At Nugget Collective LLC (“we”, “us” or “our” in this Policy (as defined below)), we are committed to respecting your privacy and protecting the Personal Data (as defined below) that we obtain and hold about you and others.
1. Introduction and General Terms
The Site is operated by Nugget Collective LLC, a Delaware, USA, limited liability company. The Site allows users to view various travel information and listen to podcasts, among other things (“Services”).
Where we decide the purpose or means for the processing of the Personal Data that you provide when using our Site, we are the “data controller” for the purposes of the European General Data Protection Regulation 2016 (“GDPR”).
Our Site may contain hyperlinks to third party websites. These websites operate fully independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Site is not an endorsement. Should you use any of these websites, such use is at your own risk and we would recommend that you review their respective privacy policies and our Terms.
2. What Information Will We Collect About You?
You may voluntarily give us information about you by filling in forms when using our Services, setting up an account, signing up to our newsletter, or contacting us with email and other similar inquiries. Such information can include:
- Identity and contact data: including your name (and your child’s first name which you may provide), email address, hometown, your child’s age, number of children, and your own personal websites and social media pages and handles.
- Site Account (as defined below) information: including a username and other identity and contact data listed directly above.
- In the event that we offer merchandise products: purchase data, including products that you have requested or purchased.
- Other information: with your consent.
We may automatically collect information such as log information, or information that our servers automatically generate when you use our Site. Log information may include information like your search queries, your IP address, browser type, hardware settings, browser language, and cookies that uniquely identify your browser, plugins and time zone settings (see below for more information about cookies).
The foregoing shall be referred to herein as “Personal Data”.
3. How We Use Your Personal Data
We may legally use and retain your Personal Data where we need to perform the Terms and/or contract we are about to enter into or have entered into with you, and in our legitimate interest to improve the services we provide on our Site. We use Personal Data when:
- Creating a Site Account (as defined in the Terms) for you.
- Providing you access to your Site Account and the Services.
- In the event that we offer merchandise products in the future, we may process purchases (including any shipping details) under applicable terms of sale, and in conjunction with third-party payment providers (“Payment Provider”), which may collect, store and process payment information from you, including your name, email address, credit card number and bank account details. We will ensure that our servers will not collect or have access to your payment details. For the avoidance of doubt, in the event that we offer merchandise products in the future, any purchases you make via the Site shall be additionally governed by the Payment Provider’s terms and conditions and/or privacy policies.
If you contact us via our Site, to make an inquiry or otherwise, in certain situations we will ask you to provide a limited amount of Personal Data about yourself, such as your name, email address, and your message or inquiry in the free text box. We will use this information to respond to your inquiries, for example:
- In line with the legitimate interest we have in promoting our business, we will process your inquiries to reply to your inquiry, including providing you with information about the Services we offer and keeping track of your purchase history (if applicable).
- We may also process inquiries to take steps you ask of us with a view to entering into an agreement to provide you with our Services.
- You are under no obligation to provide us with any details, but if you choose not to provide us with relevant information, we may not be able to respond and/or provide the assistance that you request.
If you ask to be added to our mailing list by subscribing to our newsletter and opting in, we will keep you updated with information on news, offers, updates on new products and events via email.
In line with the legitimate interest we have in promoting our business, we will use the email address you give us via our Site to provide you with this information. If you would like to be removed from that list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive. After you unsubscribe, you will be removed from our mailing list within a reasonable time.
There may also be circumstances where we will ask you for your prior consent in respect of our use of your Personal Data or where we may rely on an alternative lawful basis to process your Personal Data in which case you will be notified at the time.
We use Google Analytics. When you visit our Site (regardless if you are a Site Account holder or unregistered user), these analytics service providers may collect the following data, which for the avoidance of doubt, maybe in the form of a text file stored on your computer or device through your web browser, but such data will be anonymized and aggregated before reporting back to us. However, if you have a Site Account, the cookies may identify that your web browser has accessed aspects of our Services and may associate the information with your Account:
- number of visitors to our Site;
- pages visited while at the Site and time spent per page;
- page interaction information, such as scrolling, clicks and browsing methods;
- websites where visitors have come from and where they go afterward;
- page response times and any download errors; and
- other technical information relating to end-user devices, such as IP address, browser type, or browser plug-in.
This analysis is fundamental to the running of our online business and we, therefore, undertake such monitoring in the pursuit of our legitimate interests in improving our Site, and to provide and improve the Services and source of information to visitors. To support and enhance the Services, we may allow third-party advertisements to be served to you through the Services, such as through a banner or pop up ad, by a third-party advertising agency, network, or research firm, with such advertisements, sometimes targeting to a user who fits a certain general profile category and may be based on anonymized information, which could include Personal Data (gender, age, etc.), Site usage patterns, or activity with third-party services. Notwithstanding the foregoing, we will not provide Personal Data to such third-parties for use outside of the Services.
Notwithstanding the foregoing, many web and mobile browsers have an option for turning off cookie feature(s), which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. In connection with viewing the Site to enable you to take advantage of the most attractive features of the Services, we recommend that you leave cookies active as we believe they will likely improve your experience.
To find out more about Google Analytics and to learn how to opt-out, please visit:
- How Google uses data when you use our partners’ sites or apps:
If you send us objectionable content or otherwise behave in a disruptive manner when using our Site, we may process Personal Data included in your messages to respond to and stop such behavior.
- We only process Personal Data in this way for the legitimate interests of ensuring that use of our Site is lawful, does not disrupt our systems, does not harass our staff or other individuals, and to enforce our legal rights and to comply with our legal obligations.
- Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your Personal Data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
Where we process Personal Data in this way, we will hold that Personal Data on our systems for as long as is reasonably necessary to achieve these objectives.
We may combine information from multiple sources and use such combined information for the purposes set out above, depending upon the source.
4. Do We Share Your Personal Data with Anyone Else?
We keep your information confidential, but we may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. If we provide your Personal Data to third parties, we shall only do so provided that they do not make independent use of the information and provide the same confidential treatment as we do.
We only permit them to process your Personal Data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your Personal Data. Activities which are carried out by, or in collaboration with, third-party service providers include our website hosting and potentially our fulfillment service provider.
In addition, we may disclose your Personal Data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the Personal Data we hold may be included as part of that sale, in which case you will be notified via email, your Site Account and/or a prominent notice on the Site of any changes in ownership or use of your information, as well as any choices you may have regarding that information..
Lastly and for the avoidance of doubt, some of your activities through the Services are public by default, including, without limitation, posting user-generated content publicly to certain areas of the Site and publicly accessible information via your Site Account page. Notwithstanding anything to the contrary contained herein, this Policy does not apply to materials you voluntarily make public through the Services. PLEASE DO NOT POST OR UPLOAD ANY INFORMATION TO THE SERVICES IN A PUBLIC WAY THAT YOU DO NOT WANT PUBLICLY AVAILABLE. In the event that you wish any information to be removed from the Services, we will use reasonable efforts to accommodate you. Please email us at: email@example.com. For more information, please see our user-generated content provisions in our Terms.
Except as provided above, we will not provide your information to third parties unless we receive your consent.
5. Your Rights In Relation to Your Personal Data Which We Process
Depending on your location, you may also have certain additional rights by law with respect to information, including Personal Data.
For data subject to the GDPR, you have the following rights over the way we process Personal Data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
- for a copy of Personal Data we are processing about you and/or to have inaccuracies corrected;
- to restrict, stop processing, rectify, or delete your Personal Data;
- for a machine-readable copy of your Personal Data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
- to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/
For data subject to California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.
To make a request in relation to any of the aforementioned rights, or other jurisdiction in the event you believe you may be afforded certain privacy in such jurisdiction, please send your requests to firstname.lastname@example.org or write to our Data Protection Team at: Nugget Collective LLC, 800 Union Street, Brooklyn NY 11215.
We will take commercially reasonable, appropriate technical and organizational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Site and Services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Site users, visitors and customers.
In particular, we will take precautions to protect against accidental or unlawful destruction, loss or alteration, and unauthorized disclosure of or access to the Personal Data transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Site and your Personal Data a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your Personal Data with us, you accept the aforesaid and provide your information at your own risk.
7. International Data Transfers
There are agreements in place to ensure that Personal Data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses. To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at email@example.com.
8. Retention Periods or Criteria
We will hold your Personal Data for only as long as is necessary for the relevant purpose for which that Personal Data was obtained, or as otherwise described in this Policy.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Notwithstanding the foregoing, we retain Personal Data while your Site Account is active and not closed, and if you do not delete your Site Account, your Personal Data may remain within your Site Account even if you have not recently purchased a product, for the purposes of providing you access to the Site, and as otherwise stated herein. We may retain portions of your Personal Data after your account is closed if required by law or to protect our legal rights.
If you would like us to stop using or holding your Personal Data and/or would like to request its deletion, please email us at firstname.lastname@example.org.
This Policy may be updated from time to time. We will notify you of any changes by posting the new Policy here and the same will be linked on www.nugget.travel, and, where feasible, by letting you know by email or your Site Account.