Privacy-Policy

Privacy Policy

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means The Cruise Project. We are committed to respecting your privacy. Our Privacy Policy sets outs out how we collect, use, store and disclose your personal information. By providing personal information to us, you consent to our collection, use, and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

A. What personal information do we collect?

1. Personal Data

• Device information
• geo-location information
• connection information
• traffic data
• input you sent for text generation

2. Usage data

• IP address
• browser type
• browser version
• the pages of our Service that You visit
• the time and date of Your visit
• the time spent on those pages
• unique device identifiers and other diagnostic data

3. Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Apple

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your Profile Picture, Your email address, Your activities, associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

B. Why do we collect and use personal information

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.

C. Retention and Transfer of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located, including the third party service providers. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

D. Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

E. Information for Individuals in the European Economic Area (EEA)

Your Choices and Rights

If you reside in the EEA, you may have several rights concerning the use of your personal data:

• Access: You can request to access and obtain copies of your personal data.
• Correction: You have the right to correct or update any inaccurate or incomplete personal data.
• Objection and Restrictions: You can request us to stop or limit the use of your personal data in certain cases.
• Deletion: Under specific conditions, you can ask for your data to be erased or for restrictions on its use, in line with the "right to be forgotten."
• Portability: In some situations, you can ask for a transferable format of your personal data to move it to another service provider.
• Consent Management: If we process your data based on consent, you can withdraw this consent anytime without needing to justify your decision.

If you are in the EEA and wish to access, modify, or delete your personal data, you can contact us. However, if changes or deletions are made, or if you choose not to share certain data, we might not be able to provide our services fully. We may refuse requests for specific reasons, such as if they are illegal or infringe on others' rights. For example, some requests may not be feasible as they would prevent us from offering our service to you.

For your safety, we may ask for proof of identity before responding to the above requests.

Legal Basis for Processing Data

This section outlines the legal grounds we rely on to process personal data.

• We may process personal data based on legitimate interests like developing, administering, and improving our services, managing business operations, promoting research, supporting recruitment, or facilitating a Corporate Transaction.
• In some instances, we process personal data to fulfill contracts with business partners, including distributors of our products.
• We may need to process personal data to defend against fraud, illegal activities, and other liabilities, including enforcing our service terms.
• Processing certain data might be necessary for legal compliance or public interest, such as for reporting adverse events and product safety.
• We may process personal data as permitted by specific legal requirements.

If consent is required for processing your personal data, we will seek it at the time of collection.

International Data Transfers

We may transfer your personal data to other countries for processing as described in this Privacy Notice. For instance, data from outside the United States may be transferred to the U.S. The data protection laws in these countries may differ from those in the country where the data was initially collected. When transferring data internationally, we consider various legal requirements.

Specifically, we may transfer personal data from the EEA to:

• Countries recognized by the European Commission as having adequate data protection,
• Recipients adhering to standard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules,
• Based on the consent of the individual concerned, or
• As allowed by EEA legal requirements.

F. Information for Residents of California: Your California Privacy Rights

As a resident of California, the California Consumer Privacy Act ("CCPA") might grant you additional rights concerning your personal information beyond those detailed in this Privacy Policy. This section outlines your rights under the CCPA if you are a "Consumer" as defined by the law. It explains how to exercise these rights and refers to Sections 1 - 4 above for information on the data we collect, including its collection, use, and sharing processes.

Access to Information and Data Portability Rights

Under the CCPA, you can request, twice in a 12-month period, information about:

• The types of personal information we have gathered about you.

• The sources from which your personal information was collected.

• The purposes for collecting or selling your personal information.

• The categories of third parties with whom we have shared your personal information.

• The specific personal information we have collected about you.

• A list of personal information disclosed for business purposes in the past 12 months, or confirmation that no such disclosure occurred.

• A list of personal information sold in the past 12 months, or confirmation that no sale occurred. If sales occurred, we will detail:

• The types of your personal information sold.

• The categories of third parties to whom the information was sold.

You also have the right to a transportable copy of your personal information collected in the past 12 months.

Data Deletion Rights

Unless we have a reason to retain your data under CCPA, you can request the deletion of your personal information that we have directly collected and are maintaining. We are not obligated to delete information not collected directly from you.

Exercising Your Rights

To request access, portability, or deletion under CCPA, send a request to the Privacy / Legal Department at support@xemail.ai. Your request must:

• Provide enough details to verify your identity or that of your authorized representative.
• Clearly describe your request to enable us to understand, evaluate, and respond.

We may not be able to verify or fulfill requests for data not sufficiently associated with your personal information (e.g., data tied to a pseudonymous browser ID). We will explain any inability to fulfill a request in our response.

We strive to identify and respond to your CCPA rights requests without charging a fee, unless the request is excessive, repetitive, unfounded, or burdensome.

Opt-Out

There  is not yet a consensus as to whether third party cookies and tracking  devices associated with our websites and mobile apps may constitute a  "sale" of your PI as defined by the CCPA. To make a request to opt-out  of sale under CCPA, send mail to cruisefrombcn@gmail.com.

We won’t discriminate against you for exercising your CCPA rights. However, prices, rates, or service levels may vary if justified by the value of the data. Financial incentives for personal information collection, sale, and retention may be offered as permitted by CCPA, potentially resulting in different prices, rates, or quality levels. The specifics of any incentive will be detailed in the program terms, which are subject to change, so please review them regularly.

If you have any questions about our privacy policy, you can contact us at cruisefrombcn@gmail.com