1. Introduction
Welcome to Tours (the "Services" or "App"), operated by Code Rev S.R.L ("Company," "we," "us," or "our"). We are committed to protecting your privacy and handling personal data in a transparent, secure, and lawful manner. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you access or use our application, website, and related services (collectively, the "Services"). This Privacy Policy is designed to meet enterprise, regulatory, and contractual standards, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and other applicable data protection laws. By using the Services, you acknowledge that you have read and understood this Privacy Policy.
2. Scope and Applicability
This Privacy Policy applies to:
- Users of the Tours application and website
- Business customers and their authorized users
- Prospective customers and individuals who contact us
This Policy does not apply to third-party websites, applications, or services that may be linked from our Services.
3. Information We Collect
3.1 Personal Information You Provide
We may collect personal information directly from you, including:
- Identifiers (e.g., name, email address, phone number)
- Account credentials and profile information
- Billing and transaction details (where applicable)
- Communications and support requests
3.2 Automatically Collected Information
When you use the Services, we may automatically collect:
- IP address and approximate location
- Device identifiers, operating system, and browser type
- Usage data, logs, and analytics (e.g., pages viewed, actions taken, timestamps)
3.3 Location Data
With your explicit consent, we may collect precise or approximate location data to enable location-based features. You may withdraw consent at any time through your device settings.
3.4 User-Generated Content
We collect and store content you upload, such as photos, videos, and media used to create virtual tours. This content may contain personal data depending on its nature.
4. Legal Bases for Processing (GDPR)
Where required by law, we process personal data based on one or more of the following legal bases:
- Performance of a contract
- Compliance with legal obligations
- Legitimate business interests
- Your consent
5. How We Use Your Information
We use personal information to:
- Provide, operate, and maintain the Services
- Authenticate users and manage accounts
- Improve performance, functionality, and user experience
- Communicate service-related and administrative information
- Send marketing communications where permitted by law
- Detect, prevent, and respond to security incidents and fraud
- Comply with legal, regulatory, and contractual obligations
6. Sharing and Disclosure of Information
6.1 Service Providers
We may share personal information with vetted third-party service providers that support our operations (e.g., hosting, analytics, payment processing, customer support). These providers are contractually obligated to protect personal data and use it only for authorized purposes.
6.2 Legal and Regulatory Disclosures
We may disclose personal information where required to do so by law, regulation, subpoena, court order, or other lawful governmental request.
6.3 Business Transactions
In the event of a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of the transaction, subject to appropriate confidentiality safeguards.
7. International Data Transfers
Your information may be processed in countries outside your jurisdiction. Where required, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) or equivalent mechanisms, to ensure adequate protection of personal data.
8. Data Retention
We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on data type and legal requirements.
9. Your Rights and Choices
Depending on your location, you may have the right to:
- Access your personal data
- Correct or update inaccurate information
- Request deletion of your personal data
- Restrict or object to processing
- Request data portability
- Withdraw consent at any time
- Opt out of targeted advertising or marketing communications
Requests may be submitted by contacting us using the details below. We will respond in accordance with applicable law.
10. CCPA / CPRA Notice (California Residents)
California residents have the right to know, access, delete, and opt out of the sale or sharing of personal information. Tours does not sell personal information as defined under California law. We will not discriminate against you for exercising your privacy rights.
11. Security Measures
We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. Despite these measures, no security system is impenetrable.
12. Data Breach Notification
In the event of a personal data breach, we will notify affected individuals and relevant authorities as required by applicable law.
13. Children's Privacy
The Services are not intended for children under the age of 13 (or 16 where required by law). We do not knowingly collect personal information from children.
14. Changes to This Privacy Policy
We may update this Privacy Policy periodically. Material changes will be communicated through the Services or other appropriate channels. The "Last Updated" date reflects the most recent revision.
15. Compliance Statement
Tours is committed to maintaining compliance with applicable data protection and privacy laws. We regularly review and update our privacy practices, policies, and controls to meet enterprise, regulatory, and customer requirements.