Privacy Policy
Cambridge Global Ventures, INC.
PRIVACY POLICY
Last Modified Date: July 25, 2024
Cambridge Global Ventures, Inc., (hereinafter, “CGVI,” “we,” “our,” or “us”) provides an array of
products and services tailored to enhance your corporate identity and streamline operations,
including TrvlPro™, our premier concierge service offering bespoke travel kits ensuring your
employees are ready for their next journey and PathoSpy™, an all-in-one tool offering public health
information and travel management features (the “Services”) to users (collectively, “you” or “your”)
through its website, CGVI.co (the “Site”) and mobile application (the “App”).
This privacy policy (“Privacy Policy”) explains the types of information relating to an identified or
identifiable natural person, or as otherwise defined under applicable Privacy Laws, (“Personal
Data”) that we may collect from you when you use the Services or interact with the Site or any
affiliated third-party website that may contain a link to this Privacy Policy. Unless explicitly stated
otherwise, any current, updated and new software and products, including the addition of new
features and services shall be subject to this Privacy Policy, as well as our Terms of Use.
If you are located in the European Economic Area (EEA), the United Kingdom (UK), or California or
if the processing of your data is subject to the laws of a member state of the EEA, the UK, or to the
laws of California, please carefully review the applicable EEA and UK Privacy Rights or California
Privacy Rights section below for more information regarding your rights and our activities relating to
your Personal Data. If the respective section is applicable to your information, then other sections in
this Privacy Policy still may apply to you but are subject to (and considered modified by) that
respective section.
Please read this Privacy Policy carefully to understand our policies and practices regarding your
Personal Data and how we will treat it. If you do not agree with our policies and practices, including
our use and disclosure of your Personal Data, please do not use the Services and do not provide us
with any Personal Data. However, if you choose to limit the information that you provide to us while
using the Site and Services, you may not be able to use or participate in certain features of the Site
and Services.
IMPORTANT: By clicking accept to this Privacy Policy or registering as a member to use the
Services, you agree to the terms of this Privacy Policy and our Terms of Use, and consent to
our privacy practices described in this Privacy Policy, including our use and disclosure of
your Personal Data as described below.
REVISIONS AND MODIFICATIONS
Because our business needs may change over time, we reserve the right to modify this Privacy
Policy. If at any time in the future we plan to use your Personal Data in a way that differs from this
Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a material change to
our Privacy Policy, we will notify you via email to the email address that you provided to us. The
date the Privacy Policy was last revised is identified at the top of this webpage as the “Last Modified
Date.” Subsequently consenting and using the Services, constitutes your agreement to and
acceptance of the Privacy Policy and its revisions and modifications. You are responsible for
ensuring we have an up-to-date active and deliverable email address for you, and for periodically
visiting the Services and our Privacy Policy to check for any updates.
COLLECTION OF PERSONAL DATA
CGVI collects different types of Personal Data about you while using the Services. We collect this
Personal Data in various ways, including:
Directly from you when you provide it to us;
Automatically as you navigate through the Site; and
From third parties.
Personal Data Collected from You Directly
CGVI may collect Personal Data directly from you when you use the Services. For example,
when you register for an account, pay for the Software, or contact us. We collect the
following types of Personal Data:
Identifiers, including name, postal address, email address, financial and bank
information;
Information Listed in the California Customer Records Statute, including
name, postal address, financial and bank information;
Legally Protected Characteristics under California or Federal Law, including
race, gender, marital status, military or veteran status, age;
Personal Data Automatically Collected
CGVI and third-party service providers may automatically collect information about you when
you use the Site. This information is primarily needed to maintain the security and operation
of the Site, and for our internal analytics so that we can improve our Services and Site. This
information includes:
Identifiers, including name, email address, photographs, cookies, and a User’s
image;
Financial/Subscription, including name, date of birth, address, payment
information (e.g., credit / debit card number, financial account information), email
address;
Internet or Other Electronic Network Activity Data, including (i) technical
information collected in our logs e.g., your IP address, page URLs, timestamp,
phone operating system, customer proprietary network information (e.g., time,
date, duration of App use) and (ii) device information such as the mobile phone
operating system, the pages or features accessed most frequently, how pages or
features of the Services are used, search terms entered, and similar analytics
about use of the Services, comments, discussion and chat (e.g., message
boards, interactive features, upload content and images), app usage data (not
covered by above categories), social network login (e.g., Facebook
connect),third-party platform login (e.g., Google Cloud), and local shared objects
(e.g., flash cookies);
Location Data, we may collect, maintain, process and use your location data,
including the real-time geographic location of your mobile device (“Location
Data”) as necessary to provide the Services’ full functionality. By using or
activating any location-based services on a mobile device, you agree and
consent to our collection, maintenance, publishing, processing and use of your
Location Data in order to provide you with the Services. We do not collect
Location Data in a form that personally identifies you. You may withdraw your
consent to our use of your Location Data at any time by turning off the location-
based services on the mobile device you are using, or by not using any location-
based features. Turning off or not using location-based features may impact the
functionality of the Services as delivered to you. Location Data provided by the
Services is used for basic navigational purposes only, and is not intended to be
relied upon in situations where precise location information is needed or where
erroneous, inaccurate or incomplete Location Data may lead to death, personal
injury, property or environmental damage. Any use of real-time route guidance
via the Services is at your sole risk. You understand that Location Data provided
by the Services may not be accurate. We do not guarantee the availability,
accuracy, completeness, reliability or timeliness of Location Data displayed by
the Services.
Personal Data Collected from Third Parties
We may also receive information about you from social media platforms, such as when you
interact with us on those platforms or access our social media content. Please note that the
information we may receive from those third-party sites (such as Facebook, Instagram,
Twitter and YouTube) is governed by the privacy settings, policies and/or procedures of the
applicable platform, and we strongly encourage you to review them before submitting any
information using a social media platform.
PROCESSING PURPOSES
We process your Personal Data for the following lawful business and commercial purposes, in
accordance with the practices described in this Privacy Policy, and based upon the legal
justifications set forth in the parenthetical:
Provide the Services. We may use your Personal Data to provide the Software, Services
(including its full functionality), and any other products or services you may request from us.
[CONSENT; CONTRACT; LEGITIMATE INTEREST]
Monitor the Services. We collect your Personal Data for monitoring purposes to help us
diagnose problems with our servers, administer and troubleshoot the Services, calculate
usage levels, analyze industry standards, and analyze transactions, trends, and statistics
regarding the use of the Services. [CONSENT; LEGITIMATE INTEREST]
Respond to Inquiries and Fulfill Requests. We may use your Personal Data to respond to
your inquiries and to fulfill your requests for information. [CONSENT]
Create and Maintain User Account. We use your Personal Data to create and maintain an
account for you to engage in and use the Services we make available. [CONSENT;
LEGITIMATE INTEREST]
Communicate with You About the Services. We may use your Personal Data to send you
marketing information about new products or services and other items that may be of interest
to you. We may also contact you on behalf of our third-party business partners about a
particular offering of theirs that may be of interest to you. [CONSENT; LEGITIMATE
INTEREST]
Improve the Services. We may use your information to make the Services more stable and
user-friendly, to analyze service issues, improve the design and consent of the Services,
personalize your experience, analyze how the Services are used, offer new products and
services, and to develop new marketing programs relating to the Services. [CONSENT;
LEGITIMATE INTEREST]
Send Administrative Emails. We may use your Personal Data to send you email and text
messages to: (a) confirm your account and your other Personal Data, (b) process
transactions that you make using the Services, (c) provide you with information regarding the
Services, or (d) inform you of changes to this Privacy Policy, our Terms of Use, or our other
policies. [CONSENT; CONTRACT]
Support Business Operations. We may use your Personal Data to support our internal and
business operations, including marketing, security, and advertising. [CONSENT;
LEGITIMATE INTEREST]
Enforce Agreements. We may use your Personal Data to enforce separate agreements
between you and us, enforce this Privacy Policy, our Terms of Use, or our third-party
partner’s Terms of Use, or in connection with a transaction with a similar effect. [CONSENT;
CONTRACT]
Fulfill Other Purposes. We may use your Personal Data to fulfill: (a) any other purpose for
which you provide it; (b) any legal or regulatory requirements and any of our internal policies;
(c) other purposes disclosed at the time of collection; (d) any other purpose with your
consent; and (e) any other purposes set forth in this Privacy Policy. [CONSENT;
LEGITIMATE INTEREST]
For Personal Data processed based only on your consent, you have the right to withdraw your
consent at any time, subject to legal exceptions.
DISCLOSURE OF PERSONAL DATA
Except as otherwise described in this Privacy Policy, we will not sell, share, rent, or otherwise
disclose your Personal Data that we collect from the Services to any third party for monetary or other
valuable consideration, unless stated below or with your consent:
Service Providers & Contractors. To help us provide superior service, your Personal Data
may be shared with our service providers, contractors, and other third parties we use to
support our business and who will safeguard it in accordance with this Privacy Policy. Such
third parties may help us process payment information, identity verification, provide certain
discounts to Users, or provide customer service. These third parties are bound by
contractual obligations to keep your Personal Data confidential and use it only for the
purposes for which we disclose it to them. Without such information being made available, it
would be difficult for you to purchase and use the Services, receive discounts from our third-
party partners, provide us feedback to improve the Services, or access certain services,
offers, and content on the Services.
o Stripe. We use Stripe to conduct sales on our website. You can read more about
how Stripe uses your Personal Data here: Privacy Policy (stripe.com).
Credit Agencies. We may share your Personal Data with credit agencies to conduct
background checks and provide credit reports. The results of which will be shared with the
requesting User for approval purposes. We will not store (except than on a temporary basis)
or use this information for any other purpose.
Authorized Representatives. If another individual is managing your account with us which
the Services connect to on your behalf (for example, an employee managing an account on
behalf of their manager), as authorized by you or as a personal representative under
applicable law, that person can view all Personal Data about you on the Services.
In the Event of Merger, Sale, Divestitures, or Change of Control. CGVI reserves the right
to transfer Personal Data to a buyer or other successor in interest that acquires rights to that
information as a result of a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of CGVI or substantially all of its assets, whether as a going concern or
as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us
about you is among the assets transferred.
With Your Consent. We may share your data for other purposes pursuant to your consent
or at your direction.
Other Disclosures. We may disclose your Personal Data if we have a good faith belief that
disclosure of such information is helpful or reasonably necessary to: (i) conform to legal
requirements and comply with any court order, law, or legal process, including responding to
any government, law enforcement, or regulatory request; (ii) enforce the CGVI Terms of Use,
terms of our business partners, or other agreements, including between you and us, and any
other documents included or referenced therein (all of which are incorporated into and made
a part of this Privacy Policy by reference); (iii) fulfill the purpose for which you provide it; (iv)
detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to
our, your, or third parties’ rights, property, or safety.
Other than as set out above, you will receive notice when Personal Data about you might go to third
parties, and you will have an opportunity to choose not to share the information.
CHOICES
Our ability to provide you with the Services through the App depends on the Personal Data and
other information you provide to us through the App. Please understand that if you choose not to
disclose data to us, it may affect your ability to use some features of the Services. You must
discontinue use of the App and our Service if you choose not to disclose the Personal Data.
THIRD PARTY LINKS AND WEBSITES
The App may contain links to third-party services, websites, mobile applications, and/or contain
advertisements from third parties that are not affiliates with us – and which may link to other
websites, services, or applications. While we endeavor to work with third parties that share our
respect for user privacy, we are not responsible for the privacy policies or privacy practices of such
third parties. Any data collected by third parties are not covered by this Privacy Policy. You are
responsible for knowing when you are leaving the App to visit a third-party website, service, or
application and for reading and understanding the terms of use and privacy policy statements for
each such third party. This Privacy Policy only governs data collected through the Services.
Social Networks. We maintain a presence on social media and other external platforms,
such as Facebook, Instagram, LinkedIn and X (Twitter). We may occasionally incorporate
third party social networking features into the Services. This Privacy Policy applies to our
use of information you submit to us there, but it does not apply to what those third-party
platforms do with your information.
The Services may allow you to share information with us that you have already provided to a
third-party social networking platform. For example, you may be able to create an account on
the Services or log in to the Services using your Facebook account or other third-party
credentials. If you do so, Personal Information or other data that you have provided to the
third party may be made available to us by that third party subject to its own privacy policy,
terms, and conditions. Privacy policies of social networks and other external platforms
explain how those third parties use, protect, and share your information, including any
information you share on those platforms from the Services, and we encourage you to read
them. The information we receive from these platforms may depend on your privacy settings.
We may also include tools in the Services that allow you to share or publicly post content
from the Services to your profile on a third-party social network. You may choose to share
information about your activities on the Services with such third-party platforms and its users,
including publishing your information about what content you may have viewed on the
Services. If you visit the Services while logged into certain social media platforms, the social
media platform may be able to identify your browser and associate the technical information
provided by your web browser with other information that they have already collected about
you, which may result in their ability to identify you. In addition, when you choose to share
information about your activities on the Services with certain social media platforms, CGVI
may send technical information about you to that platform as well as information about what
content you are viewing.
INTERNATIONAL TRANSFER OF PERSONAL DATA
The Services and data we receive from other sources are hosted in the United States and governed
by United States law. Your Personal Data may be transferred to, and maintained on, computers
located outside of your state, province/territory, or country where the privacy laws may not be as
protective as those where you live. If you are using the Services from outside of the United States
and choose to provide your Personal Data to us, you understand that your Personal Data will be
transferred and processed in the United States. As a result, this Personal Data may be subject to
access requests from governments, courts, law enforcement officials and national security
authorities in the United States according to its laws. Subject to the applicable laws, we will use
reasonable efforts to ensure that appropriate protections are in place to maintain protections on the
Personal Data. By consenting to this Privacy Policy and using the Services or otherwise providing
information to us, you consent to the processing, transfer and storage of your Personal Data to the
United States.
UNITED STATES AND INTERNATIONAL CONSUMER RIGHTS
You may object to Personal Information processed pursuant to our legitimate interest. In such case,
we will no longer process your Personal Information unless we can demonstrate appropriate,
overriding legitimate grounds for the processing or if needed for the establishment, exercise, or
defense of legal claims. You may also object at any time to processing of your Personal Information
for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by
submitting your request to info@CGVI.co with the subject line “GDPR Notice” (the latter for
instances where, for example, you would not like to receive follow-ups from our sales team). In such
case, your Personal Information will no longer be used for that purpose.
California Civil Code Section 1798.83 Pursuant to Section 1798.83 of the California Civil
Code, residents of California have the right to obtain certain information about the types of
personal information that companies with whom they have an established business
relationship (and that are not otherwise exempt) have shared with third parties for direct
marketing purposes during the preceding calendar year, including the names and addresses
of those third parties, and examples of the types of services or products marketed by those
third parties. If you wish to submit a request pursuant to Section 1798.83, please contact
CGVI via email at info@CGVI.co.
Additional U.S. Laws. Additionally, there are other state privacy laws such as the Colorado
Privacy Act; the Connecticut Data Privacy Act; the Delaware Personal Data Privacy Act; the
Indiana Consumer Data Protection Act; the Iowa Consumer Data Protection Act; the
Kentucky Consumer Data Protection Act; the Maryland Online Data Privacy Act; the
Minnesota Consumer Data Privacy Act; the Montana Consumer Data Privacy Act; the
Nebraska Data Privacy Act ; the New Hampshire Expectation of Privacy Act; New Jersey
(SB 332); the Oregon Consumer Privacy Act; the Tennessee Information Protection Act; the
Texas Data Privacy and Security Act; the Utah Consumer Privacy Act; the Virginia
Consumer Data Protection Act; and other state privacy laws as may be enacted upon their
effective dates. Due to the current number of users of CGVI, we may not be subject to these
privacy laws. However, customers from these states may reference the above sections of
this Privacy Policy for transparency regarding the information we collect and our practices
related to such information. Additionally, customers may request further information relating
access, deletion, correction, or limitation of our use of their Personal Information by
contacting us as directed in the Contact Us section below.
EEA and UK Privacy Rights. In countries within the EEA, and in the UK, you have the
right, in certain circumstances, to (i) require us delete your Personal Information, (ii) require
us to restrict processing of your Personal Information (for example, if you contest the
accuracy of that information), (iii) receive a copy of the Personal Information you provided to
us in a structured, commonly used, and machine-readable format and/or instruct us to
transmit that data to a third party; and (iv) object to our continued processing of your
Personal Information, for direct marketing (including profiling) or other purposes. You can
exercise these rights free of charge by contacting us using the details in the “Contact us”
section below.
ANONYMOUS AND AGGREGATE INFORMATION
We may use data capture, analysis, and similar tools to extract, compile, synthesize and analyze
non-Personal Data collected via your access and use of the Services (“Anonymous Data”). We
may further aggregate and combine your de-identified Anonymous Data (such as age, gender, race,
religion, marital status, net worth, household income, the type of browser you are using, device type,
the operating system you are using, and the domain name of your Internet service provider) with the
Anonymous Data of others (“Aggregated Data”). To the extent that we collect any Anonymous Data
or Aggregated Data, we shall own such Anonymous Data or Aggregated Data and may use it for any
lawful business purpose without a duty to account for such use to you, provided that Anonymous
Data is used only in an aggregated form, without specifically identifying the source of the
Anonymous Data. Without assuming any obligations or liabilities of yours, we agree to use
commercially reasonable efforts to comply with applicable laws and regulations respecting the
dissemination and use such Anonymous Data or Aggregated Data.
We may share de-identified and/or aggregate analytics with third-party partners about how you
interact with the Site and Services, including usage patterns for certain programs, content, services,
advertisements, promotions, and/or functionality available through the Site and Services.
THIRD PARTY WEBSITES
The Services may provide links to certain third-party websites, online services, mobile applications
and/or contain advertisement from third parties that are not affiliated with us – and which may link to
other website, services or applications. Please check the privacy policies and practices of those
other third-party websites to learn how they collect, use, store and share information that you may
submit to them or that they collect. We do not make any guarantee regarding those third-party
website, services, or applications, and we are not liable for any loss or damage caused by the use of
such websites. Any data collected by third parties is not covered by this Privacy Policy. This Privacy
Policy only governs information collected on the Site or through the Services
CONFIDENTIALITY & SECURITY
After receiving your Personal Data, we will store it on our systems for future use. We have adequate
physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized
access, maintain data security, and correctly use the information we collect. Unfortunately, no data
transmission or data storage solution can ever be completely secure. As a result, although we take
industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or
warrant the security of any information you transmit to or receive from us or that we store on our or
our Service Providers' systems.
RETENTION OF PERSONAL DATA
CGVI will retain your Personal Data for as long as reasonably required to fulfil the purpose(s) for
which it was collected, comply with applicable laws, and for any legitimate and essential business
purpose. When Personal Data is no longer needed or legally required, it will be permanently deleted
or de-identified so that it can no longer be associated with a specific individual. We and our Service
Providers will also delete your account information and Personal Data when you delete your
account. Personal Data may remain in backups for a reasonable period of time), or as legally
required. Otherwise, we store your Personal Data until you request us to remove it from our
servers. We store our logs and other technical records indefinitely.
CHILDREN
CGVI provides services to businesses and is not directed to individuals under the age of 18.We do
not knowingly collect any information from any minors, and we comply with all applicable privacy
laws or rules for collecting Personal Data from minors. In the event that we discover that a person
under the age of 18 has provided Personal Data to us without parental consent, we will make efforts
to delete the person’s information. If you have concerns about this, wish to find out if your child has
accessed the Services, or wish to remove your child's Personal Data from our servers, please
contact us as specified in the Contact Information section below.
CONTACT INFORMATION
If you have any questions or concerns about this Privacy Policy or our privacy practices, or would
like to submit a consumer request please contact us using any of the below methods:
Cambridge Global Ventures, Inc.
2401 Aurora Lane
Denton, TX 76207
info@CGVI.co
Copyright Cambridge Global Ventures, Inc. All rights reserved. The Services are protected by
United States and international copyright, trademark, and other applicable laws. This includes the
content, appearance, and design of the Services, as well as the trademarks, product names,
graphics, logos, service names, slogans, colors, and designs.