Monaeo, Inc. is a technology and analytics company helping business travelers live and work better. This document details information regarding the use and disclosure of user data collected through Monaeo’s services. The security of your data is important and we will attempt to take commercially reasonable steps to limit any risk that it may be lost, damaged or misused.
We do not provide any facility for sending or receiving private or confidential electronic communications. However, we may allow users to e-mail files and information to others from within the Services. Any sending or receiving capabilities are provided by your own e-mail service and are not provided by us.
Please note that this site may be hosted on servers located both inside and outside the United States. Therefore, your information may be processed and/or stored in a variety of countries. As a result, federal, state, and local governments, courts, law enforcement, or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the countries in which information is processed and stored. Your use of these Services, or your submission of any personal information, will constitute your consent to the transfer of your personal information outside of your home country, including the United States, which may provide for different data protection rules than in your jurisdiction.
1. Data Collected
The transmission of data via the Internet can never be completely secure. We use commercially reasonable physical and technical safeguards to preserve the security of your personal data. However, we cannot warrant the security of any data you transmit to the Services and you do so at your own risk.
A username and password is required to use several features. Personal information may be requested at time of registration, including an email address, phone number and domicile location. Personal information may be added on a voluntary basis after registration.
When you visit our Services, we may send one or more cookies to your computer that uniquely identifies your browser session. Our Services uses both session cookies and persistent cookies. If you delete your persistent cookie, some of our Services’ features may not function properly.
When you visit our Services, our servers may automatically capture information that your web browser sends, including but not limited to: the web request, IP address, browser type, browser language, referring URL, platform type, domain names and the date and time of your request.
We receive and store any information you enter on our Services or provide to us in any other way. We automatically receive your location when you use the Services. Your location may include country, state, and city information, and/or GPS coordinates such as latitude or longitude. If you ask us to remember your phone number, we will associate your phone number with your account. If you change your device or hardware, you will have to re-associate this new device or hardware with your account by downloading the relevant application and logging in using your username/password.
Should you ever delete your account (your profile including your location history), or only location records, your location information will be removed from the Services and deleted from our servers, and any third party servers under our direction. Because of the way we maintain the Services, such deletion may not be immediate and residual copies of your profile information or location information may remain on backup media for up to 180 days. Unless you delete your account, your location information will be retained by Monaeo for your use.
We may provide methods to export, download, and otherwise retrieve user information, including location information, from the Services. We will strive to, but cannot guarantee, the accuracy of any exported data. We will not be responsible for the privacy or security of exported data in your possession.
If you contact us, we may keep a record of that correspondence.
2. How Collected Data is Used
Your information submitted to the Services may be used to provide both regular and personalized features. We will not sell collected data to third parties.
We may send to you information regarding products or services offered by our affiliates or partners, inform you about any of our related products or services, or provide you with information about any item that we think, in our sole discretion, may be of interest to you.
We may also use your email address for non-marketing or administrative reasons.
We may analyze aggregated user patterns to increase the efficiency of our marketing and hosting operations, and to generally improve the quality of the Services.
We may employ other companies and people (“Agents”) to perform tasks on our behalf and may need to share data, including any information you provide us, with them to provide services to you. Our Agents do not have any right to use personal information we share with them beyond what is necessary to assist us.
3. When We Disclose Information
We may disclose personal information collected via the Services (including but not limited to personal and location information) to third parties to comply with any court order, such as a subpoena, or other legal obligation, protect the rights, property, or safety of the Company, our customers, or others. It is our policy, whenever commercially possible and legally permissible, to attempt to notify you of an obligation to supply data to any third party.
If the Company or substantially all its assets are acquired, or in the unlikely event that the Company goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party.
4. How We Send Notices
Any notice required to be given under this Agreement may be provided by email to a functioning email address or by a general posting on the Services. You can change the email address to which notice is to be sent at any time. Notices by customers to us shall be given by electronic messages.
5. EU-US Privacy Shield Policy
The United States Federal Trade Commission (FTC) is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.
These are our promises to you:
- Notice. When we collect your personal information, we’ll give you timely and appropriate notice describing what personal information we’re collecting, (see Section 1, “Data Collected”), how we’ll use it (see Section 2, “How Collected Data is Used”), and the types of third parties with whom we may share it (see Section 3, “When We Share Your Data”).
- Choice. Monaeo does not currently share personal information with any third parties, but if in the future our data sharing policy changes, we will offer individuals appropriate opt-in or opt-out choice.
- Accountability for Onward Transfer.If we transfer your personal information to a third party, we’ll take appropriate measures to keep your personal information secure. Monaeo is potentially liable in cases of onward transfers of Privacy Shield data to third parties.
- Security. We’ll take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
- Data Integrity and Purpose Limitation. We will take appropriate steps to make sure your personal information is not used in ways other than that for which it was supplied.
- Access. We acknowledge the individual’s right to access their data. We’ll provide ways for you to access your personal information, as required by law, so you can correct inaccuracies, or delete your data (see Section 1, “Data Collected”).
- Recourse, Enforcement and Liability. We’ll regularly review how we’re meeting these privacy promises, and we’ll provide an independent way to resolve complaints about our privacy practices.
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Monaeo has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Monaeo is subject to the investigatory and enforcement powers of the FTC. Under certain limited conditions, “last resort” arbitration may be invoked.
Monaeo may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirement (see Section 3, “When We Share Your Data”).