Trip Trustees (herein referred to as “Trip Trustees”, “we”, “us” or “our”) operates a platform and community marketplace that helps people form offline experiences and relationships directly with one another, where they can list and book Travel Facilitator Services through the Trip Trustees website or Application services (“Platform”).
“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.
“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.
“Data Controller” means Trip Trustees, the company responsible for the use and processing of Personal Information.
“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and Trip Trustees.
“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
What types of information does Trip Trustees gather about its users?
We receive, store and process information, including Personal Information that you make available to us when accessing or using our Platform and Services. Examples include when you:
fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;
access or use the Platform, such as to search for or post Listings, make or accept Trip Booking Requests, book or pay for any associated services that may be available, post comments or reviews, or communicate with other users;
link your account on a Third-Party site (e.g. Facebook) to your Trip Trustees Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;
communicate with Trip Trustees; and
share information with another Member.
Information we get from your use of our Platform
We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
You may use your contact information, such as your email address or phone number to create or customize your account or to enable certain account features, for example, for login verification. If you provide us with your email address or phone number, you agree to receive emails to that email address and/or text messages to that phone number, as the case may be. We may use your contact information to send you information about our Platform and Services, to market to you, and to help prevent spam, fraud, or abuse.
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Trip Trustees or logged in to your Trip Trustees Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.
Cookies and other Tracking Technologies
While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Trip Trustees services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.
We may, either directly or through Third Parties that we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties that we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. If you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access.
Third-Party social plugins
Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.
As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.
How Trip Trustees uses and processes the information that you provide or make available
We use, store and process information about you for the following general purposes:
to enable you to access and use the Platform;
to enable you to communicate with other Members, including but not limited to by sending them messages or other information during the Trip Booking Request process;
to operate, protect, improve and optimize the Platform, Trip Trustees’ business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;
to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;
to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Trip Trustees, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings in your Trip Trustees Account;
to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Trip Trustees or our Third Party business partners; and
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.
How Trip Trustees Uses and Processes User Communications
We may, either directly or through Third-Parties that we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages and attachments to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Clients to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, Trip Booking Requests and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Trip Trustees, in its sole discretion, may, either directly or through Third-Parties that we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.
When Trip Trustees discloses or shares your personal information, and to whom
Your Personal Information may be transferred, stored, used, processed and disclosed as follows:
Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.
Your public Listing page will always include some minimum information such as your listing description, your calendar availability, your public profile photo, your responsiveness in replying to Travel Clients’ queries, and any additional information you share with other Members. Your public Listing page may also include aggregated demand information (such as number of page views over a period of time). Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display your approximate geographic location on a map, such that a user can see the general area of the Trip origination.
The Platform allows your public profile and public listing pages to be included in search engines, in which case your public profile and public listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public listing pages, Third-Party search engines may not update their databases quickly or at all. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.
When you submit a Trip Booking Request, your full name, and the full name of any confirmed individuals with you (if applicable), and other Personal Information you agree to pass through to the Travel Assistant will become visible to the Travel Assistant to which you submit your initial Trip Booking Request. We may also disclose parts of your public profile; other Member reviews of you; and any additional information you share with other Members. We will not share your phone number unless there is a confirmed Trip Booking Request; if there is a confirmed Trip Booking Request, your phone number will become visible to the Travel Assistant/Travel Client, who may call you directly.
When your Trip Booking Request is accepted by the Travel Assistant or when a Travel Client books your Travel Facilitator Services, we will disclose some of your Personal Information to other Member, however, your billing and payout information will never be shared with another user.
When a Travel Assistant confirms your Trip Booking Request, the Travel Assistant may elect to use Third-Party services, whether or not made available through the Trip Trustees platform, to assist with managing the Travel Facilitator Services as mutually agreed upon with you, the Travel Client through a separate and independent contract, not involving Trip Trustees. The Travel Assistant may use features on the Trip Trustees platform to share information about the Travel Client with that Third-Party service provider for the purposes of coordinating the travel or managing the certain Travel Facilitator Services. Information that may be shared for this purpose may include Travel Client’s name, Travel Client’s phone number, and the Travel Client’s email address which would be converted to an anonymous email.
When Travel Clients use a Travel Assistant’s Travel Facilitator Services, we may ask you to review the Travel Assistant and their Travel Facilitator Services. If you choose to provide a review, your review may be public on the Platform. Likewise, another Member’s review of you as a Travel Client may be public on the Platform.
You may link your account on a Third-Party social networking site to your Trip Trustees Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:
some of the information you provide to us from the linking of your accounts may be published on your Trip Trustees Account profile;
your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;
a link to your public profile on that Third-Party social networking site may be included in your Trip Trustees public profile;
other Trip Trustees users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
other Trip Trustees users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s);
the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
the publication and display of information that you provide to Trip Trustees through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.
We may distribute parts of the Platform (including your Listing) for display on sites operated by Trip Trustees’ business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request. We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf.
For any jurisdiction in which we facilitate the Collection and Remittance of Taxes, Travel Assistants and Travel Clients expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, Trip Booking Requests, Listings and Taxes, including, but not limited to, personally identifiable information such as Travel Assistant or Travel Client’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received by Travel Assistants from Travel Clients, or allegedly due, contact information and similar information, to the relevant Tax Authority.
We will use commercially reasonable efforts to notify users about law enforcement or other legal requests for their data unless:
providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
we believe that providing notice would be futile, be ineffective, or would create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Trip Trustees’ property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).
In instances where Trip Trustees complies with legal requests for user data without notice to the user for the reasons described above, Trip Trustees will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
State Privacy Laws
For California & Vermont residents: Trip Trustees Payments will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by your state’s law.
Business transfers by Trip Trustees
How to access, change or delete your information, or cancel your Trip Trustees account
You may review, update, correct or delete the Personal Information in your Trip Trustees Account. If you would like to correct your information or cancel your Trip Trustees Account entirely, you can do so by logging in to your Trip Trustees Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your Trip Trustees Account is cancelled.
Securing your personal information
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. We cannot guarantee the security of your transmissions to us and of your Personal Information that we store, and we make no warranty that your transmissions to us and your Personal Information stored will be 100% secure.
Your privacy when you access third-party websites and resources
Special Features and Programs
Referral service and requesting references
The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform. The Platform also allows you to ask your friends and contacts to write a reference for you, to be published on your Trip Trustees profile.
We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third-party site itself. These messages will be sent by the third-party site, and Trip Trustees does not collect or retain the contact information that is used to send them.
You may also send invitation/request emails via the Platform itself, in which case we will ask you for the contact information to which to send your invitation/request. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your friends and contacts an invitation or request for a reference, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Trip Trustees in response to your referral.
If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.
If you are allowed to join Trip Trustees’ Affiliate Program and you sign up for it, you will have to provide us with certain Personal Information to enable us to provide the Affiliate Program to you.