Privacy Policy
PETIT PASSEPORT’s mission is to encourage more families to explore the world together by elevating family travel, and we rely on our community of travelers and Members to help further this mission. Our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared is an important part of this mission.
This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy, Data Processing Agreement (“DPA”), and Account Settings.
Introduction
We are an online publication and community for family travelers and professionals who cater to this audience. People use our Services to access and share information and content, resources, and promotional offers related to family travel. Our Privacy Policy applies to any Member or Visitor to our Services.
Our registered users (“Members”) post and view relevant content, may share their identities when posting content, and access resources and promotional offers from third parties. Content and data on some of our Services is viewable to non-members (“Visitors”).
Services
This Privacy Policy, including our Cookie Policy, applies to your use of our Services.
This Privacy Policy applies to PETIT PASSEPORT's website, communications and services (“Services”), including off-site Services, such as third-party social media activity (e.g., Instagram, YouTube, etc.), but excluding services that state that they are offered under a different privacy policy. For California residents, additional disclosures required by California law may be found in our California Privacy Disclosure.
Data Controllers and Contracting Parties
PETIT PASSEPORT Corporation will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.
As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.
Change
Changes to the Privacy Policy apply to your use of our Services after the “effective date.”
PETIT PASSEPORT (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.
1. Data We Collect
1.1 Data You Provide To Us
You provide data to create an account with us.
Registration
To create an account you need to provide data including your name, email address and/or mobile number, and a password. If you register for a Paid Service, you will need to provide payment (e.g., credit card) and billing information.
You create your PETIT PASSEPORT profile (completing your profile helps you get the most from our Services).
Profile
You have choices about the information on your profile. You are not required to provide additional information on your profile. However, profile information helps you get the most from our Services, including helping tailor content to Member preferences. It is your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be shared with PETIT PASSEPORT personnel and authorized representatives.
Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., Contact Us form, etc.), submit a comment or property review, or purchase a Paid Service.
You don’t have to post or upload personal data; though if you don’t, it may limit your ability to receive tailored information, communications and offerings through our Services.
1.2 Data From Others
Content
You and others may post content that includes information about you or your Company on our Services (e.g., via comments or responses to reviews, or comments on your property, service, or product). We also may collect public information about you or your Company, such as from third-party search engines, social media profiles, and news media organizations, and make it available as part of our Services.
Customers
We receive personal data (e.g., your name, job title, and email address) about you when you use the services of our customers, such as registering for a third-party sponsored promotion or giveaway with PETIT PASSEPORT.
1.3 Service Use
We log usage data when you visit or otherwise use our Services, including our sites and platform technology, such as when you view or click on Promoted Content, perform a search, share Promoted Content, express interest in, or share content on our website. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
1.4 Cookies and Similar Technologies
As further described in our Cookie Policy, we use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. We also collect (or rely on others who collect) information about your device where you have not engaged with our Services (e.g., ad ID, IP address, operating system and browser information) so we can provide our Members with relevant ads and better understand their effectiveness. Learn more. You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.
1.5 Your Device and Location
When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
1.6 Employer Provided Information
When your employer buys a Paid Service for you to use, they give us data about you.
Others buying our Services for your use, such as your employer, provide us with personal data about you and your eligibility to use the Services that they purchase for use by their employees.
1.7 Sites and Services of Others
We get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others’ services with your PETIT PASSEPORT account.
1.8 Other
We are improving our Services, which means we get new data and create new ways to use data.
We often introduce new Services and features, which may require the collection of new data. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.
Key Terms
2. How We Use Your Data
We use your data to provide, support, personalize and develop our Services.
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your Account settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including Promoted Content) can be more relevant and useful to you and others.
2.1 Services
Our Services help you find content, resources, and services from Customers.
We use your data to authorize access to our Services and honor your Account settings.
2.2 Paid Services
Our paid Services (“Paid Services”) help paying users to promote content (e.g., information, media, news, resources, services, events, promotional offers, etc.).
Customers can export information you choose to submit to them through Lead Generation Forms. We do not provide identifiable User Profile or contact information to Customers as part of these Paid Services without your consent. Paid Services Customers can store information they have about you in their own systems. The data stored about you by these Customers is subject to the policies of those Customers.
2.3 Communications
We contact you and facilitate communications among Members. You can control what messages you receive and how often you receive some types of messages in your Account settings.
We will contact you through email, mobile phone, notices posted on our websites, third-party social media, messages to your PETIT PASSEPORT Account, and other ways through our Services, including text messages. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, relevant updates, reminders, and promotional content from us and our Customers. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving Service messages from us, including security and legal notices.
We also enable communications between you and others through our Services, such as sharing comments or reviews, or contributing content.
2.4 Promoted Content and Advertising
We display Promoted Content and Advertising to you both on and off our Services. We offer you choices regarding personalized Promoted Content and Advertisements, but you cannot opt-out of seeing other Promoted Content and Advertisements.
We target and measure the performance of Promoted Content to Users both on and off our Services directly or through third-party partners, using the following data, whether separately or combined: (I) Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers; (ii) Member-provided information (e.g., profile, contact information); (iii) Data from your use of our Services (e.g., search history, feed, page visits, clicking on content or Promoted Content, etc.), including as described in Section 1.3; (iv) Information from Customers, advertising partners, vendors and publishers; and (v) Information inferred from data described above (e.g., using information from a profile to infer compensation bracket; using device data to recognize you as a Member, etc.).
We will show you ads called Promoted Content which are labeled as resources (e.g., “Featured Content or Resources” or “Promoted Content or Resources”).
Promoted Content or Advertisement Relevance
We strive to ensure Promoted Content and Advertisements displayed on PETIT PASSEPORT’s website and shared with our Members via email communications, etc., are relevant to Members, per our Promoted Content Policies.
Info to Promoted Content Services or Advertisement Providers
We do not share your personal data with any third-party Promoted Content Services Customers, advertisers or advertisement networks except for: (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a Lead Generation Form); or (iii) data already visible to any Users of the Services (e.g., review or content contribution, etc.). However, if you view or click on Promoted Content or an advertisement on or off our Services, the Promoted Content or advertisement provider will get a signal that someone visited the page that displayed the Promoted Content or advertisement, and they may, through the use of mechanisms such as cookies, determine it is you. Promoted Content Providers or Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.
2.5 Marketing
We promote our Services to you and others. In addition to promoting our Services, we use Members’ data and content for invitations and communications promoting membership growth, engagement and our Services, such as by sharing content or Promoted Content published on PETIT PASSEPORT.
2.6 Developing Services and Research
We use data, including public feedback, personal data available to us, publicly-available data, polls and surveys conducted by us and others through our Services, to develop our Services and conduct research. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data. You are not obligated to respond to polls or surveys conducted through PETIT PASSEPORT, and you have choices about the information you provide. You may opt-out of survey or research invitations in your Account settings.
2.7 Customer Support
We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).
2.8 Deidentified Insights
We use your data to produce and share insights that do not identify you (e.g., membership statistics or demographics), to calculate Promoted Content impressions or clicks, or to publish demographics for a Service.
2.9 Security and Investigations
We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our Terms of Use and/or attempts to harm our Members, Visitors or others.
3. How We Share Information
3.1 Our Services
Profile
Your profile is not visible to other Members, Users, or customers of our Services.
Promoted Content Postings
When you share a comment, content, or Promoted Content Posting, it can be viewed by everyone and re-shared anywhere. Members, Visitors and others may be able to find and see your publicly-shared content.
Your employer can see how you use Services they provided for your work (e.g., as a Promoted Content Poster) and related information.
3.2 Others’ Services
You may share your personal data with others when engaging with their Promoted Content or Services.
3.3 Related Services
We share your data across our different Services to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others.
3.4 Service Providers
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
3.5 Legal Disclosures
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to comply with legal obligations. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
3.6 Change in Control or Sale
We may share your data if our business is sold to another party, but it must continue to be used in accordance with this Privacy Policy.
We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
4. Your Choices and Obligations
4.1 Data Retention
We keep most of your personal data for as long as your account is open.
We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.
4.2 Rights to Access and Control Your Personal Data
You can access or delete your personal data. You have many choices about how your data is collected, used and shared.
We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.
For personal data that we have about you, you can request that we (i) delete data, (ii) change or correct; (iii) limit or restrict use of data Right to Access and/or Take Your Data.
You can also ask us for a copy of your personal data using the contact information below and we will consider your request in accordance with applicable laws.
4.3 Account Closure
If you choose to close your PETIT PASSEPORT account, we generally delete closed account information within thirty (30) days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Professionalism Policy), enforce our Terms of Use, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.
Information you have shared with others (e.g., reviews or comments, content, or Promoted Content) will remain visible after you close your account, and we do not control data that other Members have copied out of our Services.
5. Other Important Information
5.1. Security
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant or guarantee the security of any information that you send us.
5.2. International Data Transfers
We may process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.
5.3 Lawful Bases for Processing
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (you have the right to withdraw or decline your consent at any time), contract and legitimate interests (to which you have the right to object).
5.4. Direct Marketing and Do Not Track Signals
Our statements regarding direct marketing and “do not track” signals.
We currently do not share personal data with third parties for their direct marketing purposes without your permission. Learn more about this and about our response to “do not track” signals.
5.5. Contact Information
If you have questions or complaints regarding this Policy, please first Contact Us online. You can also reach us by physical mail.
California Consumer Privacy Act
Notice for California Consumers
This notice describes the rights of Californians under the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA requires businesses like us that receive information from more than fifty thousand California consumers to provide certain information to them. We fully describe our practices to all our members and visitors in our Privacy Policy, but use this separate notice to ensure that we meet the CCPA’s requirements.
1. We Do Not Sell Your Personal Information
The CCPA requires us to disclose whether we sell your personal information. We do not sell your personal information.
2. Your Rights Under the CCPA
The CCPA provides Californians with the following rights:
2.1 Requests for Information
You or your authorized agent can request a copy of your personal information. Under the CCPA, you can also request that we disclose how we have collected, used, and shared your personal information over the past twelve (12) months, including the categories of personal information we collected and our purposes for doing so; the categories of sources for that information; the categories of third parties with whom we shared it for a business purpose and our purposes for doing so. Companies that sell personal information (we do not) must make additional disclosures.
If you are not a PETIT PASSEPORT member, you can submit your request via the Contact Us form.
2.2 Your Right to Opt Out of Sales
We do not sell personal information, so we don’t have an opt out.
2.3 Your Right to Notification
Under the CCPA, a business like PETIT PASSEPORT cannot collect new categories of personal information or use them for materially different purposes without first notifying you.
2.4 Nondiscrimination for Exercising Your CCPA Rights
The CCPA prohibits businesses from discriminating against you for exercising your rights under the law. Such discrimination may include denying services, charging different prices or rates for services, providing a different level or quality of services, or suggesting that you will receive a different level or quality of goods or services as a result of exercising your rights.
2.5 Your Right to Delete Personal Information
You can request that we delete your personal information by closing your PETIT PASSEPORT account. You also can request that we delete specific information about you. We honor such requests unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when information is being used to detect, prevent, or investigate security incidents, comply with laws, identify and repair bugs, or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
2.6 PETIT PASSEPORT Annual Metrics as Required by Regulation § 999.317(g)
The CCPA Regulations promulgated by the California Attorney General require that certain businesses disclose annual metrics regarding their responses to certain consumer requests under the CCPA. This notice contains PETIT PASSEPORT’s CCPA-specific metrics for the 2021 calendar year. In particular, these metrics reflect the number of requests PETIT PASSEPORT received in which the requester specifically invoked the CCPA. Because PETIT PASSEPORT offers all its Members the ability to exercise their rights to access and delete their data without the need to identify the law that authorizes their request, these metrics exclude data regarding the majority of successfully completed access requests.
In the calendar year 2021, PETIT PASSEPORT processed the following number of requests that explicitly invoked the CCPA:
CCPA Annual Metrics: Calendar Year 2021
3. The CCPA Categories of Personal Information We Collect and the Sources
Our Privacy Policy describes the information we collect and its sources. This notice organizes that information around the personal information categories set forth in the CCPA.
CCPA Personal Information Categories and corresponding sources of this information:
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers): information you provide directly or through your interactions with our Services (as defined in our Privacy Policy) or Customers (as described in Sections 1.2 and 2.4 of our Privacy Policy); Vendors that provide information to help us display relevant Promoted Content to members and understand the Promoted Contents’ effectiveness; information from other PETIT PASSEPORT members or customers.
Characteristics of protected classifications under California or Federal law (e.g., your gender or age) (“Characteristics of Protected Classifications”): information you provide to us directly and inferences we make based on that information; information from our customers.
Commercial information (e.g., information regarding products or services purchased, obtained, or considered): information you provide to us directly, such as to buy a Paid Service; your interactions with our Services; information from our partners and customers.
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services): your interactions with our Services; “follow us” or other social media activity; as needed for fraud prevention and security purposes.
Geolocation Data: information you provide to us directly or through your interactions with our Services, as explained in Section 1.5 of our Privacy Policy.
Professional or Employment-Related Information: information you provide to us directly; information from our customers, partners, or other members.
Inferences: information you provide to us directly or through your interactions with our Services; information from our customers and partners.
Personal information described in Cal. Civ. Code §1798.80(e) (such as name, address, telephone number, education, employment history, credit card or debit card number): information you provide directly or through your interactions with our Services; information from our customers or partners.
Audio, electronic, visual or similar information: information you provide directly or through your interactions with our Services, Members or Customers.
We use the above personal information for the purposes outlined in Section 2 of our Privacy Policy.
4. The CCPA Categories of Personal Information We Share for a “Business Purpose”
While we do not sell your personal information, we may share it to support our own operational purposes in providing our Services to you, as described in our Privacy Policy. These operational purposes, known as “business purposes” under the CCPA, are described below. In addition, we may share personal information at your direction, such as when you choose to communicate with other members through our Services.
4.1 Auditing Interactions
We may share the types of personal information listed in Section 3 with Vendors and related companies in order to audit interactions and transactions.
4.2 Security Purposes
In order to secure our Services, including to detect, prevent, and investigate security incidents or violations of our Professionalism Policy or applicable laws, we may share the types of personal information listed in Section 3 with our Vendors, law enforcement, and related entities.
4.3 Service Improvements
In order to improve our Services (such as to identify bugs, repair errors, or ensure that Services function as intended) or conduct internal research and analysis to improve our technology, we may share the types of personal information listed in Section 3 with our Vendors and related entities.
4.4 Vendors and Other Notified Purposes
We may share the types of personal information listed in Section 3 with Vendors or Service Providers as defined by the CCPA in order to have them perform services specified by a written contract or with others for a notified purpose permitted by the CCPA (e.g., to respond to law enforcement requests).