Layla AI GmbH, a limited liability company with its registered office at Belziger Straße 69-71, 10823 Berlin, Germany, which operates the Trip Planner AI service (the “Company” or “Trip Planner AI”), takes the users’ (“Users”) privacy very seriously. The purpose of this “Privacy Policy” is to explain to Users how Trip Planner AI may collect, retain, process, share and transfer Users’ personal information in order to provide its Services through the website: www.tripplanner.ai.

For the purposes of this Privacy Policy, Users shall be natural (human) persons that request Trip Planner AI’s services.

By providing Trip Planner AI with their personal data through the Website, Users expressly consent to the fact that Trip Planner AI may process such data in accordance with the terms of this Privacy Policy and for the purposes set forth herein.

Users must read this Privacy Policy before registering or using the Services on the Website. By signing in with a Google account, Users state that they have read this Privacy Policy and expressly agree to it. In no event will Trip Planner AI collect Personal Information from Users without their consent or that is not voluntarily given by them.

Trip Planner AI reserves the right, at Trip Planner AI’s discretion, to change this Privacy Policy from time to time to reflect changes to Trip Planner AI’s business or services, or applicable laws. For that purpose, Trip Planner AI will provide Users with thirty (30) days prior notice for any modification on the Privacy Policy page of Trip Planner AI’s Website. Trip Planner AI also may notify Users about the modifications using contact information, email or other means of contact if provided by Users. The revised Privacy Policy will be effective as of the publication date. Users may contact Trip Planner AI if they have questions about Trip Planner AI’s privacy practices that are not addressed in this Privacy Policy.

Users agree to provide true and accurate data. Furthermore, they shall be solely responsible for any loss or damage that may be suffered by Trip Planner AI or any of its subsidiaries or third parties as a result of the information provided being false, inaccurate, out of date or not genuine.

Trip Planner AI respects and makes a constant effort to comply with the European General Data Protection Regulation 2016/679 (“GDPR”) in order to protect, safeguard and preserve the rights that may apply to Users.

1. Who is the Controller in relation to the Personal Information Provided by Users?

All Personal Information provided or collected through the Website will be processed by Trip Planner AI, whose contact information can be found below, as file controller.

2. About the Website and Services

Trip Planner AI helps Users explore travel destinations and gather inspiration for their trips (the “Service” or “Services”). The focus is on helping Users find and compare Activities, Accommodations and Meals in different destinations, and connecting Users to Layla (available at layla.ai) and to third-party partners where the detailed planning and any booking take place. Trip Planner AI does not offer any guide, tour or touristic services; Trip Planner AI just provides Users a Website where they can explore and plan their trips.

The User understands and accepts that any concept not defined in this document may be defined in the Terms and Conditions of Service complementary to this Privacy Policy.

A) What Information Does Trip Planner AI collect and how is it collected?

Trip Planner AI processes personal information of Users to offer its Service (“Personal Information”).

In general, a User’s Personal Information shall include their email and, where provided by Google, their name and profile picture. Particularly, Trip Planner AI may collect the following information:

• Registration and use information – When Users use the Services by establishing an account through Google (“Account”), Trip Planner AI will collect Personal Information as necessary to offer the Activities, Accommodations and Meals to Users. Trip Planner AI may collect the following Personal Information from the User’s Google account: email and, where provided by Google, name and profile picture. Trip Planner AI reserves the right to require Users to provide additional Personal Information.
• Trip Information: When Users use the Service to optimize their travel, Trip Planner AI may require Users to provide Trip Planner AI with information regarding their future trips. Particularly, Trip Planner AI may collect information about: the destination, currency, number of days, starting and ending dates of the trip, language, the destinations and options the User explored on the Website, the User´s location and timezone, browser, and initial referrer.
• Additional information that the Users wants to share: information that Users provide to Trip Planner AI for other purposes, for example when contacting Trip Planner AI for support or when choosing to make a trip public in the Community Trips section.
• Information about the communications made with Trip Planner AI: Trip Planner AI will have access to information that Users provide for the resolution of doubts or complaints about the use of the Website, when Users make such claims through help@layla.ai.
• Non-Identifying Information: Trip Planner AI also may collect other information, such as zip codes, demographic data, information regarding the User’s use of the Service, and general trip-related data (“Non-Identifying Information”). Trip Planner AI may aggregate information collected from Trip Planner AI registered and non-registered users. In some cases, Trip Planner AI may render Personal Data (generally, email address) into a form of non-identifying information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify the User directly, but it may be used to connect the User’s activity and interests on the Website.

Information Received from Third Parties

Third parties may also provide Trip Planner AI with information about the User. If Trip Planner AI combines such information with information about the User collected through the Service or the Website, Trip Planner AI will still process that combined information as set forth in this Privacy Policy.

Information Collected Automatically

Like other online companies, Trip Planner AI receives technical information when the User uses the Website or the Services. Trip Planner AI uses these technologies to analyze how Users use the Service, to improve the Website, and to save the User’s log-in information for future sessions.

Trip Planner AI and its third party service providers, including analytics and third party content providers, may automatically collect certain information from the User whenever the User accesses or interacts with the Service or Website. This information may include, among other information, the browser and operating system the User is using, the search terms the User entered into a search engine that led the User to the Service, areas within the Service that the User visited, which links the User clicked on, which pages or content the User viewed and for how long, other similar information and statistics about the User’s interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites. Trip Planner AI does this in order to improve Trip Planner AI Services, and to improve the Website.

In order to perform the Service, the Website may use cookies, tracking pixels and related technologies. Cookies are small data files that are served by the Website. They enable Trip Planner AI to identify Users when they use and navigate through the Website in order to provide and improve the Services.

B) What Privacy Choices Are Available To Users?

Users have choices as to the privacy practices and communications described in this Privacy Policy.

Choices Relating to the Personal Information Trip Planner AI Collects. Users may decline to provide Personal Information, but certain Services or all of the Services may then be unavailable to Users.

Choices Relating to Cookies. Users may have options available to manage their cookie preferences. For example, the User’s browser or internet device may allow Users to delete, disable, or block certain cookies and other tracking technologies. Users may choose to enable these options, but doing so may prevent Users from using many of the core features and functions of the Service and may degrade their experience. Users may have an option regarding the use of cookies and other tracking technologies when they visit the Website. For example, Users may be asked whether they want the Service or the Website to “remember” certain things about them, and Trip Planner AI will use cookies and other tracking technologies to the extent that Users permit them.

Choices Relating to Registration and Account Information. Users have an Account, which they register through their Google email. Users may review and edit their Personal Information through their Google account. Users understand and agree that Trip Planner AI does not have any influence over the modification of the User's Google account information.

Choices Relating to Communication. Notices, Alerts and Updates from Trip Planner AI:

Informational and Other: Trip Planner AI will send communications to Users that are required or necessary to send to Users regarding the Service, notifications that contain important information and other communications that Users request from Trip Planner AI.

C) For What Purpose is the Personal Information Collected?

Trip Planner AI has no interest in retaining Personal Information about Users for any other purpose than the effectiveness of its Service. Trip Planner AI may retain Personal Information to fulfill Trip Planner AI’s legal obligations and for Trip Planner AI’s legitimate business purposes, as further described in Section H) below.

In case Trip Planner AI needs to close an Account, Trip Planner AI may take steps to mask Personal Information and other information, but Trip Planner AI reserves the possibility to retain and access the data for so long as required to comply with applicable laws. Trip Planner AI will continue to use and disclose such Personal Information in accordance with this Privacy Policy.

Trip Planner AI collects, processes and discloses Users’ personal data only for specific and limited purposes. For example, to provide the Service, to assess and handle any complaints, to develop and improve the Service, communication methods and the functionality of the Website, and to provide personalized services and communications to Users.

Trip Planner AI collects, processes and discloses Users’ Personal Information for the following purposes:

• To execute the proposed Services on the Website;
• To deal with Users’ enquiries and requests, and assess and handle any complaints;
• To process and answer Users inquiries or to contact them to answer their questions and/or requests;
• To develop and improve the Service, communication methods and the functionality of the Website;
• To communicate information to Users and to manage Users’ registration and account;
• To authenticate the identity of individuals contacting Trip Planner AI by email or other electronic means;
• To understand and assess the interests, wants, and changing needs of consumers, to improve the Website, current services, and/or developing new services;
• To provide personalized services, communications and service recommendations to Users;
• To manage risk and protect the Website, the Service and Users from fraud by verifying Trip Planner AI’s and Users’ identity, and helping to detect and prevent fraud and abuse of the Website or Services.
• To manage Trip Planner AI’s business needs, such as monitoring, analyzing, and improving the Services and the Website performance and functionality.
• To comply with Trip Planner AI’s obligations and to enforce the terms of Trip Planner AI’s Website and Services, including to comply with all applicable laws and regulations. Trip Planner AI will recommend and encourage Users to comply with all applicable regulations regarding data privacy in all applicable jurisdictions.

If Trip Planner AI’s ownership changes or the majority of its assets are acquired by a third party, Users are informed that Trip Planner AI will transfer their data to the acquiring organizations in order to continue to provide the Service subject to the processing of data. The new file controller will inform Users of its identification data. Trip Planner AI states that it will comply with its duty of information to the relevant supervisory authority in the event of such circumstances arising, and it shall inform Users of the change of file controller if and when this happens.

Trip Planner AI may share Users’ personal data with third parties associated with Trip Planner AI, provided that the Users have given their express, informed and unequivocal consent for it and are aware of the purpose and recipient of such transfer.

D) Profiling

Trip Planner AI uses Users’ Personal Information to build profiles. Trip Planner AI creates profiles by analyzing the information about Users’ online surfing, searching and browsing behavior by building segments (creating groups that have certain common characteristics) and by placing Users’ personal data in one or more segments. These segments are used by Trip Planner AI to personalize the Website and to show Users relevant content when they use the Service. Trip Planner AI profiles the Personal Information where Users have provided consent for Trip Planner AI to do so (for example, by accepting the Privacy Policy or accepting the setting of cookies in their browser).

Users can withdraw their consent to prevent their Personal Information being used this way at any time by adjusting their cookie preferences in their browser.

E) Do We Share/Transfer Personal Information?

Only for the purposes stated in this Privacy Policy and to perform the Service, Personal Information may be disclosed by Trip Planner AI, when necessary, to authorities, to Trip Planner AI’s affiliates and partners, and to other third parties, such as third-party service providers used in connection with the Trip Planner AI Service and services related thereto.

Trip Planner AI may also share non-identifying information with third parties. The User has choices as to whether Trip Planner AI shares the User’s personal information with third parties.

Trip Planner AI may share aggregated non-identifying information and Trip Planner AI may otherwise disclose non-identifying information (including, without limitation, Hashed Information) to third parties. Trip Planner AI does not share the User’s Personal Data with third parties for those third parties’ marketing purposes unless Trip Planner AI first provides the User with the opportunity to opt in to or opt out of such sharing.

Trip Planner AI may also share the information Trip Planner AI has collected about the User, including Personal Data, as disclosed at the time the User provides their Personal Data, with the User’s consent, as otherwise described in this Privacy Policy, or in the following circumstances:

• Service Providers: Trip Planner AI may employ third party companies and individuals to facilitate the Service, to provide the Service on Trip Planner AI´s behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics, fraud detection and improvement of Trip Planner AI’s features) or to assist Trip Planner AI in analyzing how the Service is used. These third parties may have access to the User Personal Data in order to perform these tasks on Trip Planner AI´s behalf.
• Legal and Investigative Purposes: Trip Planner AI will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Trip Planner AI cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Trip Planner AI will disclose information about the User to government or law enforcement officials or private parties as Trip Planner AI, in Trip Planner AI’s sole discretion, believes necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where Trip Planner AI determines, in Trip Planner AI’s sole discretion, that the disclosure is necessary to (a) protect the property and rights of Trip Planner AI or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity Trip Planner AI may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
• Internal and Business Transfers: Trip Planner AI may share information, including Personal Data, with any current or future subsidiaries or affiliates, primarily for business and operational purposes, including activities such as IT management, for them to provide services to the User, or support and supplement the Services Trip Planner AI provides. Trip Planner AI may sell, transfer, or otherwise share some or all of Trip Planner AI´s assets, including the User personal data, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

Trip Planner AI is operated by Layla AI GmbH, a company established in Germany. Trip Planner AI primarily processes and stores the User information within the European Union and the European Economic Area (“EU/EEA”), and Trip Planner AI´s service providers may process and store it elsewhere subject to the safeguards described below.

The Service is managed by Trip Planner AI’s team at the registered office of Layla AI GmbH in Berlin, Germany. Trip Planner AI relies on service providers to operate the WebSite and provide the Services. Trip Planner AI processes Users´ Personal Information in accordance with the European General Data Protection Regulation 2016/679 (“GDPR”) and applicable German data protection law.

In some cases, Personal Information may be transferred outside the EU/EEA, including but not limited to, the United States of America, where Trip Planner AI relies on service providers located in such countries. These countries may not have the same data protection laws as the EU/EEA. Trip Planner AI will only send Personal Information collected within the EEA to foreign countries in circumstances such as (i) to follow Users instructions, (ii) to comply with a legal duty or, (iii) to connect Users with Layla and third-party booking partners.

In such case, such transfers outside the EEA will be performed subject to appropriate safeguards and safety measures such as standard data protection clauses adopted in respective agreements or otherwise approved by the EU Commission in accordance with the GDPR.

F) How Do We Protect Users' Personal Information?

Trip Planner AI maintains technical, physical, and administrative security measures designed to provide reasonable protection for Users’ Personal Information against loss, misuse, unauthorized access, disclosure, interference and alteration. The security measures include information access authorization controls. Nevertheless, considering that the current online environment is not fully secure, Trip Planner AI cannot guarantee that the security measures taken will prevent illegally and maliciously operating third parties from obtaining access to Users’ Personal Information, or guarantee the absolute security of that information during its transmission or its storage on Trip Planner AI systems. While Trip Planner AI is dedicated to securing its systems, the Website and Services, Users are responsible for securing and maintaining the privacy of their password(s) and Account, registration information and verifying that the Personal Information Trip Planner AI maintains about the Users is accurate and current. Access to Users’ Personal Information is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties.

As mentioned above, Trip Planner AI has taken the necessary steps recommended by the European Commission and the competent authority to maintain the required security level, according to the nature of the personal data processed and the circumstances of the processing, in order to avoid, to the extent possible and always in accordance with the state of the art, its alteration, loss or unauthorized access or processing.

G) Which are the Users´ Rights?

Trip Planner AI respects the rights of the Users with regard to the protection of personal data. To this end, the User understands and accepts that he/she has the following rights:

• The right to be informed. Users have the right to be provided with clear, transparent and easily understandable information about how Trip Planner AI uses their Personal Information and their rights. Therefore, Trip Planner AI is providing them with the information in this policy.
• The right to access and rectification. Users have the right to access, correct or update the Personal Information Trip Planner AI holds about them at any time by contacting Trip Planner AI at help@layla.ai. Where a User wishes to change the details of their underlying Google account, they must do so directly with Google LLC, which provides the Google sign-in used to access the Account.
• The right to data portability. The personal data Users have provided to Trip Planner AI is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
• The right to be forgotten. Under certain circumstances, Users have the right to request that Trip Planner AI delete their data. If Users wish to delete the Personal Information Trip Planner AI holds about them, please let Trip Planner AI know and Trip Planner AI will take reasonable steps to respond to the request in accordance with legal requirements. If the Personal Information Trip Planner AI collects is no longer needed for any purpose and Trip Planner AI is not required by law to retain it, Trip Planner AI will do what it can to delete, destroy or permanently de-identify it.
• The right to restrict processing. Under certain circumstances, Users have the right to restrict the processing of their Personal Information.
• The right to object. Under certain circumstances, Users have the right to object to certain types of processing, including profiling used to personalize the content shown to them.
• The right to withdraw consent. If Users have given their consent to anything Trip Planner AI does with their personal information, they have the right to withdraw their consent at any time (although if they do so, it does not mean that anything Trip Planner AI has done with their Personal Information with their consent up to that point is unlawful). Users can withdraw their consent to the processing of their Personal Information at any time by contacting Trip Planner AI with the details provided below.

Personal Information subjects may exercise the aforementioned rights by sending a written request to Trip Planner AI at help@layla.ai.

If Users consider that their rights under the data protection laws have been infringed, Users may file a complaint with the supervisory authority of their place of residence. As an example for Europe, Data Protection authorities are independent public authorities that supervise, through investigative and corrective powers, the application of the data protection law. They provide expert advice on data protection issues and handle complaints lodged against violations of the General Data Protection Regulation (GDPR) and the relevant national laws. There is one in each EU Member State. Generally speaking, the main contact point for questions on data protection is the data protection authority in the EU Member State where the User is based. The European Data Protection Board (EDPB) maintains a list of the national supervisory authorities at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

H) Retention of Personal Information.

Trip Planner AI will retain Users' Personal Information for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The Personal Information may also be retained so that Trip Planner AI can continue to improve Users’ experience through the Service. Trip Planner AI will actively review the Personal Information it holds and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.

I) Links to other WebSites

The WebSite contains links to other websites. If the User chooses to click on a third party link, the User will be directed to that third party’s website. The fact that Trip Planner AI links to a website is not an endorsement, authorization or representation of Trip Planner AI´s affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. Trip Planner AI does not exercise control over third party websites. These other websites may place their own cookies or other files on the User’s computer, collect data or request Personal Data from the User. Trip Planner AI encourages the User to read the privacy policies or statements of the other websites the User visits.

J) Shared Information

Trip Planner AI restricts access to the User's information to authorized employees and contractors and only shares the User's personal information with third parties in the following circumstances.

Other Service Providers, Users, Contractors or Vendors: for providing the Service with accountants, for analytics and reporting, auditing, communicating with the User, managing Trip Planner AI´s customer database, and connecting the User to trip information and booking services provided by third-party websites.

3. Changes to this Privacy Notice

Changes to this Privacy Policy will be posted on this page. If Trip Planner AI makes a material change to Trip Planner AI’s privacy practices, Trip Planner AI will provide notice on the Website and by other contact information the User or Users have provided.

4. Governing law. Disputes

This Privacy Policy shall be governed by the laws of the Federal Republic of Germany. Any conflict arising from the interpretation or execution of the current Privacy Policy or for any other cause will be submitted to the applicable laws of Germany and to the exclusive jurisdiction of the competent courts of Berlin, Germany, to the extent permitted by applicable law. This does not affect any mandatory data protection rights a User may have under the laws of their country of residence, including the right to lodge a complaint with their local supervisory authority.

5. Contact Us

If Users have any questions or concerns regarding Trip Planner AI’s Privacy Policy, please contact Trip Planner AI. All contacts and inquiries related to this Privacy Policy should be addressed to help@layla.ai.