Comtrade (Comtrade Inc., 275 Grove St. Suite 2-400, Newton, MA 02466, USA) operates the Voyego Platform with aim to enable Business Users to provide hospitality industry services to End Users, and to enable End Users to inquire and purchase hospitality industry services from Business Users.

This Privacy Policy applies to the Comtrade’s use of personally identifiable information (PII) on the Voyego Platform.

For the use of the specific parts of Voyego Platform this Privacy Policy may be supplemented (or superseded) by Supplemental (or complete, when superseded) Product or Service Specific Privacy Policy, governing the Comtrade’s use of PII in the specific product or service. Supplemental (or entire, when superseded) Product or Service Specific Privacy Policy is presented to the user before the specific product or service is available to user. If Product or Service Specific Privacy Policy does not declare itself otherwise and it pertains to the Voyego branded product and/or service by Comtrade, it is Supplemental and supplements this Privacy Policy.

Business Users may publish and enforce their own Privacy Policies that apply to their use of PII on the Voyego Platform.

For the exact meaning of terms: Voyego Platform, Business User, End user, Comtrade Contractual Partners, Business Services and End User Services use the Voyego Platform Terms of Use.

Information Comtrade Collects

Throughout the Voyego platform Comtrade Collects different types of PII and associates it with other data about individuals, to be able to provide services to Business Users and End Users.

Comtrade collects PII from End User and Business User input, or based on legal relationship between Comtrade and Business User through integration.

PII submitted by Business Users

Business User is responsible that forwarding PII to Comtrade is compliant with applicable legislation governing the legal relation between Comtrade and Business User.

PII submitted by organizational End Users

Organizational End User (legal entity) is responsible that forwarding PII to Comtrade is compliant to applicable legislation governing the legal relation between Comtrade and End User.

PII collected, acquired and/or processed by Comtrade

PII and associated attributes may include:

– general identification data and attributes, such as personal name and addresses (contacts, residence, etc.), gender birth data, unique personal identifiers etc.
– login information, such as username and password (encrypted),
– technical user profile for the use of Voyego platform (preferences, settings),
– communication metadata needed for Voyego platform (IP address, device IDs, connection times, data addresses retrieved, error statuses, etc.), recent history of it for troubleshooting purposes,
– location data,
– past and current actions of users in Voyego platform,
– aggregated business profile of the user (types of personal interests and preferences that may be of interest for hospitality industry)
– social network or other groups membership.

Comtrade may collect and/or store all above types of data for all services and/or products.

Comtrade does not collect nor store Cardholder Data in the sense of Payment Card Industry Data Security Standard.

How Comtrade uses and processes Personally Identifiable Information

Comtrade may use PII to:

– provide the services of Voyego Platform to the End User and Business User,
– including provide customized information in the scope of hospitality industry, via Voyego Platform itself and external communication channels integrated with Voyego platform, such as e-mail,
– including direct targeted/customized marketing, unless you opt out;
– troubleshooting in case of problems,
– prevent fraud,
– direct targeted marketing for Comtrade’s own purpose (services provided outside Voyego Platform and/or hospitality industry), unless you opt-out.

Comtrade does not necessarily exercise all stated uses all the time or/and on all applicable markets, channels, products and/or services. Comtrade may start or stop exercising any of stated use at any time, on any applicable market, product and/or services that is part of Voyego Platform, at its own sole discretion.

Security

Comtrade will use reasonable effort to protect the security of PII and associated attributes. Voyego Platform uses a variety of security technologies and procedures to help protect PII from unauthorized access, use, or disclosure. Examples include access control to the PII, and use of Transport Layer Security (TLS) or Secure Socket Layer (SSL) for encryption and integrity when PII travel over public network.

If your user password is used to help to protect your accounts and PII, it is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a device (computer, smart phone, tablet etc) with anyone you should always make sure you are logged out of a service to protect access to your information from subsequent users. Some parts of the Voyego platform are protected only by security measures, provided by your device, so it is your sole responsibility to protect your device from unauthorized use.
You are responsible for protecting your device (computer, smart phone, tablet) from malware. In case that user’s device is infected with malware, Comtrade cannot be hold responsible for unauthorized disclosure of, or tampering with your PII, or other malicious deeds the malware is capable of, and all related consequence.

Outsourcing

Comtrade may outsource processing of PII to external provider with appropriate security. Comtrade remains responsible for security of PII to the extent defined in this Privacy Policy even if processing of PII is outsourced.

Sharing Personally Identifiable Information

Cases where Comtrade shares PII with other parties:

– Outsourcing: Comtrade may use external provider for some services that are part of the Voyego Platform. In this case PII are shared with the external provider, limited to the purpose of specific service outsourced.
– Affiliates: Comtrade may engage Affiliates (other than Business Users) to promote and sell Voyego Platform’s services either to Business Users or End Users, and share PII needed for promotion and selling, with Affiliates.
– Comtrade Group: Comtrade may share PII with other companies in Comtrade group, for the purpose of developing, maintaining, operating, promoting and improving the Voyego Platform. Members of Comtrade group will handle the PII according to this Privacy Policy.
– Legal Proceedings, Administrative Procedures: Comtrade will present PII needed to defend its interest in legal proceedings and administrative procedures.

– When relevant law requires us to do so, we will share PII to applicable authorities.
– Comtrade may share PII of individual End Users, and individuals, that act on behalf of organizational End Users, to Business Users and other parties from hospitality Industry, as a part of Comtrade’s services for hospitality industry market.
– Change of ownership of Comtrade and/or Voyego Platform: In course of its business activities, the Voyego Platform or Comtrade may be acquired by third party. Third party succeeds all Comtrade’s rights and obligations related to PII bound to the Voyego Platform with the acquisition of Comtrade.
– Cease of existence: In case Comtrade’s cease of existence, there is a chance that PII bound to the Voyego Platform will be transferred to third party.

Accessing Your Personal Information

You may access most of your PII through your user profile in the Voyego Platform. If you have further inquiry about your PII in the Voyego Platform, please contact Comtrade as stated in Contact section of this Privacy Policy.

Cookies and Similar Technologies Use

Comtrade uses cookies (and sometimes also similar technologies, such as web beacons, HTML5 storage, and local storage in mobile apps) for certain functions of Voyego Platform. For more information about cookies, please visit http://www.allaboutcookies.org/ .

Comtrade does not use tracking cookies in the Voyego Platform. Comtrade may add services that rely on tracking cookies when promoting the use of Voyego Platform.
Examples where Comtrade uses cookies are:

– Analytics to improve the Voyego Platform (not associated with your real identity),
– Enabling user login on web pages (associated with your real identity),
– Store the preferences, e.g. display language, of unauthenticated user visiting the web page of the Voyego Platform (not associated with your real identity).

Children

Children under 13 years of age are not allowed to use the Voyego Platform.

FERPA imposes requirements on U.S. educational organizations regarding the use and disclosure of student education records

Display of Advertising

For the services and products related to the Voyego Platform and/or hospitality industry, where we do provide targeted direct marketing , we provide you the opt-out page here link.

For the services and products other than hospitality industry, you are given opt-in opportunity when you register to the Voyego platform and accept Terms of Use. You can change your preference later in your profile preferences link.

Location Based Services

Certain services or features can use information about your location to provide services you request or personalize your experience. Location information may include data identifying nearby cell towers and Wi-Fi hotspots, as wells as Global Position System (GPS) data, or your IP address, beacons on hospitality premises only.

Voyego Account

Contact

For any inquiries related to processing of PII in the Voyego Platform, or your privacy as it relates to the Voyego Platform, please contact:

Comtrade Inc.
275 Grove St. Suite 2-400
Newton
MA 02466
USA
Phone: +1 617 663 4871
File Number: 000964802
e-mail: info.us@comtrade.com (English)

Other contacts:

http://www.voyego.net/about-us/

 

1) Supplemental Product or Service Specific Privacy Policy – VOTG (Voyego On-The-Go)

 

This Supplemental Product or Service Specific Privacy Policy for VOTG supplements the Voyego Platform Privacy Policy. link
To be able to use all functionality in Voyego On-The-Go application, you will have to register your application against the hotel’s system. Key information while registering is your e-mail address that you have used for booking process. You will be asked to provide your e-mail address, to which you will receive a security token. Security token has a limited validity of 2h, after that you will have to request another one. Once security token is provided, your application/device will be linked to your account in the hotel’s system.

To speed up Check-IN process, in My Profile you can fill out yours and your accompanying guest’s data, which includes:

– Gender
– First name and last name
– Date of Birth
– Address
– City
– Post number
– State/Country
– Phone
– E-mail
– Document ID
– Arrival/departure

To speed up Check-OUT process, in case you want to split your bill between private and company folios, you will have to enter company’s data which includes:

– Name of the company
– VAT ID
– Address
– City
– Post number
– State/Country
– Phone
– E-mail

Application does not need your credit card number to initiate orders.

 

2) Supplemental Product or Service Specific Privacy Policy for Voyego Surprise/Aquapass

 

This Supplemental Product or Service Specific Privacy Policy for Voyego Surprise/Aquapass supplements the Voyego Platform Privacy Policy.

The End Users of Voyego Surprise/Aquapass service provides the following PII:

– First name and last name
– E-mail
– Address
– Postal code
– Country
– Telephone
– Loyalty card number

 

3) Supplemental Product or Service Specific Privacy Policy for Voyego Guest Experience Manager (GEM)

 

This Supplemental Product or Service Specific Privacy Policy for Voyego GEM supplements the Voyego Platform Privacy Policy.

The Business Users of Voyego GEM service provides the following PII:

– Gender
– First name and last name
– Address
– City
– Postal code
– Country
– Telephone
– Loyalty card number
– Date of birth
– Email

 

4) Supplemental Product or Service Specific Privacy Policy for Voyego Events

 

This Supplemental Product or Service Specific Privacy Policy for Voyego Events supplements the Voyego Platform Privacy Policy.

The End Users of Voyego GEM service provides the following PII:

– Gender (title)
– First name and last name
– Address
– City
– Postal code
– Country/State
– Telephone
– Loyalty card number
– Email

 

5) Supplemental Product or Service Specific Privacy Policy for Voyego Booking

 

This Supplemental Product or Service Specific Privacy Policy for Voyego Booking supplements the Voyego Platform Privacy Policy.

The End Users of Voyego Booking service provides the following PII:

– First name and last name
– E-mail
– Address
– Postal code
– Country
– Telephone
– Loyalty card number