Privacy Policy
1. Introduction
At Voya, we place a high value on privacy and strive to be transparent about our data collection and usage. This policy (“Policy”) explains how we—together with our affiliates and subsidiaries—collect, use, protect, and disclose your personal information when you use our website (“Site”), our blogs (“Blogs”), or any other service we offer (collectively referred to as “Services”). It also describes your rights regarding the information (“Personal Information”) we gather and how you can get in touch if you have any questions or concerns.
Your continued use of our Services signifies your acceptance of this Policy. If you have any questions, contact us at support@atvoya.com.
2. What Information We Collect
We collect different types of personal information depending on how you interact with our Services. Generally, the categories include:
Identifiers: This can include your real name, alias, postal address, unique personal identifier, IP address, email address, account credentials, national ID or Social Security number, driver’s license number, and passport number (or other similar identifiers).
Personal Information Categories: Examples here might include your name, signature, government-issued IDs (e.g., driver’s license), addresses, telephone numbers, insurance details, education and employment history, as well as certain financial information such as bank or credit card numbers.
Protected Classification Characteristics: Data relating to your age, race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, disability, gender identity/expression, sexual orientation, veteran status, or similar demographic details.
Commercial Information: This refers to purchasing or usage histories, including records of products or services you considered or actually purchased from us.
Biometric Information: We currently do not collect biometric data (e.g., fingerprints, retina scans, or other identifiable physical markers).
Internet/Similar Network Activity: This includes data about browsing history, clickstream information, session heatmaps, device details (like operating system, browser type, and screen resolution), the internet service provider used, referring/exit pages, and timestamps of visits.
Geo-Location Data: This involves data about your physical location or travel movements when using certain location-based features.
Sensory Data: We do not collect audio, visual, or similar sensory information (e.g., voice or video recordings) unless expressly stated.
Professional/Employment-Related Info: This may include your job history, performance evaluations, or work-related references.
Non-Public Education Information: We generally do not collect educational records (e.g., grades, transcripts) unless they are directly relevant to the Services and you have provided them voluntarily.
Inferences: We do not compile profiles of your preferences, characteristics, or other traits unless doing so is necessary for delivering specific Services you request.
Equipment Information: This covers details about your internet connection, the devices you use to access our Site, and related usage statistics.
3. How We Collect This Information
Through Your Use of Our Services
When you browse the Site, read our Blogs, or interact with our Services (for instance, making inquiries or bookings), we track sessions, usage, and associated data, often through cookies or comparable technologies.Information You Provide Voluntarily
We collect the data you give us when creating or managing an account, booking a property, submitting forms, or contacting us via phone or email.Information from Third Parties
We may also acquire information from external sources (e.g., payment processors, credit agencies). These third parties collect data to process payments or carry out background checks, and we receive the necessary data to fulfill your request.
Some information entered into our Services is processed by third-party providers on our behalf. For example, when you input credit or debit card details for a transaction, that data is often sent directly to a secure payment processor.
4. How We Use This Information
We use Personal Information to:
Provide Our Services: Manage bookings, process payments, issue invoices, and register new or existing users.
Communicate With You: Send important updates (e.g., technical notices, billing questions, or customer support).
Improve and Develop Services: Assess usage patterns, troubleshoot, and refine or create offerings.
Marketing and Promotions: Notify you about relevant offers, rewards, or events hosted by Voya or approved partners.
Audits and Compliance: Meet legal requirements and conduct internal assessments.
Fraud and Illegal Activity Prevention: Investigate and prevent unauthorized or unlawful actions that might harm Voya or our users.
Analyzing Trends: Observe how people interact with our Site and Blogs, identifying ways to serve users better.
Other Purposes: Fulfill any other purpose described to you at the time of collection or for which you explicitly consent.
We keep your Personal Information as long as it is needed to fulfill the reasons outlined above or comply with legal obligations.
5. How We Disclose Personal Information
Under certain circumstances, we may share your Personal Information:
Subsidiaries and Affiliates: We may share data with our corporate family, provided it is in line with this Policy.
Service Providers: Entities that aid with services like hosting, payment processing, analytics, or customer support.
Legal/Regulatory Compliance: When required by law or to comply with legal processes.
With Your Consent: Where you explicitly allow sharing with third parties (e.g., for special offers).
Aggregated or De-Identified Form: Data that does not identify specific individuals may be used for marketing or analytics.
Corporate Transactions: If we undergo a merger, sale, or other business reorganization involving the transfer of assets (including Personal Information).
Voya does not “sell” your Personal Information under the definitions of applicable consumer privacy laws.
6. Your Rights Over Personal Information
Depending on your jurisdiction, you may have rights such as:
Access: View the Personal Information we hold about you.
Data Portability: Obtain a machine-readable copy of specific data.
Rectification: Request corrections for inaccurate or incomplete data.
Erasure: In certain instances, ask us to delete your Personal Information.
Restriction: Limit how we use your Personal Information, in specific cases.
Objection: Contest particular data uses if no compelling legitimate grounds justify continued processing.
Before releasing any records, we may require you to confirm your identity. If you have concerns or wish to exercise your rights, contact us at support@atvoya.com. You are also entitled to lodge a complaint with a relevant supervisory authority if you deem our response insufficient.
7. Information Security and Incident Reporting
We apply suitable technical, administrative, and physical safeguards to prevent unauthorized access or misuse of your Personal Information. However, no system is entirely secure. If you identify a security vulnerability or suspect a breach, please notify us at support@atvoya.com.
8. Interest-Based Advertising
To provide relevant advertising, we or our third-party partners may gather details about your online activities across different websites or services. You can often choose to opt out of such data collection by visiting:
If you supplied your email address, we may use a hashed (encrypted) version of it for matching with advertising platforms. We do not read or store the content of your emails for ad-targeting purposes.
9. Communication from Voya
From time to time, we may send you promotional or marketing messages by email, text, or phone. If you wish to opt out, you can follow the unsubscribe link in our emails or let us know at support@atvoya.com. However, essential service or billing messages (e.g., account notices) are not subject to an opt-out process, as they are necessary to provide our Services.
10. Voya Job Applications
If you apply for a position with Voya, we collect the details you share (e.g., résumé, contact information) for recruitment. We may retain this data for a specified period (e.g., two years) to consider you for future roles. To request access, updates, or deletion of your application records, contact support@atvoya.com.
11. Opting Out of Collection by Third Parties
Certain third-party networks or advertisers might gather information through our Services. To learn more about limiting this or opting out, see Section 8 or consult:
12. Third-Party Links and Websites
Our Site or Blogs may include links to websites operated by third parties. We do not control and are not responsible for the data practices of such sites. Consult their respective privacy policies to understand how they handle your information.
13. Children’s Privacy
Our Services are intended for individuals aged 18 or older, unless explicitly noted otherwise. We do not knowingly collect data from minors under 18 without parental consent. Should you become aware that a child has provided personal data without authorization, please contact support@atvoya.com to have the information removed.
14. Visitors from Outside Luxembourg / Cross-Border Transfers
Our operations are based in Luxembourg. Depending on where you reside, we may transfer or store your data in other countries that have different data protection laws. By using our Services, you agree to such cross-border data transfers as detailed here.
15. Updates to This Policy
We reserve the right to modify this Policy as necessary—due to shifts in our business, legal changes, or technological developments. We encourage you to periodically review this document for updates. Where material changes occur, we will endeavor to notify you in advance or when they take effect.
16. How to Contact Us
If you have inquiries or feedback about this Privacy Policy or wish to exercise any of your rights, please get in touch:
Email: support@atvoya.com
Postal Address:
Upstream Living (Voya)
Boulevard Prince Henri 15
L-1724, Luxembourg
We will make every reasonable effort to respond promptly and in compliance with applicable laws.