1. Who We Are
Twin America, LLC (doing business as Gray Line New York) collects, uses and is responsible for certain personal information about you. We collect personal information in relation to the services and products we provide. See: www.graylinenewyork.com.
2. Children’s Online Privacy Protection Act
This website and any products and services offered herein are not intended for purchase by persons under the age of 13. We do not knowingly collect information from anyone under 13 years of age. We prohibit children under the age of 13 from using all interactive portions of this website, including submitting information, purchasing product or services or making payments. We will not knowingly collect personally identifiable information from children under 13. If we learn that we have any information or content from anyone under the age of 13, we will delete that information.
3. The Personal Information We Collect and Use
a. Information Collected by Us
We may collect, use, and is responsible for certain personal information that you provide when you voluntarily order a service or product or otherwise contact us via an online form or e-mail. The information collected may include your name, e-mail address, phone number, date of travel, credit card information and/or other billing information. You are not required to provide any personally identifiable information to merely access or visit this website.
We, and our third-party vendors may collect nonpersonal information through the use of these technologies. Nonpersonal information might include the browser you use, the type of computer you use and technical information about your means of connection to this website such as the operating systems and the Internet service providers utilized and other similar information. Our systems may also automatically gather information about the areas you visit and search terms you use on this website and about the links you may select from within this website to other areas of the Internet.
If you are located in the European Economic Area (EEA), we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.
b. Information Collected from Other Sources
We also obtain personal information from other sources, such as our third party affiliates or, at times, from authorized resellers of our products. We obtain such information only in relation to the services and products we provide.
c. How we use your personal information
We collect such information in order to send e-mails, fulfill orders, deliver services and products, complete customer transactions, conduct website live chat, solicit customer reviews, oversee contests and promotions and improve website performance and customer service.
d. Who We Share Your Personal Information With
We respect your privacy and will never sell, trade or transfer your personally identifiable information to unaffiliated third parties (beyond what is necessary for fulfilling a customer transaction or for the basic functionality of an online service) without your consent.
We do, however, share personal data such as customer name, email, phone number, travel date and address with credit card processors and, exclusive of credit card information, with ecommerce platforms, marketing tools and other platforms. This data sharing enables us to deliver our product and services and improve the overall customer experience. Those third-party recipients are based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see Transfer of your information out of the EEA, or contact us, see How To Contact Us.
We may release personal information to enforce our Website Terms and Conditions of Use, other Terms and Conditions, manage its business, protect users or the general public, or to otherwise comply with legal obligations. We may share information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.
If you give us your permission, we may also use personal identification information for internal or external marketing and promotional purposes.
On occasion, we may collect personal identification information from you in connection with optional contests, special offers or promotions. We will share such information with necessary third parties for the purpose of carrying out the contest, special offer or promotion. We will ask for your consent to such disclosure and use of such information, prior to your participation in the contest, special offer or promotion.
We will not share your personal information with any other third party.
e. Whether Information Has to Be Provided by You and Why
The provision of name, e-mail, address, phone number, date of travel, credit card information and/or other billing information is required from you to enable us to process and complete your order for our products or services. We do not require you to provide any personal data in order to browse on the website. We will inform you when we collect it whether you are required to provide the information to us.
f. How Long Your Personal Information Will Be Kept
We will hold your personal information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- whether we have any legal obligation to continue to process your information (such as any recordkeeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost and liability involved with us continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate; and
- any relevant surrounding circumstances (such as the nature and status of our relationship with you).
g. Reasons We Can Collect and Use Your Personal Information
We collect and use your personal information to further the following legitimate interests: to send e-mails, fulfill orders, deliver services and products, complete customer transactions, oversee contests and promotions and improve website performance and customer service.
4. Use and Transfer of Your Information Out of the EEA
This website is operated in the United States and third parties with whom we might share your personal information as explained above are located in the United States. If you are located in the EEA or elsewhere outside of the United States, please be aware that any information you provide will be transferred to the United States. By using this website, participating in any of its services and/or providing your information, you consent to this transfer.
The United States does not have the same data protection laws as the United Kingdom and EEA. While the European Commission has not given a formal decision that the United States provides an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to certification under an approved certification mechanism as permitted under GDPR Article, Article 46(f) https://gdpr-info.eu of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the such certification mechanism see https://www.privacyshield.gov.
If you would like further information, (see “How to contact us” below). We will not otherwise transfer your personal data outside of the EEA or to any organization (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
5. Your Rights
If you want to unsubscribe from receiving e-mails from us, you may do so at any time. Each e-mail from us includes instructions for unsubscribing from these e-mail communications.
If you are covered by the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to:
• Fair processing of information and transparency over how we use your use personal information
• Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
• Require us to correct any mistakes in your information which we hold
• Require the erasure of personal information concerning you in certain situations
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• Object at any time to processing of personal information concerning you for direct marketing
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• Object in certain other situations to our continued processing of your personal information
• Otherwise restrict our processing of your personal information in certain circumstances
You may also have the right to claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, available at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .
If you would like to exercise any of those rights, please:
• Email, call, or write to us
• Provide us enough information to identify you (e.g., account number, user name, registration details)
• Provide us proof of your identity and address (a copy of your driver’s license or passport)
• Provide us with the information to which your request relates including, any account or reference numbers, if you have them
6. Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable authorities of a suspected data security breach where we are legally required to do so.
Please note that any comments or information that you post on the website and social media pages, become public and third parties may use your information. We are not responsible for any unauthorized uses by third parties in such context. You disclose such information at your own risk.
7. Links to Other Sites
You may see advertising or other content on this website that links to the sites and services of ourpartners, suppliers, advertisers, sponsors, licensors or other third parties. Any products or services reached through a third-party link are subject to separate privacy policies. We are not responsible for or liable for any content on or actions taken by such third-party websites.
8. How to Complain
We hope that we can resolve any question or concern you raise about our use of your information.
If you are covered by the General Data Protection Regulation, you may lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
9. Changes to This Privacy Notice
10. How to Contact Us
10.1 This website is owned and operated by TWIN AMERICA, LLC.
10.2 We are a Delaware, United States of America limited liability company and our registered office is at 1430 Broadway, Suite 507, New York, NY 10018.
10.3 Our principal place of business is 1430 Broadway, Suite 507, New York, NY 10018.
10.4 You can contact us:
(a) by post to the postal address given above
(b) using our website contact form
(c) by telephone on the contact number published on our website from time to time
(d) or by e-mail using the e-mail address published on our website from time to time.
10.5 Our data protection officer’s contact details are:
Alan G. Katz
Saretsky Katz & Dranoff LLP
475 Park Avenue South
New York, NY 10016
e-mail: [email protected]
11. Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).