Wertu Trips Privacy Policy

This privacy policy (the “Policy”) describes how Wertu Trips Ltd., (the “Company”, "us" or "we" or "our") collects and uses information from the website https://www.wertu.ai/ (the “Site” or "Platform"). By accessing and using the Platform and its' services, you agree to be bound by this Privacy Policy. If you do not agree to any of the provisions as set hereunder in this Privacy Policy, please do not use the Platform or any of its services. This Policy should be read together with the Terms of Use ("TOU") which also apply to the Platform [Dear Client: please add a link to TOU on the words "Terms of Use"]. This Policy does not apply to other websites that post different statements, regardless of whether or not the Site links to them or not.

1. AGE RESTRICTIONYou must be 18 years old or older to use the Platform. If you are under 18, please refrain from using the Platform and/or from providing us with any information. We do not knowingly collect information from users under the age of 18. If we become aware that we have collected personal information from a child under the age of 18 years old, we will use reasonable efforts to delete such information.
If you are older than 13 but under 18 you may only use the Site after you have provided us, and we confirm that we have received, Parental Consent. The Parental Consent is an email from your parents or legal guardians, in which they specifically agree to your use of the Site. The email needs to contain (1) a signed photocopy of your parents identification documents (driving license, passport or other officially accepted documentation) and (2) the following statement: "We, the parents of [your name], have read the Privacy Policy and Terms of Use for the Site https://www.wertu.ai/ and agree to the terms and take full responsibility for monitoring our son's/daughter's activities on the Site".We may terminate your account if we find that you are younger than the Permitted Age and/or if we did not receive Parental Consent. We may at any time request additional information to confirm your age.

We collect the following information so that we can provide you with our service:
2.1 Information You Give Us. We collect your full‎ name, email address, phone number, date of birth, nationality, gender, age, passport number, ID number, passport expiration date, ID expiration date as well as other information you directly give us on our Platform (for example, in your profile), or that you send us (including, but not limited to, information sent to us when you connect and/or interact with the Platform through other third party services or platforms, such as Facebook and Google if your account settings on those platforms allow this). 
2.2 Information We Get from Others. We may get information about you from other sources, for example, other users or social platforms (such as Facebook), with which you connect to the Platform (if your account settings on those platforms allow this).
2.3 Anonymous Information. We automatically log anonymous information about you and the device (computer, mobile phone etc.) you use when using the Platform in order to improve our services and your experience. For example, when visiting our Platform, we log your device's operating system, browser type, browser language, and other general statistical information.
2.4 Cookies. We may log information using "cookies." Cookies are small data files stored on your device. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on our Platform, for example, cookies help store your username when you login so that you don't have to insert this information every time.
You can remove or block cookies from the Platform through your browser settings. You can also block cookies on most mobile devices under "settings". Please note that if you remove or reject our cookies, it could affect how our Platform works for you and/or prevent you from being able to access/use certain features.
This Privacy Policy does not cover the use of cookies by third parties, advertisers and/or partners on our Platform (all information referred to herein will be referred to as "User Data").

We use your personal information to provide you with the services on our Platform and to improve your experience on our platform. Additionally, we may use your information to:
- Operate, maintain and improve our Platform; 
- Send you information including confirmations, invoices, updates, security alerts, and support and administrative messages; 
- Respond to comments and/or questions and to assist you with any technical support (establish and set up your account, verify or re-issue a password), log your activity and contact you;
-  Protect, investigate and deter against fraudulent, unauthorized or illegal activity;
- Provide and deliver products and services that you may request;
- To protect you and/or other users and prevent any use of the Platform which is unlawful or against our TOU.
- To resolve disputes and troubleshoot problems, and:
- Send you marketing emails if you agreed to these when signing up. You may ask to be unsubscribed at any time.

We may share personal information as follows:
- When you provide your consent. For example, you may let us share personal information with third parties. Third parties are subject to their own privacy policies.
- When we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
- For legal, protection, and safety purposes, for example:
* To comply with laws.
* To lawful requests and legal processes.
* To protect the rights and property of the Company, its agents, customers, and others. This includes enforcing our agreements, policies, and TOU.
* In an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
- With Travel suppliers  (for instance, the specific hotel you have requested us to reserve) as well as third-party service suppliers (such as Agoda.com), airlines, car rentals, sports experiences and activities, who are responsible for fulfilling your travel reservations. These suppliers, acting as independent data controllers, may reach out to you as required to collect further details, assist with your travel arrangements, including contacting you before arriving to discuss your stay, in line with their individual privacy policies.
- With third party service providers in order to provide you with specific services and/or features. For example, if we use a third-party payment application.
- We may also share general aggregated and/or anonymized data with others for their own uses. This information does not personally identify you.

5.1 Due to the fact that some of the services are provided by third parties located in various locations worldwide, your information may be transferred to, and stored on, computers located at these other countries - outside of your country or LEGAL jurisdiction (the "Transfer"). Additionally, the privacy laws of these countries may differ from those in your jurisdiction. By using our services and/or providing us with your personal information, you are giving us your consent to this Transfer.
5.2 Our services may integrate with third party social applications and/or services such as Facebook, Instagram, Twitter etc. (the "Social Apps"). These Social Apps let you share information and actions that you take on our Platform, on the Social Apps. For example, an action you take on our Platform may be published on Facebook if your account has been set-up this way. Please check your privacy settings in your profile on the Platform (as is applicable), and the settings and privacy policies of the relevant Social Apps for more information about how they handle the data you share through them.

Your personal information is protected in several ways. For example, access to your account and personal information is available only through a password and unique username/user ID selected by you (or the password and username selected on the Social App through which you logged in). Additionally, your personal information is stored on secured servers of approved third party service providers, and only selected personnel have access to. 
By creating an account, you agree to keep your password and username in strict confidence and not disclose such information to any third party. Should you feel that your password or account has been compromised, please let us know immediately.
Although we use industry standard security measures to protect your personal information so that it is not made available to unauthorized parties, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure and any information you provide is your sole responsibility and subject to this Policy and our TOU. 
We retain personal data for the duration needed to support our ordinary business activities operating the Service. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information, such as encrypted transmission of the data we communicate to and from users.
However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.

Additional Information For Users In The EU
Wertu Travel Ltd. is the data controller for the purposes of the personal data processed on the platform.
The Company is based in Israel.
Our European representative, for the purposes of this Policy, is GDPR-Rep.eu
If you are within the European Economic Area, you may contact our European representative the at the following address: gdpr-rep.eu
Our Data Protection Officer (DPO) is Matan Noti. You may contact our DPO the at the following address: matan@wertu.ai.
The legal basis for collecting and processing User Data is the performance of our term of service contract in providing you the Service and our legitimate interests in administering and managing the Service.
The legal basis for processing User Data that is considered special categories of data (sensitive information), is that this processing relates to personal data which you manifestly made public by posting it publicly on the Service and our legitimate interests in developing and enhancing the Service and our business and our legitimate interests in maintaining an appropriate and safe environment on the Service, as well as protecting the vital interests of other users of the Service.

The legal basis under EU law for voluntarily sharing your data with competent authorities is our legitimate interests in defending and enforcing against violation and breaches that are harmful to our business.
The legal basis under EU law for sharing your data if we are legally required to do so by authorities, is our legitimate interests in complying with mandatory legal requirements imposed on us.
The legal basis under EU law for sharing your data in the event of a structural change of our business is our legitimate interests in our business continuity.
The legal basis under EU law for processing your information to invite you to participate in surveys by academic research institutions is the legitimate scientific research interests of those research institutions.
The legal basis under EU law for using your email address to send you updates to this Policy is its necessity for our compliance with the legal obligations of the GDPR.
The legal basis for sharing information about your use of our Service with Facebook and other advertising partners is your consent.

Information we collect from you will be processed in Israel, which is recognized by the European Commission as having adequate protection for personal data.
If we transfer your information from within Europe to other jurisdictions outside Europe, we will always endeavor to do so using adequate safeguards determined by the EU Commission, such as Privacy-Shield certified companies in the United States.
If you are in the EU, you have the following rights under the GDPR subject to the limitations that the GDPR attaches to these rights:
Right to Access your personal data that we process and receive a copy of it.
Right to rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
Right to Data portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
Right to object, based on your particular situation, to using your personal data on the basis of legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims. You may also object at any time to the use of your personal data for direct marketing purposes.
Right to restrict processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you opposes the erasure of the personal data and requests instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.
Right to be forgotten. Under certain circumstances, such as when the personal data are no longer necessary for the purposes for which they were processed, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

If you wish to exercise any of these rights, contact us at hello@wertu.ai
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

Additional Information For Users In The United States
With regard to the transfer of User Data to the United States, your personal information will only be transferred to third-parties who undertook to provide guarantees as to the secure processing of personal data in accordance with the Privacy Shield (data protection shield) recognized by the European Commission as ensuring an adequate level of protection.

By signing up to our Platform, you agree to receive emails with promotional content related directly or indirectly to our services, including, for example, service suggestions and other news about products and services offered by us and our selected partners. You can opt-out of these communications at any time using the 'unsubscribe' link provided in them, or by contacting us by email, after which we will no longer send you promotional emails. We may still send you non-commercial emails which are necessary in order to provide you with the services.

This Policy may be changed occasionally. If we make any substantial changes, we may notify you by sending you an e-mail to the last e-mail address you provided, and/or by posting notice of the changes on our Platform. Any changes will be effective upon the earlier of ten (10) calendar days following our email or ten (10) calendar days following our posting of the notice on our Platform. These changes will be effective immediately for new users of our Platform. Continued use of our Platform following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

We take your privacy seriously. If you have any concerns, please let us know. Contact us at hello@wertu.ai

Last Updated: [May] 2024