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CREATOUR, LLC – PRIVACY POLICY

Effective Date: 01/26/1016
 

1. INTRODUCTION: This Privacy Policy ("Policy") outlines how CreaTour, LLC ("CreaTour," "we," "us," "our"), a limited liability company organized under the laws of the Commonwealth of Massachusetts, collects, uses, maintains, and discloses information collected from users ("User," "you," "your") of the CreaTour website and in connection with our travel services ("Services").
 

This Policy applies to the Site and all products and services offered by CreaTour. By using our Site or booking our Services, you signify your acceptance of this Policy.
 

2. INFORMATION WE COLLECT:  We collect information that is necessary to plan, book, and safely operate your tour.
 

2.1 Personal Identification Information (PII) We may collect PII from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, place an order, fill out a form, and in connection with other activities, services, features, or resources we make available on our Site. Users may be asked for, as appropriate:
 

  • Identity Data: Full name, date of birth, passport details, and gender.

  • Contact Data: Billing address, delivery address, email address, and telephone numbers.

  • Financial Data: Bank account and payment card details (processed via our secure third-party payment processors).

  • Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.

  • Sensitive Data: Information regarding your health, dietary requirements, or mobility needs, which we collect only with your explicit consent to ensure your safety and comfort during a Tour.
     

2.2 Non-Personal Identification Information: We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer, and technical information about Users' means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
 

3. HOW WE USE COLLECTED INFORMATION:  CreaTour collects and uses Users' personal information for the following specific purposes:
 

  • 3.1 To Process Transactions & Payments: We use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.

  • 3.2 To Provide Financial Protection: To comply with our legal obligations and ensure the protection of your funds, your data is shared with our financial protection partners.

  • 3.3 To Improve Customer Service: Information you provide helps us respond to your customer service requests and support needs more efficiently.

  • 3.4 To Send Periodic Emails: We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests.
     

4. FINANCIAL PROTECTION & PAYMENT PROCESSING: 

4.1 Payment Processor: We utilize Trust My Travel Ltd (trading as Repayd), a company registered in England and Wales, as our third-party payment processor. By booking with us, you acknowledge and agree that your personal data (specifically Financial and Transaction Data) will be processed by Repayd to facilitate your payment and ensure financial protection.
 

4.2 Data Sharing with Repayd: In accordance with our contractual obligations, we share necessary data with Repayd to:

  • Process your Booking information;

  • Administer the Trust Account and financial protection scheme;

  • Comply with anti-money laundering and fraud prevention laws.
     

4.3 Repayd Privacy Policy: The processing of your data by Repayd is governed by their own privacy policy, which can be viewed here: https://www.repayd.com/privacy-policy (or such other URL as Repayd may provide).
 

5. SHARING YOUR PERSONAL INFORMATION: We do not sell, trade, or rent Users' personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above.
 

We may share your information with these third parties for those limited purposes:
 

  • Service Providers: Destination Management Companies (DMCs), hotels, airlines, and transport providers solely for the purpose of fulfilling your Travel Arrangements.

  • Compliance: To comply with applicable laws, regulations, and legal processes.
     

6. INTERNATIONAL DATA TRANSFERS: To operate your Tour, we must transfer your personal information to our suppliers in the destination country (e.g., Italy, Turkey, Greece). By booking a Tour, you acknowledge that this transfer is necessary for the performance of our contract with you. We implement appropriate safeguards, including Data Processing Agreements (DPAs), with our suppliers to protect your data.


7. DATA SECURITY: We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Site.


8. YOUR RIGHTS (GDPR & CCPA): 

8.1 General Rights: You have the right to access, correct, delete, or restrict the processing of your personal data. You may also object to the processing of your data for direct marketing purposes.

8.2 California Residents (CCPA): If you are a California resident, you have the right to know what personal information we collect, the right to request deletion of your data, and the right not to be discriminated against for exercising these rights. We do not "sell" your personal data as defined by the CCPA.

To exercise these rights, please contact us at the email address listed below.
 

9. CHANGES TO THIS PRIVACY POLICY: CreaTour has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.
 

10. CONTACTING US: If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us at:

CreaTour, LLC 810 Memorial Drive, STE 103 Cambridge, MA 02139 United States Email: info@creatour.com

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