Privacy Policy - Tour Plan

Last Updated: August 01, 2024

Welcome to the Tour Plan! And thank you for using our platform!

At Tour Plan, we believe that memorable trips start with the peace of mind that comes with having your information safe. By using our services, you entrust us with your personal data, and for this reason, we are committed to ensuring your privacy with the utmost rigor and transparency.

This application and its content are controlled and operated by: CELERE TECNOLOGIA E INOVAÇÃO INOVA SIMPLES (I.S.), a private legal entity registered with the CNPJ under No. 55.093.712/0001-94, located at QUADRA SQSW 304 BLOCO A, AP 404, SETOR SUDOESTE, BRASÍLIA - DISTRITO FEDERAL, CEP 70.673-401, e-mail contact@tourplan.travel, and all rights are reserved to this one.

In accordance with the provision of article 41 of the Brazilian General Data Protection Law, the Tour Plan indicates MARCELLO PEREIRA DE ARAUJO LIMA, cpf 907.871.027-68, Systems Analyst responsible for the Tour Plan, as the person in charge of data processing, and it is possible to contact him through the e-mail contact@tourplan.travel.

This Privacy Policy ("Policy") aims to detail, in a clear and accessible way, how we collect, use, store and share your personal data.

Acceptance of our Policy will be made when you access or use the Tour Plan website, app or services. This will indicate that you are aware of and fully agree with how we will use your information and data.

This Policy is divided as follows to make it easier for you to understand:

I. INFORMATION WE COLLECT

II. WHAT PURPOSE DO WE COLLECT THIS INFORMATION?

III. HOW WILL THE DATA BE DELETED?

IV. UNDER WHAT CONDITIONS AND WITH WHOM MAY WE SHARE YOUR INFORMATION?

V. WHAT RIGHTS DO YOU HAVE IN RELATION TO THE DATA WE COLLECT?

VI. HOW DO WE PROTECT YOUR INFORMATION?

VII. ABOUT PAID SERVICES

VIII. REQUEST FROM AUTHORITIES

IX. UPDATES

X. GOVERNING LAW

This document should be read in conjunction with our Terms and Conditions, available in our application, which contains an overview of our platform. If you have any questions or need to address any matter related to this Policy, please contact us at contact@tourplan.travel.

I. INFORMATION WE COLLECT

The General Data Protection Law (LGPD) defines your personal data as any information that identifies you, directly or indirectly. This includes, for example, your name, CPF, date of birth, address, and even browsing data such as IP and access history.

At Tour Plan, we collect only the data we really need to give you the best possible experience, in a secure and transparent way. See what they are:

  • Personal information: full name;

  • Contact information: e-mail; and

  • Browsing Information: This includes, but is not limited to, traffic data, IP address, location data, duration of activity, operating system and web browser, as well as resources you access.

It is important that, when providing personal data, you or an authorized person only enter true and up-to-date information. The responsibility, in any case, civil and/or criminal, is yours as to the veracity, accuracy and authenticity of the information included.

Tour Plan does not collect personal data nor does it allow the use of the platform and services by minors under 14 years of age. To access or use our website, you must be 18 years of age or older. If you are over 14, but under 18 years old, the use of our website or app must comply with the provisions of article 14 of Law 13.709/2018 (LGPD), and the minor must be under the supervision of their parents or guardians or another responsible adult. If we become aware that a minor has provided us with information without parental or guardian consent, such information will be deleted.

Tour Plan also allows you to connect or log in through third-party services such as Apple. When this occurs, you authorize us, through the explicit acceptance requested in the application login, via Apple, to collect data provided by you in these services, such as: full name, first and last name and email. In this case, your privacy settings will be respected and with your consent to the collection of such data.

a) DATA FROM WHEN YOU USE OUR PLATFORM

In addition to the personal data collected, the following information generated during the use of the Tour Plan is also automatically collected:

  • Access Logs: Tour Plan automatically records access data, including IP address, date and time of access. This data is collected as required by Law 12.965/2014 (Civil Rights Framework for the Internet), and will only be provided to third parties with your express authorization or upon judicial demand.

  • Interactions on the Platform: We collect information about your interactions on the Tour Plan, such as navigation, pages and content accessed or created, searches, participation in surveys or forums, and other activities conducted on the platform.

  • Location Data: The Tour Plan app may collect location data while the device is open, for route establishment and trip planning. The authorization to share your location can be revoked at any time, but this may disable some features of the platform.

  • Payment Data: When you make payments in the app, we store information about the transaction, such as the date, time, amount, and other details, which can be used for fraud prevention purposes, providing a secure environment for your transactions.

  • Cookies: We use cookies, which are text files generated and stored on your browser or device by websites, applications, and online advertisements. Cookies can be used to prevent you from having to log in every time you access the Tour Plan, to remember your preferences and offer you a more personalized navigation, to understand how you use the platform so that we can offer you an even better service, to show you advertisements that are of interest to you, etc.

II. WHAT PURPOSE DO WE COLLECT THIS INFORMATION?

It is worth remembering that here at Tour Plan we value your privacy very much. Therefore, all data and information about you is treated as restricted access information, with the necessary protection provided for by law, and we will only use it for the purposes described herein and authorized by you. Our main goal is to ensure that you can fully utilize the Tour Plan, continuously improving your user experience. In this way, we will use your data to:

  • Full access to the Tour Plan: So you can enjoy all the features of the platform and plan your trips with peace of mind;

  • Important messages: To send you alerts, notifications about updates and support, whenever necessary;

  • Offers and news: To communicate with you about products, services, promotions, news and events that may be of interest to you;

  • Traffic Analytics: To understand how users navigate the Tour Plan and improve the platform continuously;

  • Relevant advertising: To show you ads that are of interest to you, based on your tastes and preferences;

  • Tailor-made services: To adapt the Tour Plan to your needs and offer you the best possible experience;

  • New services and functionalities: To create new features that make your trips even safer and more enjoyable;

  • Combating fraud: To detect and prevent fraud, spam, and other security incidents that may compromise your data;

  • Information verification: To confirm the veracity of the information you provide and ensure the security of the platform;

  • User understanding: To analyze users' behavior and build behavioral profiles that help us improve the Tour Plan;

  • Exclusive features: To allow access to special features of the Tour Plan, according to your needs and profile;

  • Compliance with legal obligations: To comply with applicable laws and regulations.

Our purpose with Tour Plan is to promote road safety by allowing travelers to pre-plan their routes and manage fatigue during trips. By collecting and using your information, we seek to create conditions for a safer and more conscious trip, contributing to the mitigation of incidents or accidents on the roads.

As a result, we may use data for purposes not provided for in this privacy policy, but these will be within your legitimate expectations. Any use of your data for purposes that do not comply with this prerogative will be made with your prior authorization.

Importantly, all information collected is stored solely on your device. Therefore, Tour Plan does not access or be responsible for the integrity of this data in the event of an operational failure of the device, nor does it back up the lost data.

III. HOW WILL THE DATA BE DELETED?

All data collected will be deleted from our servers when you request it, through a free and facilitated procedure, or when it is no longer necessary or relevant for us to offer our services. Deletion will occur except in cases where there is a reason for keeping the data, such as a legal obligation to retain or the need for preservation to protect Tour Plan's rights.

However, please note that despite the deletion request, Tour Plan will not be able to delete your purchase history, as this is managed directly through Apple's App Store platform and also through the platform called RevenueCat. In this way, you are aware that Tour Plan is exempt from this responsibility and that you must observe the provisions of its own Terms of Use and Privacy Policy.

a) MONITORING AND EXCLUSION FOR VIOLATION OF RULES

Tour Plan reserves the right to monitor the entire platform, mainly to ensure that the rules described in our Terms of Use are being observed, or that there is no violation or abuse of applicable laws.

We reserve the right to exclude a user, regardless of the type of user, if this Policy or the Terms of Use are not respected. As we value a good relationship with users, we recognize that they have the right to seek to understand the reasons and even contest them, which can be done by the following email: contact@tourplan.travel.

IV. UNDER WHAT CONDITIONS AND WITH WHOM MAY WE SHARE YOUR INFORMATION?

  • Through this Privacy Policy, you authorize us to share the information we collect with:
    Travel and tourism agencies: To assist you in planning amazing trips, we may share your data with partner agencies. This will allow them to offer you personalized offers and help you organize every detail of your adventure;

  • Groups of travelers: Sharing your data with other participants of the trip allows you to follow the itinerary, stay on top of the news and connect with your fellow travelers;

  • Service and product providers: In order for you to have a complete and safe experience while traveling, we may share your data with companies that provide services such as hotels, tours, car rentals, and others;

  • Hospitality and lodging industries: We may share your data with hotels and B&Bs so that you receive personalized offers and make the most of your stay.

These third parties may be located both in Brazil and in other countries depending on your trip and Tour Plan's operation. The sharing of information will occur anonymously, whenever possible, in order to preserve your privacy.

In cases where there is a need for international transfer of personal data to other countries, Tour Plan undertakes to close agreements only with suppliers and users who adopt security measures and good practices compatible with the level of protection established by Brazilian law, as regulated by the National Authority for Personal Data (ANPD).

In the absence of specific regulation, we are committed to working only with companies and users adhering to other data protection standards, such as the European GDPR or American CCPA; or with companies whose contracts contain specific clauses for transfers with the Tour Plan, as well as restricting the transfer only to what is strictly necessary for the fulfillment of the obligations assumed with you.

a) OTHER SHARING

Tour Plan allows other companies and ad networks to advertise on our platform, through different technologies. Therefore, you may eventually receive ads, content, and links displayed directly in your app, according to your interests and behaviors on our platform or other services with which you interact. To this end, data may be shared between Tour Plan and these other companies, mainly unique identifiers, IP addresses, cookies and java scripts, which can be used to measure the effectiveness of online advertising.

You hereby expressly authorize such sharing. However, Tour Plan is not responsible for the acts, advertisements and content generated by our commercial partners and ad networks. This Policy does not apply to them, as Tour Plan does not control them. We suggest that you access and read the privacy policies of the companies with which you may interact.

All data, information and content about you may be considered active in the case of trades in which the Tour Plan is a part. Therefore, we reserve the right to include your data among the company's assets if it is sold, acquired or merged with another.

You hereby agree and are aware of this possibility.

Tour Plan reserves the right to provide your data and information about you, including your interactions, if legally requested, to ensure compliance with national laws, or if you expressly authorize it.

V. WHAT RIGHTS DO YOU HAVE IN RELATION TO THE DATA WE COLLECT?

You can always choose not to disclose your data to us, but please keep in mind that some of this data may be necessary to use the functionalities of our applications. Regardless, you will always have rights related to privacy and the protection of your personal data. Thus, below we summarize all the rights you have under Brazilian sectoral laws regarding data protection and the General Data Protection Law ("LGPD"), which are:

  • Right of access: This right enables you to request and receive a copy of the personal data we hold about you;

  • Right to rectification: This right allows you, at any time, to request the correction and/or rectification of your personal data, if you identify that some of it is incorrect. However, in order to make this correction, we will have to check the validity of the data you provide us. You can directly rectify some of your personal data by emailing: contact@tourplan.travel;

  • Right to erasure: This right enables you to ask us to delete the personal data we hold about you. All data collected will be deleted from our servers when you request it or when it is no longer necessary or relevant for us to offer you our services, unless there is any other reason for its maintenance, such as any legal obligation to retain data or the need to preserve it to protect the rights of the Tour Plan. To change your personal information or delete it from our database, simply send an email to: contact@tourplan.travel;

  • Right to object to processing: You also have the right to object where and in what context we are processing your personal data for different purposes. In certain situations, we may demonstrate that we have overriding legitimate grounds to process your data, which override your rights, if, for example, it is essential for the provision of our applications;

  • Right to request anonymization, blocking, or erasure: This right allows you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) where you need the data to be kept even if we no longer need it as necessary to establish, exercise or defend legal claims; or (c) if you have objected to our use of your data, but in this case we need to verify whether we have overriding legitimate grounds to use it;

  • Right to portability: We will provide you, or a third party you have chosen, with your personal data in a structured, interoperable format;

  • Right to withdraw your consent: You have the right to withdraw your consent in relation to the terms of this Privacy Policy. However, this will not affect the lawfulness of any processing carried out previously. If you withdraw your consent, we may not be able to provide certain services;

  • Right to review of automated decisions. You also have the right to request the review of decisions made solely on the basis of automated processing of your personal data that affect your interests, including decisions aimed at defining personal, professional, consumer and credit profiles and/or aspects of your personality.

a) REQUEST FOR ACCESS AND EXERCISE OF RIGHTS

To ensure that your personal data is only accessed by you or those who have the right, we may need to request specific information from you to confirm your identity. This security measure aims to protect your data from unauthorized access.

We may contact you to ask for more information related to your request in order to expedite our response. We commit to responding to all legitimate requests within five (5) business days. However, if your request is particularly complex or if you have made multiple requests, we may need a longer timeframe. In this case, we will keep you informed of the progress of your request.

If you have questions about these issues or how to exercise your rights, please contact us at contact@tourplan.travel.

VI. HOW DO WE PROTECT YOUR INFORMATION?

All your data is of restricted access and only people with the proper authorizations will have access to it. Any use of these will be in accordance with this Policy. Tour Plan will make all reasonable market efforts to ensure the security of our systems and your data. Our servers are located in different locations to ensure stability and security, and can only be accessed through previously authorized communication channels.

All your information will be, whenever possible, encrypted, if it does not make it impossible to use it by the platform. At any time you can request a copy of your data stored in our systems. We will keep the data and information only as long as they are necessary or relevant for the purposes described in this Policy, or in case of periods predetermined by law, or as long as they are necessary for the maintenance of the legitimate interests of Tour Plan.

Tour Plan considers your privacy extremely important and will do everything in its power to protect it. However, we cannot guarantee that all data and information about you on our platform will be free from unauthorized access, especially if there is improper sharing of the credentials necessary to access our application. Therefore, you are solely responsible for keeping your access password in a safe place and sharing it with third parties is prohibited. You undertake to notify Tour Plan immediately, through a secure means, of any unauthorized use of your account, as well as unauthorized access by third parties to it.

In addition, due to the very nature of the Internet, there is a risk that malicious third parties may improperly access the information stored on our systems. If this occurs, we are responsible within the limits provided for in the applicable current legislation, and users will be informed about the problem and the measures adopted by the company, as well as guidelines to ensure the security of the account.

The use of any device, software or other resource that may interfere with the activities and operations of Tour Plan, either through the website or through other systems or databases, is prohibited. If any intrusion, attempt, or activity is identified that violates or contravenes the laws of intellectual property rights and/or the provisions stipulated in this Policy and/or applicable laws in force, including the LGPD, the responsible party will be subject to the applicable sanctions, whether they are in law or provided for in this document. The person responsible must also indemnify for any damages caused.

VII. ABOUT PAID SERVICES

Through our platform, you can access third-party websites or payment platforms to make payments for services provided. Tour Plan does not have access to your bank details provided in these transactions. Therefore, you declare to be aware that Tour Plan does not assume responsibility for any matter related to this situation. In addition, we recommend that you review the privacy policies of these third parties before providing any personal or financial information.

VIII. REQUEST FROM AUTHORITIES

Tour Plan is committed to cooperating with the competent authorities and third parties to ensure compliance with the laws, including in terms of the protection of industrial and intellectual property rights, fraud prevention, protection of personal data, among others. In this context, we will only disclose your personal data upon requests from competent judicial or governmental authorities, within the scope of investigations and proceedings conducted by them, provided that there is no legal prohibition establishing confidentiality.

IX. UPDATES

Tour Plan may update this Privacy Policy by posting a new version on the platform. If any modification is made that may affect your rights, increasing your obligations, Tour Plan will notify you by email or by a notice on the platform.

You should periodically review the Privacy Policy to be up to date on all news. Your continued use of our services after posting or, as the case may be, after you provide notice of changes to this Privacy Policy, implies that the processing of your Personal Data will take place in accordance with the updated Privacy Policy. If you do not agree with any of the changes, you can contact us via email contact@tourplan.travel or delete your account, as appropriate.

X. APPLICABLE LAW AND GENERAL PROVISIONS

This document is governed by and shall be construed in accordance with the laws of the Federative Republic of Brazil. The Court of the District of Brasília/DF is hereby elected as the competent one to settle any issues that may arise from this document, with express waiver of any other, however privileged it may be.

This Privacy Policy is available in the following languages: Portuguese, English, Spanish, French, Italian, and German. In case of any divergence of interpretation between the translations, the text in Portuguese shall prevail.