Effective Date: May 15th, 2020
2. INFORMATION WE COLLECT
When using the Services, we collect and process Personal Information. “Personal Information” is information by which a person may be personally identified such as name, mailing address, email address, phone number, and other information which personally identifies a person, and in certain jurisdictions, information collected automatically such as device identifiers and IP addresses.
We also collect information that does not individually identify you and is generated automatically as a result of using the Services such as your internet connection, the device being used, IP address, device identifiers and other usage details (“Usage Information”). In certain jurisdictions, some Usage Information such as device identifiers and your IP address is considered Personal Information.
3. HOW WE COLLECT THIS INFORMATION
A. Through Information you Voluntarily Provide
When you choose to use the Services, we collect certain Personal Information. If you choose not to provide us with the Personal Information that we legitimately require to provide the Services, we may be unable to provide the services you have requested. The Personal Information we may collect through the Services includes:
- Name, address, email, username and password, telephone or mobile number when you create an account to access and use the Services.
- Required travel information for booking tickets: name, gender and birth date.
- Other travel information such as mailing or home address, email address, government issued identification or other identity verification, such as passport, government redress numbers, or known traveler number (TSA), frequent flier traveler number, and travel related preferences.
- Payment information, including credit card type, card number, expiry date, and card code or ACH information to process bookings.
- Billing details, including first and last name, country, street address, city, state, and zip code to process bookings.
- Personal information and data about other people, such as travelers for whom you are making a booking.
- Searches you conduct, transactions, and other interactions on the Services.
- When you contact us, either online (by email or through a chat function) or by phone, we may collect your first and last name, email address, telephone number, physical address, order number and any personal information you may provide.
- Your email address when you sign up to receive newsletters or other marketing communications.
- Automatically collected information about your internet connection, equipment, device, device identifiers, browsing and usage details, IP address, location via IP address and browsing history. See “Usage Information Collected Through Technology” below.
- We may collect other relevant data which may be deemed Personal Information under applicable law.
We may use other third party service providers (which are third parties who work on our behalf to provide and enhance the Services) to collect this information.
B. Usage Information Collected Through Technology
When using the Services, we automatically collect Usage Information about your equipment, browsing actions and patterns including:
- IP address.
- Internet service provider.
- Browser and device information, such as the type of device you are using, its operating system, and browser used.
- Device identifiers.
- Information about your browsing activities on the Services (pages you visit, features you use, date and time of your use, length of visit, browsing and search history)
- Referring URL or exit pages.
- General geolocation of your device via IP address.
- Mobile carrier.
- Aggregated de-identified data or analytics data that is non-personal, statistical information.
The information collected automatically helps us to understand, analyze and improve the Services, manage the Services, diagnose problems with the Services, and to deliver a better and more personalized service. The standard technologies we (or our service providers) use to automatically collect Usage Information includes:
- Server log files (IP Address). Our server logs automatically record certain usage and activity and information from the device that you are using such as your IP Address. Your IP address is a number that is automatically assigned to your computer by your internet service provider and may be identified and logged automatically in our server logs whenever a user of that device accesses the Services, along with the time of the visit and the pages visited. We use IP addresses to administer the Services, track users’ movements, determine use levels, analyze trends, diagnose server problems and gather broad demographic information for aggregate use.
- Through your browser or device. When you access the Services, certain information is collected by the browser you are using or automatically through the device you are using, such as the type of device you are using, its operating system, and the browser the device is using.
- Location Information. We also collect general information about the location of the device from which our Services are accessed (e.g., approximate geographic location inferred from an IP address) to provide better Services.
Through Cookies (or browser cookies). A cookie is a small text file
that a website or email may send to your browser to uniquely identify it and which is generally stored by your computer
can send its own cookies to your browser and most browsers are set up to initially accept cookies.
Using cookies allows us or our service providers to collect information about how many people have
visited the Services, the time spent on the Services, what pages were viewed, and other usage or
traffic data. We use this information to better serve all of our online visitors and improve the
content and design of the Services. Examples of cookies used on the Services:
- Session Cookies to operate the Services
- Preference Cookies to remember your preferences and various settings
- Security Cookies for security purposes
- Analytics Cookies for statistical aggregated information on how the Services are used
- Through Web Beacons/Pixel Tags. Pages of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us or our service providers, to count users who have visited those pages, or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
For information on how you may be able to control these tracking technologies, see “Your Rights and Choices” below.
C. Information from other Sources
We may obtain Personal Information about you when we receive it from third parties such as registered account holders who use the Services to book travel on your behalf. We may also receive Personal Information from third parties who provide services to our business or through public sources.
4. HOW WE USE YOUR INFORMATION
We use Personal Information and Usage Information collected through the Services to carry out our obligations between you and us and for the legitimate interests of our business, including:
- To create, maintain and update registered accounts.
- To carry out our obligations to book requested travel.
- To provide information and services requested from us.
- To process and respond to inquiries.
- To process payment transactions.
- To provide travel booking confirmations and updates.
- To maintain search and travel history.
- To provide newsletters and email marketing information unless you have opted not to receive such information through the unsubscribe instructions in the email we send.
- To provide notifications about changes to the Services and our policies.
- To monitor the usage of the Services.
- To gather analytics related to the Services usage and help us better understand our users interests and needs, measure and analyze the effectiveness of any email marketing campaigns, and improve the Services.
- To detect, prevent and address technical or security issues and protect our users and visitors of the Services and to protect our business.
- For the purposes for which it was provided.
- As described when collecting your personal information.
- To share and disclose information as described below.
Aggregate/De-Identified Data. We may aggregate and/or de-identify information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers and/or others. By using the Services you consent to such use.
5. HOW WE DISCLOSE AND SHARE YOUR INFORMATION
We may disclose or share Personal Information collected through the Services as set forth below. Please note a Services user may choose not share certain information as described in “Analytics Providers” below.
- To any of our affiliates in furtherance of our business who will be required to maintain that information consistent with this Policy.
- To third party service providers who received or process Personal Information we collect to perform functions that support our business and the Services, such as hosting the Services, our Global Distribution Systems (GDS) provider for booking reservations, email marketing, processing payments, online chat functions, customer services. These parties are required to protect the Personal Information we share with them and may not use such information other than to provide the contracted for services. We only provide these parties with the minimum amount of information necessary to complete the requested service, product or transaction.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us about the users of the Services is among the assets transferred.
- To fulfill the purpose for which you provide it.
- To comply with any court order, law, legal process or legal obligation, including responding to any government or regulatory request or subpoena.
- If we believe in good faith disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others, or to prevent or investigate possible wrongdoing in connection with the Services.
- For any purpose as to Aggregate/De-Identified Information.
- For analytics through third-party analytics tools to better understand who is using the Services and how people are using it (as described next).
You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout for your web browser.
We do not share or sell your Personal Information with unaffiliated third parties for their own direct marketing purposes. We currently do not engage in third party advertising or remarketing services (behavioral or targeted advertising services).
6. YOUR RIGHTS AND CHOICES
You have certain rights and choices with respect your Personal Information as follows:
- E-Mail Opt Out Rights. If you do not wish to have your email address used by us for our promotional or marketing purposes, you can opt-out at any time by clicking the unsubscribe link at the bottom of our email communication. You can also opt-out by sending us an email as set forth in “Contacting Us” below with your opt-out request. Even after you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing preferences. It may take up to 30 days to process your e-mail related requests. Please note that after you opt-out of receiving marketing communications from us, we may still contact you for transactional or informational related purposes, for example, as related to bookings or to answer questions you may submit to us.
- Limiting Web Beacons. In some cases, web beacons can generally be disabled by setting your browser to be in text mode only. There are also browser add-ons and extensions that specifically block web beacons. If you object to web beacons in emails, we recommend that you follow the instructions for disabling cookies above. We will still know how many of our emails are opened and we will automatically receive your IP address or other unique device identifier but we will not identify you as an individual.
- Limiting Analytics. Please see the information under the caption “Analytics Provider” above.
- Changing Your Account Information. To change your account information, you may log in to your account on the Services and change your name, email, phone number or password. Your administrator may also update this data and/or delete your account. If you are unable to log in to your account, please contact us as set forth in “Contacting Us” below.
- Closing Your Account. You may close your account by contacting us as set forth in “Contacting Us” below. If the email account associated with your email address is not active, we may close your account without notice.
7. LINKS TO OTHER SITES
We implement a variety of security measures to protect the safety of your personal information when you enter, submit, or access your personal information. Please keep your account password secure to help ensure the safety of your personal information.
While we take reasonable measures to protect the information you submit via the Services, we cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free.
We cannot guarantee that transmissions of your Personal Information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.
Any information collected through the Services is stored and processed in the United States. If you use the Services outside of the United States, you consent to have your data transferred to the United States.
9. DATA RETENTION POLICY
We will retain your information for as long as you use the Services and for a reasonable time thereafter. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information we have collected may be required for the Services to function properly.
10. DO NOT TRACK
Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on the Services.
You must be at least 18 years of age to use the Services. We do not knowingly collect personal information directly from children under 13. If we learn we have collected or received personal information directly from a child under 13, we will delete that information. If you believe we might have any information directly from a child under 13, please contact us as set forth in “Contacting Us” below.
12. CONTACTING US