Last modified: March 21, 2024

Scott's Cheap Flights, Inc. DBA Going (collectively, “Going”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal information that may be collected. This privacy policy and notice (“Notice”) describes how we collect, use, and share your personal information when you use https://going.com/, and any other Going website or client portal (collectively, the “Websites”), any Going mobile or desktop apps (the “Apps”), and any content, functionality, technology solutions and services offered on or through the Websites or Apps, including the free and paid subscription services (“Services”), and the purchase of products or goods (the “Goods”) and gift cards available through the Websites or Apps, as well as your choices in connection with such use.  The Websites, Apps and Services are collectively referred to as the “Going Platform.” 

INFORMATION THAT WE COLLECT 

Through your use of the Going Platform we may collect personal information, which is information that identifies you as an individual, relates to you as an identifiable individual, or that, along with other information, could identify you. We collect the following types of personal information:

Information you provide to us:

We collect personal information from you when you use the Going Platform. We do not require you to provide any personal information in order to navigate the Going Platform. We collect information from you when you:

Sign up: In order to use the Going Platform, you would need to provide account information, including contact information, such as your email address, password, and your airport preferences. We need this information in order to provide you with the Going Platform. If you do not provide this information, we would not be able to provide the Going Platform to you.

Paid Services and Goods:  If you sign up for our Services we will additionally need your payment information. For memberships purchased on our website, we use Stripe, a third-party provider, to process credit card information and only retain the last four digits of the credit card. All of this information is collected by Stripe directly, and we do not collect or store it. If you have questions about how Stripe protects such information, please read Stripe’s services agreement and privacy policy. For memberships purchased on our mobile application, we use RevenueCat, a third-party provider, to process credit card information and don’t retain any credit card information.  If you have questions about how RevenueCat protects such information, please read their privacy policy. We need this information in order to provide you with the Going Platform. If you do not provide this information, we would not be able to provide access to the Going Platform to you.

Interact with the Going Platform: When you participate in a sweepstakes or contest or any other promotion, post a product review, engage with us on our various social media platforms, participate in one of our surveys, or send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, you provide us with personal information such as your name, email address, social media username and IP address.

Information provided through feedback, surveys, suggestions, etc., except the specific information that identifies you, is considered non-confidential and non-proprietary. We may use and share such information on an anonymous and aggregated basis with third parties.  

Information we get from third parties:

If your employer signs up for the Going for Teams employee perk services, your employer may provide your email address and other contact information.

Information collected automatically:

We may automatically collect the following types of information as you use the Going Platform:

  • Usage Information: which pages on the Going Platform you access, the frequency of access, what you click on while on the Going Platform and when you accessed the website.
  • Location Information: information about your location, which may be determined through your IP address, GPS and other sensors that may reveal information on nearby devices, Wi-Fi access points, and cell towers.
  • Device Information: information about the device you are using, such as hardware model, operating system, application version number, browser, and IP addresses.
  • Mobile Device Information: mobile network information, such as the unique device identifier assigned to that device, mobile carrier, operating system, telephone number, and other device attributes.
  • Social Media Widgets: The Going Platform includes social media features, such as the Facebook “Like” button, and other widgets, such as the “Share” button or interactive mini-programs provided by third parties. These third parties collect information about you when you use the Going Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. You can control your interactions with these widgets through the relevant social media network.
  • Google Analytics:  We use a tool called “Google Analytics” to collect some information we listed above about your use of the Going Platform. We use the information we get from Google Analytics to improve the Going Platform.  In order to collect this information, Google Analytics may set cookies on your browser or mobile device or read cookies that are already there.  See “Cookies" and Other Tracking Technologies.” Google Analytics may also receive information about you from apps you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to the Going Platform to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here https://tools.google.com/dlpage/gaoptout/.
  • Braze:  We use an email and push notification platform called “Braze” to track your interactions on the Going Platform, such as link clicks, email opens, push notification clicks, push notifications, etc. and stores this information on your user profile.  To learn more about Braze and how it stores this data, please view Braze’s privacy policy here: https://www.braze.com/company/legal/privacy.
  • PostHog: We use PostHog to collect anonymized data on user interactions and device information to improve our Website and Services. This includes tracking pages visited, actions taken on our site, and understanding device types for optimization purposes. The data helps us enhance user experience, identify technical issues, and guide feature development. To learn more about PostHog and how it stores this data, please view Posthog’s privacy policy here: https://posthog.com/privacy
  • AppsFlyer: We utilize AppsFlyer for mobile attribution, enabling us to understand how users discover our App. This tool helps us track the effectiveness of our marketing campaigns by attributing App installs to specific sources. Data collected is used exclusively for analyzing campaign performance and improving marketing strategies. To learn more about Appsflyer and how it stores this data, please view AppsFlyer’s privacy policy here: https://www.appsflyer.com/legal/privacy-policy/.  

“Cookies” and Other Tracking Technologies

“Cookies” are small pieces of information that are stored by your web browser software on your computer’s hard drive or temporarily in your computer’s memory, or on your mobile phone or other device when you visit a website. We or our third-party providers place and store Internet cookies on your hard drive or device. Cookies can save any of the types of information noted above. Cookies enable us to personalize your viewing experience. When you revisit the Going Platform, we can recognize you by the cookie and customize your experience accordingly. For example, we use cookies to recognize your access privileges to the Websites, track Website usage and traffic patterns, identify you and keep track of your preferences, prevent fraudulent activity or improve website security, assess the performance of the Websites, add advertisements for goods or services of interest, and estimate the Websites’ audience size.  

You can find out more about the cookies we use from each of the categories below.

Category: Strictly Necessary
Purpose: Security
Description: Some cookies help us detect, prevent, and mitigate malicious and fraudulent activities on the Going Platform. Security cookies also support and enable other security features.

Category: Functional
Purpose: Analytics and Research
Description: We use some cookies to collect information about how people are using the Going Platform. For example, these cookies allow us to know which pages are visited the most often, our site’s page load times and page response times. Overall, these cookies provide us with analytical information about how the Going Platform is performing and how we can improve them.

Category: Functional
Purpose: Preferences and Settings
Description: Your preferences may be stored in our cookies so you do not have to reset them every time you visit the Going Platform. These cookies allow us to remember the choices you make to tailor this website and provide enhanced features and content to you. For example, these cookies can be used to remember your user name and region information.

Category: Functional
Purpose: Social Media Plugins
Description: In order to enhance your internet experience and to make the sharing of content easier, some of the pages on the Going Platform contain tools or applications that are linked to third party social media service providers such as Facebook, Twitter, LinkedIn, or Google. Through these tools or applications the social media service provider may set its own cookies on your device. We do not control these cookies and you should check the social media service provider’s website for further details about how they use cookies.

Category: Advertising
Purpose: Advertising
Description: These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information may be shared with other organizations such as advertisers. This means after you are done using the Going Platform you may see some advertisements about the Going Platform elsewhere on the Internet.

Emails we send contain a bit of code known as a “web beacon.” This code allows us to understand the time and date when you have opened an email. If you wish to disable our web beacons, you should do so by turning images “off” in your email client (e.g., Outlook, Gmail). Please see your email client for more information.

To learn how you can control information collected about you using cookies and other technologies see ”CHOICES ABOUT YOUR INFORMATION.”

HOW WE USE THE INFORMATION

We use your personal information to provide the Going Platform to you, to improve our Going Platform, and to protect our legal rights. We limit the collection of personal information to that which is relevant for these purposes. We will not store, access, transmit, retain or otherwise use personal information in any way that is incompatible with the purposes for which it has been collected or stored as described in this Notice without your consent. We use the personal information we collect in the following ways:

We process your information for the following purposes as necessary to provide the Going Platform to you and perform our contract with you:

  • Facilitate your purchase: to facilitate your purchase of premium Services or Goods.
  • Communicate with you: to communicate with you about the Going Platform (including the notifications that are part of the Going Platform), to send you account updates or other communications regarding your account or to inform you of any changes to the Going Platform.
  • Provide Customer Support: to provide you support or other services you request. For example, we may need your information in order to provide technical support or answer questions about the Going Platform.

We process your information for the following purposes as part of our legitimate interest in the improvement and marketing of the Going Platform, and in the security of the Going Platform. We apply appropriate safeguards to protect your information including as described in this Notice:

  • Communicate about new features: We send you notifications about new features or information available on the Going Platform or that we feel might be of interest to you. You can opt-out by emailing us at [email protected] or clicking the Unsubscribe link in the email notifications you receive.
  • Promotions and giveaways: We send you emails about special promotions or giveaways that we feel might be of interest to you. You can opt-out by emailing us at [email protected] or clicking the Unsubscribe link in the email notifications you receive.  
  • To maintain and improve the Going Platform: We analyze how our users interact with the Going Platform in order to maintain and improve the Going Platform. We also use information that we collect to diagnose any problems with the Going Platform.
  • Benchmarking: We aggregate your information in order to gain insights into the Going Platform. For example, to calculate the percentage of users in a particular city or country.
  • To create audience lists: We process and use your email information to create custom audience lists for our targeted marketing purposes on advertising platforms such as Facebook, Instagram, Twitter, Google, Bing and Pinterest, or to create lookalike audiences to target with marketing and advertising materials.

In our processing of your information, we also share your personal information to defend our rights and the rights of others, to efficiently maintain our business, and to comply with the law as described in ’HOW WE SHARE INFORMATION’ below. 

HOW WE SHARE INFORMATION

We share your information with our service providers, among our entities, in connection with a corporate restructuring, to prevent harm, to comply with the law, for marketing and advertising purposes, and to protect our legal rights. The legal basis for this is our legitimate interest in providing the  Going Platform, complying with the law, and protecting our rights and those of others. We apply appropriate safeguards for this sharing of your information including as described below in this Notice.

  • Service Providers: We share information with service providers that help us perform Going Platform functions and process your transactions.
  1. We use Google Analytics to conduct data analytics on usage of the Going Platform.
  2. We use Braze to track your interactions on our site, such as link clicks, email opens, push notification clicks, push notifications, etc., and stores this information on your user profile. PostHog: We use PostHog to collect anonymized data on user interactions and device information to improve our Website and Services. This includes tracking pages visited, actions taken on our site, and understanding device types for optimization purposes. The data helps us enhance user experience, identify technical issues, and guide feature development. 
  • AppsFlyer: We utilize AppsFlyer for mobile attribution, enabling us to understand how users discover our App. This tool helps us track the effectiveness of our marketing campaigns by attributing App installs to specific sources. Data collected is used exclusively for analyzing campaign performance and improving marketing strategies. 
  • Corporate Structure: We would share information if we are involved or intend to be involved in a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or in connection with bankruptcy or liquidation proceedings.
  • To Prevent Harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
  • To Protect Our Rights and As Required by Law: We will share information where we are legally required to do so, such as in response to court orders or legal process, to exercise our legal rights, to defend against legal claims or demands, or to comply with the requirements of any mandatory applicable law. We will also share information as necessary to enforce the terms of this Notice, the Going Platform Terms of Use and Service (https://going.com/terms-of-use), and any other terms that you have agreed to, including to protect the rights, property, or safety of Going, its users, or any other person, or the copyright-protected content of the Going Platform.
  • Marketing and Advertising of the Going Platform: We will share your email information with major advertising platform providers such as Facebook, Instagram, Twitter, Google, Bing, and Pinterest, to create custom audiences that may be used by us to engage in targeted marketing. On Facebook, the process works as follows. Other sites are similar. Our customer list is hashed locally on our browser and then sent to Facebook. There, it is matched against Facebook’s existing list of Facebook’s users’ hashed IDs and the matches are added to Going Custom Audience. Hashing turns the data in Going's customer list into short fingerprints that can’t be reversed. It happens before the data is sent to Facebook. After the Custom Audience is created by Facebook, the matched and unmatched hashes are deleted.

With Your Consent: We will request your permission to use or share your personal information for a specific purpose that is not compatible with the purposes listed in the Privacy Policy. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. With your consent, we may also share your quotes and reviews on the Going Platform for promotional purposes. If we rely on your consent to use or share your information, your consent may be revoked at any time by contacting us at [email protected].

SECURITY

The security of your personal information is important to us. We maintain reasonable physical, technical, and administrative security measures to protect and limit access to your personal information. No method of transmission over the Internet or electronic storage technology, however, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

CHOICES ABOUT YOUR INFORMATION

Access, correct or delete your information: You may use your account to access or correct the information you provided to us and which is associated with your account by logging into your account on the Going Platform at https://app.going.com/login. You can also request this, as well as request deletion of your information, by writing us at [email protected].  Even if you terminate your account, keep in mind that deletion of your personal information by our third-party providers may not be immediate and that deleted personal information may persist in backup copies for a reasonable period of time and as required by applicable laws and regulations. See: ’HOW LONG DO WE KEEP YOUR INFORMATION.

In the event that we refuse a request under rights of access, we will provide the individual with a reason as to why. Individuals residing in the states in countries identified below may have additional rights.

Advertising cookies: To opt out of interest-based advertising or to learn more about the use of this information by our service providers you can visit the Network Advertising Initiative website (http://www.networkadvertising.org/managing/opt_out.asp) or the Digital Advertising Alliance website (http://www.aboutads.info/choices/), or if you are in the EU, the EDAA (http://www.youronlinechoices.eu/). If you choose to opt out, we will place an “opt-out cookie” on your computer or device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for some cookies that are important to how the Going Platform works (“essential cookies”). If the cookie is removed or deleted, if you upgrade your browser, or if you visit us from a different computer or device, you will need to return to the applicable website to re-select your preferences.

Cookies: If you would like to opt out of accepting cookies altogether, you can generally set your browser to not accept cookies or to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. Please note that certain functions of the Going Platform may not function properly if your web browser does not accept cookies. If you choose to opt out, we will place an “opt-out cookie” on your computer or device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for some cookies that are important to how the Going Platform works (“essential cookies”). If the cookie is removed or deleted, if you upgrade your browser, or if you visit us from a different computer, you will need to return and update your preferences.

Google Analytics:  See http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here: https://tools.google.com/dlpage/gaoptout

Promotional emails: To unsubscribe from promotional emails please click the unsubscribe link included in the footer of all of promotional emails or log in to update your Notification Settings. By unsubscribing, you will be removed from our promotional email list and you will no longer receive any communications from us, including emails pertaining to the Going Platform.

Email tracking: To disable our web beacons you may turn images “off” in your email client (e.g., Outlook, Gmail).

Advertising platforms: To edit your information and ad preferences on major marketing platforms, you will need to visit each platform. The following is a list of locations where this can be done:

Facebook/Instagram:

Twitter:

Pinterest:

Google:

Bing:

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law may permit Users who are California residents to request and obtain from Going, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below. The California Code of Regulations defines a “residents” as:

  • every individual who is in the State of California for other than a temporary or transitory purpose and
  • every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

Your rights with respect to your personal data

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information we collected about you.

In accordance with applicable law, Going is not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

We will not discriminate against you if you exercise your privacy rights. 

We do not process consumer's sensitive personal information. 

Verification process. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights. 

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

You can opt out from the selling or sharing of your personal information as otherwise set forth in the Privacy Policy or on the Going Platform.

To exercise these rights, you can contact us by submitting a data subject access request, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

RIGHTS OF COLORADO RESIDENTS

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you may have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • Right to be informed whether or not we are processing your personal data.
  • Right to access your personal data.
  • Right to correct inaccuracies in your personal data.
  • Right to request deletion of your personal data.
  • Right to obtain a copy of the personal data you previously shared with us.
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

We may sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email [email protected] or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

RIGHTS OF CONNECTICUT RESIDENTS

This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), you may have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • Right to be informed whether or not we are processing your personal data.
  • Right to access your personal data.
  • Right to correct inaccuracies in your personal data.
  • Right to request deletion of your personal data.
  • Right to obtain a copy of the personal data you previously shared with us.
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

We may sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email [email protected] or submit a data subject access request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

RIGHTS OF UTAH RESIDENTS

This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you may have the rights listed below. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • Right to be informed whether or not we are processing your personal data.
  • Right to access your personal data.
  • Right to request deletion of your personal data.
  • Right to obtain a copy of the personal data you previously shared with us.
  • Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data.

We may sell personal data to third parties or process personal data for targeted advertising. You can opt out from the selling of your personal data or targeted advertising by disabling cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email [email protected] or submit a data subject access request.

RIGHTS OF VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act (VCDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition of “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data. Your rights with respect to your personal data.

  • Right to be informed whether or not we are processing your personal data.
  • Right to access your personal data.
  • Right to correct inaccuracies in your personal data.
  • Right to request deletion of your personal data.
  • Right to obtain a copy of the personal data you previously shared with us.
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

We sell personal data to third parties or process personal data for targeted advertising. Please see the following section to find out how you can opt out from further selling or sharing of your personal data for targeted advertising or profiling purposes.

Exercise your rights provided under the Virginia VCDPA

You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies as set forth in this Privacy Policy. To submit a request to exercise any of the other rights described above, please email [email protected] or submit a data subject access request.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

RIGHTS OF RESIDENTS IN THE EUROPEAN UNION (EU), UK

If you use the Going Platform and reside in the EU or UK, you are entitled by law to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below. Please note that these rights are not absolute and certain exemptions apply. To exercise these rights please contact Going at support.  For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. In the event that we refuse a request under rights of access, we will provide you a reason as to why. 

  • The right to access: You have the right to ask Going for copies of your personal information. This right has some exemptions, which means you may not always receive all the information we process. When making a request, please provide an accurate description of the data you want access to.
  • The right to rectification: You have the right to ask Going to rectify information you think is inaccurate. You also have the right to ask Going to complete information you think is incomplete.
  • The right to erasure: You have the right to ask Going to erase your personal information in certain circumstances, including (i) when your personal information is no longer necessary for the purposes for which it was collected or processed or (ii) your information must be erased to comply with a legal obligation in EU Union or Member State law.
  • The right to restrict processing: You have the right to ask Going to restrict the processing of your information in certain circumstances, including (i) when the accuracy of the information is brought into question or (ii) when we no longer need the information for purposes of the processing, but you require such information for the establishment, exercise, or defense of a legal claim. See “choices about your information” for some ways you can restrict processing.
  • The right to object to processing: You have the right to object to processing if we are able to process your information because the process is in Going’s legitimate interests. See “choices about your information” for some ways you can object to processing.
  • The right to data portability: This only applies to information you have given Going. You have the right to ask that we transfer the information you gave Going from one organization to another or give it to you.
  • The right to lodge a complaint with the supervisory authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

RIGHTS OF CANADIAN RESIDENTS

If you are located in Canada, we may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.

For investigations and fraud detection and prevention.

For business transactions provided certain conditions are met.

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.

If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.

If the collection is solely for journalistic, artistic, or literary purposes.

If the information is publicly available and is specified by the regulations.

HOW LONG DO WE KEEP YOUR INFORMATION

We will retain your personal information until the later of (i) the information is no longer necessary to accomplish the purpose for which it was provided, (ii) there is no ongoing business reason to keep the information, or (iii) until you request that your account be deleted.

We retain your information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. More specifically, we would retain some data for longer periods of time for the following reasons:

  • Security, fraud & abuse prevention: i.e. To protect you, other people, and us from fraud, abuse, and unauthorized access.
  • Financial record-keeping: When you make a payment to us we are often required to retain this information for long period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations.
  • Complying with legal or regulatory requirements: To meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
  • Direct communications with us: If you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.

Even if you delete your account, keep in mind that the deletion by our third-party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. For any privacy or data-protection-related questions, please write to [email protected].

CHILDREN’S PRIVACY

The Going Platform is not intended for use by children. We do not knowingly collect personal information from children under the age of 16 years. If we become aware that a child under 16 has provided us with personal information, we take steps to delete such personal information without undue delay. California users under the age of 18 may request the removal of their content or information publicly posted on the website by emailing us at the appropriate email address identified below.

LINKS TO OTHER WEBSITES

The Going Platform may contain advertisements for or links to other websites, products, or services not operated or controlled by Going. The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

UPDATES TO THIS NOTICE

We may update or modify this Privacy Policy and Notice from time to time. We will post the changes to this page and will indicate the date they go into effect. We encourage you to review our Privacy Policy Notice on a regular basis to stay informed.  If we make changes that materially affect your privacy rights we will notify you of the changes by posting a prominent notice on our Websites or using other methods that we select, such as sending you an email.

“DO NOT TRACK”

The Going Platform is not currently configured to respond to Do Not Track signals sent by Internet browsers.

CONTACT US

Any questions or concerns about the interpretation or operation of this Privacy Policy and Notice or about what may or may not be done with regard to your information should be directed to:

Going

4845 Pearl East Circle, Suite 118

PMB 28648

Boulder, CO 80301-6112

[email protected]