Last updated: June 2, 2023
The privacy of your data — and it is your data, not ours! — is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.
You supply us with your personal information at your own risk. Although current encryption methods and techniques are very secure, we can’t guarantee that every single transfer of data will be 100% secure, nor what hacking techniques will pop-up in the future.
If you’re allowed access to our systems, you are responsible for your login and password. Don’t use an easy one and do not share it!
If you think your privacy is breached, let us know. You can inform our DPO directly on email@example.com.
How we collect your data
We use different methods to collect data from and about you including through:
Direct interaction: You directly provide Lato with most of the data we collect. We collect data and process data when you: interact with any of our online services, voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
Third parties or publicly available sources: We can receive personal data about you from various third parties and public sources such as advertising networks, our partner network, identity and contact data from publicly available sources and data brokers, technical data from parties such as analytics providers and search information providers
Information which is freely available through public internet searches
What we collect and why
Identity & access
When you sign up for Lato, we typically ask for identifying information such as your name, email address, and maybe a company name. That’s just so you can personalize your new account, and we can send you invoices, updates, or other essential information. We sometimes also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.
We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
We also log full IP addresses used to sign up a product account. We keep this record forever because it is used to mitigate spammy signups.
Web analytics data — described further below — are also tied temporarily to IP addresses to assist with troubleshooting cases. We blind all web analytics data after 30 days.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services. We blind all of these individual identifiers after 30 days.
We may use third party services (such as CAPTCHA) across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts and fill specific forms, the service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human. We retain these data via our subprocessor forever because they are used for anti-spam mitigation.
Cookies and Do Not Track
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write Lato with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
Information we do not collect
We don’t collect any characteristics of protected classNameifications including race, religion, sexual orientation, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
How we approach mobile app permissions
We may offer optional mobile apps for certain products. Our philosophy is to ask for the bare minimum of permissions from you to give you a great app experience with maximum privacy. By default, we have access to the network to ensure the app can connect to and communicate with the Internet. In most cases, we ask for permission just-in-time so that you can decide if you want to grant access to things like contacts, camera, and calendar. A few exceptions:
- For our iOS apps, we’ll ask for permission to use push notifications upon first sign-in.
- Android apps do not require permission to send push notifications.
It’s impossible for our apps to try to use a sensitive OS feature without requesting access explicitly from you, so you’ll always know exactly when and what we’re requesting. You will never be required to grant any permission (although a given feature may not work or work well without it).
When we access or share your information
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. Having subprocessors means we are using technology to access your data. No Lato human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring.
To help you troubleshoot or squash a software bug, with your permission.If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses.Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
When required under applicable law.
Lato travel app bv is a Belgian company and all data infrastructure is located in the EU.
- If the appropriate law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share data, we have to comply. Otherwise, we flat-out reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made.We have never received a National Security Letter or Foreign Intelligence Surveillance Act (FISA) order.
- Similarly, if Lato receives a request to preserve data, we refuse unless compelled by the appropriate law enforcement authorities. In these situations, we notify affected customers as soon as possible unless we are legally prohibited from doing so. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we destroy any preserved copies we made of customer data once the preservation period lapses.
- If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from their accounts, you can do so directly from within the app or by contacting us.
- If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we only share the bare minimum needed such as billing addresses and tax exemption information.
Your rights with respect to your information
At Lato, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Lato recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Lato because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not be subject to Automated Decision-Making.You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at firstname.lastname@example.org. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.
How we secure your data
All data is encrypted via SSL/TLSwhen transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest.
Location of Site and Data
Our products and other web properties are operated in the European Union. If you are located in the United States or elsewhere outside of the European Union, please be aware that any information you provide to us will be transferred to the European Union. Some of our external third parties are based outside the European Economic Area so their processing of your personal data will involve a transfer of data outside the EEA. Whenever your personal data is transferred oustside the EEA, we ensure a similar degree of protection is afforded to it. By using our site, participating in any of our services and/or providing us with your information, you consent to this transfer.
How long is your data kept
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Changes & questions
We may update this policy, at our sole discretion, as needed to comply with relevant regulations and reflect any new practices. We strongly encourage you to regularly check for any changes as your continued use of the Site or Services indicates acceptance of the new policies. Whenever we make a significant change to our policies we will also announce them via email or post a notice on the Site.
Should you wish to report a complaint or if you feel that Lato has not addressed your concern in a satisfactory manner, you have the right to contact the Belgian Data Protection Authority.