Privacy Policy

This Privacy Notice for Detour (Individual Entrepreneur) ("we", "us", or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at detourguidee.com, or any website of ours that links to this Privacy Notice
• Use Detour. Detour is a digital travel guide book in PDF format. The guide includes curated walking routes, restaurant and bar recommendations, hidden attractions, beaches, hikes, and day trips.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@detourguidee.com.

Legal Compliance

We are committed to handling your personal data responsibly and in accordance with applicable privacy laws. Our practices are designed to align with the General Data Protection Regulation (GDPR) for users in the European Union and European Economic Area, and we extend these same protections to all our users worldwide. As an independent creator based in Ukraine, we respect the privacy rights of every user regardless of their location, and provide the protections outlined in this Policy.

Summary of key points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We receive feedback voluntarily submitted through Google Forms, which is hosted by a third party. We do not otherwise collect information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

Table of contents

1. 1. What information do we collect?
2. 2. How do we process your information?
3. 3. What legal bases do we rely on to process your information?
4. 4. When and with whom do we share your personal information?
5. 5. Do we use cookies and other tracking technologies?
6. 6. Is your information transferred internationally?
7. 7. How long do we keep your information?
8. 8. How do we keep your information safe?
9. 9. Do we collect information from minors?
10. 10. What are your privacy rights?
11. 11. Controls for do-not-track features
12. 12. Do United States residents have specific privacy rights?
13. 13. Do other regions have specific privacy rights?
14. 14. Do we make updates to this notice?
15. 15. How can you contact us about this notice?
16. 16. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• feedback and responses voluntarily submitted via Google Forms

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Creem. You may find their privacy notice link here: https://www.creem.io/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect approximate location data based on your IP address. This helps us understand where our users are located. We do not collect precise GPS-based location data.

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When and with whom do we share your personal information?

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We work with third-party vendors whose terms of service and privacy policies include data protection commitments. We encourage you to review their respective privacy policies linked in this section.

The third parties we may share personal information with are as follows:

• Payment Processing and Digital Delivery: Creem (creem.io). Creem acts as our Merchant of Record and also hosts the secure download page through which your purchased guide is delivered. Creem may process your name, email address, payment details, and download activity. Please review Creem's Privacy Policy at https://www.creem.io/privacy for more information.
• Feedback Collection: Google Forms (Google LLC). When you submit feedback via our Google Form, your responses are stored and processed by Google. Please review Google's Privacy Policy at https://policies.google.com/privacy for more information.
• Website Hosting: Cloudflare
• Website Analytics: Google Analytics (Google Ireland Ltd.), only if you accept cookies on our website. Google may receive your IP address, browser and device information, the pages you visit, how you arrived at our website, and events such as starting checkout or completing a purchase (including order value and order ID). Please review Google's Privacy Policy at https://policies.google.com/privacy for more information.
• Advertising Measurement: Meta Platforms Ireland Ltd. (Meta Pixel), only if you accept cookies on our website. Meta may receive your IP address, browser and device information, the pages you visit, and events such as starting checkout or completing a purchase (including order value and order ID). Please review Meta's Privacy Policy at https://www.facebook.com/privacy/policy/ for more information.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we use cookies and other tracking technologies?

Essential. We use your browser's local storage to remember your cookie choice and to avoid counting the same purchase twice. This is necessary for the website to work and does not require consent.

Analytics (optional). With your consent, we use Google Analytics 4, provided by Google Ireland Ltd. It sets cookies (such as _ga and _ga_*) and collects information about your visit: pages viewed, how you arrived at our website (for example, from Instagram or an ad), approximate location derived from your IP address, browser and device information, and when you start checkout or complete a purchase (order value, currency, and order ID). We use this to understand how visitors use our website and to improve it. Google may transfer this information outside the EEA. Our legal basis for this processing is your consent (Art. 6(1)(a) GDPR).

Advertising measurement (optional). With your consent, we use the Meta Pixel, a tracking technology provided by Meta Platforms Ireland Ltd. It sets cookies (such as _fbp and _fbc) and sends Meta information about your visit: page views, when you start checkout, and when you complete a purchase (order value, currency, and order ID), together with your IP address and browser and device information. We use this to measure the results of our ads on Facebook and Instagram and to show them to people who are more likely to be interested. Meta may combine this information with data it holds about you if you have a Meta account, and may transfer it outside the EEA. Our legal basis for this processing is your consent (Art. 6(1)(a) GDPR).

Neither Google Analytics nor the Meta Pixel is loaded until you click "Accept" in the cookie banner. You can change or withdraw your choice at any time via Cookie Settings (also linked in the website footer). Withdrawing consent stops further data from being sent to Google and Meta and removes their cookies from our domain.

When you click through to our feedback form hosted on Google Forms, you will be redirected to Google's domain where Google's own privacy policy and cookie practices apply independently of ours.

6. Is your information transferred internationally?

Our servers are located in the United States and European Union. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), including facilities in the United States, European Union, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

7. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 5 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 16 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 16 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 16 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 16 or the equivalent age as specified by law in your jurisdiction, please contact us at support@detourguidee.com.

10. What are your privacy rights?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent to advertising cookies at any time via Cookie Settings, and any other consent by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at support@detourguidee.com.

11. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

12. Do United States residents have specific privacy rights?

Categories of Personal Information We Collect. The categories of personal information we have collected in the past twelve (12) months are limited to identifiers — such as your name and email address. We do not collect sensitive personal information, biometric information, financial details we store ourselves, or other categories beyond those described in this notice.

Sources of Personal Information. We collect this information directly from you and automatically when you use our Services, as described in section "WHAT INFORMATION DO WE COLLECT?"

Your Rights. You have rights under certain US state data protection laws, which may include the right to: request access to and obtain a copy of your personal information; correct inaccuracies; request deletion; and opt out of the processing of your personal information for targeted advertising, the sale of personal information, or profiling. We will not discriminate against you for exercising any of these rights.

How to Exercise Your Rights. To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at support@detourguidee.com, or by referring to the contact details at the bottom of this document.

Request Verification. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.

Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us. If your appeal is denied, you may submit a complaint to your state attorney general.

13. Do other regions have specific privacy rights?

Australia and New Zealand. We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act). This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information. If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services. At any time, you have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa. At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are: The Information Regulator (South Africa), complaints.IR@justice.gov.za.

14. Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at support@detourguidee.com or contact us by post at:

Detour (Individual Entrepreneur)
Ukraine
support@detourguidee.com

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.