Introduction

NIYOS cares about your privacy. For this reason, we collect and use personal data only as it might be needed for us to deliver to you our products, services, apps and websites (collectively, our “Services”).

Your personal data includes information such as your name, address, telephone number, email address and and other data collected that could directly or indirectly identify you.

Our Privacy Policy is intended to explain who we are, how and what data we collect, and how and why we use your personal data. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process.

If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer (“DPO”) by contacting us at privacy@niyos.com. This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.

Who we are

We are NIYOS Ltd (subsequently referred to here as “NIYOS”, “we”, “us” or “our”), an exempted limited company registered as no. 400259, incorporated under the laws of the Cayman Islands.

Our registered address is at Sinclair Group Centre, 3rd Floor Genesis Building, Genesis Close, PO Box 498, Grand Cayman KY1-1106, Cayman Islands.

Our website (“Website”) address is: https://niyos.com.

This Privacy Policy has been developed in accordance with the Personal Data (Privacy) Ordinance (Chapter 486) of the laws of Hong Kong and other applicable data protection regulations, including the EU’s General Data Protection Regulation (“GDPR”). These regulations provides data subjects with rights to ascertain whether NIYOS holds personal data relating to them, to obtain a copy of that data, and to correct any data that is inaccurate.

How to contact us

You can contact us via our Contact web page and select the purpose of your contact. We monitor all communication received via this channel of communication regularly.

We do not publish email addresses to avoid them harvested by spammers.

EU Website Visitors and GDPR

For Website visitors from the EU, our site is in compliance with the General Data Protection Regulation (GDPR).

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/

After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

What information do we collect?

We collect information so that we can provide the best possible experience when you utilize our Services. Much of what you likely consider personal data is collected directly from you when you:

(1) create an account or purchase any of our Services (e.g. billing information, including name, address, credit card number, government identification);
(2) request assistance from our customer support team (e.g. phone number);
(3) complete contact forms or request newsletters or other information from us (e.g. email); or
(4) participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.

However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance. These methods of collection may not be as obvious to you, so here we highlight and explain more about what these might be, since they vary from time to time, and how they work:

Account related information is collected in association with your use of our Services, such as account number, purchases, information requests, and customer service requests and notes or details explaining what you asked for and how we responded.

Cookies and similar technologies on our websites allow us to track your browsing behavior, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our Services. This allows us to provide you with more relevant product offerings, a better experience on our sites, and to collect, analyze and improve the performance of our Services. We may also collect your location (IP address) so that we can personalize our Services. For additional information, and to learn how to manage the technologies we utilize, please see the Cookies section below.


Data about Usage of Services is automatically collected when you use and interact with our Services, including metadata, log files, cookie/device IDs and location information. This information includes specific data about your interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and some of this data collected might be capable of and be used to approximate your location.

Supplementary data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyze the accuracy of our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

How we utilize information

We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes.

These uses include:
Delivering, improving, updating and enhancing the Services we provide to you. We collect various information relating to your purchase, use and/or interactions with our Services. We utilize this information to:
– Improve and optimize the operation and performance of our Services
– Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
– Detect and prevent fraud and abuse of our Services and systems
– Collecting aggregate statistics about use of the Services
– Understand and analyze how you use our Services and what products and services are most relevant to you.

Often, much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.

Sharing with Trusted Third Parties

We may share your personal data with affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:
– Processing credit card payment
– Serving advertisements
– Conducting contests or surveys
– Performing analysis of our Services and customers demographics
– Communicating with you, such as by way email or survey delivery
– Customer relationship management.

We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).

Communicating with You

We may contact you directly or through a third party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you will find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:
– Email
– Text (SMS) messages
– Telephone calls
– Automated phone calls or text messages.

You may also update your subscription preferences with respect to receiving communications from us and/or our partners by sending us an email at marketing@niyos.com.

If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at privacy@niyos.com

Transfer of Personal Data Abroad

If you utilize our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders. Also, when you call us or initiate a chat, we may provide you with support from one of our global locations outside your country of origin. In these cases, your personal data is handled according to this Privacy Policy.

Compliance with Legal, Regulatory and Law Enforcement Requests

We may receive requests to cooperate 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 (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.

To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process. We will also share your information to the extent necessary to comply with ICANN or any ccTLD rules, regulations and policies when you register a domain name with us.

Website Analytics

We use various web analytics tools provided by service providers, such as Google Analytics, to collect information about how you interact with our website, including what pages you visit, what site you visited prior to visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our Services.

These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Each cookie cannot be used by anyone other than the service provider (e.g. Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies we use by utilizing settings in your browser or third-party tools, such as Disconnect, Ghostery and others.

Targeted Offers

Targeted interest-based offers may be presented to you based on your activities on our webpages and based on the products you currently own. We may partner with third parties to manage our offers on our webpages and other websites. Our third party partners may use technologies such as cookies to gather information about such activities in order to provide you with offers based upon your browsing activities and interests, and to measure effectiveness.

Third-party websites. Our website contain links to third-party websites. We are not responsible for the privacy practices or the content of third-party sites. Please read the privacy policy of any website you visit.
How you can access, update or delete your data.

To easily access, view, update, delete or port your personal data (where available), please sign into your Account and visit “Account Settings.”

If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

If you are unable for any reason to access your Account Settings, you may also contact us by one of the methods described in the “Contact section below.

How we secure, store and retain your data

We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilization of encryption where appropriate.
We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:
– mandated by law, contract or similar obligations applicable to our business operations;
– for preserving, resolving, defending or enforcing our legal/contractual rights; or
– needed to maintain adequate and accurate business and financial records.
If you have any questions about the security or retention of your personal data, you can contact us at privacy@niyos.com.

‘Do Not Track’ notifications

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
Age restrictions.

Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.
Changes in our Privacy Policy.

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

Contact us

If you have any questions, concerns or complaints about our Privacy Policy, our practices or our Services, you may contact our DPO by email at privacy@niyos.com.

We will respond to all requests, inquiries or concerns within thirty (30) days.

Site visitors can freely explore this Website largely without having to reveal any personal data. On occasion however, it may be necessary for Niyos to gather information on you for a specific purpose. We will always inform you when we are collecting such information. It is our intention to respect your request for privacy, and we try our best to provide you with communication channels to facilitate this. Once all gathered information has been used for the intended purpose, it is destroyed or de-identified.

Niyos has created this statement in order to demonstrate its firm commitment to protecting your privacy. The following discloses our information gathering methods and dissemination practices for this Website. Niyos is not responsible for the privacy practices of other linked sites.
Use of your Personal Information

Niyos collects certain information from you when you use our Website. This includes:

Contact details and basic user information including your name, age range, email address, telephone number, country of residence;
Your marketing preferences including interests and market list assignments, marketing objections, preferred language, website data;
Usage information including how you use our Website such as clicks and pages which have been shown to you, referring webpage address;
Device data and log information including IP addresses, device ID and type, and details about your use of our Website, browsing history, search queries, browser type, session frequency, geolocation information, wireless and mobile network connection information;
Cookies and tracking technologies including technologies cookies and web beacons and advertising IDs (Please see our separate Cookie Policy for further details on cookies).

This information is used by us to further our statutory objectives. In particular, Niyos may use the data collected and provided by you for one or more of the following purposes:

To create customer profiles, maintain customer records and to communicate with you, fulfil your requests and respond to your enquiries, bookings and feedback;
To send you important notices or personalised messages;
To administer the operation of our Website to allow you to use the services and functions of our Website, to conduct Website maintenance, trouble shoot problems and to continually improve your Website experience and improve our products and services;
To provide services in connection with bookings or registration with our events and programmes;
To identify you for entry into promotional activities or events;
To facilitate promotional activities or events and notify you of the results of promotional activities or events, announce winners and arrange for the subsequent presentation or redemption of prizes;
To tailor and personalise content and make recommendations (including by sending you push notifications) to suit your tastes, interests and preferences;
To develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of websites, mobile applications or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them. We may also recommend content to you based on information we have collected about you and your viewing habits;
To send you marketing materials, news and information which we think will be of interest to you such as our latest promotional activities and upcoming events;
To assist with identification of visitors, and to determine appropriate services;
To monitor, evaluate and analyse trends, data, usage and activities in connection with our Website and services;
To keep internal records, decision making and facilitate internal purposes such as auditing, data analysis, and research to improve our products and services, in addition, such internal records will be used to maintain opt-in and opt-out lists;
To detect, investigate and prevent fraud and other illegal activities and protect our rights and property; and
To use your personal information for purposes associated with our legal or regulatory obligations.
When you come to our Website, our server software records the domain name of your computer. We may also track the pages you visit. We do these things so that we can measure traffic, gauge the popularity of various parts of the Website, gain some general knowledge about our audience and compile aggregated statistics.
Direct marketing

We may use your personal information such as your name, e-mail address, address, telephone number and geolocation to send you direct marketing communications about products and services in the travel industry or related services including our latest e-newsletter and upcoming events and offers. This may be in the form of email, post, SMS, telephone or targeted online advertisements or in-app notifications. We limit direct marketing to a reasonable and proportionate level, and to send you communications and otherwise share content with you which we think will be interesting and relevant to you, based on the information we have about you.

We may share your personal information with third party sponsors or co-operation partners on a specific campaign or promotional basis for direct marketing by such sponsors and partners. We will only do so upon providing you with a clear notice and upon obtaining your explicit consent.

From the effective date of this Policy onwards, where you register for our events, programmes or offers, sign-up for our e-newsletter or entered a lucky draw and have elected to receive direct marketing information by email or SMS or other means, then for the purposes of the PDPO and the relevant orders and regulations, we will ask you for your consent for our processing of your personal information for direct marketing purposes.

You have a right to stop receiving direct marketing at any time. You can do this by following the opt-out links in electronic communications (such as emails), or by contacting us using the details set out under “Contacting Us” below.
Who we share your personal information with

Data collected by Niyos is used only for the purposes indicated above. Personal information will not be disclosed to any third party except that we may share your personal information with our worldwide offices and representatives and third parties on a confidential basis to help manage our business and deliver services. These third parties may from time to time need to have access to your personal information. These third parties may include:

Our partners, such as banks, financial service providers, government departments and public bodies and other companies involved in providing services to you or fulfilling your requests;
Service providers, who provide administrative, marketing and research, e-marketing, distribution, data processing and management, advertising delivery, computer system, web development, payment gateway and other functions on our behalf to help us operate our business, such as sending postal mail and e-mails, help manage our IT and back office systems, analysing data, providing marketing and targeted advertising services assistance, providing search results and links (including paid listings and links). If you share your data through our Website with a third party account such as Facebook, Twitter or Instagram, your personal information will be managed respectively by one of those third parties. Please review the third party’s privacy policy, as their data processing will not be covered by this Policy;
Event sponsors or authorised managers, agents or contractors, who facilitate the event or programmes registrations, lucky draws, presentation, redemption or delivery (as appropriate) of prizes in connection with the associated events or activities organised or promoted by us;
Government or non-government authorities and/or regulators;
Other third parties, for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public;
Professional advisors (including our lawyers and auditors).
We may also disclose your personal data to the extent we may be required to do so by laws and when you indicate your choice to receive promotional materials from third parties as described in the “Direct Marketing” section above.

Niyos will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests and is undertaken in accordance with any rules governing such transfers.

We may also share with our advertisers information on an aggregate basis.
Data Security

You have the right to request access to and correction of information held by us about you. To do so, please contact us via the contact information below.
“Opt-Out”

You can opt-out from receiving information from Niyos or ask us to delete your information from our records at any time should you no longer wish to receive updates of Niyos developments, activities and promotions. To opt out, please e-mail us at privacy@niyos.com