Privacy Notice

 
 

Introduction

Bridge to Poland ("Bridge to Poland" or "we" or “our” or “us”) respects your privacy and is committed to protecting your Personal Information (defined below).  This privacy notice will let you know how we collect, use, process, maintain, and share your Personal Information through this website (the “Website”), our other digital properties, and offline.  What Personal Information we collect may vary based on your interaction with us and requests for our services. 

We encourage you to read this notice together with any other privacy notice we may provide on specific occasions when we are collecting or using Personal Information about you so that you are fully aware of how and why we are using your information. This notice supplements the other notices and is not intended to override them.  By accessing or using this Website, or otherwise providing us with your Personal Information, you agree to this privacy notice. This notice may change from time to time (see Acceptance and Changes to Our Privacy Notice). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the notice periodically for updates.

This notice aims to give you information on how Bridge to Poland receives, collects and processes your Personal Information in connection with our websites (including bridgetopoland.com), social media channels, electronic newsletters, and other Bridge to Poland digital properties (the “Digital Properties”), our trips and tours, presentations, speaking engagements, events, surveys, marketing, advertising, contests, promotions and any of our other products or services.  These are collectively referred to as “Services” throughout this notice.

Children Under the Age of 13

Bridge to Poland and our Services do not target, market to, nor are intended for children under 13 years of age without the approval or supervision of parents or legal guardians.  We do not knowingly collect personal information from children under 13. If you are under 13, please do not provide us any personally identifying information. If we learn we have collected or received personal information from a child under 13 without verification of parental or legal guardian consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

What Categories of Personal Information Do We Gather about You?

We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together follows:

  • Identity Data (for example, your first name, maiden name, last name, username or similar identifier, birth year, gender, marital status, title, government issued IDs, or other demographic information).

  • Contact Data (for example, your billing address, delivery address, email address and telephone numbers).

  • Financial Data (for example your bank account and payment card details).

  • Transaction Data (for example, details about payments to and from you and other details of Services you have purchased from us, taxes, spending habits).

  • Technical Data (for example, your internet protocol (IP) address, internet service provider (ISP), browser type and version, browser language, referring/exit pages, operating system, date/time stamp, clickstream data, time zone setting and basic geolocation, device type, unique device identifiers, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services and Digital Properties).

  • Usage Data (for example, information about how you use our Digital Properties and Services, including, for example, if you contact Bridge to Poland, we may log information about the means through which you contacted us and our interaction with you).

  • Profile Data (for example, purchases or orders made by you; your interests, preferences, feedback and identified-survey responses; country of origin; source of income; job information; preferences; behavioral; character; professional; social status; and other demographic information).

  • Marketing and Communications Data (for example, your preferences in receiving marketing from us and our third parties, if any, and your communication preferences).

  • Credit History.  (for example, we may collect your credit information if you are a local service provider, when conducting due diligence for partnership/engagement purposes).

  • Employment Information. (for example, you may be asked to provide your past and current employment history when engaging with Bridge to Poland as a local service provider. We may also collect your employment information if you are taking a trip with us in connection with your place of employment, or for emergency contact information).

  • Image and Voice Recordings.  (for example, if you attend or participate on one of our trips, you may be photographed or videoed).

  • Educational & Training Data. (for example, you may be asked to provide information about your education and training when engaging with us as a local service provider, or if you are taking a trip with us through your school.  We may also collect this information when conducting due diligence to learn more about our existing and potential travelers to better meet your needs).

  • Family Circumstances.  (for example, we may collect your this for emergency contact information or to learn more about our existing and potential travelers in order to grow our business).

  • Health Information (for example, you may share with us your dietary requirements or access needs/accommodations for your trip)

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. Or, we may aggregate information about our travelers to provide materials and external reports, to identify areas of interest, or to grow our business.  However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this notice.

Personal Information does not include, and this privacy notice does not cover, data from which individual persons cannot be identified, where the identity of an individual has been irretrievably removed, or situations in which personal information is anonymized.

How Is Your Personal Information Received or Collected?

There are different ways that we may collect information about you, but generally we will collect your Personal Information from either you (directly or indirectly), third parties, or public resources.  For example:

  1. Directly from You.  We may collect your Personal Information directly or indirectly from you, offline or online.  For example, you may provide us with your information when you register to go on one of our tours or attend an event, to partner with us, participate in a survey, request information from us or otherwise communicate with us, or otherwise use our Services. Depending upon your device and browser settings, we collect your personal information, including information about your device, via cookies and tracking mechanisms.

A note on cookies and other tracking technologies: As is true with most websites and digital properties, when you interact with our Digital Properties, or by email, we may automatically collect, or facilitate the collection of, Personal Information on your interactions with us and our Digital Properties and about your equipment.  For example, we may collect Personal Information by using first and third party cookies, Flash cookies, HTML5 local storage, server logs, web beacons, clear gifs, and other similar technologies. Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize the device when it visits websites or uses online services. The website you visit may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies.

We may automatically use some cookies that are strictly necessary for the core functionality of our Digital Properties, providing the services you request, enabling communications, and providing a secure digital environment. They also help us know where you have indicated certain cookie preferences, including refusals, to ensure your preferences are honored. We use these automated technologies and the Personal Information collected for different purposes, as well, for example:

·  Our Digital Properties may use, or facilitate the use of, non-essential functionality cookies that enable helpful functions to provide an enjoyable user experience (for example, by recognizing when you return to this Website, enabling us to personalize content for you, remember your preferences, and the like). 

·  We may also use, or facilitate the use of, analytic or performance cookies, which allow us and our third party service providers to recognize and count the number of visitors to see how visitors move around our Digital Properties when they are using them. This helps us improve how our Digital Properties works, for example by ensuring that visitors can easily find what they need on our website. These analytic cookies generally generate aggregate statistics that are not associated with an individualized profile.  For example, the Website may use Google Analytics and Adobe Typekit to track how often visitors access or read our content.  We use this information in the aggregate to understand what pages and features of our website’s visitors find useful. To better understand Google Analytics, and how you can opt-out of the Google Analytics features, we encourage you to visit the following: https://tools.google.com/dlpage/gaoptout/.  We do not control third party service provider websites, platforms and applications collecting your Personal Information, in this regard, and are not responsible for their privacy statements. We encourage you to read the privacy notice or policy of every website you visit or application you use when you use or enable these platforms and applications, or leave the Website.  

·  Bridge to Poland does not use or put cookies on your device cookies for advertising purposes.

·  We use Google analytics.

Your permission for our collection and use of your Personal Information using automated tracking mechanisms may be managed in a variety of ways at the operating system level of your device or equipment, through third-party platform extensions, or you can learn how else you can exercise your option not to accept these cookies. However, cookies are very important for our Website to properly function and disabling or limiting their use may limit or interfere with your experiences or ability to access Website features, functions and customization.

  1. Information from Third Parties.  We may receive your Personal Information from third parties, offline or online.  For example, we may receive your Personal Information from your place of employment or school if you are using our Services through your relationship with them. Similarly, if you are using a travel agent, third party agent, or other third party arranging your trip with us on your behalf, they may provide us with your Personal Information.  Or, you may apply to partner with us through a third-party entity or website, which in turn provides your Personal Information. We also may partner with other organizations or tour groups and we may receive your Personal Information through those relationships (for example, if they refer you to us due to a scheduling conflict). As is the case with most organizations, Bridge to Poland uses subcontractors and vendors to assist with our technology, security, payment processing, order-fulfillment, delivery, advertising/marketing, analytics, digital-development and –deployment, and other business services who, in the course of acting on our behalf, may provide us with your Personal Information. Another third party source of your Personal Information may be through social media, which depends upon your privacy settings with that third-party platform (as explained further, here).

  2. Public resources.  We may also collect your Personal Information from public resources, which is usually used to supplement Personal Information we have received from you and third parties in order to better meet the needs of our traveler, prospective travelers, and grow our business.  For example, we may collect Personal Information from corporate or educational institution websites to better understand the makeup of a particular group touring with us.

How Might We Use Your Personal Information

  1. To provide our services and products

  2. To provide relevant news and developments about Bridge to Poland Services and products that may be of interest to you.

  3. To provide information about different Bridge to Poland Services and third party marketing

  4. For inquiry/request response.  For example, we may use your Personal Information when you contact us for information or support for our Digital Properties, Services, or other information in order to respond and provide the appropriate assistance and response.

  5. For processing and fulfillment of orders and engagements

  6. To make, provide, or facilitate transportation, travel, and accommodation arrangements.

  7. To maintain travelers’ relationship records.   

  8. To conduct due diligence and ethical screening.  

  9. To generate reports on work, services and events provided.      

  10. In connection with surveys, feedback, reviews, testimonials, and exemplars

  11. To monitor Digital Properties’ usage, trends, and experience. 

  12. In connection with our vendors, consultants, and other service providers. We, and third party subcontractors acting on our behalf, may use your Personal Information in connection with the operation of our business and the Services we provide you, including for the functionality and security of our Digital Properties and other Bridge to Poland properties, to satisfy legal obligations or enforce legal rights, to enhance and otherwise improve our Digital Properties, Services and content, to provide you with enhanced experiences, and to advance the Bridge to Poland mission. These third parties and public sources could include: the possibility to partner with other travel, touring, landmark, or historical organizations, subcontractors in technical, payment, delivery, meeting, event and conference, marketing, recruiting, and survey services, analytics providers, marketing partners, search information providers, social media platforms, credit reference agencies, or (if you are applying for a position) background checking agencies.  Some third parties gather Personal Information on our behalf for the purpose of understanding how users are using our sites, making improvements to our sites, services, content, and products, and for providing or delivering the Services. We do not control third party service provider websites, platforms and applications collecting your Personal Information, in this regard, and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit or application you use when you use or enable these platforms and applications, or leave our Digital Properties. You may also be able to manage the automated technologies being used for these purposes, and your preferences, through your device and browser settings.

  13. In connection with Third Party Sites. We may allow you to interact with a third party's website, mobile application, or digital property (collectively "Third Party Sites") through our own websites, apps, or digital properties.  When doing so, we may collect Personal Information that you share with Third Party Sites depending upon that Third Party’s privacy practices and, possibly, your privacy settings with that Third Party.  We do not control these third party websites, platforms and applications collecting your Personal Information and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit or application you use when you use or enable these platforms and applications, or leave our Digital Properties. Some sections of our websites are operated by third parties.

  14. In connection with marketing research/statistics

  15. To help with our marketing and advertising and to grow our business. For example, with your permission, we may include photographs from our trips in which you appear, on our Website or social media channels.

  16. When we provide you geographically relevant Services, offers, or marketing.

  17. In connection with social media platforms. We may also collect your Personal Information when you connect with us through social media (e.g. Facebook, Twitter, Youtube and Instagram).  For example, this could be when you choose to use social media features like the Bridge to Poland Facebook “Like” button, or if you interact with us on our social media channels (for example, if you “follow” us or post on our channel). These features are operated by third parties and we do not have control over third party privacy practices, which we encourage you to read.  If you connect using your social media account, depending on your privacy settings with that social media platform, we may receive Personal Information you provided to that social media platform.  Subject to the third party social media platform’s terms of use and privacy notice, we may use this Personal Information to communicate with you (for example, to respond to your messages or posts to us), as well as to help us provide, enhance, and personalize our Services.  If you do not want to provide us with this information, you need to adjust the privacy settings on your social media account, and/or otherwise follow the third party’s instructions.

  18. Events held by or in partnership with Bridge to Poland.

  19. In connection with government reporting/audit/requests requirements

  20. To verify and/or authenticate an identity, access rights, privileges, etc

  21. At your direction

  22. For and in connection with security purposes.

  23. For other business-related purposes.

  24. As otherwise obligated by law

  25. For emergency purposes.

  26. By your consent. If we otherwise notify you and you consent to the sharing.

  27. In connection with staff administration.

  28. In connection with Bridge to Poland job and volunteer application administration

  29. In connection with internal audits and compliance reviews.

A note on marketing communications:

When you sign up to receive our Services we may use your Personal Information necessary to provide you information about a new or improved Service similar to what you may already receive, major changes to Bridge to Poland’s properties, an upcoming event, or other necessary marketing communications on our behalf.  We may share your Personal Information with third party service providers to facilitate these communications on our behalf and at our direction.  We may also obtain and use information about you from other companies or organizations that have your permission to share that information, as well as from other online and offline sources, which we may then combine with information that we collect directly and indirectly from you, for these purposes. 

Opting Out: If you wish to discontinue receiving these marketing messages sent by us, simply follow the unsubscribe options at the bottom of the email or contact us through our contact form.  Please note that, in such cases, it will remain necessary for us to process your Personal Information to the extent it is needed to maintain a suppression list, and we may also be required to disclose your opt-out information to third parties so they can suppress your name, from future solicitations. Also, if you are a member or subscriber to our products or services, you will continue to receive information and communications pertaining to your Bridge to Poland account and/or Bridge to Poland services even where you have opted out of marketing communications.

With Whom Do We Share Your Personal Information?

Except as set out in this privacy notice or as required by law we do not sell, license, rent, or swap your Personal Information without your permission.  We may have to share your Personal Information with the categories and types of parties set out herein for the purposes outlined in this notice or another supplemental notice provided by us. For example, we may share your Personal Information with our partner travel/tourism organizations, with our service providers and vendors, with accommodation and travel providers, social media platform providers, other Bridge to Poland travelers on your trip, or research and analytics solution providers. We require all third parties to respect the security of your Personal Information and to treat it in accordance with the applicable law.  Here are some examples of how we may share your information:

  1. Within Bridge to Poland. For example, your Personal Information may be shared within Bridge to Poland and (depending upon your trip’s tourism group) among Bridge to Poland travelers, to provide our Services and to better understand our business, analyze our operations, improve the Services, to develop new Services and areas of interest, to support and grow our organization and advance our goals. In addition, we share Personal Information to provide our travelers and prospective travelers with information on the Services that we think are most relevant to them and to enable us to measure the success of our marketing activities.

  2. Service Providers and Vendors. For example, we contract with service providers to help us with credit card and bill processing, shipping and delivery, email distribution, list processing, travel and accommodation arrangements, tour arrangements, analytics, promotions management, business growth, event facilitation, and other services to advance our business goals and meet the needs of our clients. We provide service providers only with the information they need to perform their services. For example, if you are a Bridge to Poland traveler, we may share your email address with a service provider necessary to send you emails (including newsletters) on our behalf. That service provider may not share your email address or Personal Information with other companies, and may only send you emails on behalf of Bridge to Poland.  Other service providers may help us with delivering or shipping to you our print materials, materials related to an upcoming trip, or other products you may order, and to ensure fulfillment of your orders, purchases, and registrations. We may also share, or facilitate the sharing of, your Personal Information with third party retail or payment processing platforms or vendors in order to process and confirm payment. Or, we may share your Personal Information with third party customer service providers and vendors that allow us to assist in answering and addressing your technical issues, complaints, or inquiries, as well as to receive and collect your feedback on our Services, your trip, etc.  We may also share your personal data with partners we have engaged to assist us in offering or arranging travel services on your behalf. As described above, we may also engage service providers to collect and analyze information about your use of our Digital Properties in order for us to improve our Services and grow our business.

  3. Social Media Platforms.  We may use widgets and tools from third party social media platforms on our Digital Properties to enable sharing and other functions through social media platforms, which facilitates the collection and sharing of your Personal Information by these social media platforms.

  4. Promotions, Contests, Surveys, and Events.  We may facilitate the collection of, or share your Personal Information with a third party service provider, vendor, co-host, or the like when we conduct, administer, host, or co-sponsor promotions, contests, surveys, or events.

  5. Marketing and Advertising Partners. We share personal data with third parties for marketing and advertising so they can assist us in promoting our Services and mission on and off our Digital Properties to current and future travelers, as well as travel-partners, through targeted marketing campaigns.

  6. Local Travel and Tour Partners.  We may share your personal data with local partners and service providers, such as accommodation and travel providers, tour locations and facilities, venues, events, and other activity providers in connection with our services and your tour.   

  7. Auditors and Due Diligence.

  8. Merger or Acquisition Partners.  We may share your Personal Information with third parties to whom we may choose to sell, transfer, or merge parts of our organization or our assets. Alternatively, we may seek to acquire other organizations or merge with them. If a change happens to our organization, then the new owners may use your Personal Information in the same way as set out in this privacy notice.

  9. With other third parties, as required for legal compliance, law enforcement, public safety, or security purposes. For example, we may disclose your Personal Information if we have a good faith belief that disclosure is necessary to comply with the law or with legal process, such as to comply with a subpoena, protect and defend our rights and property, to protect against misuse or unauthorized use of our websites, or to protect the personal safety or property of our users or the public. Or, for example, we may release Personal Information to comply with a court order or subpoena. Or, if you provide false information or attempt to pose as someone else, we may release Personal Information as part of any investigation into your actions.

California Privacy Rights.

If you are a California resident, you have the right, under California Civil Code Section 1798.83, to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed Personal Information for their direct marketing purposes in the prior calendar year. Please send requests for such information to us through our contact form.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted using SSL technology.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Acceptance and Changes to Our Privacy Notice

This Privacy Notice may be amended from time to time, consistent with the applicable data protection and privacy laws and principles. We will post those changes on our Website so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.  We reserve the right to modify this Privacy Notice at any time, so please review it frequently. We will also notify you by email or a means of a notice on our Website prior to the changes becoming effective, if we make changes that materially affect the way we handle Personal Information.  If you do not wish your information to be subject to the revised Privacy Notice, you will need to deactivate with us and stop using our Digital Properties and Services.  Your use of our Digital Properties and Services after the posting of such changes will constitute your consent to such changes. 

By using Bridge to Poland’s Services and our Digital Properties, and/or submitting any of your Personal Information to us, you agree to the terms of this Privacy Notice.  Please do not send us any Personal Information if you do not want that information used in this way.

Who Should you Contact if you Have Questions?

To ask questions or comment about this privacy notice and our privacy practices, contact us at:

Email: Contact us through our contact form [Link]

Mail: Bridge To Poland

P.O. Box 248

Lexington, MA 02420

Updates to Personal Information: If you would like to update the Personal Information that we have about you, or if you no longer desire our Services, please contact us at the above contact information.

Unsubscribe Requests: If you would like to contact us about unsubscribing from our email lists, you can do so by using the unsubscribe link in an email from Bridge To Poland, or by emailing us through our contact form and providing all of your email addresses that could appear on our email lists, as well as the name of the list, newsletter, or communication category from which you would like to unsubscribe.

Please read this notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and to not provide us with your Personal Information.