Last updated: June 1, 2022
Table of Contents
- Who’s This Policy For And What Does It Cover?. 1
- What is “Personal Information”?. 2
- Personal Information We Collect And How We Collect It 2
- How We Use Personal Information. 3
- How We Share Personal Information. 4
- Children’s Privacy. 5
- Cookies And Online Tracking. 6
- Quality And Retention of Personal Information. 8
- Data Security. 8
- Your Rights And Choices. 9
- Links To Third Party Sites. 9
- Third Party Direct Marketing. 9
- Data Subjects In The EEA, United Kingdom and Switzerland. 9
- Changes To This Policy. 11
- Contact Us. 11
1. Who’s This Policy For And What Does It Cover?
You may see other privacy notices when we collect your Personal Information for certain purposes. Those notices supplement this Policy.
This Policy also contains important statements specific to residents of certain areas, including the European Economic Area, United Kingdom and Switzerland, based on laws in those areas. Those statements supplement the rest of this Policy, but to the extent they differ from other parts of the Policy, the statements govern in their applicable areas.
2. What is “Personal Information”?
Generally speaking, your “Personal Information” includes your unique identifiers (for example, your full name, phone number, or email address); and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you. “Non-Personal Information,” on the other hand, is information that has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to an individual.
3. Personal Information We Collect And How We Collect It
Categories of Personal Information that we may collect about you are listed in the following table:
|Category of Personal Information collected |
|What does this mean?|
|Identity Data||First name, last name, or similar identifier, title, or other forms of identification. |
|Contact Data||Your email address and telephone numbers. |
|Transaction Data||Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties (including your credit history). |
|Content Data||Any content you post to the Services not already included in another category, including without limitation, travelling details, questions, preference settings, answers, messages, comments, and other contributions on the Services, and metadata about them (such as when you posted them) ( “Content”). |
|Marketing and Communications Data||Your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses. |
|Behavioral Data||Inferred or assumed information relating to your behavior and interests, based on your online activity. This is most often collated and grouped into “segments.” |
|Technical Data||Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.|
No Sensitive or Special Categories of Personal Information. We do not collect any “sensitive” or “special” categories of Personal Information about you (such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, or trade union membership).
What happens when you do not provide necessary Personal Information? Where we need to process your Personal Information either to comply with law, or to perform 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 (for example, to provide you with the functionalities of the Services). In this case, we may have to stop you using our Services.
Sources of Collection
Some of this information is logged through the use of “cookies” and similar technologies, which are described here.
From Third Party Sources
We may obtain information about you from other sources, including our service providers; product dealers or distributors; or product repair providers. We may combine such information with information we have collected from you. We are not responsible for the accuracy of any information provided by third parties.
4. How We Use Personal Information
Subject to any limitation under applicable law, we may use your Personal Information for the purposes described in the table below. We may use non-Personal Information for any purpose, whether that information is derived from your Personal Information or not.
|Purpose||Why do we do this|
|Providing, updating, and maintaining our Services, Site, and business||To deliver the Services you have requested.|
|Research and development||To enable us to improve the Services and better understand our users and the markets in which we operate. For example, we may conduct or facilitate research and use learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, areas for additional features and improvement of the Services and other insights. We also test and analyze certain new features with some users before introducing the feature to all users. |
|Communicating with users about the Services||To send communications via email, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts. We may also provide tailored communications based on your activity and interactions with us. |
|Providing customer support||To respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support. |
|Enhancing security||To keep our website, our Services and associated systems operational and secure. |
|Marketing, promoting and driving engagement with the Services and third-party products and services||To send promotional communications that may be of specific interest to you, including, for example, by email and by displaying promotions and other information on our Site or other companies’ websites. These communications may be aimed at driving engagement and maximizing what you get out of the Services or promoting third-party products and services. You generally can control whether you receive these communications as described in this policy under Marketing Communications Preferences. |
|To comply with applicable law, legal process and regulations and protect legitimate business interests||As we believe is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organization or audit or to protect the safety of any person, to address fraud, security issues, or to protect our legal rights, interests and the interests of others.|
5. How We Share Personal Information
We may share Personal Information with contractors, service providers, and other vendors who assist or support us in providing the Services. Examples of these third party services may include hosting our site, storing data, performing analytics, processing payments, or sending marketing communications. Where necessary and appropriate, our agreements with vendors prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing services to us.
Analytics, Social Media and Advertising Partners
We may share your Personal Information with analytics providers, advertising networks, or social media companies to measure performance of our Service or marketing efforts, offer social media features, or deliver interest-based advertising. This sharing may involve the use of browser cookies and similar technologies placed through our Service by our partners, as explained here. For example, when you visit our Site, our partner’s Cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other online identifiers, device information and internet activity.
To enhance the public understanding of patterns and trends in the markets served by or Services, we may provide Personal Data to third parties under confidentiality obligations such as, for example, academics or contractors for research purposes.
Mandatory Disclosures And Legal Proceedings
Change In Control Or Merger
We may transfer your information in the event of the sale of substantially all of the assets of our business to a third-party or in the event of a corporate merger, consolidation, acquisition or reorganization. However, in such event, any acquirer will be subject to the provisions of our commitments to you or we will not disclose your information.
With Your Direction Or Consent
We will share your Personal Information with other third parties as you may direct or otherwise consent.
6. Children’s Privacy
Our Services are not directed to children (individuals under the age of 18). We do not knowingly collect, maintain, or process children’s Personal Information unless the child’s parent or guardian consents and provides the information. If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will immediately delete the information.
7. Cookies And Online Tracking
What Are Cookies?
A browser cookie is a small piece of data that a website stores in your device’s browser. It holds information that the site uses to function properly, remember your preferences, or personalize your experience. A typical cookie contains a cookie ID, which is a unique string of characters used to identify your browser during the browsing session, or in some cases, during subsequent browsing sessions. Cookies, cookie ID’s and similar pieces of data may be considered Personal Information under applicable law.
Other online technologies, similar to cookies, may allow users to be identified and tracked across multiple browsing sessions, and in some cases tracked across different websites and online services for marketing or advertising purposes. These technologies include, but are not necessarily limited to, pixels, web beacons and scripts (collectively with browser cookies, “Cookies”).
How Cookies May Be Used On Our Services
Our Service uses “first party” Cookies, which are set by our web domain (testfortravel.com). Our Service also uses some “third party” Cookies, which are set by other web domains associated with our vendors or partners. This means that, when you visit our site, your browser may automatically connect to our vendor or partner’s web server, as well as ours, and provide them with access to your online Identifiers and Internet Activity, including information about how you use our site.
Both First Party and Third Party Cookies may be used on our Services for the following purposes:
|Type of cookies||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the Services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. |
|Functionality Cookies||These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site. |
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use a number of different tools including Google Analytics, Segment, Amplitude, Intercom, and Fullstory for this purpose. |
|Targeted and advertising cookies||These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. |
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this. These cookies may also include certain code that has been placed on the Site to help track conversions from ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—users who have already taken certain action on the Site.|
Some of the Third Party Cookies used on our Site are provided by Google Analytics (https://policies.google.com/technologies/partner-sites?hl=en-US) and Facebook (https://www.facebook.com/about/privacy).
How You Can Block Cookies
You can block, disable or delete cookies at any time by changing the settings in your browser. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our site or other sites. You can find more information about cookies and other options you may have for restricting them at www.allaboutcookies.org and www.youronlinechoices.com.
“Do Not Track” Signals
Your browser may offer a Do Not Track (DNT) setting. If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third party sites. We don’t currently respond to these signals because there is not yet a common understanding of how to process them or a consensus on what “tracking” means.
8. Quality And Retention of Personal Information
9. Data Security
In order to safeguard Personal Information against unauthorized access or use, we maintain administrative, physical and technical security procedures and practices appropriate to the nature of the information. We regularly assess the performance and adequacy of those procedures and practices and will adjust them when new operations or risks require it. Unfortunately, in our increasingly connected digital world, no one can guarantee perfect data security, and we cannot promise that our procedures and practices will always prevent a breach of Personal Information. Should we detect such a breach, we will promptly notify affected individuals, third parties and law enforcement agencies as required by applicable law.
We encourage you to help maximize security by applying your own personal security measures. For more information about what you can do to protect your data, please see the tips and resources offered by the U.S. Federal Trade Commission at https://www.consumer.ftc.gov/topics/privacy-identity-online-security and the California Attorney General at https://www.oag.ca.gov/privacy/consumer-privacy-resources.
10. Your Rights And Choices
Opt-Out Of Marketing Communications
You may opt-out of our marketing emails by using the unsubscribe link provided in the email.
Your Browser And Device Settings
See Section 7 for options to restrict Cookies.
If you reside in the European Economic Area, United Kingdom or Switzerland, you may have additional rights and choices.
11. Links To Third Party Sites
12. Third Party Direct Marketing
We do not share your Personal Information with third parties for their direct marketing purposes without your consent.
13. Data Subjects In The EEA, United Kingdom and Switzerland
Personal Information that we collect regarding individuals who reside in a member state of the European Economic Area (“EEA”), the United Kingdom or Switzerland is controlled by Covid Clinic, Inc., a non-profit organization, which is headquartered in Huntington Beach, California, U.S.A. Our address is 18800 Delaware St., Suite 800, Huntington Beach, CA 92648.
Lawful bases for processing
We may process your Personal Information for the purposes described above if at least one of the following grounds for processing applies:
- Processing is necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract;
- Processing is necessary to comply with our legal obligations;
- Processing fulfills our legitimate interests in a manner that does not outweigh your rights and freedoms. Our legitimate interests include: protecting our Services against malicious intrusions and unauthorized use; maintaining and improving our Services; understanding how our Services are used; personalizing our Services; promoting our Services effectively; and complying with legal obligations and protecting our legal rights.
- Processing is necessary to protect the vital interests of you or another individual
- You have consented to the processing
Covid Clinic, Inc. is headquarters in the United States. Information we collect about you will therefore be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Commission under Article 45 of the General Data Protection Regulation (“GDPR”). To the extent we make transfers of Personal Information to third parties in the United States or other countries that have not received an adequacy finding, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we make such transfers: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We endeavor to enter into data processing agreements and European Commission-approved standard contractual clauses with service providers with vendors whenever feasible and appropriate.
Automated decision making
We do not make any decisions involving the use of algorithms or profiling that significantly affects you.
Your rights under GDPR
The GDPR provides you with the following rights, which you can exercise by contacting us at _____________:
- The right to request access to and rectification of your Personal Information. You may obtain additional information about our processing and a copy of your stored information. You also have the right to request that we update your information if it is inaccurate or incomplete.
- The right to request erasure of your Personal Information. You may request for us to erase your information from our systems if it is no longer necessary for the reason we collected it, or you withdraw consent and no other legal basis for processing exists.
- The right to restrict our processing of your Personal Information. You have the right to restrict our processing if: (1) you disagree with the accuracy of your information; (2) our processing is deemed unlawful and you do not want us to erase your information; or (3) we no longer need your information for the purposes for which we collected it but we must store it to comply with our legal obligations.
- The right to data portability. You may receive and transmit your Personal Information to another controller where our processing is based on consent you gave us and was carried out by automated means.
- The right to object. You have the right to object to our processing of your Personal Information where we process it because of a legitimate interest.
You also have the right to file a complaint with the supervisory authority of your member state.
14. Changes To This Policy
15. Contact Us
If you have any questions or concerns about this Policy, please contact us via [email protected]