Privacy Statement and Cookie Statement

Last modified: February 6, 2022

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Attenvo, a product of Attenvo Technologies Limited (“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, your rights in determining what we do with the information that we collect or hold about you and tells you how to contact us.

 

Privacy Statement Summary

This is a summary of our Privacy Statement. To review our Privacy Statement in full, please click here, or scroll down.

 

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

     How you can access and update your information.

     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 Attenvo Technologies Limited, 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.

 

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, make reservations for an experience, activity or event, assist with your participation in an experience, activity or event reserved through our platform, 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 below.

 

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 support. Our Privacy Statement has more information about the options and data protection rights and choices available to you.

 

How to contact us

 

More information about our privacy practices is in our full Privacy Statement. 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, username, email address, telephone number, and home, business, and billing addresses (including street and postal code)

     Government issued Identification required for booking or identity verification, such as passport, driver’s license, government issued numbers, and country of residence

     Travel-related preferences and requests such as favorite destination and accommodation types, and special dietary and accessibility needs, as available

     Event-related preferences such as favourite experiences and activities

     Loyalty program and membership information

     Birth date and gender

     Geolocation

     Images (including facial photographs), 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, creators, organisers and travellers,

     and in-group chat and traveller-collaboration tools

     The searches and transactions conducted through the platform

     Data you give us about other people, such as your travel or experience companions or others for whom you are making a booking

     Information we receive about you from other Attenvo products 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)

Our Cookie Statement section, included in this Privacy Statement, further explains how we use cookies and similar tracking technology.

 

Mobile Apps

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. 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, which depend on the site you visit or the app you use.

 

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, experiences and travel preferences, and similar information about your use of Attenvo’s 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 Expedia Group companies

Communications and Marketing:

 

     Respond to your questions, 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 & experience 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 de-identified 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

 

Lawful bases for processing:

 

We will collect personal information from you only (i) where the personal information is necessary to perform a contract with you (e.g., manage your bookings, process payments, or create an account at your request), (ii) where the processing is in our legitimate interests and not overridden by your rights (as explained below), or (iii) where we have your consent to do so (e.g., sending you marketing communications where consent is required). In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.

 

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

 

Certain countries and regions allow us to process personal information on the basis of legitimate interests. If we collect and use your personal information in reliance on our legitimate interests (or the legitimate interests of any third-party), this interest will typically be to operate or improve our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us, to respond to your queries, undertaking marketing, or for the purposes of potentially detecting or preventing illegal activities.

 

We may in some cases use automated decision-making, for example, in relation to assessing fraudulent transactions or suspicious activity on our site. As part of this processing, automated decisions may be made by putting your personal information into a system and the decision is calculated using automatic processes. If you pose a fraud risk, this may affect your ability to book on our site. You may have rights in relation to automated decision making, including the ability to request a manual decision-making process instead or contest a decision based solely on automated processing. If you want to know more about your data protection rights, please see the Your Rights and Choices section below.

 

Sharing of Personal Information

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

 

Attenvo Ecosystem. We share your personal information within the Attenvo products developed and owned by Attenvo Technologies Limited. Attenvo Technologies Limited share, access and use your personal information as described in this Privacy Statement.

 

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).

 

Lifestyle merchants. We share personal information with lifestyle-related merchants 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 experience and travel bookings. Please note that lifestyle merchants 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. 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 transactions. 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 (not available for all Attenvo products) or (2) contacting us here.

     You can access, amend or 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 Attenvo products) 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, your rights and choices, and in order to make a request to amend or update your information, please contact us here.

 

In addition to the above rights, you may have the right to complain to a data protection authority about our collection and use of your personal information. However, we encourage you to contact us first so we can do our best to resolve your concern. You may submit your request to us using the information in the Contact Us section. We respond to all requests we receive from individuals wanting to exercise their personal data protection rights in accordance with applicable data protection laws.

 

Information Security

We have implemented appropriate administrative, technical, and physical security procedures to help protect your information.

 

We only authorize specific employees to access personal information and they may do so only for permitted business functions. We use encryption when transmitting your information between your system and ours, and between our system and those of the parties with whom we share information. We also employ firewalls and intrusion detection systems to help prevent unauthorized access to your information. However, we cannot guarantee the security of information from unauthorized entry or use, hardware or software failure, or other circumstances outside of our control.

 

Information Retention

We will retain copies of your information for as long as you maintain your account or as necessary in connection with the purposes set out in this Statement, unless applicable law requires a longer retention period. In addition, we may retain your information for the duration of any period necessary to establish, exercise or defend any legal rights

 

Contact Us

If you have any questions or concerns about our use of your personal information, or wish to inquire about our personal handling practices, please contact us via our contact form.

 

Updates to Statement

We may update this Statement in response to changing laws or technical or business developments. If we propose to make any material changes, we will notify you by means of a notice on this page. You can see when this Privacy Statement was last updated by checking the last updated date displayed at the top of this Statement.