1. Introduction

When you use Valmeego, you trust us with your personal data. We're committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it is used and shared, and your choices regarding this data. We recommend that you read our privacy overview, which highlights key points about our privacy practices.

2. Overview

This notice applies to users of Valmeego's service anywhere in the world, including users of Valmeego's websites, Progressive web Application, features and other services.

This notice specifically applies to:

• Trip Planners and Participants: Individuals who use and plan their trips on Valmeego.
• Ameegos: Individuals who provide knowledge and recommendations to Trip planners through Valmeego.
• Service Providers: Individuals who provide services to Valmeego's users via the travel feed.

This notice also governs Valmeegos other collections of personal data in connection with its services. For example, we may collect the contact information of individuals who use accounts owned by Valmeego for Business customers; personal data of those who start but do not complete applications to be Ameego's or service providers; or other personal data in connection with our mapping technology and features. All those subject to this notice are referred to as “users”. Our practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region, if permitted under their laws.

3. Data controller and transfer

Valmeego Ltd are the data controllers for the personal data collected with use of Valmeego's services in the European Economic Area, the United Kingdom and elsewhere.

Valmeego operates, and processes personal data, globally. The exercise of data protection rights can be directed at any controller mentioned above, preferably via the designated channels, and will be handled by Valmeego as a group. We may also transfer such data to countries other than the one where our users live or use Valmeego's services. We do so in order to fulfil our agreements with users, such as our Terms of Use, or based on users' prior consent, adequacy decisions for the relevant countries.

4. Data collections and uses

4.1 The data we collect:

4.1.1 Valmeego collects personal data

• Provided by users to Valmeego, such as during account creation.
• Created during use of our services, such as preferences, app usage and device data.
• From other sources, such as other users, business servicesm Ameego's, destination promoers and governmental authorities.

The following personal data is collected by or on behalf of Valmeego:

Data provided by users:

• User Profile: We collect data when users create their Valmeego accounts. This may include their name, email, phone number, email, password, profile picture, business name, nationality , location, and languages. This also includes gender and occupation when required for certain Valmeego services such as becoming an Ameego.
• Demographic Data:We may collect demographics data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
• User Content: We collect the data submitted by users when they contact Valmeego costumer service, provide ratings or recommendations for other users, businesses, Ameego's or otherwise contact Valmeego. This may include feedback, photographs and audio or video recordings collected by users in connection with customer support.
• Travel Information: We collect travel plan information, including the times and dates trip plans begin and end, lodgings, and transport times from users through our itinerary feature.

Data created during use of services

• Travel data (Trip Planners and Trip Participants): We collect Trip Planners precise number of trips created, amount of Ameego's used, searchable feed and location data to enhance use of our PWA. Enabling Valmeego to detect and prevent fraud and to satisfy legal requirements.

  Valmeego collects this information when Valmeego's progressive web application (PWA) is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their technology device.

• Travel data (Service Providers and Ameego's) We collect Service providers and Ameego's interactions to enable and enhance use of our pwa, including to improve Ameego's performance and recommendations, facilitate bookings, and detect fraud.

  We collect such data from user's mobile devices if they enable us to do so. Valmeego collects such data from the time users plan, book, up until the trip is completed, and any time the app is running in the foreground of the mobile device.

• Transaction Information: Valmeego uses Stripe payment infrastructure to accept payments and store all transactional information such as card details, name, and amount of transaction, date, and time the booking was made, amount charge, and payment method.
• Usage Data: We collect data about how users interact with our services. This includes data such as access dates and times, pwa features, page views, pwa crashes and other system activity. We may also collect data regarding the third-party services used before interacting with our services, which we use for marketing.

  In some case, we collect this data through cookies, and tags.

• Device data:We may collect data about the devices used to access our services, including the hardware models, IP address or other unique device identifiers, operating systems, software, preferred languages, advertising identifies, and mobile network data.
• Communication data: We enable users to communicate with each other through Valmeego's Chat Channels. Users can communicate to all user groups through Valmeego's pwa and website. For Example, Valmeego enables all users to have a direct line of contact to each other. (Generally, without disclosing their telephone numbers to each other) To provide this service, Valmeego receives some data regarding the texts including the data and time of the communications and the content of communications.

  Valmeego use this data for safety, security purposes, to improve our services and features, and for analytics.

Data from other sources

• Valmeego account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of Valmeego for Business accounts
• Users or others providing information in connection with claims or disputes.
• Valmeego business partners through which users create or access their Valmeego account, such as payment providers, social media services, apps or websites that use Valmeego's APIs or whose APIs Valmeego uses.
• Publicly available sources
• Marketing service providers whose data Valmeego use for marketing or research.
• Law enforcement officials, public health officials and other government authorities.

4.1.2 How we use personal data:

Valmeego uses personal data to enable secure trip planning, convenient booking, and other services. Valmeego does not sell or share user personal data with third parties for their direct marketing, except with users' consent.

We also use data:

• to enhance the safety and security of our users and services
• for customer support
• to enable communications between users
• to send marketing and non-marketing communications to users
• for research and development
• in connection with legal proceedings

Valmeego uses data to provide, personalize, maintain, and improve our services for all users. This includes using data to:

• Create and, or update accounts
• Enable booking and recommendation services, and features that involve data sharing (ratings)
• Track and share the progress of Ameego's
• Personalize user's travel feed. For example, we may present users with personalized deals, services, recommendations based on prior searches and bookings.
• Perform necessary operations to maintain our services (such as troubleshoot software bugs to conduct data analysis, testing and research. We monitor and analyse usage and activity trends on Valmeego)

Safety and security

We use personal data to maintain the safety, security and integrity of our service and users. This includes:

• Verifying users' identity and eligibility to access Valmeego's platform.
• Using data from services and Ameego's to detect unsafe behaviour such as fraud, and mistreatment of information.
• Using devices, user profiles, location, usage data to prevent, detect and combat fraud. Identifying fraudulent accounts or uses of our services, preventing unauthorised Ameego's or travel services, verifying user identities in connection with certain security and payment methods.
• Using user ratings, reported incidents, and other feedback as grounds for deactivating users with low ratings or who have violated their guidelines.

Valmeego performs the above activities on the grounds that they are necessary to fulfil our obligations to users under the Terms of Use or other agreements with users, and/or for purposes of the legitimate safety and security interests of Valmeego or other parties, including users and members of the public.

Customer Support

Valmeego uses the information we collect to provide customer service, addressing user concerns, monitoring, and improving our customer support responses and processes.

Enabling communication between users.

A Trip Planner can message any user directly through Valmeego. For example, a Trip planner may request a quote or make bookings through services advertised on Valmeego. Valmeego performs the above activities on the ground that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users.

Marketing

Valmeego may use personal data to market our services to other users. This includes sending Valmeego's users communications about our services, features, promotions, studies, news, updates, and events. We may do so by email, push notifications, in-app communications, ads and on third party platforms.

Non-marketing Communications

Valmeego may use personal data to generate and provide users with receipts; inform them of changes to our terms, services, or policies. Valmeego performs the above actives on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use.

Automated decision-making

We use personal data to make automated decisions relating to use of our services. This includes:

• Determining user ratings, and deactivating users with low ratings. In the European Union or where otherwise required by law, such deactivation occurs only after human review and/or the possibility to appeal.
• Matching available Ameego's or businesses to users requesting services. Users can be matched based on preferences, proximity, availability, and other factors.
• Flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm Valmeego, its users and others. In some cases, such as when a user is determined to be abusing Valmeego's referral program or has submitted fraudulent documents, such behaviour may result in automatic deactivation, or in the European Union or where otherwise required by law, deactivation after human review.

5. Cookies and third-party disclosure

Valmeego uses cookies and other identification technologies on our website, Progressive web application, emails and online ads for purposes described in this notice and Valmeego's Cookie Notice.

A Cookie is a small piece of data that is stored on your browser or device by websites, progressive web applications, online media and advertisements that are used to remember your browser/ device during and across website visits. Valmeego uses cookies for such purposes such as:

• Authenticating users
• Improving users by remembering use preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of our advertising campaigns
• Analysing site traffic and trends and generally understanding the online behaviours and interest of users who interact with our services.

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the internet. Please see our cookie policy for more information regarding the use of cookies.

6. Data sharing and disclosure

Some of Valmeego's service and features require that we share personal data with other users or at a user's request.

We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Valmeego may share personal data:

6.1 With other users

This includes sharing:

• Ameego's and services name, ratings, occupation, type of service, and profile pictures.
• Trip Planners profile information such as contact details, name, profile picture, number of group participants, nationality.
• For Ameego's and businesses, we may share their data with Trip Planners, Trip Participants, and other Ameego's or Businesses such as, business name, profile picture, cover picture, contact information (if permitted by applicable laws), average rating provided by users, period of time since they signed up to be an Ameego and/or business.
• We also provide Trip Planners and order recipients with receipts containing information such as the breakdown of amounts charged per booking. We also include other information on those receipts required by law.

6.2 At the User's Request

This includes sharing data with:

• Other people at the user's request. For example, we share a user's location with a friend when requested by that users, or a user's trip information.
• Emergency services. We offer features that enable users to their data with police, fire, and ambulance services in the event of an emergency or after certain incidents.

6.3 With the public

Questions or comments from users through Valmeego's social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

6.4 With the Valmeego account owner

If a user makes a booking owned by another party, we may share their order of trip information.

6.5 With Valmeego service providers and business partners

Valmeego provides personal data with our subsidiaries to help us provide our services or conduct data processing on our behalf.

These include:

• Service Providers from whom order recipients make bookings and/or the point of sale providers, including the order fulfilment, communications and marketing purposes.
• Payment processors and facilitators
• Background check and identity verification providers
• Google in connecting with the use of Google Maps in Valmeego's pwa (see Google's privacy policy for information on their collection and use of data)
• Social media companies, including Facebook, twitter in connection with Valmeego's use of their tools in Valmeego's pwa and websites. (See Facebook's and Twitter privacy policies for information on their collection and use of data)
• Marketing platform providers, including social media advertising services, advertising networks, third-party providers, and other service providers to reach or better understand our users and measure advertising effectiveness.
• Consultants, lawyers, accountants, and other professional service providers
• Insurance and financing partners

6.6 For Legal reasons

Valmeego may share User's personal data if we believe it is required by applicable law, regulation, operating license, legal process, or governmental request. This includes sharing personal data with law enforcement officials, public health officials, and other government authorities as necessary to enforce our terms of Service, and user agreements. In the event of a dispute relating to use of an others person's credit card, we may be required by law to share your personal data, including trip, booking information, with the owner of that credit card.

6.7 With Consent

Valmeego may share user's personal data other than described in notice if we notify the user and they consent to sharing.

7. Data Retention and deletion

Valmeego retains user data for as long as necessary for the purpose described above. Users may request deletion of their accounts at any time.

Valmeego may retain user data after a deletion request due to legal or regulatory requirements or for reason stated in this policy. Valmeego retains user data for as long as necessary for the purpose described above. This means we retain different categories of data for different period of time depending on the type of data, whom the data relates to, and the purpose for which we collected the data.

Users may request deletion of their account at any time through the Profile Settings in the Valmeego pwa or through the Valmeego website.

Following an account deletion request, Valmeego deletes the user's account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety and security.

8. Choice and Transparency

Valmeego enables users to access and/ or control the data Valmeego collects including through:

• Privacy settings
• Device permissions
• Marketing choices

Valmeego also enables users to request access to or copies of their data, changes, updates to their accounts, or deletion of their accounts.

1. Privacy Settings

   The settings in Valmeego's pwa allows users to set and update their preferences regarding data collection and sharing, emergency data sharing and notifications.

2. Device permissions

   Most mobile device platforms have defined certain type of data that PWA cannot access without the device owner's permission, these platforms have different methods for how that permission can be obtained.

3. In- app ratings pages

   After every trip or booking users are able to rate each other from a scale of one to five. An average of those ratings is associated with a user's account and is displayed to other users for whom they provide or receive services from. For example, Trip Planners are able to rate Ameego's based on the knowledge they have provided, and Ameego's are in turn able to rate the Trip Planner and group trips they have been in contact with.

   This two-way system holds everyone accountable for their behaviour. Accountability helps create a respectful, safe environment for Valmeego users.

   • Trip Planners can see their average rating on the personal profile.
   • Services can see their average rating after clicking into their public profile.
4. Marketing Choices

   Users may opt out of certain marketing communications and use of their data for marketing in the following ways:

   Marketing emails and messages: To opt out of receiving marketing emails from Valmeego, users can choose to unsubscribe. We may still send users who have opted out non- promotional communications, such as receipts for trips or information about their account.

   Cookies: For information on how to opt out of personalised ads using cookies and related technologies, please see our Cookie notice.

   User Personal Data request

   Valmeego provides user with a variety of ways to learn about, control and submit questions and comments on Valmeego's handling of their personal data.

   Accessing data: Users can access data including their profile data and trip history through the Valmeego pwa or website.

   Changing or updating data: Users can edit the name, phone number, email address, payment method and photo associated with their account through the settings in their profile.

   Deleting data Users may request deletion of their account at any time through the profile settings in the Valmeego pwa, or Valmeego's website.

   Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data. This includes objecting to our use of personal data that is based on Valmeego's legitimate interests. Valmeego may continue to process data after such objection or request to the extent required or permitted by law.

9. Changes to this privacy policy:

We may update this privacy policy from time to time. If we make any material changes, we will notify you prior to the changes taking effect by posting a notice on our website.