This Privacy Policy clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") we collect, use and process as a part of our online offer and the websites and applications functions and contents connected with it as well as external online presences, such as our Social Media Profile (hereinafter referred to as "services"). This Privacy Policy applies to our entire services, websites and applications including our Intuiguide IOS and Android Application.

Who we are

We are Intuiguide (“we”, “our”, “us”) of [insert address]. We operate to the highest standards when protecting your personal data and respecting your privacy. If you have any questions about your personal data, or how we use it, you can contact us via our contact forms or email at [insert email]. We are the data “controller”, which means we are responsible for deciding how and why your personal data is used. We’re also responsible for making sure it is kept safe, secure and handled legally.

The Regulation

Our Headquarters being in Vanuatu, national Data Protection Law applies to our services. However, we have voluntarily committed to the EU`s Regulation (EU) 2016/679 (GDPR).

Accuracy

It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

What data do we collect and process?

• Inventory data (e.g., names, country, city, date of birth).

• Contact details (e.g., e-mail).

• Contract data (e.g., object of contract, duration, customer category).

• Usage data (e.g., pages visited, interests, trips planed, access times, location data when permitted).

• Meta/communication data (e.g., device information, IP addresses).

• Information you voluntarily provide us with such information in the course of using our Services.

Automated decision-making and profiling

As a responsible company we do not use automation for decision-making and profiling.

What are the categories of data subjects?

Customers, interested parties, visitors and users of the online offer, business partners. Visitors and users of the online offer. In the following, we refer to the data subjects collectively as "users".

What are the purposes for processing?

• Provision of the online offer, its contents and application functions.

• Provision of contractual services, service and customer care.

• Answering contact enquiries and communication with users.

• Marketing, advertising and market research.

• Security measures.

What are the relevant legal bases for processing your data?

The following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:

• Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.

• Contract – This is where we process your information to fulfil a contractual arrangement we have made with you.
  Answering your business enquiries – This is where we process your information to reply to your messages, e-mails, calls, etc.

• Legitimate Interests - This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.

• Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.

• Vital interests – This is where we process your information for communications about security, privacy and performance improvements of our services. Or for establishing, exercising or defending our legal rights.

When do we disclose your Personal Data?

We may share your information with organisations that help us provide the services described in this policy and who may process such data on our behalf and in accordance with this policy, to support this website and our services. This will only be done on the basis of a legal authorisation (e.g. if a transfer of the data to third parties, such as payment service provider Apple Pay and Google Pay in accordance with the above stated regulations).
Also, if you have consented to it, or where there we have a legal obligation to do so or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to perform our contractual obligations, administrative tasks and duties efficiently and effectively).
If we commission third parties to process data on the basis of a so-called "processing agreement", this is done on the basis of the above stated regulations.
In relation to information obtained about you from your use of our website, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimisation of our website which is subject to our Cookies Policy.
We may also disclose information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.

Permissions for the Intuiguide App

Our app requires the following permissions:

• INTERNET (retrieve data from the internet/access to all networks):

• ACCESS_FINE_LOCATION (Exact location): This allows the current position to be displayed on the map. You can deactivate this in the settings menu.

• WAKE_LOCK (Disable Sleep): Needed to process and display incoming push notifications, when enabled.

• VIBRATE (control vibration alert): Needed to vibrate for push notifications, when enabled.

• ACCESS_NETWORK_STATE (Get network connections): Needed to access the network state (online/offline).

• BILLING (Google Pay and Apple Pay billing service): Used to process the sale of the paid version.

• BIND_GET_INSTALL_SERVICE (Play Install API): Used for statistical purposes.

Use of location data

In our app, you have the option to disclose your general and your current location.
The use of location data (e.g. displaying the current position or centring the map) is usually done on your mobile device. Only the functionality of receiving location alerts for the current position requires the transmission of a coarsened location information to our server infrastructure. The location alerts only use an accuracy of 35*50 km. Therefore, there is no way to infer their current position.
Enabling the location option in the app settings will result in the app being allowed access to your location information.
You can activate or deactivate the functionality of receiving location alerts separately. You can deactivate the respective app's access to your location at any time in the corresponding settings.

Use of push services

The app also uses push services of the operating system manufacturers. These are short messages that are shown on the user's display with the user's consent and with which the user is actively informed about your trip.
In the case of the use of push services, a device token from Apple or a registration ID from Google is assigned. The sole purpose of their use by us is to provide the Push Services. These are only encrypted, anonymised device IDs. Intuiguide cannot draw any conclusions about the individual user.
You can decide during the installation of the app whether you want to use this functionality. To disable the push messages at a later date, you can use the unsubscribe option in the Intuiguide app. You can find this in the settings menu.
The collection and processing of device-specific information is carried out for the purpose of processing contractual relationships with you or if and insofar as this is necessary to protect our interests or those of third parties. This may include, in particular, the transfer to hosting or cloud computing providers for the purpose of optimising the services and increasing usability and user-friendliness. Disclosed data may only be used by third parties for the aforementioned purposes.

Evaluation of usage data

Anonymised usage data is evaluated for the secure operation and further development of the Intuiguide app. However, this data cannot be linked to your identity. We have no way of assigning this data to you personally and do not combine this data with other data sources.

Firebase and Firebase Crashlytics

The information generated about the use of the Intuiguide app is transmitted with an anonymised IP address to a Google server in the USA and stored there. The IP anonymisation function in Analytics sets the last octet of IPv4 user IP addresses and the last 80 bits of IPv6 addresses in memory to zero. This means that the user's exact IP address is not stored
Google will use this information to evaluate your use of the Intuiguide app in order to compile reports on activity for the app operators. Google may also transfer this information to third parties.
This usage data forms the basis for statistical, anonymous evaluations, so that trends can be identified, which can be used to improve the offer accordingly.
The integration is based on your express consent and It is done in order to make our app more user-friendly and interesting. This constitutes a legitimate interest within the meaning of the aforementioned provision.

MapBox

We use MapBox API, a service of MapBox. We use MapBox to visually display geographical information. When using MapBox, MapBox also collects, processes and uses data about your use of the map functions.
When you call up one of our services in which the MapBox service is integrated, MapBox stores a cookie on your end device via your Internet browser. This transfers information about your use of our website, including your IP address, to a MapBox server in the USA and stores it there. This data is processed for the purpose of displaying the maps or ensuring the functionality of the MapBox service. MapBox may pass this information on to third parties if this is required by law or if the information is processed by third parties on behalf of MapBox.

Service provider

We reserve the right to use service providers for the collection or processing of data. Service providers only receive the personal data from us that they require for their specific activities. This may also include the transfer to hosting or cloud computing providers for the purpose of optimising the services and increasing usability and user-friendliness.Service providers may also be contracted to provide server capacity. Service providers are usually integrated as so-called order processors who may only process personal data of the users of this online offer according to our instructions.The data passed on may be used by the third party exclusively for the purposes stated.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, the data processed by us will be deleted or restricted in their processing in accordance with the above stated regulations. If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

How do we protect your Personal Data?

We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.

Economic Analyses

In order to run our business economically, to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, enquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of the above stated regulations, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purposes of business management evaluations, marketing and market research.
In doing so, we may take into account the profiles of registered users with details, for example, of their purchasing transactions. The analyses serve us to increase user-friendliness, to optimise our offer and business efficiency and are not disclosed externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Do Not Track

Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that you should have genuine control over how your info gets used and our site responds to Do Not Track requests.

Do Not Sell My Personal Information

We do not sell information that directly identifies you, like your name, address, banking information, or phone records. In fact, we do not even share that type of information except with service providers who can use the information solely to provide a service on our behalf, when a consumer directs us to share the information.

Communication by mail, e-mail, or telephone

We use means of distance communication, such as telephone or e-mail, for business and marketing purposes. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
The processing is based on the above mentioned regulations and in connection with legal requirements for advertising communications. Contact shall only be established with the consent of the contact partners or within the scope of the statutory permissions and the processed data shall be deleted as soon as they are not required and otherwise with objection/ revocation or discontinuation of the basis for authorisation or statutory archiving obligations.

Online presences in social media

We maintain online presences on the basis of our legitimate interests. We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

Contact form

All your personal data and other information that you provide to us via the contact form set up on our website will only be collected and processed for the purpose of processing and responding to your enquiries. Your data will be forwarded to us by e-mail via our provider. If they are not provided, it is unfortunately not possible for us to contact you and process your request. An automated decision-making process will not be carried out.

Customer login and User registration

All your personal data and other information that you provide to us via the login area will only be collected and processed for the purpose of processing and answering your enquiries. Your data will be forwarded to us by e-mail via our provider. If they are not provided, it is unfortunately not possible for us to provide you with the customer login area, to contact you and to process your request. An automated decision-making process is not carried out.

Personal Data Statement

Commercial Partners: Individual(s) or companies that have been approved by us as a recipient of organizational Personal Data and from which Intuiguide has received confirmation of their data protection practices conformance with the requirements of this policy. Commercial Partners include all external providers of services to Intuiguide and include proposed Commercial Partners. No Personal Data can be transmitted to any vendor in any method unless the vendor has been pre-certified for the receipt of such information.
Personal Data Audit(s): Intuiguide conducts audits of Personal Data maintained by Intuiguide in conjunction with fiscal year closing activities to ensure that this policy remains strictly enforced and to ascertain the necessity for the continued retention of Personal Data. Where the need no longer exists, Personal Data will be destroyed in accordance with protocols for destruction of such records and logs maintained for the dates of destruction.
Data Breaches/Notification: Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, Intuiguide will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible.
Confirmation of Confidentiality: All company employees must maintain the confidentiality of Personal Data as well as company proprietary data to which they may have access and understand that that such Personal Data is to be restricted to only those with a business need to know. Employees with ongoing access to such data will sign acknowledgement reminders annually attesting to their understanding of this company requirement.
Violations of Personal Data Policies and Procedures: Intuiguide views the protection of Personal Data to be of the utmost importance. Infractions of this policy or its procedures will result in disciplinary actions under Intuiguide’s discipline policy and may include suspension or termination in the case of severe or repeat violations. Personal Data violations and disciplinary actions are incorporated in Intuiguide’s Personal Data on boarding and refresher training to reinforce Intuiguide’s continuing commitment to ensuring that this data is protected by the highest standards.

Direct marketing

From time to time we may use the personal information we collect from you to identify particular products offers which we believe may be of interest to you. We may contact you to let you know about these products and services and how they may benefit you.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or relationship with us.
Direct Marketing from generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by Intuiguide, or by our contracted service providers. Every directly addressed marketing form sent or made by us or on our behalf should include a means by which customers may unsubscribe (or opt out) of receiving similar marketing in the future. You can ask us to remove or amend any previous consent you provided by contacting us.

Your Rights

• Right to information: You can request information from us as to whether and to what extent we process your data.

• Right to rectification: If we process your data that is incomplete or incorrect, you can request that we correct or complete it at any time.

• Right to erasure: You may request that we erase your data if we are processing it unlawfully or if the processing disproportionately interferes with your legitimate interests in protection. Please note that there may be reasons that prevent immediate deletion, e.g. in the case of legally regulated retention obligations. Irrespective of the exercise of your right to deletion, we will delete your data immediately and completely, insofar as there is no legal or statutory obligation to retain data in this respect.

• Right to restriction of processing: You may request us to restrict the processing of your data if you dispute the accuracy of the data for a period of time that allows us to verify the accuracy of the data, the processing of the data is unlawful, but you object to erasure and request restriction of data use instead, we no longer need the data for the intended purpose, but you still need this data to assert or defend legal claims, or you have objected to the processing of the data.

• Right to data portability: You may request that we provide you with the data you have provided to us in a structured, commonly used and machine-readable format and that you may transfer this data to another controller without hindrance from us, provided that we process this data on the basis of a revocable consent given by you or for the performance of a contract between us, and this processing is carried out with the aid of automated procedures. If technically feasible, you may request us to transfer your data directly to another controller.

• Right to object: If we process your data for legitimate interest, you may object to this data processing at any time; this would also apply to profiling based on these provisions. We will then no longer process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the assertion, exercise or defense of legal claims. You may object to the processing of your data for the purpose of direct marketing at any time without giving reasons.

• Right of complaint: If you are of the opinion that we violate applicable data protection law when processing your data, please contact us so that we can clarify any questions. Of course, you also have the right to contact the supervisory authority responsible for you, the respective state office for data protection supervision. If you wish to assert any of the aforementioned rights against us, please contact us. In case of doubt, we may request additional information to confirm your identity.
  Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.
  The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.

Changes

This Privacy Policy and our commitment to protecting the privacy of your personal data can result in changes to this Privacy Policy. Please regularly review this Privacy Policy to keep up to date with any changes.

Queries and Complaints

Any comments or queries on this policy should be directed to us using the following contact details.