Privacy Policy

GASTROTERRA PRIVACY POLICY

This Privacy Policy is effective September 15, 2021. This Privacy Policy supersedes any and all previous Privacy Policies.

1. Our Service

Welcome to GastroTerra. GastroTerra is where trade professionals and other industry stakeholders come together to meet for networking, and to share knowledge and information about our industry.

This Privacy Policy (“Privacy Policy”) explains our privacy practices and how we handle your personal information collected through GastroTerra, as well as through social media, our marketing activities, our live events, and other activities described in this Privacy Policy. This Privacy Policy also explains how we use and share such information and the choices you have.

We use “GastroTerra” to refer to the GastroTerra websites and our iOS and Android apps (also referred to as our “Services”). We also use “GastroTerra,” “we,” “us,” and “our” to refer to the companies operating the Services as described in the Member Agreement.

Unless otherwise indicated, this Privacy Policy applies to all of our Services in all geographies in which GastroTerra offers its Services. Certain portions of this Policy apply only to Services offered in particular geographies; please see Section 11 for additional information. Capitalized words used but not defined have the meanings described in the Member Agreement.

2. What information is collected?

We may collect personal information from you, through technology that automatically collects information from your browser or device, and from third party sources. See below for examples. Note that not all GastroTerra account types and features are available in all locations, so some of the examples below may not apply where you live. We may also collect personal information that is not specifically listed below, which we use consistent with this Privacy Policy or as otherwise described at the time of collection.

2.1. From you.

● Your contact details.

○ When you sign up for GastroTerra, you may provide your name, address, phone number, profile photo, email address, location, date of birth, gender, demographic information, professional information, business information and similar information.

○ If you want to join GastroTerra, or use a GastroTerra service, before it has been introduced to your country, then you can choose to give us your contact information and ask us to notify you when we do introduce the service to your country.

○ If you contact support, you may provide us with your contact information and a description of the issue so we can respond.

● Data from other accounts. If you use a third party, like Facebook, Google, or Apple to log in to GastroTerra (or later connect your third-party account to your GastroTerra account), then you authorize the third party to share your personal information with us, including your name, photo, email address, and any other information you agree to share.

● Posts, interests, location, and recommendations.

○ You may share information about yourself in your profile, including your interests, skills, a picture, information about your household, biographical information (such as your job, hometown, time you have spent living in the area, etc.), emergency contact, or even what you love about your job or profession.  Note that you may maintain only personal (individual) profiles on GastroTerra. If you wish to maintain a business, organizational or destination profile, you must do so on our World Food Travel Market service instead.

○ You may share information about your interests, including joining a Group or following a discussion or topic.

○ You may post on GastroTerra or send a private message. Posts may include, but are not limited to text, photos, or video, tagging people or places, posting articles or links to articles, and anything else you want to share.

○ You may choose to share information about your business in the form of a recommendation, comment, or by creating a separate profile (with separate subscription and separate Terms) on our World Food Travel Market service.

● Payment information. If you make a payment either to or through GastroTerra, then you are providing our third-party payment processors (for example, Stripe) with your payment card details and other payment information in order to complete the transaction.

● Survey data. We may contact some Members to request participation in a survey or other general research. If you choose to take part in these, you may provide information, feedback, and comments to us in response.

● Contests, sweepstakes, and prize drawings data. If you take part in a contest, sweepstakes, or prize drawing, then you may provide information, feedback, and comments in response.

● Messages and email data. We collect information about you when you send, receive, or engage with messages, emails or physical mail in connection with our Services, including whether you have opened or acted on those messages.

● Photos and videos. You may choose to grant the Services permission to collect images, video and other information from your device’s camera and photos, such as when you include images and video in your posts. These files may include metadata indicating how, when, where and by whom the files were created and how they are formatted. Metadata can make your files more searchable and interactive, but it may be accessible to other Members or anyone else who can access the files.

● Geolocation. You may choose to grant the Services permission to access your device’s precise geolocation, which we use to confirm your address and help us operate or personalize our Services, including by tagging posts, adding information to a map, and helping us show you more relevant content or ads.

● Business information. If you use our Business Services (“World Food Travel Market”, you may share details about your relationship with a business and services offered by you or the business.

2.2. From your browser and device.

With your permission, or when or where it is required by applicable laws, we, our service providers and partners collect technical information when you visit or use GastroTerra, engage with our partners, or interact with our or our partners’ marketing communications, including:

● Device data, such as your device’s manufacturer and model, operating system and version, screen resolution, RAM and disk size, CPU usage, unique identifiers (including identifiers used for advertising purposes), crash data (if applicable), what device settings you enabled, carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, province, region or geographic area. Your device and software settings affect what information your device makes available to us.

● Online activity data, such as the date and time you visited, duration of access, the browser or app version you used (and its settings), the URLs you come from and go to, and how you used GastroTerra and interacted with our emails and other messages (for example, how you navigated and which links you clicked on).

Some of the data collection described above is facilitated by cookies and similar technologies, as described in more detail in our Advertising and Cookie Policy.

2.3. From third parties and public sources.

We may collect information from third parties (such as service providers and partners) and public sources. For example:

● GastroTerra Members may sync their contacts with GastroTerra, including their contacts’ email addresses, mailing addresses, and phone numbers.

● Vendors provide us with map and business address information in order to help us launch GastroTerra in new countries and update existing countries.

● Vendors provide information about Members and their homes for advertising, analytics, personalization, and measurement purposes.

● Vendors and partners provide information about businesses to help us create business pages and offer our Services to businesses.

● Advertisers provide us with information about their users or potential customers to help us personalize advertising and measure the performance of their advertisements.

● Public sources, such as census data, street addresses, and business registration information, provide us with information that helps us understand our Members, improve our Services, and determine potential areas for expansion.

3. How is your information used?

We use personal information for the following purposes or as otherwise described at the time we collect it:

3.1. Establishing and developing countries and groups.

We use personal information to identify and invite potential new Members to GastroTerra, and to set up new GastroTerra groups. For example, you can ask us to send invitations to potential new Members and reminders on your behalf, send direct mail invitations, invite your friends, or notify you when we start offering the Services to your country or area.

3.2. Setting you up on GastroTerra.

To get Members started on GastroTerra, we use personal information to:

● Confirm Member accounts by employing several techniques, including checks against third party data and public records, verification codes, or geo-verification. In some circumstances, we may ask for additional information (such as government-issued identification and business documentation) to confirm Member accounts.

● Notify members of new Members as they join a group.

● Populate Member profiles and personalize GastroTerra.

● Create and offer Business Services, which help Members learn about the businesses in their countries.

3.3. Provide and improve the Services.

We use both manual and automated systems to analyze and use your Content (as defined in the Member Agreement) and other information, including:

● To operate GastroTerra, create groups, suggest groups, invite industry professionals, and improve our products and features.

● To help you create, publish, view, share, and respond to Content, including highlighting interesting posts.

● To highlight groups, community topics or other resources.

● To administer and obtain feedback via surveys, sweepstakes, contests, or other promotional activities.

● To highlight businesses, ads, offers, products, and services you may be interested in.

● To provide Business Services, such as enabling Business Pages and promotional services in our World Food Travel Market platform.

● To personalize your experience.

● To understand the trends, usage statistics, and demographic data of the Members and groups we serve.

● To respond to your support requests and comments.

● To test and evaluate potential new products and features on GastroTerra.

● To diagnose and resolve problems, analyze trends, and monitor usage and resource needs.

● To accept payments, through our third-party payment processors.

● To facilitate sending urgent alerts.

● To communicate with you about the Service, including by sending announcements, updates, security alerts and support messages via email, notifications, and text messages.

3.4. Create and maintain a trusted environment.

We may use your information to help create and maintain a trusted environment on GastroTerra, including:

● To detect and prevent fraud, spam, abuse, security incidents, and other harmful, unauthorized, unethical or illegal activity.

● To conduct security investigations, audits and risk assessments.

● To comply with our legal obligations.

● To confirm or authenticate information or identification.

● For the legal and safety reasons described below in Section 4.3.

3.5. Advertising.

We use your information to provide and improve advertisements and other commercial offerings both on and off the Services:

● To help personalize advertisements based on what we think may interest you.

● To provide and measure the effectiveness of personalized advertising, including whether it is interesting to Members and effective for the advertiser.

● To improve the personalization of advertisements.

● To send you promotional messages, marketing, advertising and other information that we think may interest you.

● To invite you to events and relevant opportunities.

We may customize advertising offers you see on GastroTerra based on information from our advertisers or vendors, on the demographics of your country, or on your actions, selections, or preferences on GastroTerra. For example, a public relations professional might provide a list of contacts with contact information who are eligible for a special deal that we may offer to GastroTerra Members in the professional’s area of service. Or, if you search GastroTerra for a particular keyword, we might show you advertisements for providers of services or products related to that keyword or related or similar products and services. Our third-party advertising partners also use cookies and similar technologies to collect information about Members for advertising purposes as described in Section 4.4 below and in our Advertising and Cookie Policy.

3.6. Research and Development.

We may use your personal information for research and development purposes. As part of these activities, we may create aggregated, de-identified and/or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

4. Is your information shared with third parties?

We reserve the right to share your personal information as follows:

4.1. Content shared on GastroTerra.

GastroTerra is a platform for industry professionals to share information with each other. To that end, the Content you post on GastroTerra, such as posts, replies, recommendations, messages, and your profile information, may be visible to other Members, businesses, governments and agencies, or the public, including Visitors (as defined in the Member Agreement) and search engines. You can adjust the visibility of your posts in the preferences in your settings, the preferences on the Content you provide, and as described in Section 5 below. Please be sure to read the options you have under the “What are My Choices” section below. If this information is cached by third party search engines or other third parties, please note we do not control the practices of these third parties, and they may use caches containing outdated information. Please consult these third parties’ privacy policies.

4.2. Account confirmation.

We may share your personal information with our verification partners, such as identity verification services, telecommunications providers (if you choose to confirm your account by providing your telephone number) and data providers to confirm your account.

4.3. Legal and safety reasons.

We may retain, preserve, or share your Content and personal information with law enforcement, government authorities, and private parties if we have a good-faith belief that it is reasonably necessary to: (a) respond, based on applicable law, to a legal request (e.g. a subpoena, a search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other unauthorized, illegal or unethical activity, security, or technical issues; (c) protect our or others’ rights, property, or safety; (d) enforce our Member Agreement or any other agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including you and Members of the general public. For example, we may share your personal information with disaster relief agencies, first responders, and other individuals to facilitate disaster or emergency response efforts.

4.4. Advertising.

If you view, click on, or reply to an advertisement or other offer on the Services, we may share your reply and limited Member profile information with the advertiser, and we may log your interaction as part of tracking the overall effectiveness of the advertisement. We may also pre-populate replies to messages you click on with your contact details, but those details are not shared with the advertiser without your consent.

The Services are supported by third party advertising networks. With your consent, our advertising partners use cookies and similar technologies to collect information about our Members and their devices over time across GastroTerra and other online services. Where permissible according to applicable law, we may share certain limited personal information, such as hashed emails and advertising identifiers, with our advertising partners that help serve targeted online advertising to those Members or to similar audiences. Our advertising partners may be able to associate this information with you based on your advertising identifiers or other personal information they have about you. Our advertising partners then use the information they collect to provide our Members with personalized ads on GastroTerra and on different websites and services, and to measure the effectiveness of the ads.

4.5. Third party partners.

GastroTerra may partner with third party companies to offer Members the ability to book a range of different services, such as media relations, research, graphic design, web design, and so on. These offers may be integrated into GastroTerra, or GastroTerra may contain links to other websites or apps featuring the offers. In order to tailor these offers to you, we may share limited personal information with such third parties, such as your country and postal code, the nature of the content you are viewing, or a business search query (for example, a search for “research”). When you engage with one of these offers, you may share additional information (such as contact information) directly with the third-party partner. If you engage with third party partners through GastroTerra, the third parties may share with us certain personal information about you to allow us to coordinate, assess, and improve the services provided to you. This may include information about a booking you make with the third party, including type of service, name and address of provider, and the time of booking. These third parties have their own privacy policies, which will apply to your activity if you click on or interact with their offers featured on GastroTerra or other websites or apps.

4.6. Service providers.

We may also share your personal information with service providers and/or data processors to help us operate, provide, improve, understand, customize, support, and market our Services. These service providers and data processors are contractually required to use it only to provide their service to us and are contractually prohibited from using it for their own purposes. They provide a variety of services, including payment processing, information technology, cybersecurity, fraud prevention, hosting, customer relationship management and support, communications delivery, marketing, advertising, and website and mobile application analytics.

4.7. Social Media.

Our Services include certain social media features, including social media share button. If you choose to share a post using the social media share button, information about that Content will be shared with the relevant social media platform.

4.8. Within the GastroTerra corporate family.

We may share your information within our “corporate family”, including between GastroTerra, the World Food Travel Association, the World Culinary Culture Institute, and World Food Travel Market, to help provide, maintain, and improve Services. Some of these companies may not be located in your home country. As we grow and GastroTerra becomes used in more countries, we may expand the corporate family within which we share your information by establishing local subsidiaries or other affiliates in these countries as needed to help us provide better service there.

4.9. Business reorganization.

We may need to share your personal information with the relevant participants in transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, restructuring, reorganization, or sale or other disposition of some or all of the assets of, or equity interests in, GastroTerra or our affiliates (including, in connection with a bankruptcy or similar proceedings).

4.10. Professional advisors.

We may share personal information with our professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

5. What are your choices?

You can choose the degree to which your personal information, such as your profession and location, is shared in your personal profile and alongside your posts by using your account settings. You can modify these account settings at any time.

When you post content on GastroTerra, you also can choose who gets to see your post. You can read more here about the choices you have regarding the sharing and visibility of your posts. Some of these choices may not be available for our Business Services, such as our Business Pages.

You can opt out of third-party personalized advertising by adjusting your cookie settings or changing the privacy settings on your mobile device. For more information about third party use of cookies, mobile advertising identifiers, and similar technologies and how to adjust your settings, see our Advertising and Cookie Policy. Our systems are not currently configured to accept browsers’ “Do Not Track” signals, as no industry-wide standard for handling them has been adopted.

See our jurisdiction-specific disclosures in Section 11 below for more information about legal rights you have if you live in a listed jurisdiction.

6. How long is your information kept?

We retain your information in our server logs, our databases, and our records for as long as necessary to provide the Services. We may need to retain some of your information for a longer period, such as to comply with our legal or regulatory obligations, to resolve disputes or defend against legal claims, or to enforce our Member Agreement.

7. How is your information protected?

7.1. Account security.

GastroTerra uses technical and organizational measures intended to keep your data secure, including using https on our web pages to reduce the risk of unauthorized interception of your communications during your visits to the website and two-factor authentication where appropriate. However, the internet is not a fully secure environment, and we cannot guarantee that your personal information will not be intercepted or improperly accessed. Please ensure that you keep your password safe and do not share it with anyone.

7.2. Other services and websites.

When using GastroTerra, you may come across links to websites and services operated by third parties that are not owned or controlled by GastroTerra (for example, if a Member shares a link to a video on YouTube, or if an advertiser provides a link to a contest or sweepstakes). This Privacy Policy does not apply to information collected on any third-party site or application that may link to or be accessible from the Services. These third parties have their own privacy policies, which will apply to any personal information they collect. We do not accept any responsibility or liability for such external sites’ privacy and security practices.

8. Children

Children are not allowed to use the Services if they are under 13 years old or not old enough for GastroTerra to process their personal information without parental or age-specific consent where they live. If you believe we might have collected personal information from a child in one of these categories, please contact us at help(at)worldfoodtravel(dot)org, and if we learn that we have such information, we will delete their personal information.

9. Amendments to this Privacy Policy.

We may make changes to this Privacy Policy from time to time, so please review it periodically. If we materially change our Privacy Policy, we will take steps to notify you in advance of the change as required by applicable law, for example by emailing you or by posting a notice in your membership feed. If you object to any changes, you may close your account. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use, and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

10. Contact us.

No matter where in the world you live, contact us at World Food Travel Association d/b/a GastroTerra, 4110 SE Hawthorne Boulevard Suite 440, Portland, OR 97214. Phone: +1 503 213 3700. Email: help(at)worldfoodtravel(dot)org.

11. Jurisdiction-specific disclosures.

11.1. California.

If you are a California resident, this section applies to you. This section describes how we collect, use, and share your personal information in our capacity as a “business” under the California Consumer Privacy Act of 2018 (“CCPA”), and the rights that you have with respect to your personal information. For purposes of this section, “personal information” has the meaning given in the CCPA but does not include information excluded from the CCPA’s scope.

11.1.1. Personal information (“PI”) we collect, use, and disclose.

The chart below summarizes the personal information we collect by reference to the categories of personal information specified in the CCPA and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free form webforms, may contain other categories of personal information not described below. More information regarding the sources from which we collect personal information can be found in Section 2 above titled “What information is collected?”; business and commercial purposes for which we collect your personal information can be found in Section 3 above titled “How is my information used?”; categories of recipients with whom personal information is shared or sold can be found in Section 4 above titled “Is my information shared with third parties?”

Statutory category of personal information (PI) (Cal. Civ. Code § 1798.140)PI we collect in this category (See Personal information we collect above for description)Source of PIBusiness/ commercial purpose for collectionCategories of third parties to whom we may “disclose” PI for a business purpose
Identifiers (other than online identifiers)● Contact details● Network details● Data from other accounts● Posts, interests, location, and recommendations● Business information● Information from third parties and public sources● You ● Third parties and public sourcesEstablishing and developing groups ● Setting you up on GastroTerra ● Provide and improve the Services ● Create and maintain a trusted environment ● Advertising ● Research and development  ● Public Verification partners ● Legal and safety-related third parties ● Advertising partners ● Third party partners ● GastroTerra corporate family ● Business transferees ● Professional advisors
California Customer Records (as defined in California Civil Code section 1798.80)Contact details ● Network details ● Data from other accounts ● Posts, interests, location, and recommendations ● Payment information ● Business information●  You ● Third parties and public sources● Establishing and developing groups ● Setting you up on GastroTerra ● Provide and improve the Services ● Create and maintain a trusted environment ● Advertising ● Research and development● Public  Verification partners ● Legal and safety-related third parties ● Advertising partners ● Third party partners ● GastroTerra corporate family ● Business transferees ● Professional advisors
Commercial Information● Contact details● Network details● Posts, interests, location, and recommendations● Payment information● Survey data● Contests, sweepstakes, and prize drawings data● Messages and email data● Business information● Online activity data● Information from third parties and public sourcesYou● Your browser and device● Third parties and public sourcesEstablishing and developing groups ● Setting you up on GastroTerra ● Provide and improve the Services ● Create and maintain a trusted environment ● Advertising ● Research and development Public  Verification partners ● Legal and safety-related third parties ● Advertising partners ● Third party partners ● GastroTerra corporate family ● Business transferees ● Professional advisors
Financial InformationPayment informationYouProvide and improve the Services● Create and maintain a trusted environment● Research and developmentand safety-related third parties● Third party partners● GastroTerra corporate family● Business transferees● Professional advisors
Online IdentifiersMessages and email data● Contact lists● Geolocation● Device data● Online activity data● Information from third parties and public sources            ●You● Your browser and device● Third parties and public sourcesEstablishing and developing groups● Setting you up on GastroTerra● Provide and improve the Services● Create and maintain a trusted environment● Advertising● Research and developmentVerification partners● Legal and safety-related third parties● Advertising partners● Third party partners● GastroTerra corporate family● Business transferees● Professional advisors
Internet or Network InformationMessages and email data● Device data● Online activity dataYou● Your browser and device● Third parties and public sourcesEstablishing and developing groups● Setting you up on GastroTerra● Provide and improve the Services● Create and maintain a trusted environment● Advertising● Research and developmentLegal and safety-related third parties● Advertising partners● Third party partners● GastroTerra corporate family● Business transferees● Professional advisors
Geolocation DataGeolocation● Device dataYou● Your browser and deviceEstablishing and developing groups● Setting you up on GastroTerra● Provide and improve the Services● Create and maintain a trusted environment● Advertising● Research and developmentLegal and safety-related third parties● Advertising partners● GastroTerra corporate family● Business transferees● Professional advisors
InferencesMay be derived from your:● Contact details● Network details● Posts, interests, location, and recommendations● Survey data● Contests, sweepstakes, and prize drawings data● Messages and email data● Geolocation● Device data● Online activity data● Information from third parties and public sourcesN/A     ● Establishing and developing groups● Setting you up on GastroTerra● Provide and improve the Services● Create and maintain a trusted environment● Advertising● Research and developmentLegal and safety-related third parties● Advertising partners● Third party partners● GastroTerra corporate family● Business transferees● Professional advisors
Professional or Employment InformationBusiness information● Information from third parties and public sourcesYou● Third party sourcesEstablishing and developing groups● Setting you up on GastroTerra● Provide and improve the Services● Create and maintain a trusted environment● Advertising● Research and developmentPublic● Verification partners● Legal and safety-related third parties● Advertising partners● Third party partners● GastroTerra corporate family● Business transferees● Professional advisors
Sensory InformationPhotos and videosYouEstablishing and developing groups● Setting you up on GastroTerra ● Provide and improve the Services● Create and maintain a trusted environment● Advertising● Research and developmentPublic● Legal and safety-related third parties● Third party partners● GastroTerra corporate family● Business transferees● Professional advisors

11.1.2. What are my rights?

The following rights are not absolute and are subject to exceptions, and we may be required or permitted by law to decline your request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

11.1.2.1. Access Categories of Information.

You may request the following information about how we have collected and used your personal information during the past 12 months:

● the categories of personal information we have collected about you;

● the categories of sources from which we collected the personal information;

● the business or commercial purpose for collecting or selling the personal information;

● the categories of third parties with whom we share the personal information;

● the categories of personal information that we sold or disclosed for a business purpose; and

● the categories of third parties to whom the personal information was sold or disclosed for a business purpose.

You may make this request by logging into your account if you have one and selecting “Request my information” under the Privacy section of your account settings, submitting a request via email to legal(at)worldfoodtravel(dot)org, or calling +1 503-213-3700.

11.1.2.2. Access.

You can see much of your personal information by logging into your GastroTerra account.

You may request a copy of the personal information we have collected about you during the past 12 months by logging into your account if you have one and selecting “Request my information” under the Privacy section of your account settings, submitting a request via email to legal(at)worldfoodtravel(dot)org, or calling +1 503-213-3700. You may read this article for more information about how to request a copy of your personal information.

11.1.2.3. Deletion.

You can remove most content you have posted to GastroTerra by logging into your GastroTerra account.

You may request that we delete personal information we have collected from you by contacting us if you have an account: please select the “My account” option in the first drop-down menu and the “Delete my account – Calif.” option from the second drop-down menu. You may also submit a request via email to legal(at)worldfoodtravel(dot)org, or calling +1 503-213-3700.

11.1.2.4. Opt-out of sales.

We use services that help deliver interest-based ads to you, which enable us to provide the Services and relevant offers to you.

Our use of these services may be classified under the CCPA as a “sale” of your personal information to the advertising partners that provide the services because they collect information from our users (i.e., the device data and online activity data described in Section 2.2) to help them serve ads more likely to interest you.

You can request to opt-out of this “sale” of your personal information by clicking on the “Do Not Sell My Personal Information” link, where you will find instructions on opting out of the use of your information for interest-based advertising.

11.1.2.5. Nondiscrimination.

You are entitled to exercise your rights described above free from discrimination as prohibited by the CCPA.

11.1.3. Requests by authorized agents.

Your authorized agent may make a request for information, access, and deletion on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. Authorized agents are required by California law to implement and maintain reasonable security procedures and practices to protect their clients’ information.

11.1.4. Verifying requests for information, access, and deletion.

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your legal residency.

If you are a Member, you can verify your identity by submitting your request while logged into your GastroTerra account.

If you are a Visitor or a Member who is unable to log in to your account, we may verify your identity by requiring you to provide government identification, give a declaration as to your identity under penalty of perjury, reply to a text message sent to the phone number we have in our records, and/or provide additional information.

11.1.5. Shine the light.

Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to GastroTerra, Inc., 420 Taylor Street, San Francisco, CA 94102, Attention: Chief Legal Officer. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, email, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

11.2. Australia, Canada, UK, and Europe.

If you live in the UK or Europe, this section applies to you. If you live in Australia or Canada, you may have some of the following rights under applicable law.

11.2.1. On what legal basis do you collect my information?

To the extent required by applicable law, we will collect your personal information with your consent where required and in accordance with our legitimate need to provide you our Services.

Under EU law, GastroTerra is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.

● Performing the Member Agreement

GastroTerra processes your information as is necessary to perform our contract with you, the Member Agreement. For example:

– we use your information in order to create your account and set you up as a Member on GastroTerra;

– we may transfer your information outside of the EU to the U.S., such as to our World Food Travel Association servers, in order to provide the Services.

● Your Consent

GastroTerra processes certain information based on your consent, which you may revoke at any time. For example:

– we and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent;

– where you choose a method of verification to confirm your address, we do so in accordance with your consent;

– if you decide to use location services in the context of GastroTerra, we collect and process such location information based on your consent;

– we rely on your consent to tailor ads based on off-GastroTerra actions and information, including based your activity on other websites and partner data, such as inferred interests;

– we will send you marketing communications where you have consented to receiving such communications in accordance with applicable law;

– where you ask us to notify you when GastroTerra is available in your country, we do so based on your consent.

● Legal Obligation

GastroTerra may process your information in order to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:

– we may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g. a subpoena, search warrant, court order, or other binding request from government or law enforcement); and

– we may retain and process your information where it is necessary for compliance with applicable tax laws.

● Vital Interests

GastroTerra might process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:

– we may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person, including you, other Members, Visitors, our staff, or the public;

– we may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat;

– we may share your personal information with disaster relief agencies, first responders and other individuals to facilitate disaster or emergency response efforts.

● Legitimate Interests

We may process your information where it is necessary for the purposes of GastroTerra’s or a third party’s legitimate interests, such as those of Visitors, Members or partners. In particular, we process your information in furtherance of the following legitimate interests:

– Keeping the Services safe and secure: We use your information because it is necessary to pursue our and our Members’ legitimate interests in ensuring GastroTerra is secure, such as implementing and enhancing security measures and protections, protecting against fraud, spam and abuse, and enforcing our Member Agreement.

– Providing, improving, and developing the Services: We use your information to provide the Services, including any personalized services, and to understand and improve our business and our Member relationships. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Members on a sustained basis.

– Providing seamless Services across the GastroTerra group of companies: Where the Services require the engagement of other GastroTerra companies, we share your information with such affiliates to provide and improve the Services. For example, information controlled by GastroTerra EMEA is transferred to GastroTerra, Inc., which assists GastroTerra EMEA in technically and infrastructurally supplying the Services.

– Providing ads, and measurement and analytics services: We use your information to provide personalized ads both on and off GastroTerra and to measure and analyze the success of those ads in order to provide accurate and reliable reporting to our advertisers. We do so as necessary to pursue our legitimate interests of marketing and monetizing our Services.

– Sending marketing communications: We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.

– Sharing information for legal and safety reasons: Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.

As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.

11.2.2. What are my rights?

You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below.

In certain cases, such as for access to, rectification or deletion of your information, please be sure to read the options you have under the “What are My Choices” section above.

11.2.3. Access.

If you are unable to obtain the desired information by logging into your GastroTerra account, or if you are not currently a GastroTerra Member, email us at help(at)worldfoodtravel(dot)org to request a copy of your GastroTerra information. If requested and required to do so by applicable law, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties as you request.

11.2.4. Rectify, restrict, delete.

You can access, rectify, and delete your GastroTerra information by logging into your GastroTerra account. If you cannot do this or you do not have a GastroTerra account, please contact us and we will rectify, restrict, or delete your information if requested and if required to do so by applicable law.

11.2.5. Object.

If we process your information based on our legitimate interests explained above, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing (including if we are permitted to continue processing under applicable law) or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object by using the unsubscribe link in such communications, changing your email account settings or, if you do not have an account, by contacting us.

11.2.6. Revoke consent.

Where consent is required for processing under applicable law, you may have the right to withdraw your consent to the processing of your information at any time. If you withdraw your consent to the use of your information for the purposes set out in this Privacy Policy, you may not have access to all (or any) of our Services and we might not be able to provide you all (or any) of the Services under this Privacy Policy and our Member Agreement. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so, or if your withdrawal of consent was limited to certain processing activities.

11.2.7. Complain.

If you have a UK or EU Member account and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or GastroTerra’s lead supervisory authority, the Irish Data Protection Commission.

If you have an Australian or Canadian Member account, please contact us and provide us with as much detail as possible about your complaint. We take all privacy complaints seriously and will assess any complaint with the aim of resolving it in a timely and efficient manner. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner (for Australian Members) or the Office of the Privacy Commission of Canada (for Canadian Members).

11.3. Where is my information stored?

If you live in Australia or Canada, we transfer your personal information to the U.S.

If you live in the UK or the EU, we transfer your personal information under these protections:

11.3.1. Standard contractual clauses.

We may use a legal mechanism known as “standard contractual clauses” to protect information transferred outside the EU and the UK. Standard contractual clauses refer to contracts between companies transferring personal information (for example, from World Food Travel Association to World Culinary Culture Institute.) that contain standard commitments approved by the EU Commission protecting the privacy and security of the information transferred. To request a copy of the clauses, please email us at legal(at)worldfoodtravel(dot)org.

By continuing to use GastroTerra, you understand that we may transfer and store your data outside your home country, including to and in the U.S., as described in this Privacy Policy. The privacy protections and the rights of authorities to access your personal information in some of these countries may not be the same as in your home country. GastroTerra will only transfer personal data as permitted by law, and will take steps intended to ensure appropriate protection of your personal information. If you have questions, please contact us.