Apex Privacy Policy

Introduction

Last Updated in August 2017

Apex-turism.pl is owned and operated by Apex – Transport Sh.p.k. oddział w Polsce Sp. Z o.o.("Apex" or "we"), a company registered in Poland. The following Privacy Policy describes how we as a data controller collect, use, disclose, and otherwise process personally identifiable information that we collect about individuals ("Personal Data") in connection with the services available from Apex through the website located at www.apex-turism.pl ("Site"). References to the Site are deemed to include derivatives thereof, including but not necessarily limited to mobile websites and applications. By visiting the Site, you are consenting to the collection, use, disclosure and processing of your Personal Data as described in this Privacy Policy.

On occasion, Apex may revise this Privacy Policy to reflect changes in the law, our Personal Data collection and use practices, the features of our Site, or advances in technology. If we make revisions that change the way we collect or use your Personal Data, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. Apex will also prominently post such material changes prior to implementing the change. If you do not agree with any changes or modifications to the Privacy Policy, please do not continue using the Site. You will be deemed to have consented to any modification of the Privacy Policy when you use the Site after the effective date of the modification.

Information We Collect

We collect Personal Data about you that you provide to us when using the Site. Personal Data may include your name, address, phone number, credit card details, e-mail address, accommodation name, accommodation location and/or length of stay. In addition to this, when using our Site, even if you do not make a reservation, we may collect other certain information, such as your IP address, geographic data, your nationality and password, search preferences related to specific searches, which browser you’re using, and information about your computer’s operating system, application version, language settings and pages that have been shown to you. If you are using a mobile device, we might also collect data that identifies your mobile device, device-specific settings and characteristics and latitude/longitude details, and if you participate in an Apex program there may be limited additional data that we may collect from the accommodation about your stay, for example, a list of charges (anonymized) as part of the Apex Reception program. When you make a reservation, our system registers through which means and from which websites you have made your reservation.

Pre-reservation chat support: in certain circumstances we may provide Apex customers with pre-reservation chat support. The purpose of this support is to help customers with any pre-reservation questions that they may have but should a customer decide to proceed with the reservation on the Site, the customer will be expected to follow the normal reservation procedure him or herself. As such, we will generally not ask customers for any Personal Data e.g. no credit card numbers or customer email addresses but in case any information a customer provides to Apex is deemed by law to be Personal Data or if the customer decides to disclose Personal Data to Apex or where such Personal Data is required to be collected in order to provide pre-reservation chat support, then this Privacy Policy will apply to such Personal Data collected.

Protecting Your Personal Data

To prevent unauthorized access, we maintain reasonable physical, electronic and organizational procedures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. To protect credit card transactions, Apex currently uses Secure Socket Layer technology to encrypt credit card information during transit.

How We Use the Information We Collect– Credit Card on File

i) General Use: We use Personal Data and other information collected through the Site to (a) register you with the Site and create your user account, (b) provide you with the requested services (mainly to process and confirm your reservation with the accommodation provider or other supplier) after verifying your credentials, (c) provide you with information about our services on the Site or on other websites and to communicate with you to the extent necessary to provide such requested services, (d) build features that will make the services available on the Site easier to use, (e) for an improved user experience, internal training and general optimization purposes, (f) for the detection and prevention of fraud and other illegal or unwanted activities or (g) contact you in case there is any issue with your booking. This includes faster purchase requests, better customer support and timely notice of new services and special offers.

ii) Marketing Activities & Reminders: We also use your information for marketing activities, as permitted by law. For example:

·  When you make a reservation with us, set up a user account, complete or enter details into a booking form, or provide us with your contact details we may use your contact information to send you news of products and services relevant and useful for travellers. With your consent – if consent is required under local law – we may also send you other regular newsletters by email. You can opt out, or unsubscribe, from marketing communications at any time using the "Unsubscribe" link in each newsletter or communication, or you can administer your subscriptions through your account (if you've created one).

·  Based on the information you share with us, individualized offers may be shown to you on the Site, in mobile apps or on third-party websites, including social media sites. These might be offers that you can book directly on the Site, or third-party offers or products we think you might find interesting.

·  If you have not finalized a reservation online, we may send you a reminder to continue with your reservation. We believe that this additional service is useful to you because it allows you to carry on with a reservation without having to search for the accommodation again or fill in all the reservation details from scratch.

·  Please see the section below titled “Cookies, Page Tags and Data Use” on how we use this data for advertising purposes.

Please note that the confirmation emails and text messages sent after your booking, as well as the guest review emails sent after your departure, are not marketing messages. These messages are part of your accommodation reservation process. Respectively, they contain information for you to check in at your booked accommodation, and tools to optionally rate that accommodation after your stay. You will continue to receive them, even if you have opted out of our marketing messages. Similarly, opting into receiving Price Alerts will not affect any other choices you have made regarding receiving communications from us. If you elect to receive Price Alerts, you will be able to opt out of receiving the same by clicking on the “turn off price alerts” or a similar message found in the Price Alert sent to you.

Sharing Your Personal Data

Apex may share your Personal Data with suppliers such as accommodation properties, third party accommodation suppliers like Booking.com and other third parties we appoint to perform services on our behalf, such as third party loyalty programs, web hosting, data analysis, marketing (also on websites of such third parties), customer care, credit card and payment services and related services.. All such third parties will be under an obligation to maintain the security and confidentiality of the Personal Data, and to process the Personal Data only in accordance with our instructions.

As mentioned in our Terms of Use and in order for Apex to offer the best in class inventory to customers, Apex may source accommodation from third party accommodation suppliers and as a result. Further, and for the same purposes, such third party accommodation suppliers may also share your Personal Data to the same extent with the relevant accommodation that it has contracted with directly. In such case Apex will continue to provide you with reservation and other support services in respect of such accommodation that you have reserved on an Apex platform.

In some cases, Apex may require that you transact directly with a third party to obtain services, or when you use the Site to reserve an accommodation room or obtain another service.

When you make a reservation on one of our business partners’ websites or apps, certain personal data that you give them will be forwarded to us. If customer service is provided by the business partner, apex will share details relevant to your reservation with the business partners (as and when needed) in order to provide you with appropriate and efficient support. When you make a reservation through one of our business partners’ websites, the business partners may receive certain parts of your personal data related to the specific reservation. This is for their own internal purposes (such as analytical purposes) and, if requested by you, for the administration of loyalty programs or marketing.

When you make a reservation on a business partners’ website, please also take the time to read their privacy policies if you wish to understand how these business partners may process your personal data. When we offer you other travel-related products and/or services, your information may be shared with the offering business partners to handle or administer your request. For fraud detection and prevention purposes and as strictly necessary, we may also exchange information about our users with business partners.

Save for disclosures mentioned in this Privacy Policy or as required or permitted by law in any relevant jurisdiction as mentioned below and the disclosure of your Personal Data and information required for completing your booking with the relevant accommodation of your choice and the sharing of certain Personal Data with selected partners where relevant (your details will be used for reporting and analysis purposes only), we will not disclose your Personal Data to third parties without your consent. However, we reserve the right to disclose your Personal Data to our affiliated (group) companies (in and outside your home country), including our affiliated (group) companies' employees and our trusted agents and representatives who have access to this information with our permission and who need to know or have access to this information to perform the service requested by you (including customer services) and internal (audit/compliance) investigations.

Apex may, in compliance with applicable law, disclose Personal Data to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose Personal Data to enforce or apply the terms and conditions applicable to our services or to protect the rights, property or safety of Apex, our users or others.

In the situations described above, the recipient of the Personal Data may be located in a jurisdiction that may have different standards of data protection compared to the laws in your home jurisdiction.

Our Policy Concerning Cookies, Page Tags and others

By visiting our Site, you consent to the usage of cookies, tags, pixels, software development kits (“SDKs”) and application program interfaces (“APIs”) as described below. Our Site uses session and persistent cookies as well as page tags to collect and store certain information about you. A cookie is a small piece of data that is sent to your computer from the Site and stored on your computer’s hard drive. A page tag is a piece of code which reads and writes cookie data. Cookies or page tags may be from Apex and/or third party vendors we have chosen to work with. Session cookies disappear from your computer when you close the browser. Persistent cookies remain on your computer after the browser has been closed, but can be deleted at any time through your browser settings. The use of these cookies and page tags may vary, and are described in the appropriate sections below.

Opting Out

If you want to prevent your browser from accepting cookies, if you want to be informed whenever a cookie is stored on your computer or if you want to delete cookies from your computer, please make the necessary changes in your Internet browser settings, typically under the sections “Help” or “Internet Options”. If you disable or delete cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you will be required to re-enter your log-in details. Please also note that opting out of a third party cookie (see below) does not mean that you will no longer receive or be subject to online advertising or marketing analysis. It means that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. Please also note that if you clear all cookies on your browser, or use a different browser or computer, you will need to complete the opt-out procedure again.

Cookies, Page Tags and Data Use

Apex Cookies

Apex uses a session cookie to keep you logged in throughout your visit to the Site.

Apex uses persistent cookies to "personalize" the Site for each user by remembering information about the user's visit to and activities on the Site, e.g., the language you selected, or your log-in details so that you do not need to re-enter them at your next visit to the Site.

Apex also uses persistent cookies or page tags to analyze your surfing behavior and your visit to the Site enabling us to improve the Site and our services and to tailor our advertising (via email, on our Site, and on other websites) according to the interests of our users. Such cookies and page tags gather information about the pages you visited on the Site and the searches you performed.

Website analytics

Third party companies may use persistent cookies to analyze your surfing behavior on and your visit to this Site as well as other web sites enabling us to improve the Site and our services. Website analytics platforms may be used to collect unidentifiable information for reports such as impression reporting, demographic reporting and interest reporting. To opt out of collection of information by third parties for analytic purposes, please click on one or more of the third party links in the above “Opt Out Tools” section.

Third Party Cookies, Page Tags and Hashed Data

Our third party advertising companies may place cookies or page tags on some of the pages you visit on the Site. These cookies or page tags are designed to collect non-personally identifiable information in order to analyze your interests and searches when visiting our Site and to serve you advertisements specifically tailored to your interests and searches when you are visiting our Site or other websites or when using mobile applications. The non-personally identifiable information collected through cookies and page tags may be shared with other third parties for purpose of managing and targeting advertisements and for market research analysis. In addition, we may share one-way hashed (undecipherable) data with third party vendors using advertisement targeting products. Such third party vendors typically use hashed device identifiers to link such identifiers to their own users and to serve custom ads based on users' prior visits to the Site. As a consequence, third party vendors may show our and/or our partners’ads on other websites or mobile apps.

Advertising

Apex may use a combination of the above cookies and page tags to tailor your experience with our Site, our mobile application and our ads to your preferences. We use display and search remarketing to tailor ad content for a better experience.

Where other advertising may not require the use of cookies or page tags, third party data is used to determine when an Apex ads will be shown.

Apex takes reasonable efforts to not collect, and to prevent the use of, personally identifiable information in third party advertising solutions, unless you have authorized this. To opt out of collection of information by third parties for advertising purposes, please click on one or more of the third party links in the above “Opt Out Tools” section.

Advertising and content on other websites

Apex uses 3rd party tools to distribute ads on a variety of websites. Apex neither supports nor endorses the goals, causes or statements of the websites which display our advertisements.

Information from other partners

On occasions affiliated entities, business partners or other third party providers may share information with us. One example, is if you access or sign in to our Site through social media such as Facebook, we may collect information from you such as your user name, image, list of friends and other information made available to us via such services. In general, the ability to provide such information is through the service provider themselves and dependent upon using the service provider’s single sign in application or other similar service. In general, we may work with our partners to use this information to improve and personalize your use of our Site in accordance with this policy.

We have partnered with Facebook to provide personalized content on Apex for members of Facebook. If you are a Facebook and Apex user and you have signed into Apex via the Facebook single sign on feature, then our Site will be personalized for you to display information/stays of your Facebook friends at accommodations in the past and also future stays at accommodations bookable through the Site, that is unless you have opted out of the same (see more information below). The information that may be displayed include name, the name of the accommodation, the data of stay, the location of the accommodation, your review of past accommodation, the hotel room and price of the hotel room. (“Stay Information”), and such information may be shown and personalized to you on the search pages of the accommodation on the Site, and the search calendar amongst other places. Further, your Stay Information will also be displayed to your Facebook friends who are also Apex customers and who have signed in through the Facebook single sign on feature on the Site, as displayed on their search pages described above within the Site and updated each time you make a booking through Apex.

How to opt out: Apex has made it simple for you to opt out of this feature at any time by: toggling “no” on i) the thank you page after you make a booking, and ii) in your manage my booking page on the Site. Further, if you need help to opt out you may contact our customer experience team at any time.

How You Can Access or Change Your Personally Identifiable Information

If you wish to update any Personal Data you have previously provided, or to exercise any right of access, correction, rectification, deletion, or opposition to the processing of your Personal Data that you may have under applicable law, please contact us via our Customer Support page. To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data. Any request to access your Personal Data will be answered within a reasonable timeframe. You may also object to the processing of your Personal Data for purposes of advertising and market and opinion research. We reserve the right to charge a reasonable fee for such access in accordance with applicable laws.

If you wish to contact the Apex Data Protection Officer or our customer service representatives about privacy issues via email, you may send an email to:

norelpy@apex-turism.pl

Mobile Devices

We have free apps for a variety of mobile devices and use versions of our regular website that have been optimized for mobile and tablet browsing. These apps and mobile websites process the personal details you give us in much the same way as our website does – and they also allow you to use location services to find accommodations nearby. With your consent, we may send you push notifications with information about your reservation, potential future stays or as part of any Apex programs that you participate in, including coupons. You may grant us access to your location data or contact details in order to provide services requested by you. When you upload a picture from your mobile device, your picture may also be tagged with your location information. Please read the instructions of your mobile device to understand how to change the settings and enable the sharing of such data or the receipt of (or opt out of receiving) push notifications (including SDK and push token data). Different device operating systems may have different default settings, so please familiarize yourself with such settings governing push notifications.

Cross Device Tracking

We may make use of something known as cross-device tracking in order to optimize our services and marketing activities. This may be done with or without the use of cookies. For more information about cookies and other similar technologies, please see our Cookie paragraph above. With cross-device tracking, Apex is able to track user behaviour across multiple devices. As part of cross-device tracking, Apex may combine data collected from a particular browser or mobile device with another computer or device linked to the computer or device from which the data was collected.

In order to optimize the content of Apex communications to you, Apex combines the searches and reservations you have made from different computers and devices. If you do not want Apex to combine such data for its optimization of communications to you please unsubscribe from the Apex communications i.e. the newsletter.

Personalized advertisements shown to you on other websites or in apps, can be offered based on your activities on linked computers and devices. By opting out of the NAI behavioural advertising program (see in our Cookie paragraph above), you can opt out of cross-device tracking for advertisement purposes. You should know that logging out of your user account will not actually mean that you opt out of personalized advertisements.

We may also use cross device tracking to optimize the content you view on our websites and/or apps. By opting out of the NAI behavioural advertising program (see in our Cookie paragraph above) and by logging out of your device or computer, you can opt out of cross-device tracking for these purposes.

A Special Note About Minors

Persons under the age of 18 are not eligible to use the accommodation reservation services on our Site. Minors can normally accompany their parent(s) or legal custodian(s) who have booked an accommodation, except where indicated otherwise in the accommodation property policies.

Language

This Privacy Policy has originally been drawn up in the English language. Translations in other languages are available for your convenience. In case of conflict between the English language version and a translated version, the English language version shall prevail.

Terms of Use

Please consult the Apex Terms of Use for more details on using our Site. This Privacy Policy forms an integral part of our Terms of Use.