Last updated: September 12, 2018
What types of information do we collect?
At Go Overseas, we collect information which on its own, or in combination with other information, may be used to identify you as an individual (“Personal Data”) and information that cannot be used individually to identify you but must be combined with other information to identify you personally (“Non-Personal Data”).
Here is a breakdown of the ways we collect Personal Data and Non-Personal Data and how it is stored:
- As a Go Overseas user,you can register for an account in a variety of ways, including by signing up for an account, leaving a review, participating for a scholarship or contest, booking a program directly on Go Overseas or through one of our Partners (as defined below), asking a question or providing an answer, or adding a program to your wish list. In all of these cases, your information is stored in our servers up until such point as you request your account to be deleted. We also use services including MailChimp and Mandrill to handle email marketing, and your Personal Data may be stored in these systems as well.
- As a Go Overseas partner, if you reach out to any member of our Partner Growth team (including via the [email protected] email address), your information will be automatically added to our CRM tool, Hubspot. Hubspot will retain Personal Data related to your account to help us provide a better partner experience.
What Personal Data is collected?
If you decide to use or access our Platform, we may collect the following Personal Data from you: your name, username, phone number, physical address and/or email address, state and country of residence/nationality, age/date of birth, social media information, IP address, and employment information. As part of the functionality of the Platform, you may also choose to voluntarily provide photos, videos, and other content through the Platform. If you wish to purchase or book anything via the Platform we may collect your payment information via a third party payment processor which may include your credit card number and other payment details. We do not require you to submit any Personal Data to access the site, however, you may not be able to utilize certain features of the site that require registration or receive materials such as newsletters unless such information is provided. We may request additional information as part of scholarships and contests which help us verify eligibility. You may provide the foregoing Personal Data described in this paragraph directly on the Platform, or through a third party service.
What Non-Personal Data is collected?
In addition to the Personal Data collected, we may collect non-Personal Data. In order to create an account with Go Overseas, you will be asked to submit a password and other non-personal information such as your gender, location and program preferences. In addition, your web browser or client software may transmit certain information about your computer and site usage, including but not limited to your zip code, gender, browsing history, search history, and registration history, interactions with the website, location, referring URL, browser, operating system, and Internet Service Provider.
Go Overseas may use this information to generate statistics about our user community and provide such information to our advertisers. Go Overseas may also use this information for security, system integrity or enforcement purposes.
How do we use your personal information?
The Personal Data you provide Go Overseas will allow us to fulfill your customer services and requests; alert you of new products or services, features, or enhancements; handle/route your customer service or technical support questions or issues; assist us in providing our services to you; to share with third parties that you have indicated an interest in; and/or notify you of contests, promotions, or special events and offers.
What are the legal bases for your processing of my Personal Data?
The legal grounds for our processing, and our Partners’ processing, of your Personal Data for the purposes above are:
- first and foremost, you provided your consent by agreeing to this Policy, which you may withdraw at any time by emailing us at [email protected];
- it is necessary for our contractual relationship;
- the processing is necessary for us to comply with our legal or regulatory obligations; and/or
- the processing is in our legitimate interest as a provider of the services described in this Policy and on the Platform (for example, to protect the security and integrity of our systems and to provide you with customer service and the core functionality of our services).
With whom may your personal information be shared?
Go Overseas may also have message boards and/or chat areas, where users can exchange ideas and communicate with one another. When posting to a message board or chat area, please be aware that the information is being made publicly available online and the user does so at his or her own risk.
When will my information be shared with law enforcement?
What choices do I have regarding the collection, use, and distribution of my personal information?
Go Overseas allows you to control the way that we use Personal Data that we might obtain. At the time you provide personal information, Go Overseas may give you the option of declining any future offers or information about new products, promotions, or services. In addition, many of the "mailings" Go Overseas may send you, such as newsletters, have procedures within them to cancel the receipt of any future mailings.
Additionally, you may opt out of some communications by using controls in your Go Overseas account dashboard or update your Personal Data by changing information listed in your account. We currently do not offer functionality for you to opt out through “do not track” listings. If you wish to opt out of certain communications or information collection, please contact us at [email protected]
Please note that even if you opt out of, or choose not to opt in to, marketing and commercial communications including future offers or information about new products, promotions, or services, we may continue to send you communications in furtherance of the services that you are a part of on the Platform, such as communications specific to scholarships or contests, or booking a program directly on the Platform.
You can also change some of your Personal Data through the account settings provided on the Platform. In addition, if you wish to access, receive a copy of, change or delete the Personal Data we hold about you, you may contact us as described at the end of this Policy. In addition, we encourage you to contact our Partners to access, receive a copy of, change or delete the Personal Data and we agree to work with our Partners in good faith to assist with your request.
You may withdraw the consent granted in this Policy for us or our Partners to use the Personal Data described in this Policy by contacting us as described at the end of this Policy. Please note that if you do so, it will not affect the lawfulness of the use of your Personal Data based on your prior consent.
In addition, you may contact us as described at the end of this Policy to request that we do not disclose your Personal Data to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors) or to request that your Personal Data not be used for a purpose that is materially different from the purposes for which it was originally collected or for purposes subsequently authorized by you. However, if you choose to exercise such right, some functionality of our services may no longer be available to you.
Upon receipt of any of the above request(s), we will use reasonable efforts to reflect any changes you request in our databases to the full extent required by GDPR, Privacy Shield, or other applicable law.
If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
What are cookies and pixels and how do you use them?
Cookies and pixels are features of your Web browser that allows Web sites to transfer bits of information to your computer for record-keeping purposes. A cookie or pixel stored on your computer can be used to "remember" things like your password, your preferences, or that you have already registered. This allows us to speed up your future activities, saving the time you would normally spend entering information such as your password or registration.
- We use the Google Tag Manager to implement both a Google Analytics pixel and a Facebook pixel. Both of these pixels collect anonymized data which allows us to better understand what you love on Go Overseas and help you find more of that information. Additionally, a select group of our partners also access our Facebook pixel data for advertising purposes.
- We use a tool called Crazy Egg which collects anonymized, Non-Personal data about visitors behavior on Go Overseas. This data is not tied to user accounts in any way but is used as part of our efforts to improve user experience and design across Go Overseas.
What do I do if I want to correct or delete my personal information?
If you wish to alter any Personal Data you may be able to do so via your account dashboard located on the Go Overseas Platform. If for any reason you are concerned with the way we are using your Personal Data, or would like to correct or request that we delete such personal information, please contact us by e-mailing us [email protected]
Please note that the deletion of your data may lead to the termination of your account and applicable services. After you have deleted your Personal Data, please be aware that we may keep inaccessible copies of your information for a reasonable period of time for legal purposes to the extent permitted by applicable law.
How secure is my personal information?
Go Overseas has taken steps to assure that all information collected will remain secure and in its original form, i.e. free from any alteration. As such, access to all personal information is strictly controlled. When credit card information is transmitted, for example, we use industry standard, SSL (secure sockets layer) encryption. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of personal information.
Though we attempt to keep your information safe and secure, you must understand that electronic transmission of information over the internet is never 100% secure and thus we cannot guarantee the absolute safety and security of any information provided. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration, except to the extent required by GDPR, the EU-U.S. and Swiss-U.S. Privacy Shield Principles (“Privacy Shield”), or other applicable law.
Are there age requirements?
We intend to fully comply with US and international laws respecting children’s privacy including COPPA. Therefore, we do not collect or process any information for any persons under the age of 13. If you are under 13 and using our Platform, please stop immediately and do not submit any information to us. In the event that we have inadvertently collected any information from users under the age of 13 please contact us immediately and we will delete such information.
Where is my information stored?
If you choose to use the Platform from the European Economic Area, Switzerland, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Data outside of those regions to the U.S. for storage and processing. By providing any information, including Personal Data on the Platform, you consent to such transfer, storage, and processing.
Go Overseas participates in, and complies with, Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, sharing, and retention of Personal Data from the European Economic Area and Switzerland respectively. Go Overseas has certified to the Department of Commerce that it adheres to Privacy Shield. If there is any conflict between the terms in this Policy and Privacy Shield, Privacy Shield shall govern. Our participation in Privacy Shield applies to all Personal Data that is subject to this Policy and is received from the European Economic Area and Switzerland. We will comply with Privacy Shield in respect of such Personal Data.
To learn more about Privacy Shield, please visit: https://www.privacyshield.gov/. To view a list of companies that have certified that they adhere to the Privacy Shield principles, please visit: https://www.privacyshield.gov/list.
As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to Privacy Shield, we will seek to resolve it through JAMS, an independent alternative dispute resolution body based in the United States. You can learn more about JAMS at the following URL: https://www.jamsadr.com/.
In certain circumstances, you may have the right to invoke binding arbitration under Privacy Shield, as described in Annex I to the Privacy Shield Principles, which can be found at the following URL: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Privacy Shield participants, such as Go Overseas, are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, we may be liable for the transfer of personal data that we receive and subsequently transfer to a third party, as described in Privacy Shield.
As described in this Policy, we may share Personal Data with third parties and may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
How long do you store my information?
We will store your Personal Data for as long as it is needed to provide you with the functionality of the Platform, however, we may not know if you have stopped using the Platform if you do not delete your account, so we encourage you to either delete your account or contact us if you are no longer using the Platform. However, if required by applicable law, we may retain your Personal Data for such period as may be required by such law. To continue to provide an effective service, we may store Non-Personal Data perpetually and may anonymize your Personal Data and store that anonymized information perpetually.
Additionally, as described in this Policy, we use third parties to provide the functionality of the Platform and do not have full control over their practices related to storage and retention of your Personal Data. However, we will work with such third parties to delete or modify your Personal Data to the extent required by GDPR and Privacy Shield.
Mergers and Acquisitions
As with any business, your Personal Data is also an asset of Go Overseas and will become part of our normal business records. As such, we may also disclose your Personal Data to a third party if we decide to sell any portion of our business to a third party. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal information may be transferred to a Go Overseas successor or assign.
How are changes made?
Contact and Inquiry Information for Data Protection Officer
If you have any questions or wish to file a complaint, please feel free to e-mail our Data Protection Officer at [email protected], call us at +1 (415) 796-6456, or send a letter addressed to:
Go Overseas, Inc.
Attention: Data Protection Officer
2040 Bancroft Way Suite #200