© Rough Guides® is a trademark owned by Apa Group with its headquarters at 7 Bell Yard, London WC2A 2JR, United Kingdom and this site is owned & operated by Apa Digital AG, Bahnhofplatz 6, 8854 Siebnen, Switzerland, registered in the Commercial Register of the Canton of Schwyz, registration number CH-020.3.033.676-6). Apa Digital AG is the data controller and responsible for your personal data (referred to as “Rough Guides,” or “we” or “us” or a similar construction).
2. Scope of Policy
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
You have the right to make a complaint at any time to the supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance at email@example.com.
Scope & Limitations
So that there's no misunderstanding about how we handle your personal data, we will:
- Always keep your data safe and private.
- Never sell your data.
- Allow you to manage and review your marketing choices at any time.
Please note that there are some areas of the Website which you may use without any required login credentials and without the requirement that you establish an account or otherwise reveal your identity.
If you provide the Information of any other person to us, you hereby represent and warrant that you are authorized by such person (or his or her parent or legal guardian) to provide such Information for our purposes as provided herein.
By providing us with your data, you warrant to us that you are over 13 years of age. Minors may not submit booking requests and should not provide any Information to the Website without the preceding consent of their parents or their guardian. Should a minor submit a booking request it is assumed that either his parents or guardian have not supervised him or her properly and that they become liable as set forth in the Terms and Conditions and Art 333 Swiss Civil Code.
3. Information we may collect about you
We may store certain Information pertaining to your travel package requests, including Information pertaining to other participants for whom you are arranging travel, in order to allow you to complete requested information without having to re-input information for future trips or services.
Except as described herein, we will not sell your Information to third parties for their promotional activities unrelated to the purposes for which your information was submitted.
1) Information you give us "Submitted Information"
This is information you give us about you by filling in forms on the Website, or by corresponding with us (for example, by e-mail or via the chat functions on the Website). It includes information you provide when you register to use our services, subscribe to any of our services, enter into any transaction on the Website, participate in discussion boards or other social media functions on the Website, enter a competition, promotion or survey and when you report a problem with the Website or the Services. If you contact us, we will keep a record of that correspondence.
Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.
The information you give us may include
- Identity Data may include your first name, last name, username, title and gender.
- Contact Data may include your billing address, email address and telephone numbers.
- Financial Data may include your payment card details including the long number and country of billing
- Profile Data may include your username, password and other registration information, purchases or orders, your interests, preferences, feedback and survey responses
- Marketing and Communications Data may include your preferences in receiving marketing communications from us (including your email address) and our third parties and your communication preferences.
- Information that you post to our website for publication on the internet (including your user name and the content of your posts)
- Information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication)
- Specific Information Required to Process a Booking Request to enable us to submit a booking request and to process booking confirmations. We may require information such as each travel participant’s name, birthdate, postal address, telephone number, age, loyalty or rewards program information, visa or other travel/work/resident permit information, driver’s license information, and the like. We may require additional information related to your travel itineraries or preferences, such as meal preferences (possibly including related allergy/health or religious information), requirements for travel or boarding assistance, flight origin, flight destination, flight time, duration of flight, seat number, and any other travel agency your tour providers may be required to coordinate with.
All information discussed in this section may be shared, in addition to the other uses described in this Policy, with the travel provider from whom you have requested bookings or other services, as necessary or appropriate to properly confirm and assemble your tour package or other services.
2) Information we collect about you and your devices “Device information”
Each time you visit our Website we may automatically collect the following information after the consent is given:
- technical information, including the anonymized internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information
- information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page
- Transaction Data may include details about payments between you and us such as date, time, amount, currencies used, exchange rate, and other details of purchases made by you
- Usage Data may include details of your visits to our Website including details relating to your use of our services.
We may also process Aggregated Data from your personal data, but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of my site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we ARE required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have requested but if we do, we will notify you at the time.
4. Uses made of the information
How we use your personal data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Below is a summary of the key types of data that we make use of as part of the Rough Guides Website and Services. For more information on how these types of data are used and for which purposes then please see the table below.
We use information held about you in the following ways:
1) Submitted Information
We will use this information:
- to carry out our obligations arising from any transactions you enter into with us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you with information about goods or services we feel may interest you
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
2) Device Information
We will use this information:
- to administer our Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to personalise our website and services for you
- to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our services, when you choose to do so;
- as part of our efforts to keep our Website safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
What we use your information for
Type of Information
Our legitimate interests
Discussions with a prospective client/ supplier/ associate
Necessary for our legitimate interests for negotiating or performing a contract with you.
Managing current and former client/supplier/associate relationships including:
(a) Development of client/ supplier/ associate contract
(b) Manage payments, fees and charges
(c) Collecting and recovering money owed to us
(d) execution and delivery of services
e) Marketing and Communications
g) Information contained in or relating to any communication that you send to us
Necessary for our legitimate interests
- for negotiating or performing a contract with you
- to keep our records updated and recover debts owed to us
- to comply with legal obligations
Administration & protection of our business & website (including troubleshooting, data analysis, testing, system maintenance, resource allocation, support, reporting and hosting of data)
i) technical information
j) information about your visit
l) usage Data
Necessary for our legitimate interests for running our business and website.
Personalization of your experience with the Website and improve our content
i) technical information
j) information about your visit
l) usage Data
Necessary for our commercial interest in providing you with a good experience in our Website and Services.
Necessary for our legitimate interests to define types of customers for my products and services, to keep my site updated and relevant, to develop my business and to inform my marketing strategy.
Providing user support and to contact you for administrative purposes relating to your account, or to provide you support in response to your queries; please note that additional Information may be collected from or in response to your query (name, phone number, mailing address or email address and billing information) and other information necessary to assist you
1) Submitted information
i) Technical information
j) Information about your visit
Necessary for our legitimate interest to aid our users with any problems and questions they have in the context of using our Website or Services.
Create aggregate and anonymous demographic or other information which we may use for any purpose once decoupled from your personal or financial information (such as to assist our advertisers in choosing ad space or tracking campaigns)
i) Technical information
j) Information about your visit
Necessary for our legitimate interests to learn how customers use our products & services, to develop them, to grow our business and to inform our marketing strategy and serve more relevant advertising.
To deliver relevant content and advertisements to you, track conversions and measure and understand the effectiveness of our advertising.
The platforms where you may see advertisements from me are as follows. In the link you can find instructions how you can amend your privacy/ad settings for that specific platform.
e) Marketing and Communications
Necessary for our legitimate interests to learn how customers use our products & services, to develop them, to grow our business and to inform our marketing strategy.
To deliver email marketing content, free resources, provide information pertaining to Rough Guides’ services which may be of interest to you and to make recommendations about other services that may be of interest to you.
e) Marketing and Communications
To purchase ebooks from our online shop, you will be required to register an account. For this, you will be asked to provide your name, email address, a password and password reminder, your billing and delivery address. We do not share these personal details with any third parties. We use a third-party payment service (PayPal) to facilitate payment. We do not store credit card details nor do we share financial details with any third parties. Ebook purchases are subject to our Terms and Conditions of Sale & Purchase.
Forums and User Content
If you sign up to one of our forums, we will ask you to provide a username and email address so that we can let people know who posts which comment and to enable us to deal with any inappropriate or offensive behaviour.
For the same reasons, if you provide comments on any articles or upload your own content to our sites, we may ask you to provide your email address.
We want to make it clear how we use your data for marketing purposes and how you can 'opt-out' from receiving any marketing communications from us whenever you want.
Promotional offers from us
We may use your personal data (such as your Submitted Information or transaction information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have signed up to receive them and, in each case, you have not opted out of receiving marketing notifications.
We will obtain your explicit opt-in consent before we share your personal data with any company outside APA Digital AG for marketing or promotional purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the “unsubscribe link” at the bottom of any marketing message sent to you.
6. Disclosure of your personal data
Except as provided herein, we will not disclose your Information to third parties. We do share your personal Information as necessary to fulfil your requests or to enable certain functions or features on the Website, as follows:
- If you request a travel booking or otherwise use the features or functions of the Website to investigate or purchase travel services, we will share relevant portions of your Information (including state issued identification information, such as passport numbers) with the third party who provides the applicable services in order to confirm and complete bookings and perform related functions. This includes providing your Information as necessary to deliver tickets, ship items, and submit email communications to you on our behalf. Generally, this will not include your payment card information to the extent we process your payments through the Website (however, see below regarding our payment processing providers). See below for additional detail related to Information necessary to process bookings.
- If you use the Website to process deposits or payments for travel or other tourism or travel related services, we will provide your payment card information to our payment card processing provider(s) for the purposes of screening for fraud, processing payments, and handling any payment card related queries and other issues (and related purposes). We do not store your payment card information ourselves at any time and you should not provide us your payment card or national identification information outside of the secure areas of the Website which expressly request such information.
- We may be required to share your Information with government or regulatory agencies in order to comply with relevant requirements, including but not limited to border control agencies. This may include, without limitation, mandatory circumstances, such as those which involve national security, where Insight Guides is required to disclose your Information even without your consent. For example, to ensure travel security, governments may require access to passengers’ names and related records (typically name, flight origin, flight destination, flight time, duration of flight, seat location, travel agent, form of payment, credit card numbers, travel itinerary, address, telephone number).
- We may share your contact information`s with service provider who is sending the newsletter on our behalf.
- We may share your non-financial Information with other partners to fulfil your requests or our obligations to you and for the purposes of responding to your questions, but only to the extent permitted by applicable law.
- We may disclose your personal information to any of our employees, officers, insurers or professional advisers, insofar as reasonably necessary for the purposes set out in this policy.
- We may disclose your personal information:
- to the extent that we are required to do so by law;
- in connection with any ongoing or prospective legal proceedings;
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
7. Storage security & international data transfers
We take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Rough Guides employs appropriate physical, administrative and technical safeguards to protect the confidentiality and integrity of Information and to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of Information. Our contracts with our service providers require them to use appropriate safeguards and to operate consistently with this Policy.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
All electronic financial transactions entered into through our website will be protected by encryption technology.
You acknowledge that the transmission of information over the internet is inherently insecure, and that we cannot guarantee the security of data sent over the internet. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
8. Retaining your personal information
Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
Notwithstanding the other provisions of this Section on Retaining your personal data, we will retain documents (including electronic documents) containing personal data:
- to the extent that we are required to do so by law;
- if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
- in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
9. Your legal rights to your personal data
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
- Request access to your personal data (known as "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, please reach out to our support team via the email firstname.lastname@example.org.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please review your submitted information in your insightguides.com account by signing in or reach out to our support team via the email email@example.com.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you require this, please reach out to our support team via the email firstname.lastname@example.org.
- Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. If you object to the processing of certain data then we may not be able to provide our Services and it is likely we will have to terminate your account. If you require this, please reach out to our support team via the email email@example.com.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you . In this case, we may have to cancel your use of our Services but we will notify you if this is the case at the time. If you require this, please reach out to our support team via the email firstname.lastname@example.org.
- Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this, please reach out to our support team via the email email@example.com.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our Services to you. We will advise you if this is the case at the time you withdraw your consent. If you require this, please reach out to our support team via the email firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Additional information we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of our Services but we will notify you if this is the case at the time.
The Website uses a feature of your web browser called a "cookie" -- a file that your browser places on your computer's hard drive to uniquely identify your computer.
By your using this website, we imply that you have read this policy and agree to us sending you cookies.
How to disable Cookies
- Click here to learn more about the “Private Browsing” setting and managing cookie settings in Firefox;
- Click here to learn more about “Incognito” and managing cookie settings in Chrome;
- Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer; or
- Click here to learn more about “Private Browsing” and managing cookie settings in Safari.
If you want to learn more about cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google, click here.
Many jurisdictions require or recommend that website operators inform users/visitors as to the nature of cookies they utilize and, in certain circumstances, obtain the consent of their users to the placement of certain cookies.
Third Party cookies
Some features used on this website may involve a cookie being sent to your computer by a third party. For example, if you view or listen to any embedded audio or video content you may be sent cookies from the site where the embedded content is hosted. Likewise, if you share any content on this website through social networks (for example by clicking a Facebook “like” button or a “Tweet” button) you may be sent cookies from these websites. We do not control the setting of these cookies so please check the websites of these third-parties for more information about their cookies and how to manage them.
Cookies make sure that during your visit to our website the website keeps running smoothly and safely. The cookies also ensure that we can see how our website is used and how we can improve it. Furthermore, depending on your preferences our own cookies may be used to present you with targeted advertisements that match your personal interests.
What type of cookies do we use?
These cookies are necessary for the website to function properly. Some of the following actions can be performed by using these cookies. - Store articles in a shopping cart for online purchases - Save your cookie preferences for this website - Saving language preferences - Log in to our portal. We need to check whether you are logged in.
These cookies are used to gather statistical information about the use of our website, also called analytics cookies. We use this data for performance and website optimization.
These cookies enable more functionality for our website visitors. These cookies can be set by our external service providers or our own website. The following functionalities may or may not be activated when you accept this category. - Live chat services - Watch online videos - Social media sharing buttons - Login to our website with social media
Advertising / tracking cookies
These cookies are set by external advertising partners and are used for profiling and tracking data across multiple websites. If you accept these cookies, we may show our advertisements on other websites based on your user profile and preferences. These cookies also save data about how many visitors have seen or clicked on our advertisements in order to optimize advertising campaigns.
These cookies are still in the classification process. They will show up in one on the following categories; Necessary, Performance, Functional or Advertising.
11. Third party links
The Website may be, in whole or in part, an advertising supported Website, and when responding to a third party advertisement or offer, you may submit your information to such third party outside of our control.
We may also include social-media plugins like Facebook and Twitter buttons. We are in no way responsible for any of your activities in respect of your use of third party social media.
The Website may contain links to other websites that are not controlled by Rough Guides and are marked with a special character nearby. We are not responsible for the privacy practices of such other websites.
We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every website that collects personally identifiable information.
12. Other Events
All information collected or provided may be transferred or assigned by Rough Guides in conjunction with a merger or the sale of all or a portion of Rough Guides (or similar event).
We may update this policy from time to time by publishing a new version on our website. You should check this page from time to time to ensure you agree with any changes to this policy.
We may notify you of changes to this policy by email.
Address: Apa Group headquarters: 7 Bell Yard, London WC2A 2JR, United Kingdom