GDPR Privacy notice

Last updated: May 25, 2018

SUMMARY
Data Controllers
FishingBooker Inc.
101 West Main Street, Suite 101,
Norfolk, 23510
Virginia,
USA
Booker Group d.o.o
Omladinskih Brigada 21
110070 Novi Beograd
Belgrade
Serbia
Data Protection Officer Contact Information
Booker Group d.o.o.
Omladinskih Brigada 21
11070 Novi Beograd
Belgrade
Serbia

Purposes of processing

We process your information to fulfil our contractual obligations to you, to comply with applicable laws and to achieve our legitimate business interests. The legitimate interests are providing our services, preventing fraud and securing the FishingBooker platform and improving the FishingBooker platform and the services we offer.

Performance of contract with Users: name, email, phone number, password and authentication tokens, bookings and booking history, listing information and change history, business documents, availability data and change history, business information and payout history.

Complying with applicable laws: postal codes, location data, business documents, business information, payout history.

Legitimate interests
Providing our service: name, email, password and authentication tokens, profile pictures, phone numbers, bookings and booking history, fishing reports, review replies, listing information and change history.
Preventing fraud and securing the FishingBooker platform: IP addresses, change history, location data, communication history and online behavior, government issued ID, professional and business licenses, boat registration certificate and boat insurance policy data.
Improving the FishingBooker platform and the services we offer: postal code, time zone, connected account Facebook, connected account Google ID, notification preferences, booking and booking status history, reviews, profiling and analytics, widget load statistics, NPS score, location data.

Categories of recipients of the data
We transfer your data to two types of recipients
1.  Our processors, which enable us to provide and/or improve our services and store data.
2.  Other FishingBooker Users, which enables us to provide our services and book fishing trips.

International transfer of data
We transfer data outside the EU to be able to provide our services. We use agreements on the basis of EU Model Clauses (sets of clauses issued by the European Commission) to ensure adequate level of data protection between Data Controllers.
Other information
We do not knowingly collect special categories of personal data, and we urge our Users not to share such data while communicating via the FishingBooker platform. We do not knowingly process personal data from persons under the age of 18. If you become aware of a child sharing their data, please contact us so we can delete such data.

POLICY

FishingBooker provides this Privacy Policy to inform you of our policies and procedures regarding the processing, collection, use and disclosure of personal information we receive from Users of https://ru.fishingbooker.com/ and any other products or services made available by FishingBooker. Under this Privacy Policy, FishingBooker Inc is responsible for your information and is the Data Controller.

This Privacy Policy may be updated from time to time. We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your FishingBooker Account) or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use (https://ru.fishingbooker.com/pages/terms).

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

What Information We Process and Why

Under the General Data Protection, a Data Controller must have a legal basis for processing a Data Subject’s data. In the case of FishingBooker, we will process your information to adequately perform our contract with our Users (Data Subjects), to comply with applicable laws and to fulfil legitimate interests we have in providing our service and running the FishingBooker platform.

Adequate performance of our contact with our Users

The following data we collect so we can adequately perform the contract we have with our Users: name, email, phone number, password and authentication tokens, bookings and booking history, listing information and change history, business documents, availability data and change history, business information and payout history.

Legitimate interests

Our legitimate interest in providing our service
The following data we process so we can provide our services: name, email, password and authentication tokens, profile pictures, phone numbers, bookings and booking history, fishing reports, review replies, listing information and change history.

Our legitimate interest in preventing fraud and securing the FishingBooker platform
≈ The following data we process so we can prevent fraud and secure the FishingBooker platform: IP addresses, change history, location data, communication history and online behavior, government issued ID, professional and business licenses, boat registration certificate and boat insurance policy data.

Processing this data enables us to operate the FishingBooker platform, provide customer service, send our Users operative messages, updates, and account notifications. It also enables our Users to communicate and interact with FishingBooker Users and our team.

Processing this data enables us to detect and prevent fraud, abuse, security issues and other activity which may be harmful for our Users or the FishingBooker platform, conduct security investigations and risk assessments, conduct checks against databases and other information sources, comply with legal obligations, resolve any disputes with our Users or between them, enables us to enforce our agreements with third parties, and enforce our policies and Terms of Use.

As part of the Service, FishingBooker Users may communicate with FishingBooker Vendors through use of the "Contact Owner" feature on the Services. If the functionality exists for FishingBooker Users to have selected the option of adding one or more email addresses to an online form, the message they create in the corresponding template will be sent from FishingBooker to those email addresses on their behalf.

Please note that calls to and from FishingBooker may be recorded. We may use the call recordings to monitor our customer service for quality or compliance purposes, to check the accuracy of the information or to provide training to our staff. We will keep the call recordings for as long as is reasonably necessary to perform such activities and then delete them. Any personal information accessed during these calls will be treated in accordance with this Privacy Policy and its provisions.

We may review, scan, analyze and store all communication (including emails, phone calls, messages, etc.) sent or received using FishingBooker communication tools, (including communications with other Users) for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and remove references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve and expand product offerings. Automated methods are used whenever reasonably possible, however, we may need to manually review some communications occasionally. This may be done to provide customer support, conduct fraud investigations as well as assess and improve the functionality of these automated tools. We will not review, scan, analyze or store your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
We reserve the right to block the delivery of or review communications that we, at our sole discretion, believe may contain malicious content, spam, or that may pose a risk to you, our Users, FishingBooker, or others

These communications and their contents may be disclosed in response to lawful government requests or legal process, in other circumstances in which we have a good faith belief that a crime has been committed by a user of our services, that an emergency exists that poses a threat to the safety of our users or another person, if necessary to protect our rights or property, or for us to render the service you have requested.

To make sure that we work with licensed captains and guides, we may collect verification information *such as your government issued ID, Captains/Skipper’s license, local fishing license, boat registration certificate and boat insurance policy) or other authentication information.

Our legitimate interest in improving the FishingBooker platform and our services
The following data we process so we can improve the FishingBooker platform and the services we offer to our Users: postal code, time zone, connected account Facebook, connected account Google ID, notification preferences, booking and booking status history, reviews, profiling and analytics, widget load statistics, NPS score, location data.

Processing this data enables us to measure the performance of our service, make it easier for Users to log into their account and personalize the services to individual Users. Namely, Users may link their FishingBooker Account login information to FIshingBooker through the Site, Service or Application, or may allow FishingBooker to access Users’ Third Party Account, as is permitted under the applicable terms and conditions and that govern your use of each Third Party Account. If you decide to register by logging into a Third Party Account via our Site or Application, we may obtain the personal data you have provided to the applicable Third Party Account and use that information to create your FishingBooker Account and Fishing Booker Account.

When you visit the Services, whether as a FishingBooker User or a non-registered user just browsing, our services automatically record information that your browser sends whenever you visit a website. This data may include information such as your computer’s IP address, browser type or the webpage you were visiting before you came to our Services, pages or features of our Services that you visit or use, the time spent on those pages, information you search for on our Services, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for the technical administration of the Services, to increase the functionality and user-friendliness of the Services, and to better tailor our Services to our visitor’s needs. We also use this information to verify that visitors to the Services meet the criteria required to process their requests. We do not treat this data as Personal data or use It in association with other Personal data, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other non-identifying information.

Cookie policy

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Services. Second, we utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by FishingBooker Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. Third party advertisers on the Services may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or functionality of the Service.

Our Services may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics zto analyze how our Services are used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

Our legitimate interest of direct marketing purposes
The following data we process to provide our Users with direct marketing which may be useful to them: profiling and analytics data and location data.

Complying with applicable laws

The following data we process to be able to comply with applicable laws: postal codes, location data, business documents, business information, payout history.

How we store and secure the information we process

FishingBooker is very concerned with safeguarding your information. When you enter personal information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Services, you can contact us via [email protected]

FishingBooker will have the right to access your account to make any changes to reservations, listings, or profile information at its sole discretion.

How we share your information

With other FishingBooker Users

When you create a FishingBooker Account, we will set up a FishingBooker Account profile page for you. Your FishingBooker Account profile page will include your first name and last name and connections you have established between your Account and any TPAs, and a biography and links to your Listings. You can select the other items of Personal Information that you wish to be included in your FishingBooker Account profile page – including, but not limited to, a profile picture, or, other information knows as your "Profile Information". We will display your Profile Information in your FishingBooker Account profile page publicly via the Services, and, with your prior permission, on third party sites. Any information you choose to provide as part of your Profile Information will be publicly visible to all FishingBooker Users and consequently should reflect how much you want other FishingBooker Users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage vendors to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your Profile Information at any time.

If you post a Listing, we may publish that Listing publicly via the Services and may enable third parties to publish your Listing on their websites through the use of an HTML "widget". We may also display the geographical location of your Listing in the form of a map to potential Users.
If you request to make a booking via the Services, FishingBooker will share the following information about you with the applicable Owner: (i) your first and last name, (ii) a link to your FishingBooker Account profile page where the owner can view your booking history, reviews, and description. All of this information will enable the Owner to decide whether to confirm or reject your booking. When an Owner confirms a booking we will share pieces of the Owner’s Identify Information, including, but not limited to, full name and the Vendor’s address, with the applicable User selected by the Owner and we will share pieces of the User’s Identify Information with the Owner, including, but not limited to their full name. In no event is a User’s Billing Information shared with an Owner.

With processors

When we share your information with processors outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This is done via agreements on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection on request.

FishingBooker cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of FishingBooker or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

How long we retain your data

We will retain your information as long as your account is active, as necessary to provide you with the Services or as otherwise set forth in this Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect FishingBooker’s legal rights.

We also process and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations.

How to control your information

You have rights to your own data and can request to have your information provided to you, changed, or erased. If you think that any of the information we have on you is incorrect for any reason, please notify our Customer Service or Data Protection Officer to have it corrected. If you would like us to provide you with any or all data we have processed about you, please send a written request to [email protected] and we will provide you with the information within 30 days. If you do not wish to receive notifications from FishingBooker you can always change your preferences in your account Settings.

You have the right to lodge a complaint with your local Supervisory Authority.

If you wish to have your data removed, please send a request to [email protected] Please note that while your data will be anonymized and not used on the platform any longer, some information which we are required to keep for tax purposes will be kept. Furthermore, we may keep some of your data, such as your name, email and phone number to ensure we no longer contact you.

Under the GDPR, you have the right to object to processing of your personal information if it is processed on the basis of a business’ legitimate interest. If you object to such processing, FishingBooker will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or if such processing is necessary for the establishment, exercise or defense of legal claims. Please note however that this may lead to difficulties in accessing some or all of our Services.

International transfers of data

We collect data globally and primarily store that information in the United States. We transfer, process and store your information outside of your country of residence to the United States, Serbia and where ever our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

When we share your information with corporate affiliates or third party service providers outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This is done via agreements on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We can provide further information on the means to ensure an adequate level of data protection on request.

Other important privacy information

Processing of special categories of personal data

FishingBooker does not knowingly or intentionally collect or process sensitive data (as defined in Art. 9 of the GDPR, namely: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation). We urge our Users not to share sensitive personal data about themselves or others over the FishingBooker platform. However, we are aware that some Users may divulge sensitive information about themselves while communicating through the FishingBooker platform. If we do come across such data, it will not be processed in any way by FishingBooker Inc. We will use reasonable means to detect and remove such data.

Our policy towards children

Furthermore, the FishingBooker platform and application are not directed to individuals under 18. We do not knowingly process personal data from persons under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, he or she should contact us. If you become aware that a person under the age of 18 has provided us with their personal data, please notify us via [email protected] so we way delete such information from our files.