Effective Date: 15 March 2021

Emmy Blue respects your privacy. Set out here is the personal information we collect, what we do with it and your choices and rights.

By using our website and services, you confirm you have read and understood this Privacy Policy and our Cookie Policy.

1. Some key terms

In our Privacy Policy, when we refer to you, we mean clients, customers and guests who use our services, including visitors to our site. 

2. How does this Privacy Policy apply?

This Privacy Policy describes what we do with personal information that we collect and use for our own purposes such as how you use and interact with our services, including information you submit to our team.

We use cookies and similar technologies. Our Cookie Policy describes what we do in that regard.  

3. Personal information we collect

We collect various personal information regarding you or your device. This includes the following:

• Information you provide specifically such as email address, first name and last name. 
• If you pay for services or bookings, we receive a portion of your payment information from our payment processor (such as the last four digits, the country of issuance and the expiration date of the payment card) and we ask you to select your jurisdiction.
• Your marketing preferences.
• The emails and other communications that you send us or otherwise contribute, such as customer support inquiries.
• The messages we exchange via messenger service to coordinate your bookings and travel, and enhance your experience.
• Information you share with us in connection with surveys, contests or promotions.
• Information from your use of our services. This includes: IP addresses, preferences, web pages you visited prior to coming to our site, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the services (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).
• Information we get from our partners to support our marketing initiatives, improve our services and better monitor, manage and measure any ad campaigns.
• Other information you submit to us directly or through third party services, which are partners and applications we’ve selected in order to provide you with our services.

4. How we collect personal information

We obtain personal information from various sources. We do this in three main ways:

• You provide some of it directly (such as by registering).
• We record some of it automatically when you use our services (including with technologies like cookies).
• We receive some of it from third parties (like when you register for an account using a third party service or when you make payments to us using our payment processor).

5. How we use your personal information

We use the personal information we obtain about you to:

• Provide our services. Provide and personalize our services, process payments and respond to your inquiries.
• Communicate with you. Communicate with you, including by sending you emails about your transactions and service-related announcements.
• Surveys and contests. Administer surveys, contests and other promotions.
• Promotion. Promote our services and send you tailored marketing communications about products, services, offers, programs and promotions -- and measure the success of those campaigns. 
• Advertising. Analyze your interactions with our services and third parties’ online services so we can tailor our advertising to what we think will interest you. 
• Customizing the services. Provide you with customized services.
• Improving our services. Analyze and learn about how our services are accessed and used, evaluate and improve our services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. 
• Security. Ensure the security and integrity of our services.
• Third party relationships. Manage our vendor and partner relationships.
• Enforcement. Enforce our legal terms and policies.
• Protection. Protect our and others’ interests, rights and property.
• Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

We process your personal information for the above purposes when:

• Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.  
• Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one.
• Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
• Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:
  • To operate Emmy Blue and provide you with tailored advertising and communications to develop and promote our business.
  • To analyze and improve the safety and security of our services - we do this as it is necessary to pursue our legitimate interests in ensuring Emmy Blue is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.
  • To provide and improve our services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to you on a sustained basis.
  • To anonymize and subsequently use anonymized information.
• Protecting you and others. To protect your vital interests, or those of others. 
• Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness.  

6. How we share your personal information

We share personal information in the following ways:

• Affiliates. We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
• Business partners.  We may share personal information with business partners. For example, we may share your personal information when our services are integrated with their third party services, but only when you have been informed or would otherwise expect such sharing.
• Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.
• Process payments. We transmit your personal information via an encrypted connection to our payment processor.  
• Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests or prevent fraud or abuse. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
• Advertising. We share personal information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. 
• Business transfers. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.

7. Your rights and choices

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information. You can also exercise your other rights (including cancelling your membership and deleting your content) by contacting us.

You can also elect not to receive marketing communications by following the unsubscribe instruction in such communications.

Our Cookie Policy explains how you can manage cookies and similar technologies.

8. How we protect your personal information

While no service is completely secure, we are committed to keeping personal information safe. We maintain administrative and technical safeguards intended to appropriately protect against accidental or unlawful access.

9. How we retain your personal information

We retain personal information regarding you or your use of our services for as long as you’re a member or for as long as needed to provide you with the services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.  

 

Please note that in the course of providing our services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

10. Data transfers

Personal information that you submit through our services may be transferred to countries other than where you live, such as, for example, to our servers in the U.S. We also store personal information locally on the devices you use to access our services.

Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.

11. Updates to this Privacy Policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites.

12. How to contact us

If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at landi@emmy.blue.