Privacy Policy | Snap Voyagers

This Privacy Policy describes how VTX, LLC, doing business as Snap Voyagers ("Snap Voyagers", "we", "us", or "our"), collects, uses, shares, and protects personal data. It applies to all individuals who access or use the Snap Voyagers online marketplace, website, and related services (collectively, the "Platform"), including individuals who browse the Platform, book travel ("Travelers"), or lead trips ("Group Leaders").

This policy governs data for which Snap Voyagers is the data controller. It does not apply to the data practices of independent Group Leaders or other third parties, who may have their own privacy policies. By using the Platform, you acknowledge you have read and understood this Privacy Policy.

1. Key Definitions

Personal Data: Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Sensitive Personal Data: A subset of Personal Data that may include government-issued identification numbers, precise geolocation, racial or ethnic origin, religious beliefs, or health information. We process Sensitive Personal Data only with your explicit consent or as permitted by law.
Processing: Any operation performed on Personal Data, such as collection, recording, organization, storage, use, disclosure, or erasure.
Controller: The entity that determines the purposes and means of Processing Personal Data. For the purposes of this policy, Snap Voyagers (VTX, LLC) is the Controller.
Processor: An entity that Processes Personal Data on behalf of a Controller.
User Content: Includes photos, videos, text, reviews, itineraries, listings, and other content posted or submitted to the Platform.
Third-Party Providers: Means airlines, hotels, transport operators, guides, and any other third party involved in a Journey.

2. Categories of Personal Data Collected

We collect Personal Data to provide and improve the Platform, facilitate Journeys, and ensure a secure user experience. The categories of data we collect include:

Identity and Account Data: Information you provide when creating an account, such as your full name, email address, password, and contact details. Group Leaders may provide additional professional information for their public profiles, such as their background, experience, and qualifications.
Transactional and Payment Data: Details about Journeys you book or list, pricing, payment information (such as credit card numbers and billing addresses, which are processed by our third-party payment processors), and payout information for Group Leaders (such as bank account details and tax identification numbers).
User Content: Any Personal Data contained within the photos, videos, reviews, Journey listings, and other content you voluntarily upload or post to the Platform.
Communications Data: Records of your communications with us (such as emails to our support team) and messages exchanged with other users through the Platform's communication tools.
Technical and Usage Data: Information collected automatically when you use the Platform, including your IP address, browser type, operating system, device information, pages viewed, time spent, and other analytics data about your interaction with our services.
Location Data: We may collect your general location based on your IP address. With your permission, we may collect more precise location data from your mobile device to provide location-based services.
Data from Third Parties: We may receive Personal Data about you from third-party services, such as payment processors who provide transaction confirmations, identity verification services, or social media platforms if you choose to link your Snap Voyagers account.
Sensitive Personal Data: We may facilitate the collection of Sensitive Personal Data on behalf of Group Leaders, such as passport information for travel logistics or health and dietary information for safety purposes, typically through forms and waivers provided by the Group Leader. We process this data only as necessary and with appropriate safeguards.

3. How We Collect Data

We collect Personal Data in several ways, both directly from you and automatically as you use our Platform. These methods include:

When You Provide It to Us: We collect data when you voluntarily perform actions such as creating an account, building your Traveler or Group Leader profile, listing or booking a Journey, filling out forms, or communicating with our support team.
When You Post Content: We collect the information contained in User Content you submit to the Platform, including in Journey listings, public profiles, reviews, photos, videos, and messages exchanged with other users.
Automatically Through Technology: As you interact with the Platform, we automatically collect Technical and Usage Data using cookies, server logs, web beacons, and other similar technologies. This helps us analyze user behavior, ensure security, and improve our service.
From Third Parties: We may receive information from third-party partners who assist us in operating the Platform. This includes payment confirmations from our payment processors, reports from identity verification providers, and information from social media services if you choose to link your Snap Voyagers account.

4. Purposes of Processing and Legal Bases

We process your Personal Data for specific purposes and only when we have a valid legal basis to do so under applicable law, such as the EU General Data Protection Regulation (GDPR). The primary purposes for our processing activities and the corresponding legal bases are outlined below:

To Operate and Provide the Platform: To create and manage your account, display your profile and User Content, facilitate the listing and booking of Journeys, and enable communications between users.

Legal Basis: Performance of our contract with you (our Terms of Service).

To Process Payments, Payouts, and Financial Obligations: To facilitate transactions, hold funds in escrow, process payments to Group Leaders, and manage financial reporting.

Legal Basis: Performance of a contract and compliance with a legal obligation.

To Provide Customer Support and Administrative Communications: To respond to your inquiries, troubleshoot issues, send booking confirmations, and provide important notices about your account or changes to our policies.

Legal Basis: Performance of a contract and our legitimate interests in providing quality service and maintaining our user relationships.

For Security, Safety, and Fraud Prevention: To verify user identities, monitor for and protect against fraudulent or prohibited conduct, and ensure the security and integrity of our Platform.

Legal Basis: Our legitimate interests in protecting our Platform, business, and users, as well as compliance with legal obligations.

For Marketing and Promotions: To send you information about Journeys, Platform features, or promotions that may interest you.

Legal Basis: Your consent (where required by law, such as for certain email marketing campaigns) or our legitimate interests in promoting our services to our users.

For Analytics and Service Improvement: To understand how users interact with our Platform, conduct research, and use insights to improve our technology, features, and overall user experience.

Legal Basis: Our legitimate interests in developing and enhancing our business.

To Comply with Legal and Regulatory Requirements: To meet legal obligations, such as tax reporting requirements for Group Leader earnings, and to respond to lawful requests from courts or government authorities.

Legal Basis: Compliance with a legal obligation.

5. Cookies, Tracking Technologies, and Advertising

We use cookies, web beacons, pixels, and similar tracking technologies ("Cookies") to operate and improve the Platform, ensure its security, and analyze user interaction. These technologies are small data files placed on your device. We use them for several purposes:

Strictly Necessary Cookies: Essential for the Platform to function, such as for user authentication, security, and managing your session. These cannot be disabled.
Performance and Analytics Cookies: Help us understand how you interact with the Platform by collecting information about which pages you visit, how long you spend on them, and any errors you encounter. This allows us to improve our services.
Functional Cookies: Used to remember your preferences and settings (such as language or region) to provide a more personalized experience.
Advertising and Targeting Cookies: Used by us and our advertising partners to deliver advertisements that may be relevant to your interests, both on and off the Platform, and to measure the effectiveness of ad campaigns.

You can manage your Cookie preferences through your browser settings and through our [Cookie Preference Center]. Please note that disabling certain Cookies may impact the functionality and your experience of the Platform.

6. Sharing and Disclosure of Personal Data

We do not sell your Personal Data. However, we share it with certain third parties to operate the Platform, facilitate Journeys, and comply with our legal obligations. The categories of recipients include:

With Other Users: We share information between Travelers and Group Leaders as necessary to facilitate a booking. For example, a Traveler's name is shared with a Group Leader upon booking. A Group Leader's public profile, which may include their name, experience, and photo, is visible to all users. Reviews and other User Content you post may also be publicly visible.
With Service Providers and Processors: We engage third-party companies to perform services on our behalf, such as payment processing, cloud hosting, data analytics, email delivery, customer support, and identity verification. These processors are contractually bound to protect your data and may only use it to perform services for us.
With Third-Party Providers: At the direction of a Group Leader, we may share traveler information with Third-Party Providers (such as hotels or local transport operators) to facilitate Journey logistics.
With Analytics and Advertising Partners: We may share Technical and Usage Data with partners who help us with marketing, advertising, and analyzing the performance of our Platform.
For Legal Reasons and Business Transfers: We may disclose your Personal Data if required by law, subpoena, or other legal process. We may also share your data in connection with a merger, acquisition, financing, or sale of all or a portion of our business assets.
With Your Consent: We may share your Personal Data with other third parties when we have your explicit consent to do so.

7. International Data Transfers

Snap Voyagers is operated by VTX, LLC, a company based in the United States. Your Personal Data will be processed in the United States and potentially in other countries where our service providers are located. These countries may have data protection laws that are different from the laws of your country of residence.

When we transfer Personal Data from regions with comprehensive data protection laws, such as the European Economic Area (EEA), the United Kingdom (UK), and Switzerland, to other countries, we rely on legally-provided mechanisms to ensure an adequate level of protection. This may include using Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions about certain countries, or other appropriate legal safeguards.

By using our Platform, you acknowledge that your Personal Data may be transferred to and processed in the United States. For more information about the safeguards we use for international transfers, you can contact us at [PRIVACY EMAIL].

8. Data Retention and Deletion

We retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, to provide our services, to comply with our legal obligations, and to resolve disputes. The criteria used to determine our retention periods include:

Account Data: We retain your account and profile information for as long as your account is active. If you close your account, we will delete or anonymize this information within a reasonable period, subject to our backup and archival processes.
Booking and Transactional Data: To comply with financial, tax, and legal requirements, we retain data related to bookings and financial transactions for a period of up to seven years after the transaction is complete.
User Content: Content you post publicly, such as reviews or Journey listings, may remain visible on the Platform even after your account is closed. We will remove the attribution to you upon request where feasible.
Communications Data: We retain records of communications with our support team for as long as necessary to resolve any open issues and for training and quality assurance purposes.
Legal Holds: We may be required to retain your data for a longer period if it is subject to a legal hold, litigation, or government investigation.

You may request the deletion of your Personal Data by contacting us. We will comply with your request subject to our legal obligations and legitimate business interests, such as the need to complete transactions, prevent fraud, or enforce our Terms of Service.

9. Security Measures

We have implemented administrative, technical, and physical security measures designed to protect your Personal Data against unauthorized access, destruction, or alteration. These safeguards include:

Technical Measures: Using encryption to protect data in transit (using TLS) and at rest, employing firewalls, and implementing network security controls.
Administrative Measures: Maintaining internal data protection policies, restricting access to Personal Data to employees and contractors on a "need-to-know" basis, and conducting due diligence on our third-party service providers.
Physical Measures: Securing the physical locations where your data is stored through our agreements with leading cloud service providers.

While we take commercially reasonable steps to protect your information, no security system is impenetrable. We cannot guarantee the absolute security of your Personal Data.

10. Your Rights and Choices

Depending on your location and subject to applicable law, you may have certain rights and choices regarding your Personal Data. These rights may include:

The Right to Access: You may have the right to request a copy of the Personal Data we hold about you.
The Right to Rectification: You have the right to request that we correct any inaccurate or incomplete Personal Data. You can update most of your account information directly through your account settings.
The Right to Erasure (Deletion): You may have the right to request that we delete your Personal Data, subject to certain exceptions.
The Right to Restrict Processing: You may have the right to request that we restrict the processing of your Personal Data under certain conditions.
The Right to Data Portability: You may have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
The Right to Object: You may have the right to object to our processing of your Personal Data where it is based on our legitimate interests. You have an absolute right to object to processing for direct marketing purposes.
The Right to Withdraw Consent: Where we rely on your consent to process Personal Data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at [PRIVACY EMAIL] or through your account settings. We will need to verify your identity before processing your request and will respond within the timeframes required by law. You also have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Data violates applicable law.

11. Children and Age Restrictions

The Platform is not intended for or directed at children. You must be at least 18 years old or the age of legal majority in your jurisdiction to use our services. We do not knowingly collect Personal Data from individuals under this age. If we become aware that we have inadvertently collected Personal Data from a child, we will take steps to delete the information and terminate the associated account as quickly as possible. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us at [PRIVACY EMAIL].

12. Third‑Party Links and User Content

The Platform may contain links to third-party websites or services that are not owned or controlled by Snap Voyagers, including affiliate or referral links that may be included in Group Leader profiles, listings, or blog content. This Privacy Policy does not apply to the practices of these third parties. We encourage you to review the privacy policies of any third-party websites or services you visit.

Furthermore, please be aware that User Content you post, such as in public profiles or reviews, is visible to others. You are responsible for the information you choose to share publicly. We are not responsible for the privacy practices of other users who may collect and use the information you make available.

13. Data Breach Notification

In the event of a security breach that compromises Personal Data, we will take immediate steps to investigate the incident, mitigate harm, and comply with our legal obligations. If we determine that a breach has occurred that requires notification, we will notify the appropriate regulatory or supervisory authorities within the timeframes mandated by applicable law (for example, within 72 hours under GDPR where feasible). If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will also notify affected users without undue delay, providing information about the nature of the breach and the steps we have taken in response.

14. Account Closure and Effects

You may close your account at any time through your account settings or by contacting us. Upon receiving your request, we will deactivate your account and your profile will no longer be visible on the Platform. We will then delete or anonymize your Personal Data in accordance with our data retention policies.

Please note that we may need to retain certain information for a longer period to comply with our legal and financial obligations (such as tax and accounting records), resolve disputes, enforce our agreements, or for fraud prevention. Publicly posted User Content, such as Journey reviews, may remain visible on the Platform after your account is closed, but we will remove personal attribution upon request where practicable.

15. Law Enforcement and Legal Requests

We may access, preserve, and disclose your Personal Data if we have a good-faith belief that it is required by law or necessary to respond to a valid legal process, such as a subpoena, court order, or search warrant from government or law enforcement authorities. Our policy is to notify users of such requests prior to disclosure, unless we are legally prohibited from doing so or in exigent circumstances where there is a risk of imminent harm. We may challenge requests that we believe are overly broad, vague, or lack a proper legal basis.

16. Contact Information and Privacy Officer

If you have any questions, comments, or complaints about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact our Data Privacy Team.

By Email: [PRIVACY EMAIL] By Mail: VTX, LLC Attn: Data Privacy Officer [MAILING ADDRESS]

We have appointed a Data Privacy Officer whom you can reach via the contact details provided above.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make material changes, we will notify you by email or through a notice on the Platform prior to the change becoming effective. The date this policy was last updated is indicated at the top of this document. We encourage you to review this policy periodically.

18. Governing Law; International Disclosures

Unless otherwise required by applicable local law, this Privacy Policy and any disputes arising from it are governed by the laws of the State of Texas, without regard to conflict of law principles.

Disclosures for Specific Jurisdictions:

European Economic Area (EEA), United Kingdom (UK), and Switzerland: If you are a resident of these regions, you have specific rights under the GDPR and other local laws. These rights and additional details about data transfers are outlined in our EU/UK Data Addendum, which is incorporated into this policy.
California: If you are a California resident, you have specific privacy rights under the California Consumer Privacy Act (CCPA). These rights may include the right to know what personal information is collected, the right to delete personal information, and the right to opt-out of the "sale" or "sharing" of personal information. For more details on these rights and how to exercise them, please see our California Privacy Rights Addendum.

Please refer to the Appendices section for information on how to access these supplemental documents.

19. Appendices and Supplemental Materials (Cookie Table; Data Processing Addendum; EU/UK Data Addendum)

This Privacy Policy is supplemented by the following documents and resources, which provide additional detail on our data processing activities.

Cookie Policy & Preference Center: Provides detailed information about the specific cookies we use, their purpose, and their duration. You can manage your preferences at any time through our [Cookie Preference Center Link].
List of Subprocessors: A list of the key third-party service providers (processors) we use to deliver our services, such as for payment processing and cloud hosting. This list is available upon request by contacting our Data Privacy Team.
Data Processing Addendum (DPA): For our Group Leaders who may be considered data controllers under certain laws, we offer a DPA that governs our processing of Personal Data on their behalf. To execute a DPA, please contact us at [PRIVACY EMAIL].
EU/UK Data Addendum: Provides specific information for individuals in the European Economic Area, the United Kingdom, and Switzerland, as required by the GDPR and related data protection laws. This addendum is available at [LINK TO EU/UK ADDENDUM].
California Privacy Rights Addendum: Provides specific disclosures and instructions for California residents to exercise their rights under the CCPA. This addendum is available at [LINK TO CA ADDENDUM].