Effective Date: September 20th, 2018
Notice Version: 1.0
Data Controller Contact Information
Wanderlust Virtual Solutions
This document governs the privacy notice of our website www.wanderlustvirtualsolutions.com
Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may
collect from you, how we collect it, how we protect it, how we may share it, how you can access
and change it, and how you can limit our sharing of it. Our privacy notice also explains certain
legal rights that you have with respect to your personal data. Any capitalized terms not defined
herein will have the same meaning as where they are defined elsewhere on our website.
When using our website and submitting personal data to us, you may have certain rights under
the General Data Protection Regulation (GDPR) and other laws. Depending on the legal basis
for processing your personal data, you may have some or all of the following rights:
The right to be informed
You have the right to be informed about the personal data we collect from you, and how we
The right of access
You have the right to get confirmation that your personal data is being processed and have the
ability to access your personal data.
The right to rectification
You have the right to have your personal data corrected if it is inaccurate or incomplete.
The right to erasure (right to be forgotten)
You have the right to request the removal or deletion of your personal data if there is no
compelling reason for us to continue processing it.
The right to restrict processing
You have a right to ‘block’ or restrict the processing of your personal data. When your personal
data is restricted, we are permitted to store your data, but not to process it further.
The right to data portability
You have the right to request and get your personal data that you provided to us and use it for
your own purposes. We will provide your data to you within 30 days of your request. To request
your personal data, please contact us using the information at the top of this privacy notice.
The right to object
You have the right to object to us processing your personal data for the following reasons:
Processing was based on legitimate interests or the performance of a task in the public interest/
exercise of official authority (including profiling);
Direct marketing (including profiling); and
Processing for purposes of scientific/historical research and statistics.
Rights in relation to automated decision-making and profiling.
Automated individual decision-making and profiling
You will have the right not to be subject to a decision based solely on automated processing,
including profiling, which produces legal effects concerning you or similarly significantly affects
Filing a complaint with authorities
You have the right to file a complaint with supervisory authorities if your information has not
been processed in compliance with the General Data Protection Regulation. If the supervisory
authorities fail to address your complaint properly, you may have the right to a judicial remedy.
For details about your rights under the law, visit https://goo.gl/F41vAV
‘Non-personal data’ (NPD) is information that is in no way personally identifiable.
‘Personal data’ (PD) means any information relating to an identified or identifiable natural person
(‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly,
by reference to an identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person. PD is in many ways the same as
Personally Identifiable Information (PII). However, PD is broader in scope and covers more
A “visitor” is someone who merely browses our website. A “member” is someone who has
registered with us to use or buy our services and products. The term “user” is a collective
identifier that refers to either a visitor or a member.
TOPICS COVERED IN OUR PRIVACY NOTICE
Information We Collect
How Your Information Is Used
Retaining and Destroying Your PD
Updating Your PD
Revoking Your Consent for Using Your PD
Protecting the Privacy Rights of Third Parties
Do Not Track Settings
Links to Other Websites
Protecting Children’s Privacy
Our Email Policy
Our Security Policy
Use of Your Credit Card
Transferring PD from the European Union
Changes to Our Privacy Notice
INFORMATION WE COLLECT
Generally, you control the amount and type of information that you provide to us when using our
Our Legal Basis for Collecting and Processing Personal Data
Our legal basis for collecting and processing your PD when you buy our products or services is
based on and the necessity for the performance of a contract or to take steps to enter into a
contract. Our legal basis for collecting and processing your PD when you sign up for our
newsletter and information about our products and services through our website opt-in forms is
based on consent.
What Happens If You Don’t Give Us Your PD
If you do not provide us with enough PD, we may not be able to provide you with all our
products and services. However, you can access and use some parts of our website without
giving us your PD.
We Collect Your PD in the Following Ways:
We automatically receive information from your web browser or mobile device. This information
includes the name of the website from which you entered our website, if any, as well as the
name of the website you’ll visit when you leave our website. This information may also include
the IP address of your computer/the proxy server you use to access the Internet, your Internet
service provider’s name, your web browser type, the type of mobile device, your computer
operating system, and data about your browsing activity when using our website. We use all this
information to analyze trends among our users to help improve our website.
When Entering and Using Our Website
When you enter and use our website and agree to accept cookies, some of these cookies may
contain your PD.
When you Submit an Online Form
When you sign up to our newsletter or when you sign up to receive notifications about upcoming
products we collect your name and email address. When you fill out a contact form or schedule
a consultation we collect your first and last name, your website address, your email address
and any other information you willingly choose to provide to us. You should limit the information
you provide to us that is only necessary to answer your questions.
At User and Member Registration
When you register as a user or member, we collect your name, email address, and other
When Buying Products or Services
If you buy products or services from us, we collect your first and last name, email address,
physical address, billing address, credit card or other payment information, phone number, and
other information listed.
your computer or mobile device when you access certain websites. Cookies may contain text
that can be read by the web server that delivered the cookie to you. The text contained in the
cookie generally consists of a sequence of letters and numbers that uniquely identifies your
computer or mobile device; it may contain other information as well.
permission to place, store, and access some or all the cookies described below on your
Strictly Necessary Cookies
These cookies are necessary for proper functioning of the website, such as displaying content,
logging in, validating your session, responding to your request for services, and other functions.
cookies, you may not be able to access features on our website correctly or at all.
These cookies collect information about the use of the website, such as pages visited, traffic
sources, users’ interests, content management, and other website measurements.
These cookies enable the website to remember a user’s choices – such as their language, user
name, and other personal choices – while using the website. They can also be used to deliver
services, such as letting a user make a blog post, listen to audio, or watch videos on the
These cookies can be used to improve a website’s performance and provide special features
and content. They can be placed by third parties who provide services to us or by our company.
Advertising or Targeting Cookies
These cookies are usually placed and used by advertising companies to develop a profile of
your browsing interests and serve advertisements on other websites that are related to your
Interests. You will see less advertising if you disable these cookies.
These cookies allow websites to link the actions of a user during a browser session. They may
be used for a variety of purposes, such as remembering what a user has put in their shopping
cart as they browse a website. Session cookies also permit users to be recognized as they
navigate a website so that any item or page changes they make are remembered from page to
page. Session cookies expire after a browser session; thus, they are not stored long term.
These cookies are stored on a user’s device in between browser sessions, which allows the
user’s preferences or actions across a site (or, in some cases, across different sites) to be
remembered. Persistent cookies may be used for a variety of purposes, including remembering
users’ choices and preferences when using a website or to target advertising to them.
Identifying the areas of our website that you have visited
Personalizing content that you see on our website
Our website analytics
Remarketing our products or services to you
Remembering your preferences, settings, and login details
Targeted advertising and serving ads relevant to your interests
Allowing you to post comments
Allowing you to share content with social networks
you may not be able to access features on our website correctly or at all.
We may also use a technology called web beacons to collect general information about your
use of our website and your use of special promotions or newsletters. The information we
collect by web beacons allows us to statistically monitor the number of people who open our
emails. Web beacons also help us to understand the behavior of our customers, members, and
Google Analytics Privacy Notice
Our website uses Google Analytics to collect information about the use of our website. Google
Analytics collects information from users such as age, gender, interests, demographics, how
often they visit our website, what pages they visit, and what other websites they have used
before coming to our website. We use the information we get from Google Analytics to analyze
traffic, remarket our products and services to users, improve our marketing, advertising, and to
improve our website. We have enabled Google Analytics advertising features such as
remarketing with Google Analytics, Google Display Network Impression Reporting, and Google
Analytics Demographics and Interest Reporting. Google Analytics collects only the IP address
assigned to you on the date you visit our website, not your name or other identifying information.
We do not combine the information collected using Google Analytics with PD. Although Google
Analytics plants a permanent cookie on your web browser to identify you as a unique user the
next time you visit our website, the cookie cannot be used by anyone but Google. Google also
uses specific identifiers to help collect information about the use of our website. For more
information on how Google collects and processes your data, visit https://www.google.com/
You can prevent Google Analytics from using your information by opting out at this link: https://
technologies to collect or receive information from our website and elsewhere on the internet,
and use that information to provide measurement services and target ads. With Facebook
remarketing you may see our ads on Facebook after you have visited our website. For this to
happen, Facebook uses a Custom Audience Pixel that is activated when a visitor lands on a
webpage and a unique “cookie” is placed in their browser. Facebook lookalike audience
targeting allows us to show ads on Facebook to people who are similar to those who have
already visited or made a purchase from our website. To opt out of Facebook’s collection and
use of information for ad targeting visit: https://www.facebook.com/help/568137493302217
HOW YOUR INFORMATION IS USED
We use the information we receive from you to:
Provide our products and services you have requested or purchased from us
Personalize and customize our content
Make improvements to our website
Contact you with updates to our website, products, and services
Resolve problems and disputes
Contact you with marketing and advertising that we believe may be of interest to you
Send you an email newsletter 2-4 times per month with business updates and special offers
Communications and Emails
When we communicate with you about our website, we will use the email address you provided
when you registered as a member or user. We may also send you emails with promotional
information about our website or offers from us or our affiliates unless you have opted out of
receiving such information. You can change your contact preferences at any time through your
account or by sending us an email with your request to: email@example.com
Sharing Information With Affiliates and Other Third Parties
We do not sell or rent your PD to third parties for marketing purposes. However, for data
aggregation purposes we may use your NPD, which might be sold to other parties at our
discretion. Any such data aggregation would not contain any of your PD. We may provide your
PD to third-party service providers we hire to provide services to us. These third-party service
providers may include but are not limited to: payment processors, web analytics companies,
advertising networks, call centers, data management services, help desk providers,
accountants, law firms, auditors, shopping cart and email service providers, and shipping
Sharing Information With Facebook and Google for Marketing Purposes
We may share your PD with third parties for similar audience marketing purposes. Similar
audience marketing is also called lookalike audience marketing. The third parties we share your
PD with for this type of marketing include Facebook and/or Google. Using your PD, for similar
audience marketing or lookalike audience marketing helps us find new audiences (users and
customers) based on similar interests to yours, this helps us improve our marketing services.
Your PD is only shared with Facebook and Google for this type of marketing. By using our
website and agreeing to our privacy notice, you are giving your consent for your PD to be used
for the marketing purposes described within this section.
Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena,
law, or other legal process; (b) necessary to assist law enforcement officials or government
enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal
Terms; (d) necessary to protect us from legal action or claims from third parties, including you
and/or other users or members; or (e) necessary to protect the legal rights, personal/real
property, or personal safety of our company, users, employees, and affiliates.
Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become
responsible for providing the website to you, we retain the right to transfer your PD to the new
business. The new business would retain the right to use your PD according to the terms of this
privacy notice as well as to any changes to this privacy notice as instituted by the new business.
We also retain the right to transfer your PD if our company files for bankruptcy and some or all
of our assets are sold to another individual or business.
Community Discussion Boards
Our website may offer the ability for users to communicate with each other through online
community discussion boards or other mechanisms. We do not filter or monitor what is posted
on such discussion boards. If you choose to post on these discussion boards, you should use
care when exposing any PD, as such information is not protected by our privacy notice nor are
we liable if you choose to disclose your PD through such postings. Also, PD you post on our
website for publication may be available worldwide by means of the Internet. We cannot prevent
the use or misuse of such information by others.
RETAINING AND DESTROYING YOUR PD
We retain information that we collect from you (including your PD) only for as long as we need it
for legal, business, or tax purposes. Your information may be retained in electronic form, paper
form, or a combination of both. When your information is no longer needed, we will destroy,
delete, or erase it.
UPDATING YOUR PD
You can update your PD using services found on our website. If no such services exist, you can
contact us using the contact information found at the top of this privacy notice and we will help
you. However, we may keep your PD as needed to enforce our agreements and to comply with
any legal obligations.
REVOKING YOUR CONSENT FOR USING YOUR PD
You have the right to revoke your consent for us to use your PD at any time. Such an optout will
not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to
affiliates and business partners, (ii) disclosures to third-party service providers that provide
certain services for our business, such as credit card processing, computer system services,
shipping, data management services, (iii) disclosures to third parties as necessary to fulfill your
requests, (iv) disclosures to governmental agencies or law enforcement departments, or as
otherwise required to be made under applicable law, (v) previously completed disclosures to
third parties, or (vi) disclosures to third parties in connection with subsequent contests or
promotions you may choose to enter, or third-party offers you may choose to accept. If you want
to revoke your consent for us to use your PD, send us an email with your request to:
PROTECTING THE PRIVACY RIGHTS OF THIRD PARTIES
If any postings you make on our website contain information about third parties, you must make
sure you have permission to include that information in your posting. While we are not legally
liable for the actions of our users, we will remove any postings about which we are notified, if
such postings violate the privacy rights of others.
DO NOT TRACK SETTINGS
Some web browsers have settings that enable you to request that our website not track your
movement within our website. Our website does not obey such settings when transmitted to and
detected by our website. You can turn off tracking features and other security settings in your
browser by referring to your browser’s user manual.
LINKS TO OTHER WEBSITES
Our website may contain links to other websites. These websites are not under our control and
are not subject to our privacy notice. These websites will likely have their own privacy notices.
We have no responsibility for these websites and we provide links to these websites solely for
your convenience. You acknowledge that your use of and access to these websites are solely at
your risk. It is your responsibility to check the privacy notices of these websites to see how they
treat your PD.
PROTECTING CHILDREN’S PRIVACY
Even though our website is not designed for use by anyone under the age of 16, we realize that
a child under the age of 16 may attempt to access our website. We do not knowingly collect PD
from children under the age of 16. If you are a parent or guardian and believe that your child is
using our website, please contact us. Before we remove any information, we may ask for proof
of identification to prevent malicious removal of account information. If we discover that a child
is accessing our website, we will delete his/her information within a reasonable period of time.
You acknowledge that we do not verify the age of our users nor do we have any liability to do
OUR EMAIL POLICY
You can always opt out of receiving further email correspondence from us or our affiliates. We
will not sell, rent, or trade your email address to any unaffiliated third party without your
permission except in the sale or transfer of our business, or if our company files for bankruptcy.
OUR SECURITY POLICY
We have built our website using industry-standard security measures and authentication tools to
protect the security of your PD. We and the third parties who provide services for us, also
maintain technical and physical safeguards to protect your PD. When we collect your credit card
information through our website, we will encrypt it before it travels over the Internet using
industry-standard technology for conducting secure online transactions. Unfortunately, we
cannot guarantee against the loss or misuse of your PD or secure data transmission over the
Internet because of its nature.
We strongly urge you to protect any password you may have for our website and to not share it
with anyone. You should always log out of our website when you finish using it, especially if you
are sharing or using a computer in a public place.
USE OF YOUR CREDIT CARD
You may have to provide a credit card to buy products and services from our website. We use
third-party billing services and have no control over these services. We use our commercially
reasonable efforts to make sure your credit card number is kept strictly confidential by using
only third-party billing services that use industry-standard encryption technology to protect your
credit card number from unauthorized use. However, you understand and agree that we are in
no way responsible for any misuse of your credit card number.
TRANSFERRING PD FROM THE EUROPEAN UNION
(PD) that we collect from you may be stored, processed, and transferred between any of the
countries in which we operate, specifically United States and New Zealand. The European
Union has not found the United States and some other countries to have an adequate level of
protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific
situations as defined in Article 49 of the GDPR. For European Union customers and users, with
your consent, your PD may be transferred outside the European Union to the United States and
or other countries. We will use your PD to provide the goods, services, and/or information you
request from us to perform a contract with you or to satisfy a legitimate interest of our company
in a manner that does not outweigh your freedoms and rights. Wherever we transfer, process or
store your PD, we will take reasonable steps to protect it. We will use the information we collect
from you in accordance with our privacy notice. By using our website, services, or products, you
agree to the transfers of your PD described within this section.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to change this privacy notice at any time. If our company decides to
change this privacy notice, we will post those changes on our website so that our users and
customers are always aware of what information we collect, use, and disclose. If at any time we
decide to disclose or use your PD in a method different from that specified at the time it was
collected, we will provide advance notice by email (sent to the email address on file in your
account). Otherwise we will use and disclose our users’ and customers’ PD in agreement with
the privacy notice in effect when the information was collected. In all cases, your continued use
of our website, services, and products after any change to this privacy notice will constitute your
acceptance of such change.