Privacy Statement

Last Updated: January1, 2022

Travelwire, Inc . (“we” or “us”) values you as our customer and recognizes that privacy is important to you. This Privacy Statement explains how we collect, use, and disclose data when you use our platform and associated services and tells you how to contact us.

Privacy Statement Summary

1. What does this Privacy Statement cover?

This Privacy Statement is designed to describe:

• How and what type of personal information we collect and use
• When and with whom we share your personal information
• What choices you can make about how we collect, use, and share your personal information

2. What personal information do we collect and use, and how do we collect it?

We collect personal information when:

• You give us the information
• We collect it automatically
• We receive it from others

When you create an account on one of our sites, sign up to receive offers or information, or make a booking using our platform, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our sites or download and use our Apps. We also receive information from affiliated companies within Travelwire, Inc., as well as business partners and other third-parties, which help us improve our platform and associated tools and services, update and maintain accurate records, potentially detect and investigate fraud, and more effectively market our services.

3. How is your personal information shared?

Your personal information may be shared to help you book your travel and/or vacation, assist with your travel and/or vacation stay, communicate with you (including when we send information on products and services or enable you to communicate with travel providers and/or property owners), and comply with the law. The full Privacy Statement details how personal information is shared.

4. What are your rights and choices?

You can exercise your data protection rights in various ways. For example, you can opt out of marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service.

How to contact us?

You can also contact us as described below in the “ Contact Us” section to ask questions about how we handle your personal information or make requests about your personal information.

Privacy Statement?

Categories of Personal Information We Collect

When you use our platform, Apps, or associated tools or services, we may collect the following kinds of personal information from you as needed:

• Name, email address, telephone number, and home, business, and billing addressees
• Government-issued Identification required for booking or identity verification, such as passport, driver’s license, and government redress numbers, and for vacation property owners, tax identification number
• Payment information such as payment card number, expiration date, and billing address
• Travel-related preferences and requests such as favorite destination and accommodation types, and special dietary and accessibility needs, as available
• Loyalty program and membership information
• Birth date and gender
• Geolocation
• Images, videos, and other recordings
• Social media account ID and other publicly available information
• Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes)
• Searches you conduct, transactions, and other interactions with you on our online services and Apps
• Other communications that occur through the platform among partners and travelers, and in-group chat and traveler-collaboration tools
• The searches and transactions conducted through the platform
• Data you give us about other people, such as your travel companions or others for whom you are making a booking
• Information we receive about you from other Travelwire, Inc. and third parties such as our business and affiliate partners and authorized service providers which may include updated contact information, demographic information, interests, and purchase history, which we may add to your account or profile and use for market research and analysis

When you install any of our apps or use our platform, we automatically collect the following types of information from your device:

• IP address
• Device type
• Unique device identification numbers
• Internet browser-type (such as Firefox, Safari, Chrome, and Internet Explorer)
• Internet Service Provider
• Operating System
• Mobile carrier
• How your device has interacted with our online services, including the pages accessed, links clicked, trips viewed, and features used, along with associated dates and times
• Details of any referring website or exit pages, as well as general geographic location (such as at the country or city-level)

Mobile Applications:

When you download and use any of our mobile apps, we collect certain technical information from your device to enable the app to work properly and as otherwise described in this Privacy Statement. That technical information includes:

• Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module (“SIM”) operator, and SIM country
• Operating system and version
• Device model
• Performance and data usage
• Usage data, such as dates and times the app accesses our servers, the features and links clicked in the app, searches, transactions, and the data and files downloaded to the app
• Device settings selected or enabled, such as Wi-Fi, Global Positioning System (“GPS”), and Bluetooth (which may be used for location services, subject to your permission as explained below)
• Mobile device settings
• Other technical information such as app name, type, and version as needed to provide you with services

Permissions for Location-Based Services:

Depending on your device’s settings and permissions and your choice to participate in certain programs, we may collect the location of your device by using GPS signals, cell phone towers, Wi-Fi signals, Bluetooth or other technologies. We will collect this information if you opt-in through the app or other program (either during your initial login or later) to enable certain location-based services available within the app (for example, locating available lodging closest to you). To disable location capabilities of the app, you can log off or change your mobile device’s settings.

Use of Personal Information

We use your personal information for various purposes described below, depending on the site or app you visit.

Your Use of Online Sites, Apps, and Services:

• Book the requested travel or enable vacation property booking
• Provide services related to the booking and/or account
• Create, maintain, and update user accounts on our platform and authenticate you as a user
• Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of Travelwire, Inc. platform and services, and as otherwise described in this Privacy Statement
• Enable and facilitate acceptance and processing of payments, coupons, and other transactions.
• Administer loyalty and rewards programs
• Collect and enable booking-related reviews
• Help you to use our services faster and easier through features like the ability to sign-in using your account within the online services and sites of some of the Travelwire, Inc.

Communications and Marketing:

• Respond to your questions and requests for information, and process information choices
• Enable communication between you and the travel supplier like hotels and vacation property owners
• Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) to provide information like travel booking confirmations and updates, for marketing purposes, or for other purposes as described in this Privacy Statement
• Market our products and services, optimize such marketing to be more relevant to you, and measure and analyze the effectiveness of our marketing and promotions
• Administer promotions like contests, sweepstakes, and similar giveaways

Other Business Purposes and Compliance

• Conduct surveys, market research, and data analytics
• Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services
• Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as described in this Privacy Statement
• Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permissible
• Promote security, verify identity of our customers, prevent and investigate fraud and unauthorized activities, defend against claims and other liabilities, and manage other risks
• Comply with applicable laws, protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process
• Comply with applicable security and anti-terrorism, anti-bribery, customs and immigration, and other such due diligence laws and requirements

Operate our business using lawful business purposes and as permitted by law

Sharing of Personal Information

We share your personal information as described below and in this Privacy Statement and as permitted by applicable law.

• Travelwire. We share your personal information within the Travelwire companies.
• Third-party service providers. We share personal information with third-parties in connection with the delivery of services to you and the operation of our business (for example, to provide credit card processing, customer service, business analytics, and fraud prevention and compliance services, and to serve you with advertising tailored to your interests). These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide services we contracted them for. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party).
• Travel suppliers. We share personal information with travel-related suppliers such as hotels, airlines, car-rental companies, insurance, vacation-rental property owners and managers, and where available, activity providers, rail, or cruise lines who fulfill your booking. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.
• Business partners and offers. If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your information with that partner to assist in marketing or to provide the associated product or service. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. An example of such a business-partner relationship would be a third-party loyalty program for which you could earn points by completing a booking on our platform.
• Other Third-Parties. When you access certain features like Facebook’s “Like” button or a single sign-on that allows you to login with your social media credentials to our online services, you will share information with the third-party, like a social media company, such as the fact that you have visited or interacted with us. In the European Economic Area (EEA), Switzerland, and United Kingdom (UK) we will not load social media sharing or sign-on buttons on our website unless and until you accept our use of cookies and similar technologies.The third-party provider may combine this information with other information they have about you. The personal information shared will be governed by the third-party provider’s privacy policy (including any personal information we may access via the third-party provider). The third-party providers should inform you about how you can modify your privacy settings on their site.
• Legal rights and obligations. We may disclose your personal information to enforce our policies, or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a request by a law enforcement or governmental authority, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests. We may also share your personal information pursuant to a subpoena or other legal request, or as necessary to remit certain taxes in the course of processing payments as required by law or legal process.
• Corporate We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Statement.

Your Rights and Choices

• You have certain rights and choices with respect to your personal information, as described below:

· If you have an account with us, you may change your communication preferences by either (1) logging in and updating the information in your account.

· You can control our use of certain cookies by following the guidance in our Cookie Statement

· You can update the accuracy of your information at any time by either logging into your account or contacting us

· If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. You can also log into your account to change communication settings (not available for all Travelwire, Inc.) or contacting us here. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe

· For our mobile apps, you can view and manage notifications and preferences in the settings menus of the app and of your operating system

· If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent

For questions about privacy and your rights and choices, please contact us here.

International Data Transfer

The personal information we process may be transmitted or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country.

The servers for our platform are located in the United States, and the Travelwire, Inc. and third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries.

We have taken appropriate steps and put safeguards in place to help ensure that your personal information remains protected in accordance with this Privacy Statement. For example, any data transfers between our group companies are governed by our intragroup agreements which incorporate strict data transfer terms (including the European Commission’s Standard Contractual Clauses, for transfers from the EEA) and require all group companies to protect the personal information they process in accordance with applicable data protection law. In addition, certain Travelwire, Inc. U.S. affiliates have certified with the EU-U.S. and Swiss-U.S. Privacy Shield, as explained below in the “Privacy Shield” section.

We also require that third-party service providers to whom a data transfer is made has appropriate safeguards in place to protect your personal information, in compliance with applicable data protection law. The particular measures used will depend on the service provider, and our agreements with them may include European Commission approved Standard Contractual Clauses, the service provider’s certification under the EU-U.S. and/or Swiss-U.S. Privacy Shield certification, or reliance on the service provider’s Binding Corporate Rules, as defined by the European Commission.

Privacy Shield

Certain Travelwire, Inc. U.S. affiliates have certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks and that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability for personal information from the EU, Switzerland, and the United Kingdom. For more information about the Privacy Shield principles, please visit: www.privacyshield.gov.

Security

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.

Record Retention

We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Statement, unless a longer retention period is required or permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.

The criteria we use to determine our retention periods include:

• The duration of our relationship with you, including any open accounts you may have with Travelwire, Inc., or recent bookings or other transactions you have made on our platform
• Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us
• Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations

Cookie Statement

Cookie Statement

Types of cookies and similar technologies

Cookies

Cookies are small pieces of text sent as files to your computer or mobile device when you visit most websites. Cookies may be delivered by us (first party cookies) or delivered by a third-party partner or supplier (third-party cookies). Cookies are either session cookies or persistent cookies. Session cookies enable sites to recognize and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognize you as an existing user and these cookies are stored on your system or device until they expire, although you can delete them before the expiration date.

Other similar technologies

• Web beacons, gifs, and clear gifs are tiny graphics, each with a unique identifier that are embedded invisibly on sites and in emails. Web beacons allow us to know if a certain page was visited or if ad banners on our sites and other sites are effective. We also use web beacons in our HTML-based emails to let us know whether our emails have been opened by recipients, which helps us to gauge the effectiveness of certain communications, promotions, and marketing campaigns.
• Proximity based beacons send one-way signals over very short distances, to communicate with associated mobile apps installed on your phone. They can notify you, for example, about experiences related to your trip and can alert you to related deals or promotions. Beacons communicate with your device only when you are in close proximity and only if you have given consent within the relevant mobile application.
• Pixels are small objects embedded into a web page that are not visible to the user. We use pixels to deliver cookies to your computer, facilitate the log-in process, monitor the activity on our sites, and deliver online advertising.
• Tags are small pieces of HTML code that tell your browser to request certain content generated by an ad server. We use tags to show you relevant advertising and promotions.
• Scripts are pieces of JavaScript code that launch automatically when certain webpages load, to determine whether users view associated advertisements.
• Local Storage Objects , such as HTML 5, are used to store content and preferences. Third-parties with whom we partner to provide certain features on our site to display advertising based upon your web browsing activity use Local Storage Objects to collect and store information.

All of the technologies described above will be collectively referred to in this Cookie Statement as “cookies”.

Travelwire, Inc. use of cookies

At Travelwire, Inc., we use cookies for a number of reasons, including to:

• Help us improve your experience when visiting our sites
• Fulfill transactions and ensure our sites perform as intended
• Remember your preferences, such as language, region, or currency
• Provide you with relevant advertising and analyze performance of the ads
• Enable you to return to previous travel searches
• Identify errors on our sites
• Help with data protection and potentially detect and investigate malicious or fraudulent activity
• Help us understand traffic to our site, including time and date of the visit, time and date of the last visit, and other information
• Analyze how well our sites are performing

Types of information collected by cookies

The types of information that we collect through cookies include:

• IP address
• Device ID
• Viewed pages
• Browser type
• Browsing information
• Operating system
• Internet Service Provider
• Whether you have responded to, or interacted with, an advertisement
• Referring or referred links or URLs
• Features used and activities engaged in on our sites and in our apps

Types and functions of cookies

Essential Cookies

Certain cookies are required or “essential” for our sites to function as intended. Essential cookies are necessary for you to navigate our site and use certain features like logging in to your account and managing your bookings. These cookies are also used to remember security settings that allow access to particular content. Lastly, we use essential cookies to collect information on which web pages visitors go to most, so we can improve our online services. You are not able to opt out of essential cookies.

Other Types of Cookies

We also use other types of cookies to make our site engaging and useful to you:

• Functional Cookies. We want to make sure when you visit our site, your preferences (such as your preferred language), settings, and previous searches are remembered. Functional cookies enhance your experience on any Travelwire, Inc. company’s site.
• Analytics Cookies. We use analytics cookies to:
• Understand our site’s performance and how it is used, including the number of visitors, how long you stay on the site, and which parts of the site you visit. We can see details about how visitors interacted with the site, like the number of clicks visitors made on a given page, their mouse movements and scrolling activity, the search words visitors used, and the text visitors enter into various fields
• Test different designs and features for our site
• Monitor how our visitors reach our sites
• Determine effectiveness of our advertising
• Improve our services, including your experience on our site

For analytics, our third-party service providers may use cookies to perform their services and may combine the information that they collect about you on our sites with other information that they have collected. For example, we use Google analytics cookies to monitor the performance of our sites. Our ability to use and share information collected by Google Analytics about your visit to our sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. This Cookie Statement does not cover such third-parties’ use of your information.

Some analytics cookies can perform tasks essential and/or functional to online services like enabling site improvements and testing changes on a site.

• Advertising Cookies. Travelwire, Inc. and our third-party advertising partners may use advertising cookies to show you advertisements both on and off our sites that are based on your interests. We may allow third-parties to collect information about your online activities through cookies to perform their services and may combine the information that they collect about you on our sites with other information that they have collected. These third-parties include business partners who collect information when you view or interact with one of (1) their advertisements on our sites or (2) our advertising or booking information on their sites and advertising networks, which collect information about your interests when you view or interact with one of the advertisements or tracking mechanisms they place on many different sites on the Internet. Our partners may make assumptions about your interests, characteristics, or preferences and add you to groups based on those assumptions in order to show you tailored advertisements. Travelwire, Inc. does not have access to the cookies these third-parties may use to collect information about your interests, and the information practices of these third-parties are not covered by this Cookie Statement or our Privacy Statement. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here and here.

Your information choices

You can choose not to receive tailored online advertising on this site and other sites and learn more about opting out of having your information used for tailored advertising purposes by accessing one of the following resources:

• For EEA, Switzerland, and UK: http://www.youronlinechoices.eu/
• For Canada: http://youradchoices.ca/choices/
• For U.S. and rest of world:

• http://www.aboutads.info/choices/
• http://optout.networkadvertising.org/

Note that if you choose not to receive tailored ads, you will still see online advertisements, but they will be general and less relevant to you.

How can you manage your cookies?

You can set or amend your web browser controls to accept or refuse cookies whenever you like, but please remember if you do choose to reject cookies, your access to some of the functionality and areas of our site may be restricted.

Do-Not-Track Signals and Similar Mechanisms.

Some web browsers may transmit “do-not-track” signals to sites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether users are even aware of them. Participants in the leading Internet standards-setting organization that is addressing this issue are in the process of determining what, if anything, sites should do when they receive such signals. We currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess our sites’ responses to these signals and update this Cookie Statement appropriately.

Contact Us

If you have any questions or concerns about our use of your personal information, please contact us via the Privacy Section on our Customer Services Portal here.

Updates to Privacy Statement

We may update this Privacy Statement in response to changing laws or technical or business developments. You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Statement.