Who we are
Our website address is: https://testwinner.org.
Privacy and Cookie Statement
Active: December 31, 2019
Sharing your personal information with us is based on trust. We take this seriously and are committed to ensuring that we respect your privacy when you visit our website or use our services. Please review this Statement carefully to learn about our privacy practices.
We operate an online service that provides users with recommendations for a business of all kinds, travel, and travel planning, including hotels, holiday rentals and other accommodations, attractions and experiences, restaurants, flights, cruises, travel guides, and lots more. In this Statement, these are collectively referred to as our Services.
Our Services are owned and operated by Marbella Solutions S.A. By visiting our websites and related applications, whether on a computer, phone, tablet, or similar device (these are all referred to as a “Device”), you are accepting the practices described below.
As a global company, we operate in many countries and territories where the laws and customs differ. This Statement provides a general overview of our privacy practices; you can view certain country-specific information by selecting your place of residence in the jurisdiction links at the bottom of this Statement.
When you access our Services, we collect information from and about you to provide a more personalized and relevant experience. Some information we collect automatically. Other information we collect from different sources, including affiliated entities, business partners, and other independent third-party sources. When you use our Services by “clicking-through” from a third-party site or when you visit third-party sites via our Services, those third-party sites may share information with us about your use of their service. Information collected may include the following:
Contact information, including name, phone number and postal and email addresses
Billing or payment information (such as your credit card number, cardholder name, expiration date, authentication code, and billing address)
User name and password
Photos, reviews, forum, and social posts, and videos you may have provided to us
Device information, such as when you accessed our Services and information about the device used (for example, I.P. address, software or internet browser used, preferred languages, unique device identifiers, and advertising identifiers)
Online activity, including pages you have visited, content reviewed, and apps reviewed
Information about your travel plans and preferences
In instances where you have provided it, we may also collect information about other travelers, including their email address and additional travel-related information. If you are sharing information with us about other individuals, you must obtain their consent. You must obtain the permission of any other individuals if you are providing their data to us.
In addition to the categories noted above, we may also collect location information if you have instructed your device to send such information via the privacy settings on that device. For example, if you have uploaded photos tagged with location information. We may use your location information directly and/or share your location with third-parties. We collect and share location information to provide you with relevant content, analyze your Services’ use, improve our Services, and provide contextual advertising or recommendations. For example, we may use your location to show you reviews of hotels, restaurants, or attractions near you when you are traveling.
You can change the privacy settings of your device to turn off the functionality that collects and shares location information and/or the functionality to tag your photos with location information. However, turning off location sharing may affect certain features we offer. If you have any questions about your device’s privacy settings, we suggest you contact the manufacturer of your device or your mobile service provider for help.
We are committed to providing you with relevant content on our Services and respecting the data privacy laws of the different jurisdictions we operate in. We use information about you to help you enjoy and use our Services, including in the following ways:
Register and manage your account, including to allow you access to and use of our Services
Measure interest in and improve our Services
Notify you about special offers and products or services available from us, our affiliates, or our partners that may be of interest to you
Communicate with you
Enable communication between registered users and owners/representatives of listings on our Services
Enable us to publish your reviews, forum posts, photos, videos, and other content
Customize your experience, including customizing the ads shown to you on our Services and across the internet
Make inferences about your interests or preferences
Provide you with an optimized experience and to group users of our Services based on, for example, usage and demographics
Send you a survey or market research invitations
Respond to your questions and comments
Resolve disputes or troubleshoot problems
Prevent potentially prohibited or unlawful activities
Please note some information about you that is required for us to provide you with relevant offerings from us, our affiliates, and our partners and enable you to enjoy other benefits of being a registered user. Please review the “Information Choices” section below to your choices related to the collection and use of your information.
To provide some of our Services, we may need to share information with certain other third-parties, including our group of companies, in the following circumstances:
Our Group of Companies. We share information with companies in our corporate family to provide you with information about products and services, both travel-related and others, which might interest you. These companies and websites will comply with this Statement and all applicable laws governing the transmission of promotional communications.
Suppliers. We share information with certain suppliers used to facilitate our Services, including to help with transactions, such as any reservations you might make, for example, sharing data with a restaurant if you make a reservation using our Services.
Business Partners. We may share information about you, your Devices, and our Services with our trusted business partners. For example, we may share information so that we can provide you with relevant content or facilitate payment for products or services you may purchase on our partners’ websites. This sharing is generally according to written agreements, which include confidentiality, privacy, and security obligations; however, note that we do not control these third-party business partners’ privacy practices.
Social Media Sites. When you use our Services and elect to share information with third-party social media sites, the information you share will be governed by the privacy policies of those social media sites and the privacy settings you have set with those social media websites.
Advertising Networks. We sometimes collect and share information about your interests in advertising networks. Some of these companies are members of the Network Advertising Initiative, or the Digital Advertising Alliance, which offer a single location to opt out of ad targeting from member companies.
Other third-parties, such as referring websites. Third-parties may also help us collect information by, for example, operating features of our website or facilitating the delivery of online advertising tailored to your interests. We may share audience segments and other information with third parties that use that information for tailored advertising to you.
Third-parties may only collect or access information as needed to perform their permitted functions.
Specific Device operating system versions permit you to opt-out of certain types of information sharing, including specific advertising networks. Please check your Device settings if you want to limit such tracking.
You have options for the collection and use of your information. You can access, update and even close your account by visiting the Member Profile page on our website
● You may choose the way we communicate with you. You can choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our websites.
● You can prevent the collection of geolocation information, but note that turning off location sharing may affect our Services’ features.
● You also can add or update information and close your account. If you close your account, we will deactivate your account and remove your profile information from the live view. We may retain some information associated with your account (including past transactions) for internal purposes, including backups, fraud prevention, dispute resolution, investigations, and legal compliance for the period necessary to fulfill the purposes outlined in this Statement.
● As a registered member, you can modify your marketing subscriptions, including email subscription choices within your member settings. You also will be allowed to unsubscribe from promotional messages, including emails with travel-related opportunities, in any such email we send.
We are a global company and operate in many different jurisdictions. If we transfer your information to other countries, we will use and protect it as described in this Statement and accordance with applicable law.
We have implemented appropriate administrative, technical, and physical security procedures to help protect your information.
We only authorize specific employees to access personal information, and they may do so only for permitted business functions. We use encryption when transmitting your data between your system and ours, and between our system and those of the parties with whom we share information. We also employ firewalls and intrusion detection systems to help prevent unauthorized access to your information. However, we cannot guarantee the security of information from unauthorized entry or use, hardware or software failure, or other circumstances outside of our control.
We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in this Statement, unless applicable law requires a more extended retention period. Also, we may retain your information for the duration of any period necessary to establish, exercise, or defend any legal rights.
Do Not Track Signals
Our website is not designed to currently respond to “Do Not Track” (“DNT”) signal requests from browsers. This is due to the lack of globally standardized interpretation that defines “Do Not Track” signals. Once the industry has settled on standards related to this issue, we may re-evaluate this approach.
What are cookies?
The cookies we use fall into three categories.
These cookies are necessary to help you access and move around the website and use all its features. Without these cookies, the website would not work correctly, and you would not be able to use certain important features. For example, we use a cookie to keep you logged in during your visit, so the site does not require you to log in repeatedly to access different pages. We may also use essential cookies for fraud detection and prevention purposes.
You cannot turn off essential cookies through the Cookie Consent Tool, as such cookies are necessary for you to access and use the features of the website.
Analytics and customization
We use these cookies to help us understand how the website is being used and how we can improve your experience. These cookies can provide us with information to help us understand which parts of the website interest our visitors, and if they experience any errors. We use these cookies to test different designs and features for our sites, and we also use them to help us monitor how visitors reach the website.
Advertising cookies help ensure that the advertisements you see are as relevant to you as possible. For example, some advertising cookies help select ads that are based on your interests. Others help prevent the same ad from continuously reappearing for you.
We also work with third-party advertisers to give you access to travel content that might be of interest and may set cookies on our Services to provide you with advertising that matches your interests and preferences. These “third-party cookies” collect information about your browsing behavior and interaction with ads or the Services more generally. This information also limits the number of times you may see the same advertisements and improve your online experience.
Cookie Consent Tool
To give you control, we provide you with a Cookie Consent Tool, which allows you to review the first-party and third-party cookies placed through our website and adjust your cookie settings, including whether to accept such cookies or not.
You can manage cookies through the settings of your internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies.
Most advertising networks offer you a way to opt-out of advertising cookies.
If you cancel your cookies, your access to some functionality and areas of our Services might be degraded or restricted.
Our use of any information we collect through cookies is subject to this Statement, which is linked on every page of our website.
Statement Changes and Notification
We may update this Statement in the future. If we believe any changes are material, we will let you know by doing one or more of the following: sending you a communication about the changes, placing a notice on the website, and posting an updated Statement on the website. We will note at the top of this Statement when it was most recently updated. We encourage you to check back from time to time to review the most current version and to periodically review this Statement for the latest information on our privacy practices
If you have a data privacy request, such as a request to delete or access your data, please visit our dedicated privacy portal. For general data privacy inquiries or questions concerning our Privacy and Cookies Statement, please contact our privacy team by clicking here.
General Data Protection Regulation Privacy Statement (“GDPR Statement”)
This GDPR Statement applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom. This GDPR Statement supplements our Statement; however, where the Statement conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons in the EEA.
Controller of Personal Information
Marbella Solutions S.A. is the data controller of personal information we collect; however, we have appointed a representative within the European Union by applicable data privacy law.
The contact details of our representative are:
Attn: Privacy Officer
Tripadvisor Limited’s role in this respect is limited solely to being a contact point for questions on data protection from European residents and data protection supervisory authorities. For the avoidance of doubt, TripAdvisor Limited cannot field other communications or legal process on behalf of Marbella Solutions S.A.
Your rights under GDPR
You have certain rights regarding your data.
Your rights concerning your data include the following:
The right to request access to your data. This enables you to receive a copy of the personal data we hold about you.
The right to request to correct your data if it is inaccurate. You may also supplement any incomplete personal information we have, taking into account the processing purposes.
The right to request deletion of your data if:
your data is no longer necessary for the purposes for which we collected or processed them, or
you withdraw your consent if the processing of your data is based on consent. No other legal ground exists, or
you object to the processing of your data. We do not have an overriding legitimate ground for processing, or
your data is unlawfully processed, or
your data must be deleted for compliance with a legal obligation.
The right to object to the processing of your data. We will comply with your request unless we have a compelling overriding legitimate interest for processing. We need to continue processing your data to establish, exercise, or defend a legal claim.
The right to restrict the processing of personal data, if:
the accuracy of your data is contested by you, for the period in which we have to verify the accuracy of the personal data; or
the processing is unlawful, and you oppose the deletion of your data and request restriction; or
we no longer need your data for processing, but you require your data for legal claims; or
you have objected to the processing, for the period in which we have to verify overriding legitimate grounds.
The right to data portability. You may request that we send this personal data to a third-party, where feasible. You only have this right if it relates to personal data you have provided to us where the processing is based on consent or necessity for the performance of a contract between you and us. The processing is conducted by automated means.
You will not have to pay a fee to access your data (or to exercise any of the other rights described in this Statement). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive.
We may need to request specific information from you to confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. To speed up our response, we may contact you to ask you for further information about your request. You can exercise several of your rights through the personal information section of your account. To use your other rights, you can file a claim by clicking here.
We will only use your data when the law allows us to.
Under GDPR, we will use your data in one or more of the following circumstances:
We are about to enter into or have entered into with you where we need to perform the contract.
It is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation
With your consent
Your data may be stored or transferred to countries outside the EEA for the purposes described in this Statement. When we store or transfer your data outside the EEA, we take the following precautions to ensure that your data is adequately protected.
Whenever we store or transfer your data outside the EEA, we will do so by applicable law. We will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of personal data are made:
to a country recognized by the European Commission as providing an adequate level of protection; or
to a country that does not offer adequate protection but whose transfer has been governed by the European Commission’s standard contractual clauses or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
By using our services, you understand that your data may be transferred to our facilities and those third parties with whom we share it as described in this Statement.
California Consumer Privacy Act Privacy Statement (“CCPA Statement”)
This CCPA Statement is provided according to the California Consumer Privacy Act (“CCPA”) and applies to California residents and supplements our overall Statement with additional disclosures and rights.
Your rights under CCPA
As of January 1 2020, California law permits California residents to request specific details about how their personal information is shared with third parties or affiliated companies for direct marketing purposes.
California residents may also take advantage of the following rights:
You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the types of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal data that we disclosed for a business purpose, any types of personal information about you that we sold, the categories of third parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
You may request that we delete any personal information that we have collected from or about you. As described in more detail in our Statement, there are some reasons we will not be able to adequately address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation. You can also access, update, and remove your information by visiting the Member Profile page on our website.
You may request to opt-out of our sale of your personal information to third parties for their direct marketing purposes. This means that, if you were opt-out, we would not share your information with such third parties to use for their purposes unless you later direct us to do so. To effect the opt-out, please click on the Do Not Sell My Information link on our website footer or submit a request in writing to the contact information below.
To take advantage of your disclosure and deletion rights, please contact us by clicking here. We may need to verify your identity to enable us to process your request. We value your privacy and will not discriminate in response to your exercise of privacy rights. We will respond to your request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.
For purposes of compliance with the CCPA, in addition to the further details as described in the Statement, we make the following disclosures:
We collect the following categories of personal information: Identifiers/Contact Information, transactional information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.
We sell the following categories of personal information: Identifiers/Contact Information, Internet or other electronic network activity information, and conclusions drawn from the above.
We disclose the following categories of personal data for a business purpose: Identifiers/Contact Information, commercial information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.