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2. PERSONAL INFORMATION WE COLLECT
2.1 We collect personal information about you when you voluntarily submit information directly to us, through our Services or our app. This can include information you provide to us when you apply to become a member, complete a form, purchase any breaks using our platform, correspond with us, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to a survey, enter a promotion or use some other feature of our Services.
2.2 We also collect personal information from you indirectly such as information about the pages you look at on our site or our app or the device you use to view our site or connect to our app with.
2.3 The list below sets out the categories of personal information we may collect from or about you.
Contact details: We collect contact information such as your name, your email address, your telephone number and physical addresses associated with your account or any bookings you place using our Services.
Booking Information: When you book a trip through our Services, or are a member of a group booking made through our Services, we may collect additional information required to process your booking including passport numbers, information about any disability you have, dietary requirements and/or religious beliefs.
Comments and opinions: When you contact us directly, e.g. by email, phone, post or by completing an online form, we will receive your comments and opinions. We will also receive comments and opinions you express when responding to surveys, entering competitions or taking part in promotions we run.
Payment and transaction information: We keep records of the trips you purchase from us and the payment method you use for the transaction. We will use payment and transaction information to process payment for any trip you purchase from us. Although we keep records of any transactions you make through the Services, we do not store any financial details such as your credit card numbers as we use a third party payment provider to process any payments you make through the site.
Website and app login details: When you create an account with us, we collect your user name and password. If you choose to log in with or link our Services to a third party account, such as your Facebook or Google account, we may receive additional information about you, such as your name and email address. We do not receive your account login details for those services. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options.
Your preferences: We collect information about the preferences you set for notifications, marketing communications and how our Services are displayed to you.
Information about how you use and connect to our Services: We collect information about how you use our Services, such as the pages you view on our Services, the time you access our Services and how long you use them for, the website from where you came to our Services or go to after leaving our Services, and any selections and choices you make when using our Services.
We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Services. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Services through the device, your Internet service provider or mobile network, your IP address and your device's telephone number (if it has one).
Cookies and Analytics. We and our third-party partners, such as advertising and analytics partners, also collect personal information from you indirectly through cookies and similar technologies, such as web beacons. Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by us are called “first party cookies.” Cookies set by third party partners are called “third party cookies.” The parties that set these third-party cookies may use them to collect information about your online activities over time and across different online services. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Web beacons are tiny graphics files that contain a unique identifier that enables us to recognise when you have visited our Services or opened an email that we sent. In many cases, web beacons rely on cookies to function properly, so declining cookies may impact their functioning.
Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.
Information about your location: Your device's IP address may help us determine an approximate location. We will not collect or track your exact location without your consent. .
Information provided by other users: Sometimes other visitors to our site or users of our app provide information that is associated with you. Where users of our Services want to invite you to use our Services or share information with you about our Services or offers, we will use personal information that they provide about you to assist them in doing this. We will only do this though where they indicate that you have provided your consent for them to communicate with you in this way.
3. HOW WE USE YOUR PERSONAL INFORMATION
We process your personal information for the following purposes:
4. INFORMATION WE SHARE WITH THIRD PARTIES
We may share your personal information with the following parties:
Companies in the same group of companies as us: our subsidiaries (i.e. any organisation we own or control) or our holding company or ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries they own.
Hotel and travel operators: we will share personal information with the hotels and travel operators that you purchase your hotel or package holiday with so that they can arrange your booking.
Service providers: third parties who provide a service to us. For example, third party service providers help support our IT infrastructure, process payments from you on our behalf, develop analytical information for us about our products, services and marketing and provide professional services such as legal and accounting services.
Social networks and other online services: our Services allow you to, upon your direction, share information with social networking services, such as Facebook. You understand that the use of your information by any social networking website will be governed by the privacy policies of these third party platforms and your settings on that platform. We encourage you to read their privacy policies.
Advertising partners: we work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners may be members of the Network Advertising Initiative (https://optout.networkadvertising.org/?c=1#!%2F) or the Digital Advertising Alliance (https://optout.aboutads.info/?c=2&lang=EN). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt-out of receiving web-based personalized ads from member companies. You can also access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt-out of personalized ads on mobile apps.
Purchasers of our business: personal information may be disclosed or transferred to service providers, advisors, buyers or prospective buyers in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal information to or to whom we believe disclosure of your personal information is necessary or appropriate to protect our rights, property or safety or to protect the rights, property or safety of others. For example, we may provide information to the United States Customs and Border Protection agencies if you are travelling to the USA. We may also disclose personal information to third parties to help detect and investigate fraud and other illegal activities, and breaches of any agreement we have with you.
Other third parties: with your permission, we may share your contact details with selected third parties so they can provide you with information about travel offers that they believe may be of interest to you.
We may also provide third parties with aggregate statistical information and analytics that cannot reasonably be used to identify you.
5. YOUR CHOICES
5.1 Our service is about providing you with the latest hotel and luxury travel offers. When you sign up to our service, you recognise that we will contact you regularly with information about the travel offers we market. Most marketing messages we send will be by email but occasionally we may also contact you by mail. If you are using our website or app we may also send you push notifications if you accept to receive them. If you do not want to receive, or wish to reduce, marketing messages from us, you will be able to tell us by changing your marketing preferences in your account.
1. SECRET ESCAPES' APPROACH TO PRIVACY
To provide, maintain, enhance, and improve our Services. For example, to enable you to book airlines and hotels.
To personalize your experience on our Services, such as by providing tailored content and recommendations that may be relevant, valuable, or otherwise of interest to you. For example, to recommend hotels near you.
To understand and analyse how you use our Services and develop new products, services, features, and functionality.
To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support.
To enable you to participate in competitions, promotions, and similar contests.
To verify your identity.
To facilitate transactions and payments.
For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you.
To assess the effectiveness of our marketing and advertising campaigns.
To generate anonymised or aggregated data that does not directly identify you that we may use to test our IT systems, conduct research and data analysis, improve our Services, or develop new products and features.
To send you push notifications.
To find and prevent fraud or other unlawful activity, and respond to trust and safety issues that may arise.
For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
For other purposes for which we provide notice at the time the information is collected.
5.2 Location information: If you have previously given us permission to collect your precise location information, you can prevent your device from future sharing of precise location information at any time through your device’s operating system settings.
5.3 Marketing communications: From time to time, we may send you marketing communications by email, or app push notification. You can change your email marketing preferences at any time by following the instructions outlined below, or by accessing your marketing options in your account.
Email – you may opt out of future marketing emails from us by clicking on the unsubscribe link at the bottom of our marketing emails. Please be aware that even if you opt-out of receiving marketing messages from us, you will continue to receive administrative messages from us. If you have an online account with us you can also opt-out of marketing emails through your account settings. You can also manage the frequency of our communications to you. In the “your subscriptions” tab of the “your account” section of the site, you can choose to opt out of receiving communications for a period of time by clicking on the relevant slider. You can also choose to reduce the frequency of our emails by choosing the summaries option on the mail preferences slider. Once you have chosen your mail preferences, please click “Save Changes” button to let us know of your preferences.
App push notifications – you can change your push notification preferences at any time in the account settings for the app.
5.4 Third party offers: From time to time we include offers from selected third parties that we think will be of interest to you in our newsletters. If you decide you no longer want to receive such messages, you can tell us not to send such messages through your account settings. Visit the "your account" section of the site, then untick the box titled "Hand-picked partner offers".
We make reasonable efforts to implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage. However, we cannot guarantee the security or privacy of your personal information because no electronic transmission or storage of information can be entirely secure.
7. INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
If you choose to use the Services from the EU or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with the storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.
8. LINKS TO THIRD PARTY SITES
11. CONTACTING US
Secret Escapes Limited,
CALIFORNIA RESIDENT PRIVACY NOTICE
1. Personal Information Collection, Disclosure, and Sale
For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is:
Lawfully made available from government records.
Deidentified or aggregate information.
Otherwise excluded from the scope of the CCPA.
We have collected, disclosed for a business purpose, or sold the following categories of Personal Information in the preceding twelve months since this notice was last updated:
(a) Categories of Personal Information that we collect and disclose:
Identifiers - Examples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, passport number, or other similar identifiers.
Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) - Examples: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of Protected Classifications under California or Federal Law - Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.
Commercial Information - Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or Other Electronic Network Activity Information - Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.
Inferences Drawn from Personal Information - Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
(b) Categories of Personal Information that we collect but do not disclose:
Geolocation Data - Example: Precise physical location.
(c) Categories of Personal Information that we do not collect:
Biometric Information - Examples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
Sensory Information - Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information - Examples: Job application or resume information, past and current job history, and job performance information.
Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99) - Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.
In the preceding twelve months, we have not sold any California resident’s Personal Information.
2. Use of Personal Information
Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging: Debugging to identify and repair errors that impair existing intended functionality.
Transient Use: Short-term, transient use.
Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
Research: Undertaking internal research for technological development and demonstration.
Product Improvement: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.
3. Disclosure of Your Personal Information
4. Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information (as defined by the CCPA) collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you.
Right to Opt Out.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
Submit Requests. To exercise your rights under the CCPA, please send an email to firstname.lastname@example.org, or visit the “your account” section of our website. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.
Verification. To verify your access or deletion request, please contact us from the email address under which your account is registered. We may need to ask for further identification in certain circumstances.
5. Do Not Track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
6. Contact Information
If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights please email us at email@example.com or write to us at:
Secret Escapes Limited,