our newsletter or set-up a user account.
The Website and App are not intended for children (i.e. individuals aged 18 or under) and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices we give and is not intended to override them.
buzzy Limited is the controller and responsible for your personal data (referred to as “buzzy”, “we”, “us” or “our” in this privacy notice).
Culture Trip is made up of different legal entities (Buzzy ISL Ltd,Buzzy Limited, and buzzy USA Ltd). This privacy notice is issued on behalf of Buzzy Group so when we mention “Buzzy”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in Buzzy Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Culture Trip Limited is the controller and responsible for the Website and App.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise Your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity:buzzy
Email address: firstname.lastname@example.org
Postal address: Legal Team, First Floor, 75 Davies Street, London W1
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Website and App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or apps and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website or app you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below.
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, age and gender, your photograph (where you sign-up to an account with us and choose to include your picture on your account).
- Contact Data includes email address and telephone numbers
- Technical Data includes mobile device ID (when using our App), internet protocol (IP) address), your login data, browser type (for website use), time zone setting and location, operating system and platform and other technology related information about the devices you use to access the Website or App. If you use our Website or App from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS to identify your precise location
- Profile Data includes your username and password, your location, feedback and survey responses. When you log in with us via Facebook, we will receive (unless you change your settings within Facebook), your public profile information (i.e. your name and profile picture), your birth date, a list of your friends which also use the App and your current city listed in your Timeline
- Usage Data includes information about how you use the Website or App (including your content viewing habits), products and services.
- Marketing includes your preferences in receiving marketing from us and our third parties.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website or App feature or content. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- contact us regarding products or services we offer on our Website or App;
- create an account on our Website or App;
- subscribe to our newsletter;
- opt-in to receiving marketing emails from us;
- enter a competition, promotion or survey; or
- give us some feedback.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
5. Opting out of personalised content and adverts
So that we can provide you with a great user experience, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need. This is how we decide which adverts and content may be relevant for you. You will only receive marketing communications from us by email if you provided us with your express opt-in consent.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising and providing you with personalized content. We have established the following personal data control mechanisms:
How to opt- out of a personalised website or app experience
Opting out for App Users:
If you do not want your experience on the App to be tailored to you based on your viewing habits on the App, go to your profile->settings and slide the ‘Personalisation’ to ‘Off’. If you change your mind and would like to receive a personalised experience, you can simply slide the ‘Personalisation’ button back to ‘On’.
Opting out for Website users who are logged into their Culture Trip Account:
If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website, go to profile->settings and uncheck the ‘Personalisation’ checkbox. If you change your mind and would like to receive a personalised experience, you can simply re-check the box.
Opting out for Website users who do not have a Culture Trip Account:
If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website. If you change your mind and would like to receive a personalised experience, . If you click the link to opt-out, we will place a ‘do not track’ cookie on your browser. Please note that if you delete all cookies on your browser, or if you use a different browser to access the Website you will have to click this link again in order to stop us personalising your experience on our Website.
Tracking and advertising
We use products offered by Google and Salesforce in order to show you adverts which we think are likely to be relevant to you. If you do not want to receive personalized advertising, . Furthermore, you can elect to reset your mobile device Advertising ID to clear any associated ad targeting or data collection activities.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
We share your personal data within Buzzy Group. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.