Last updated: November 23, 2023

This Privacy and Cookie Policy (“Privacy Policy”) has been prepared by Evora Ventures LTD (“Vayabo”, “We”, “Us” or “Our”), the Data Controller registered with the Information Commissioner’s Office (“ICO”), located at Chase Road, A Block, Unit 361, 2nd Floor, London, United Kingdom, N14 6HF, and registered with the Companies House under the registration number 15038540.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your Personal Data when you use the Services and tells you about your privacy rights and how the Law protects you. We consider your privacy to be of utmost importance and we will always hold and process your information in accordance with data protection laws.

 

A. Interpretation and Definitions

1. Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

 

2. Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for you to access Vayabo App, Vayabo.com and Services.

Application refers to Vayabo App, the software program provided by the Company.

Business refers to the Company as the legal entity that collect your personal information and determines the purposes and means of the processing, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing.

Company refers to EVORA VENTURES LTD, for the purpose of the Law, the Company is the Data Controller.

Cookies refers to the small files that are placed on your computer or device when you visit Our Application or Website. Those are used to make our Application and Website work or to work more efficiently, as well as to provide reporting information and to help personalize your experience and remembering your preferences. On the other hand, with your explicit consent to the processing of cookies for marketing purposes, We may use cookies for analytical or marketing purposes.

Content refers to content such as text, images, or other information that can be posted, uploaded, linked to, or otherwise made available by you, regardless of the form of that content.

Country refers to United Kingdom.

Data Controller, for the purposes of the Law, refers to the Company, EVORA VENTURES LTD, as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Data Processor, for the purposes of the Law, a natural or legal person that processes Personal Data on behalf of a Data Controller as instructed by the Data Controller.

Data Subject, for the purposes of the Law, refers to an individual whose Personal Data is being collected, processed, or stored by a Data Controller or Data Processor.

Device means any device that can access the Application and Services such as a computer, a cellphone, or a digital tablet.

GDPR refers to EU General Data Protection Regulation.

Law refers to 2018 UK Data Protection Act, UK GDPR, EU General Data Protection Regulation and any other applicable data protection legislation.

Personal Data is any information that relates to an identified or identifiable individual.

Services refers to the services provided by Vayabo through the Vayabo App or Vayabo.com or both.

Service Provider refers to third-party companies or individuals employed by the Company, to provide the services to the Company.

Third-party API Services refers to any website or any social network website which a User can access through Vayabo App or Vayabo.com for various purposes, including but not limited to booking accommodations, flights, tours, or accessing additional functionalities not directly provided by Vayabo App or Vayabo.com. These third-party services are operated independently and are not under Our control. When you choose to utilize these services through Vayabo App or Vayabo.com, you may be directed to the respective third-party platforms.

Vaya (Itinerary Planner), refers a feature in Vayabo App or Vayabo.com, that allows Users to plan and organize their itineraries. Users can create, edit, and share their itineraries, including accommodation, events, activities, and restaurants. Vaya is designed to enhance the User experience and facilitate collaborative planning.

Website refers to Vayabo.com, accessible from www.vayabo.com

You or User refers the individual accessing or using the Vayabo App or Vayabo.com.

 

B. Collecting and Using Your Personal Data and Purposes of Processing

Mainly, We collect and use the Personal Data you provide to us. But in certain circumstances, we may collect your personal data from third parties. Please find below comprehensive details on our activities regarding the collection and processing of Your Personal Data, as well as the processing purposes.

 

1. On Registration

When you register on Vayabo App to create your User Account, we will request your email address and ask you to generate a unique password. The unique password you create during the registration process is securely encrypted, ensuring that even We cannot access or view your password. This information is processed for the purpose of creating and maintaining your User Account, ensuring the security of your account, and enabling you to access our Services.

If you choose to register on Vayabo App or Vayabo.com through Google or Apple, We will process your email address and profile photo obtained from Google or Apple. This information is processed to facilitate a seamless registration process and personalize your User experience.

The Services are intended for Users who are at least 16 years of age. People under the age of 16 may only use the Services with the consent of a parent or guardian.

 

2. When You Sign into Your Account

When you sign into your Account, depending on your sign-in preferences, We may process your email address and unique password each time. Alternatively, We allow you to create an Account and log in to use the Services through the third-party social media services. If you prefer to sign in through Google or Apple, we will process your email address and profile photo retrieved from your Google or Apple account. These processes are essential for User authentication, ensuring the security of your account, and providing a convenient sign-in experience.

 

3. Profile Settings

In addition to the information, We request during the registration process, We may process your full name, phone number, address, and profile photo if you choose to provide additional information through your profile settings. This information is processed to enhance your User profile, personalize your experience, and enable features such as connecting with other users.

We may request access to your camera or photo library if you wish to upload a photo for your profile. Access to your camera or gallery is solely used for the purpose of allowing you to customize your profile picture and enhance your profile.

We may also request access to your Device’s contact list to enhance your experience on our app. This access allows you to easily find and follow your contacts who are also using Our Application. Rest assured that we respect your privacy, and access to your contact list is solely used for the purpose of helping you connect with your friends and contacts within Our Application. We do not store or misuse your contact information for any other purposes.

 

4. When You Share Posts on Your Feed

Our Service allows you to post Content and share on your feed. You are responsible for the Content that you post on Vayabo App or Website, including its legality, reliability, and appropriateness under the Terms and Conditions.

In line with the ‘Privacy by Design’ and ‘Privacy by Default’ principles, your feed on the Vayabo App is set to private by default when you register your Account. However, We provide you with the option to make your feed public if you choose to do so. When you make your feed public, all Users of the Vayabo App will be able to see your posts. We believe in giving you control over your privacy settings.

 

5. Creating Vaya’s

Depending on the Vaya (Itinerary Planner) you create within Vayabo App or Vayabo.com, We may process various itinerary related details, including, dates of your travel, hotel reservations, flight or other travel information, restaurant reservations. All these itinerary-related details are processed with the primary purpose of facilitating your Vaya, ensuring a seamless experience, and offering personalized recommendations tailored to your specific journey.

When you choose to share your Vaya with other Users on Vayabo App or Vayabo.com, We may also process identity information of the individuals planning the itinerary with you. This data is used to facilitate collaboration and communication among travelers.

 

6. When You Share or Designate a Co-organizer for Your Vaya

When you wish to share your Vaya, We will transfer the Personal Data you provided to Us during the planning process to the Users you have selected. This allows for collaborative planning and communication with your chosen co-organisers.

 

7. When You Write a Blog

When you write a blog post on Vayabo App or Vayabo.com and share it on your feed, We collect and process the Content you provide to make it visible to other Users. This includes the text and media you include in your post, as well as any interactions from other Users, such as likes.

 

8. When You Get in Touch with Us

If you need to get in touch with Our customer service team or reach out to Us in a different way (such as social media) We’ll collect information from you there, too. This applies whether you are contacting Us with feedback or asking for help using Our Services.

All information collected when you reach out to Our customer service team or engage with Us through various channels, including social media, is utilized to assist you and manage your requests effectively and as well as to improve Our Services.

 

9. Location Data

You can decide to allow Vayabo.com to see your current location details. If you grant Vayabo App or Vayabo.com access to your current location while browsing on your mobile device, We employ this data to enhance your experience. This helps Us to give you the best possible Services and experience by, for example, showing you Our city guides, suggesting the nearest restaurants or attractions to your location, or making other tailored recommendations.

Please be informed that the location data we process is strictly limited to what your device permissions allow. We do not independently determine the precision of the location data; rather, we utilize the data available based on your device’s settings and allowances.

 

10. In-App User Behaviour

We believe in making your travel experiences as unique as you are. To achieve this, Vayabo App or Vayabo.com collects valuable insights through In-App User Behaviour data. This data encompasses a comprehensive view of your interactions within the Application or Website, such as your likes, the places you favourited, and other preferences. By doing so, we can offer you tailored suggestions and recommendations that align with your interests and desires. Whether you’re seeking accommodation options, restaurant recommendations, upcoming events, or must-visit attractions, our personalized approach ensures that you receive suggestions that resonate with your travel style. Your stored travel history, preferences, and reviews play a crucial role in shaping these recommendations, making your journey with Vayabo a truly personalized and unforgettable adventure.

 

11. Ensuring a Smooth User Experience: Exception Information

In Our pursuit of maintaining a seamless User experience, We rely on Firebase Crashlytics for crash and performance analysis. For diagnostic purposes, the following data is collected:

Crash Trace: Stack traces of the Application at the time of the crash.

Exception Information: Type, reason, and address of the exception leading to the crash.

Application State: Information regarding the application’s foreground/background state, memory usage, disk space, and running threads.

Device and System Information: Details such as the make, model, and version of the operating system, battery level, screen resolution, total memory, available storage, orientation, and whether the device is jailbroken.

Log Information: Logs generated by the app leading up to the crash, encompassing print statements and log messages.

Custom Keys: App-specific data that may aid in diagnosing crashes.

Previous Crashes: A log of previous app crashes in previous sessions.

Network Connectivity: Whether the device was online or offline at the time of the crash.

Session Information: Data related to user sessions, including session duration and time elapsed since the last crash.

Firebase is an analytics service provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

We also encourage you to review the Google’s policy for safeguarding your data:  https://support.google.com/analytics/answer/6004245

For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or apps webpage: https://policies.google.com/technologies/partner-sites

Please note that this information is not stored by US, but is provided as a comprehensive report by Google. Users can access this data by visiting Google’s website, ensuring transparency and user control over the diagnostic information. We prioritize your privacy and the continuous improvement of our application’s performance.

 

12. Legal Purposes

In certain cases, We may need to use your Personal Data to handle and resolve legal claims and disputes, for regulatory investigations and compliance or to comply with lawful requests from law enforcement.

 

13. Tracking Technologies and Cookies

Cookies are the small files that are placed on your computer or device when you visit Vayabo App or Vayabo.com. Those are used to make Our Application and Website work or to work more efficiently, as well as to provide reporting information and to help personalize your experience and remembering your preferences. On the other hand, with your explicit consent to the processing of cookies for marketing purposes, We may use cookies for analytical or marketing purposes.

We use both first-party and third-party cookies, as well as similar tracking technologies, to optimize Our Services.

 

Types of Cookies:

First-Party and Third-Party Cookies: First-party cookies are served directly by Us, while third-party cookies come from trusted partners, including social media, advertising, and security providers.

Session and Permanent Cookies: Session cookies exist only until you close your browser, while permanent cookies remain on your device after closing the browser, but We keep their lifespan limited for security.

 

How We Use Cookies:

Cookies are employed to collect information such as: IP address, device id, viewed pages, browser type, browsing behavior, operating system, timestamp, interaction with content, response to advertisements, referring urls and features and activities on Vayabo App or Vayabo.com.

These technologies enable Us to recognize you as a User across devices and platforms and serve you better.

Cookies fall into three categories: functional cookies, analytical cookies, and marketing cookies.

Functional Cookies: Essential for Vayabo App and Vayabo.com functionality, including security features, language settings, and User preferences. These must be enabled for you to use Our Services effectively.

Analytical Cookies: Help Us understand how Users interact with Vayabo App and Vayabo.com, allowing Us to improve our services, website, and apps. This includes evaluating the effectiveness of ads and understanding User behavior.

Marketing Cookies: Used by Vayabo App and Vayabo.com to create interest profiles based on your online activity. This helps Us display personalized content and advertisements both on Vayabo App and Vayabo.com.

These cookies categorize you based on your interests and browsing behavior, enabling Us to show relevant travel ideas and accommodations.

The table below explains the cookies we use and why.

Cookie Name Purpose / Description
WordPress Default System Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Complianz Plugin Cookies This website uses the Privacy Suite for WordPress by Complianz to collect and record Browser and Device-based Consent. For this functionality, your IP address is anonymized and stored in our database. This service does not process any personally identifiable information and does not share any data with the service provider. For more information, see the Complianz Privacy Statement.
LiteSpeed Cache Plugin Cookies This site utilizes caching in order to facilitate a faster response time and better user experience. Caching potentially stores a duplicate copy of every web page that is on display on this site. All cache files are temporary, and are never accessed by any third party, except as necessary to obtain technical support from the cache plugin vendor. Cache files expire on a schedule set by the site administrator, but may easily be purged by the admin before their natural expiration, if necessary. We may use QUIC.cloud services to process & cache your data temporarily.Please see https://quic.cloud/privacy-policy/ for more details.
Google Analytics _ga To store anonymized statistics. Records a particular ID used to come up with data about website usage by the user.
Google Analytics _ga_# To store anonymized statistics. Used to distinguish individual users by means of designation of a randomly generated number as client identifier, which allows calculation of visits and sessions.
wpEmojiSettingsSupports To store browser details. Please see https://cookiedatabase.org/cookie/wordpress/wpemojisettingssupports/ for more details.
Elementor To store performed actions on the website. Please see https://cookiedatabase.org/cookie/elementor/elementor/ for more details.

You can manage your cookie preferences through your browser settings.

You can change your cookie preferences at any time by clicking on the [*] icon on Vayabo App and Vayabo.com. You can then adjust the available sliders to “On” or “Off”, then clicking “Save and close”. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Find out how to manage cookies on popular browsers:

Google Chrome

Microsoft Edge

Mozilla Firefox

Microsoft Internet Explorer

Opera

Apple Safari

To find information relating to other browsers, visit the browser developer’s website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

 

C. Transfer of the Personal Data

We may share your personal information in the following situations:

Third-Party API Services: If you choose to utilize third-party API services such as booking reservations, We may share your Personal Data with the relevant third-party providers, such as booking platforms, to facilitate your booking and enhance your travel experience. Rest assured that we will always seek your explicit consent before sharing your data in such situations.

Service Providers: In certain circumstances, We may share your Personal Data with our trusted service providers who assist Us in delivering Our Services. It’s important to note that any data shared with these providers will be limited and proportionate to the specific service they are rendering on our behalf. We also ensure that these Service Providers commit to stringent data protection standards and follow secure data transfer protocols to safeguard your information.

Legal and Governmental Requests: We may disclose your Personal Data to courts, government agencies, or other judicial and governmental bodies when required by law or in response to their official requests. This disclosure is made to comply with legal obligations and protect the rights, safety, and integrity of Our Company, Website and Application.

Sharing with Other Users: If you choose to share your Posts or Vaya’s with other Users or authorize another User as a collaborator, your Personal Data will be shared with the authorized User(s). On the other hand, if you wish to make your feed public, all Users of the Vayabo App will be able to see your posts.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

D. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

E. Security of Your Personal Data

We take the security of your Personal Data with the utmost seriousness. We have implemented robust measures to safeguard your information, ensuring its confidentiality, integrity, and protection against unauthorized access or disclosure. Here’s how We prioritize the security of your Personal Data:

Data Encryption: We employ industry-standard encryption protocols to protect your data during transmission between your Device and Our servers. This ensures that your Personal Data remains confidential and secure during online interactions with Vayabo App and Vayabo.com.

Secure Data Storage: Your Personal Data is stored on secure servers with access limited to authorized personnel only. These servers are protected by advanced security technologies to prevent unauthorized access.

Access Controls: Access to your Personal Data is restricted to employees, contractors, and service providers who require it to perform their tasks. Our access controls and authentication mechanisms ensure that only authorized individuals can access your data.

Regular Security Audits: We conduct routine security audits and assessments to identify and address potential vulnerabilities. This proactive approach allows us to stay ahead of emerging security threats and maintain the highest standards of data protection.

Data Minimization: We collect and process only the data that is necessary for providing Our Services. Unnecessary data is not retained, reducing the risk associated with data storage.

User Authentication: We implement strong User authentication mechanisms, including secure password protocols and multi-factor authentication, to ensure that only authorized Users can access their Accounts.

Data Transfer Security: When We share your data with Third-Party Service Providers or other Users, We do so using secure and encrypted channels. We require Our partners to adhere to strict data protection standards.

Incident Response: In the event of a data breach or security incident, We have a comprehensive incident response plan in place. We promptly investigate and address security breaches to mitigate any potential impact on your Personal Data.

User Education: We empower our Users with information and resources to enhance their own data security. We encourage you to use strong, unique passwords and exercise caution when sharing personal information.

Data Protection Commitments: Our Service Providers are contractually obligated to comply with stringent data protection commitments. They are required to implement security measures consistent with industry best practices.

While we take every possible measure to protect your personal data, it’s essential to acknowledge that no system can be entirely immune to security risks. We continuously monitor and update Our security protocols to adapt to evolving threats, ensuring that your Personal Data remains safe and secure. If you have any concerns or suspect unauthorized access to your Account, please contact our customer support team immediately so that We can take appropriate action to protect your data and investigate the matter thoroughly.

 

F. Legal Basis for Processing Personal Data under the Law

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.

Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company 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.

 

G. Your Rights Regarding Personal Data

We are committed to safeguarding the privacy of your personal data and ensuring you can exercise your rights effectively. According to this Privacy Policy and applicable EU regulations, you have the following rights:

Access Your Personal Data: You have the right to access, update, or request the deletion of your Personal Data held by Us. In most cases, you can manage this directly within your Account settings. If you need assistance, please reach out to Us, and We will gladly provide you with a copy of the Personal Data we have on record.

Correct Inaccurate Information: If We hold incomplete or inaccurate information about you, you have the right to request corrections to ensure your data is accurate and up-to-date.

Object to Data Processing: You can object to the processing of your Personal Data when We rely on a legitimate interest as the legal basis for processing. If your particular situation warrants it, you may also object to the use of your data for direct marketing purposes.

Request Data Erasure: If there is no valid reason for us to continue processing your Personal Data, you have the right to request the deletion or removal of your data.

Data Portability: Upon request, we will provide you or a third party you designate with a structured, commonly used, machine-readable format of your Personal Data. This right applies primarily to automated information you initially consented to or information used to fulfill a contract.

Withdraw Consent: You can withdraw your consent to the use of your Personal Data at any time. However, please note that withdrawing consent may affect your access to specific functionalities of Our Services.

We are committed to upholding your rights and ensuring your data privacy. If you have any questions or wish to exercise any of these rights, please contact us, and we will assist you promptly.

 

H. Exercising Your Data Protection Rights

Should you wish to exercise your rights under the Law, including those related to access, rectification, deletion, and objection, please reach out to Us by using the Data Subject Request Form attached to this Policy. To ensure the security of your data, We may ask you to confirm your identity before addressing your requests. Rest assured, We will make every effort to respond promptly to your inquiries.

We value your privacy and aim to address your concerns as swiftly as possible. Please note that in accordance with Law, we will respond to your requests within 30 days at the latest.

If you are located within the European Economic Area (EEA) and have further questions or concerns, you also have the right to contact your local data protection authority for additional information or assistance.

 

I. Children’s Privacy

Our Services are designed for individuals aged 16 years and older. We do not intentionally collect Personal Data from children under the age of 16 unless it is provided by a parent or guardian with their explicit consent. Instances where We might collect Personal Data of children under 16 years old include reservations, the purchase of travel-related services, or when specific features are tailored for families. In all such cases, data collection is subject to parental or guardian consent.

We may ask a User to verify its date of birth before collecting any personal information from them. If the User is under the age of 16, the Service will be blocked or directed to parental or guardian consent. If We discover that We have inadvertently processed the information of a child under 16 years old, We will promptly delete such data to ensure compliance with privacy regulations and protect the privacy of minors.

 

J. Links to Other Websites

Vayabo App and Vayabo.com may contain links to other websites that are not operated by Us. If You click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

K. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let You know via email, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

L. Contact Us

If you have any questions about this Privacy Policy, you can contact us:

By email: info@vayabo.com

 

Data Subject Request Form

You can download our Data Subject Request Form by using this link: Vayabo – Data Subject Request Form – 24112023