Index
- 1. PRIVACY STATEMENT
- 2. WHAT PERSONAL INFORMATION WE COLLECT
- 3. HOW WE USE YOUR PERSONAL INFORMATION
- 4. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION
- 4.1. Our Affiliates and Subsidiaries
- 4.2. Our Agents, Service Providers and Suppliers
- 4.3. Legal Requirements
- 4.4. Business Transfers
- 5. CONSENT AND YOUR RIGHTS TO ACCESS DATA
- 6. USE OR DISCLOSURE FOR MARKETING PURPOSES
- 7. HOW WE PROTECT YOUR PERSONAL INFORMATION
- 8. RETENTION AND STORAGE OF YOUR PERSONAL INFORMATION
- 9. COOKIES
- 10. LINKS TO THIRD PARTY SITES
- 11. CHANGES TO THIS PRIVACY POLICY
- 12. ACCESSING, CORRECTING, UPDATING, OR DELETING YOUR INFORMATION
- 13. CONTACTING US
- 14. COUNTRY SPECIFIC ADDENDUM
- 14.1. Mexico
1. PRIVACY STATEMENT
NexusTours (“we” or “us”) are committed
to protecting your privacy, and support a general policy of openness about how
we collect, use and disclose your Personal Information (as defined below). The purpose of this Privacy Policy is to
inform you about NexusTours’ practices relating to the collection, use and
disclosure of Personal Information that may be provided through access to or
use of our websites, services or products or that may otherwise be collected by
us.
This Privacy Policy also
explains how you can contact us if you have a question about, want to access,
make a change to, object to the processing of or delete any Personal
Information that NexusTours may be holding about you. As one of our clients or someone
else with whom we do business, you understand and agree that we collect, use
and disclose your Personal Information in accordance with this Privacy Policy.
While
this Privacy Policy is intended to describe the broadest range of our Personal Information
processing activities globally, those processing activities may be more limited
in some jurisdictions based on the restrictions of their laws. For example, the
laws of a particular country may limit the types of Personal Information we can
collect or the manner in which we process that Personal Information. In those
instances, we adjust our internal policies and/or practices to reflect the
requirements of local law.
For the purpose of this Privacy
Policy, “Personal Information” means information about you that is personally
identifiable as defined in accordance with applicable law. The types of personal
information that we may collect and process (which may vary by jurisdiction
based on applicable law) include, but not limited to:
-
• your
name and surname, gender, personal and work contact details (such as
address, telephone number, e-mail address) business title, date and place
of birth, image, nationality, and passport and visa information, travel
dates, flight schedules, name of your hotel and room number;
- • guest
stay information, including hotels where you have stayed, dates of arrival
and departure, goods and services utilized, special requests made, excursions
you registered for and information concerning any incidents;
- • your
credit card or debit card details (including security code) or other means
of payment accepted by NexusTours; your ID and ID number;
- • any
information necessary to fulfil special requests (i.e. health conditions
that require specific accommodation or services);
- • information,
feedback or content you provide regarding your marketing preferences, in
surveys, contests, or promotional offers, or to our websites and those of
third parties that have a commercial relationship with NexusTours;
- • information collected while at a NexusTours
transportation or excursions through the use of closed circuit television
systems, internet systems (including wireless networks that may collect
data about your computer, smart or mobile device, or your location), and
other security and technology systems;
- • images and audio of you captured by surveillance cameras during NexusTours
transportation and excursions; and,
- • information
collected while you access a NexusTours website (we describe this in more
detail in Section 9 below).
We may collect data that is
sensitive such as ethnic background or origin, religion, past and current
health, and will seek your consent under applicable law. This sensitive data
will be treated accordingly.
The Personal
Information we process is information that you or someone acting on your behalf
knowingly provides to us or information that we receive from a third party. In
case of Personal Information belonging to minors or mentally incapables under
applicable law, we will seek consent of parents, legal guardians or legal
representatives, as appropriate. Parents, legal guardians or legal
representatives shall exercise data protection rights on behalf of such minors
or mentally incapable people.
This
Privacy Policy also applies to the Personal Information about you that we
receive from a third party, unless specifically covered by such third party’s
privacy policy.
Subject
to applicable laws, we may collect, use and disclose your personal information
in order to:
-
• book, register, confirm, provide
and charge for your hotel accommodations, special requests, transportation,
excursions (provided by NexusTours directly or through third party service
providers), and other goods and services requested by you, including those
services requested to third parties with a commercial relationship with NexusTours;
- • provide you with a better or more
personalized level of service, including providing information and
services from a third party (such as processing special requests regarding
accommodation and providing additional services of NexusTours, local
attractions, excursions and transportation);
- • respond to requests for
information and services, including services from a third party (such as hoteliers,
transportation providers and providers of excursions);
- • fulfil contractual obligations to
you, anyone involved in the process of making your travel arrangements (i.e.
tour operators, travel agents, group travel organizers or your employer)
and vendors (i.e. credit card companies, airline operators, hoteliers, excursion
and transportation providers);process claims we receive in connection
with our services;
- • provide customer support and respond to
and communicate with you about d your requests, questions and comments;
- • provide for the safety and
security of staff and clients;
- • administer general record keeping;
- • meet legal and regulatory
requirements;
- • advise you about new products and services that may be of interest
to you, subject to your consent in accordance with applicable laws (may be
considered as secondary or non-necessary purpose);
- • communicate about, and administer your participation in, special
events, programs, surveys, contests and other offers or promotions, subject to
your consent in accordance with applicable laws (may be considered as secondary
non-necessary purpose);
- develop and maintain our relationship with you and communicate
with you;
- • bill you for our products and services and collect outstanding
debts; and
- • perform data analyses and conduct other research (such as market
and consumer research and trend analysis) to develop, manage, protect and
improve our products and services, website, and business (including analyzing
the effectiveness of our marketing, sales and advertising) (may be considered
as secondary non-necessary purpose).
Except with your consent, we
will not transfer or assign in any form your Personal Information to or with
third parties. From time to
time, we may disclose your Personal Information as set out below. We would
always make that disclosure in accordance with applicable law. In some
jurisdictions, data privacy laws may require us to obtain your consent before
we transfer your information from your originating country to other countries.
When you agree to this Privacy Policy, you are, to the extent required and
permitted under your local law, granting your consent to the transfer of your Personal
Information to such other countries for the purposes set out in this Privacy
Policy and to the extent stated in this section and as described in Section 3
above. Circumstances where we might make
such disclosure (in addition to those described in Section 3 above) include:
4.1. Our Affiliates and Subsidiaries
NexusTours may disclose and you authorize NexusTours to disclose your Personal Information with its affiliates and subsidiaries including Blue Diamond Hotels and Resorts Inc.
4.2. Our Agents, Service Providers and Suppliers
NexusTours may share and you authorize NexusTours to share your
Personal Information with third parties engaged to assist NexusTours in providing
services to you or to carry out one or more of the purposes described above.
These third parties are prohibited from using your Personal Information for any
purpose other than to provide those services and we
oblige those third parties to protect your Personal Information in accordance
with the terms and conditions of this Policy, with appropriate security
measures. These third parties may not process or
otherwise use your Personal Information, except in accordance with this Privacy
Policy and in accordance with applicable law.
4.3. Legal Requirements
NexusTours reserves the right
to disclose Personal Information to a third party if a law, regulation, search
warrant, subpoena or court order legally requires or authorizes us to do so, or
in the context of discovery procedures or
if we determine it is necessary or desirable to comply with the law or to
protect or defend our rights or property in accordance with applicable laws. We
also reserve the right to retain Personal Information collected and to process
such Personal Information to comply with accounting and tax rules and
regulations and any specific record retention laws.
4.4. Business Transfers
NexusTours reserves the right to disclose and/or transfer Personal
Information to a third party in the event of a proposed or actual purchase,
sale (including a liquidation, realization, foreclosure or repossession),
lease, merger, amalgamation or any other type of acquisition, disposal,
transfer, conveyance or financing of all or any portion of NexusTours or of any
of the business or assets or shares of NexusTours or a division thereof in
order for you to continue to receive the same products and services from the
third party in accordance with applicable law and you consent to such
disclosure and/or transfer.
5. CONSENT AND YOUR RIGHTS TO ACCESS DATA
NexusTours collects Personal
Information about you only when you voluntarily provide it. You may always choose what Personal
Information (if any) you wish to provide to us. However, if you choose not to
provide certain details, some of your experiences with us may be affected (for
example, we cannot take a reservation for transportation or excursions without
a name).
We will seek consent for the
use or disclosure of your Personal Information at the time of collection. Subject to applicable laws, you have the
right to access, correct or request the deletion of your Personal Information
at any time. In certain circumstances,
you may have the right to object to the processing of your Personal Information.
In such case, please contact our Privacy Officer as described below under
“Contacting Us”.
You also have the right to
withdraw your consent at any time, subject to legal restrictions and where
applicable reasonable notice is required.
If you wish to withdraw your consent,
please contact our Privacy Officer as described below under “Contacting Us”.
We will not, as a condition of
the supply of a product or service, require you to consent to the collection,
use or disclosure of information beyond that required to fulfill the explicitly
specified and legitimate purposes for which the information is being provided.
6. USE OR DISCLOSURE FOR MARKETING PURPOSES
Your Personal Information will be used for
the purposes described in this Privacy Policy. Many of the purposes described
in this Privacy Policy are necessary for the existence, maintenance or fulfilment
of the relationship between you and NexusTours. We also use your Personal Information
for purposes that may not necessary for the existence, maintenance or
enforcement of your relationship with NexusTours. These non-necessary purposes
include sending you promotional materials, customizing your visits to our sites
and social media channels, delivering content tailored to your interests, and
participating in interest-based advertising.
If you have subscribed to
receive NexusTours and/or its affiliates promotional and marketing emails, we
may also use (but will not disclose) your Personal Information to send you
relevant information by email based on your subscription preferences. We may also disclose your Personal
Information to our affiliates so that they can send you promotional materials
directly by email.
You may unsubscribe at any time by clicking the
unsubscribe link imbedded at the bottom of NexusTours’ email communications. Note, however, that
clients of NexusTours will continue to receive periodic emails that relate to
their business relationship with us.
If you believe that any of the purposes of
use described above do not originate from or are not necessary for your
relationship with NexusTours or if you choose not to allow us to use your
Personal Information for marketing purposes, you may request that we not
process your Personal Information for those purposes by contacting us as
outlined below (see “Contacting Us”).
NexusTours makes commercially reasonable
efforts to ensure that Personal Information collected from you is protected
against loss, theft and unauthorized access, disclosure, copying, use, or
modification. This protection applies in
relation to information stored in both electronic and hard copy form. Access to your Personal Information is
restricted to selected employees or representatives. In addition, NexusTours employs generally
accepted information security techniques, such as firewalls, access control
procedures and cryptography, to protect Personal Information against loss and
unauthorized access.
NexusTours retains your
Personal Information for as long as necessary to fulfill the purpose(s) for
which it was collected according to this Privacy Policy and to comply with
applicable laws, and your consent to such purposes(s) remains valid after
termination of our relationship with you.
9. COOKIES
When you visit our website, we
or one of our third party service providers places a text file called a
“cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that
a website can store on your web browser and later retrieve information. The cookie cannot be read by any website
other than the one that placed the cookie.
Our third party service
providers use cookies on our behalf to collect and store Internet log
information, such as what time the visits occurred, whether the visitor has
been to this site before, and what site referred the visitor to the web page.
Geographic data is also determined by the IP Address of the visitor’s computer.
This information collected by the cookie is transmitted to our third party
service providers and is then used to evaluate visitors’ behaviour and to
generate statistical reports for the website activity on NexusTours’ website,
and may be used for marketing purposes.
You can choose to disable cookies in your
browser at any time by following the procedure described in the Tools or
Preferences menu in your browser. If you choose to modify your browser in this
manner, some pages of this website may not function properly. Further
information about cookies and other similar technology and how they work is
available at allaboutcookies.org.
10. LINKS TO THIRD PARTY SITES
The NexusTours’ website may
offer links to other third party websites.
You should be aware that operators of linked websites may also collect
your Personal Information (including information generated through the use of
cookies) when you link to their websites.
NexusTours is not responsible for how such third parties collect, use or
disclose your Personal Information, so it is important to familiarize yourself
with their privacy policies before providing them with your Personal
Information.
11. CHANGES TO THIS PRIVACY POLICY
NexusTours reserves the right
to modify this Privacy Policy at any time without notice to reflect changes in
legal or regulatory obligations or changes in the manner in which we deal with Personal
Information. The Privacy Policy, including updates and amendments, posted at
any time or from time to time via this website, shall be deemed to be the Privacy
Policy then in effect. This Privacy
Policy is effective as of November 1st, 2018.
You can help us maintain the
accuracy of your Personal Information by notifying us of any changes to this
information. You may also contact NexusTours’ Privacy Officer as indicated below to withdraw your consent for processing
your Personal Information, to access, correct, update, delete or object to the
processing of your Personal Information.
We will inform you of a
decision regarding your request in relation with your Personal Information in
accordance with applicable law. With respect to a request for access to your
Personal Information, we will send you a response by email, fax or postal mail as
provided.
If
you have any questions about this Privacy Policy, about the processing of your Personal
Information, or any concerns or complaints with regard to the administration of
this Privacy Policy, or if you want to submit a written request concerning your Personal
Information, then you may contact our Privacy Officer at
via email at privacy@nexustours.com.
We may require you to confirm
your identity (such as by providing government-issued identification) before
processing any request in relation with your Personal Information.
14. COUNTRY SPECIFIC ADDENDUM
14.1. Mexico
- •Turismo Nexus
S.A. de C.V., Acciones Interdinamicas S.A. de C.V. and Travesías del Caribe
S.A. de C.V. with address at Manzana 66, Lote 24, SMZA 310, Benito Juárez,
CP. 77650, Cancún, Quintana Roo, Mexico, Postal Code 77650, are the companies responsible for
processing and protecting your Personal Information in Mexico according to the NexusTours
Privacy Policy.
- • Any request regarding your Personal Information will be answered within 20 business days from the date of your request.