Effective from December 8, 2020
1. Please read carefully!
This policy describes our privacy practices – what Personal Information we collect about our users, what we do with it, how we share it, and your rights regarding that Personal Information.
2. What Personal Information do we collect
2.1. User Information:
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us from your use of the Services and other sources. Here are the types of Personal Information we collect about you:
Information you provide us. When you register for our Services, purchase and/or register for our tours, use any of our Services; and/or when you contact us directly by any communication channel (e.g., SilkRoad Moments support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), the information you include in your communications with us, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps, and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language, and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers, fraud detection and prevention providers, for example, to help us screen out users associated with fraud, ii) social media platforms when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners to monitor, manage and measure our ad campaigns.
To provide our Services, we collect Personal Information about our Users.
The Personal Information comes from you when you visit or use our services, Personal Information we collect automatically, and Personal Information we collect from other sources.
2.2. Wix Jobs Applicant Information
We also collect information that is provided to us by SilkRoad Moments jobs candidates (“Applicants”) when they apply to any of the open positions that we have published, by e-mail or otherwise.
3. Why do We collect such Personal information
We use your Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences, and difficulties;
To provide our customers with ongoing customer assistance and technical support;
To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 6 below);
To help us to update, expand and analyze our records to identify new customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
To create aggregated statistical data and other aggregated and/or inferred information, which our business partners or we may use to provide and improve our respective services;
To provide you with professional assistance, only upon your request;
To enhance our data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.
We use your Personal Information for the purposes set out in Section 3, where:
Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g., to provide you with a tour or other travel arrangements to provide you with our customer assistance and technical support);
Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of SilkRoad Moments by identifying technical issues), provided it is conducted in a proportionate way and that respects your privacy rights.
We use the Personal Information we collect about you to provide our services and make them better and safer.
We also collect and use Personal Information in order to contact Users and to comply with the laws applicable to us
4. How we share your Personal Information
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
4.1.Third-Party Service Providers: SilkRoad Moments has partnered with several selected service providers, whose services and solutions complement, facilitate, and enhance our own. These include guides, hotels, transportation operators, communications, and content delivery networks (CDNs), data and cybersecurity services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording, and remote access services, performance measurement, data optimization, and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
SilkRoad Moments may share the following categories of Personal Information with Third-Party Service Providers for a business purpose:
identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers
commercial information, for example, information regarding products or services purchased, obtained, or considered
4.2. Law Enforcement, Legal Requests, and Duties: SilkRoad Moments may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
4.3. Protecting Rights and Safety: SRM may share your Personal Information if we believe in good faith that this will help protect the rights, property, or personal safety of SilkRoad Moments, any of our Users, or any member of the general public, with or without notice to you.
4.4. Social Media Features and Framed Pages: Our Services include certain Social Media features, widgets, and single sign-on features, such as the “Facebook Connect,” “Google Sign-in,” “Facebook Like,” or “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect certain Personal Information such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Their policies and not ours govern your interactions with these third parties’ Social Media Features.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing are governed by those third parties’ policies and not ours.
4.5. Connection With a Change in Corporate Control: In addition, should Wix or any of its affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
4.6. Upon Your Further Direction: SRM may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.
We may share the Personal Information of our Users with various third parties, including certain service providers and law enforcement officials.
The Personal Information may be shared solely in accordance with this policy.
5. Where do we store your Personal Information?
Our company is hosted on the Wix.com platform. Wix.com provides us with an online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases, and general Wix.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
6. Communications from SilkRoad Moments
6.1. Promotional Messages
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls, and similar communication forms from SilkRoad Moments or our partners (acting on SilkRoad Moments' behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify SilkRoad Moments at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
6.2. Service and Billing Messages
SilkRoad Moments may also contact you with important information regarding our Services or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions, or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not able to opt-out of receiving such Service and Billing Messages unless you are no longer a SRM (which can be done by deactivating your account).
We may send you promotional messages and content.
You can easily opt-out of receiving promotional messages by contacting us or unsubscribing.
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
7. Your rights in relation to your Personal Information
SRM agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, SRM is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first at email@example.com).
Please note that permanently deleting your SRM account erases all of your Personal Information from SRM databases. After completing this process, you can no longer use any of your SRM Services, your account, and all its data will be removed permanently, and SRM will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.
You may request to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information you have stored with us. Just send us an e-mail. You may also correct and/or update your Personal Information through your account or website settings.
You can delete your Personal Information by deleting your entire account. We will respond to your requests within a reasonable timeframe.
8. Data Retention
We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy, which we apply to Personal Information in our care.
We may keep your Personal Information for as long as your account is active, and longer as needed (for example, if we are legally obligated to keep it longer, or need it to protect our interests).
9. Third-Party Websites
Our Services may contain links to other websites or services.
10. Public forums and user content
Our Services offer publicly accessible blogs, communities, and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities, or forums, feel free to contact us at firstname.lastname@example.org In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third-party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must log in to such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.
If you upload any user content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content and are not responsible for the circumvention of any privacy settings or security measures we have placed on our Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
Avoid posting any Personal Information to any public areas on our Services if you don’t want it to become publicly available.
11. Updates and interpretation
Any heading, caption, or section title contained herein, and any explanation or summary under the right “#ItsThatEasy” column, is provided only for convenience and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.
We may change this policy at any time. We will notify you of changes as required by applicable law.
Only the left column is legally binding (this column is just for clarity).
Translated (non-English) versions of these terms are provided for convenience only.