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Privacy Policy

Revised June 2, 2021

Introduction

HelloVacay (“Company” or “HelloVacay” or “we,” “our,” “us”) is dedicated to protecting your privacy and safeguarding your personally identifiable information. We are committed to adhering to the principles of applicable data protection and privacy laws.

HelloVacay respects your privacy and is committed to protecting it through compliance with this notice. This notice describes the types of information we may collect from you or that you may provide when you visit the website: https://hellovacay.com (our “Website”) or when you opt into receiving text or email messages from us (Electronic Messaging) and our practices for collecting, using, maintaining, protecting, and disclosing that information. The Website and Electronic Messaging are collectively referred to in this notice as the Services. This notice applies to information we collect (i) on the Website; (ii) in email, text, and other electronic messages between you and us; and (iii) when you interact with our advertising on other websites or third-party websites and services. Please read this notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policy and practices, your choice is not to use the Services. By using the Services, you agree to this privacy notice. This notice may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the notice periodically for updates.

Types of Information We Collect

We collect several types of information from and about users of our Services, including information: (i) by which you may be personally identified, such as name, address, email address, and telephone number; (ii) that is about you but individually does not identify you, such as your age or gender; (iii) about your internet connection, the equipment you use to access the Services, and usage details. We collect this information: (i) directly from you when you provide it to us; and (ii) automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies. The information we collect on or through our Website may include: (i) information that you provide by filling in forms on our Website; (ii) records and copies of your correspondence; and (iii) details of transactions you carry out with us or the fulfillment of your orders. As you navigate through and interact with our Services, we may use automatic data collection technologies, such as Google Analytics, to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

Online Tracking

If you choose not to provide requested information, you may not be able to use some of the features of the Services. HelloVacay does not respond to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice about behavioral tracking.

Purpose of Collection & Use

We may use and share the Personal Information and other information collected (unless otherwise restricted by applicable law):

  • To operate, provide, and enhance the Services and to provide the products, information and services you request or sign up for through the Services or that may be of interest to you. For example, we will use your Personal Information to contact you with respect to information you requested or with respect to offering or providing the Services, for any administrative, maintenance and customer service purposes, to facilitate a third party’s provision of services you request, such as third-party LLC set-up services or third-part custodian services, and to address issues such as intellectual property infringement, rights of privacy, or defamation claims;
  • to track and analyze your usage trends and preferences in order to improve the Website and Services;
  • to personalize our Services and to monitor the operation and effectiveness of the Services;
  • to analyze aggregate Website usage metrics;
  • to provide you with customized third-party content, and information;
  • to send you messages, including to notify you about changes to our Services or any products or services we offer or provide through the Services and promotional messages related to the Services and of third parties we work with. You will have the ability to opt-out of receiving any such communications, through links provided in the messages;
  • to engage in transactions with you and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
  • to respond to your requests;
  • to share your Personal Information with other selected third parties, affiliates and subsidiaries that offer complementary products or services. In such an event, please review that company’s privacy policy regarding any further interactions with them.
  • to obtain third party services from those who provide services to us, such as analytics, web site management, payment processing, information technology and related infrastructure, customer service, e-mail delivery, auditing, and other similar services. When we share Personal Information with third party service providers, we require that they use your Personal Information only for the purpose of providing services to us and subject to terms consistent with this notice.
  • to work with third party companies to help us tailor advertising that we think may be of interest to you based on your use of the Website and to otherwise collect and use data about your use of the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior. These companies may use information about user behavior in order to provide customized advertisements across various websites, services and products. In the course of providing these websites, services, products or placing advertisements, these third-party companies may place or recognize a unique cookie on your computer, and may record information to these cookies based upon your activities on our Website and on third party websites. Each of these companies use this cookie information according to their own privacy and security policies. If you do not wish to have this information used for the purpose of serving you targeted ads, you may opt-out as indicated in below. Please note this does not opt you out of being delivered advertising. You will continue to receive generic ads.
  • to license, sell, or otherwise share your Personal Information with selected third parties for compensation for their own business purposes. Once shared with such entities, this Personal Information becomes subject to the third party’s privacy practices.
  • as we believe to be necessary or appropriate to protect the health and safety of our employees and operations or the employees or operations of any of our third-party service providers.
  • as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.

We may use, transfer, and disclose other information we collect for any purpose, except where applicable law requires otherwise. If we are required to treat other information as Personal Information under applicable law, then we will only use it in the same way that we are permitted to use and disclose Personal Information.

Collection of Information

Direct Interactions: From your use of and interaction with us through the Services and other activities such as submission of forms.

Electronic Communications Protocols: We may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type or device type), your IP address (which may identify your general geographic location or company), and date and time.

We may also automatically receive and record information about your interaction with the Services, such as how often you access the Services, performance data, aggregate usage, or general geo-location data.

Cookies: We may use cookies. A cookie is a small piece of information sent by a web server to store on a web browser so it can later be read back from that browser. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, and general usage and volume statistical information. Cookies may also be used to collect individualized web site use data, provide Website personalization, or conduct and measure the effectiveness of advertising in accordance with this notice. Some cookies may remain on users’ computers after they leave the Website. While many are set to expire within 1-24 months of your last visit to the website that set the cookie, others may not expire because of their nature, like cookies that remember opt-out preferences.

Your browser may provide you with information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser. Cookies, however, are important to the proper functioning of a site, and disabling them may degrade your experience and interfere with Website features and customizations.

We may engage one or more third party service providers to track and analyze both individualized usage and volume statistical information from interactions with the Website. The service provider(s) may set cookies on our behalf. We may also use third party cookies to provide advertising and personalization services in accordance with this notice, and to track the performance of our advertisements and emails.

Managing Cookie Preferences: Your browser should allow you to access or change your cookie preferences at any time.

Flash Cookies: We may use Flash cookies, also known as “local shared objects,” on our Website that employ Flash technology. Flash cookies are used to remember the Website’s settings to personalize the look and feel of the Website. Like normal cookies, Flash cookies are represented as small files on your computer. You may be able to prevent Flash cookies from being placed by adjusting your browser’s settings.

Embedded URLs: We may use a tracking technique that employs embedded URLs to allow use of the Website without cookies. Embedded URLs allow limited information to follow you as you navigate the Website, but are not associated with Personal Information and are not used beyond the session.

Embedded Pixels and Similar Technologies: We may use embedded pixel technologies for the purposes of identifying unique user visits (as opposed to aggregate hits), and for advertising purposes. In addition, embedded pixels or other technologies may be used in e-mails and our online display advertising to provide information on when the e-mail or ad was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with your e-mail address.

Physical Location: We may collect and share the physical location of your device for purposes consistent with this notice, such as to provide you with personalized location-based services or content. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized services or content.

Preferences and Opt-Out

You may opt out of e-mail marketing by using our general unsubscribe automated link that is included in our marketing e-mails. If you have any problems using any of these opt-out mechanisms, please contact us.

Some non-marketing communications are not subject to general opt-out, such as communications related to customer services and disclosures to comply with legal requirements.

If you do not want us to use your Personal Information to notify you of products or services of interest to you or if you do not want us to share your Personal Information with selected third parties, affiliates and subsidiaries, please opt out by contacting us via email at contact@hellovacay.com or by mail at:

HelloVacay
Attn: Privacy Notice Manager
3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States

If you have consented to receiving text messages or auto-dialed telephone calls from us, you may revoke that consent by writing, emailing, or calling us or by any other reasonable means.

Cookies and Do Not Track Preferences. You may opt out of cookies by using your browser settings. We do not process or recognize any Do Not Track signals.

Information-Sharing Choices. We may only share Personal Information with selected companies after providing you the ability to make choices about the sharing, or as otherwise described in this notice. There are limitations to opting out of such sharing in the case of: (1) where you have previously requested the sharing of your Personal Information with these companies; (2) where third parties are required to perform a service in connection with our provision of Services to you; and (3) where required by law.

Access, Corrections, and Updates

You may request to review, correct, update, suppress, remove, or otherwise modify any of your Personal Information that you have previously provided to us through the Website. You have the ability to update your Personal Information by contacting us at contact@hellovacay.com or by mail at:

HelloVacay
Attn: Privacy Notice Manager
3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States

You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Information in a commonly used electronic format so that you can manage and move it.

In certain circumstances, you have the right:

  • To access and receive a copy of the Personal Information we hold about you;
  • To rectify any Personal Information held about you that is inaccurate;
  • To request the deletion of Personal Information held about you.

Please note that you may be asked to verify your identity before receiving a response to such requests. Please be aware that if you delete your Personal Information, you may not be able to continue to use our Services. Please note that if you request that we delete your Personal Information, we may in our sole discretion retain certain information, including your Personal Information, to satisfy our legal, audit and/or dispute resolution requirements. We may also retain your non-Personal Information indefinitely. If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us at contact@hellovacay.com or by mail at:

HelloVacay
Attn: Privacy Notice Manager
3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us.

While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within thirty days.

Retention and Deletion

We will retain your Personal Information for as long as your account is active; as needed to provide you the Services; as needed for the purposes outlined in this notice or at the time of collection; as necessary to comply with our legal obligations (e.g., to honor opt-outs), resolve disputes, and enforce our agreements; or to the extent permitted by law.

At the end of the retention period, we will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.

Advertising and Third-Party Websites

The Services may contain links to websites and services provided by third parties. Any personally identifiable information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies, if any, governing privacy and security. We are not responsible for the content or privacy and security practices and policies of third-party sites or services. You should read the third parties’ privacy policies before providing them with your personally identifiable information.

Security

The security of your Personal Information is very important to us. We use commercially reasonable physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We cannot, however, ensure or warrant the security of any information you transmit to us, and your transfer of your Personal Information to us is at your own risk.

In the event that your Personal Information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, we will notify you by e-mail, fax, or U.S. mail. We will give you notice promptly, consistent with the reasonable needs of law enforcement and our company to determine the scope of the breach and to investigate and restore the integrity of the data system.

Cross-borders Transfers and International Uses

This notice is intended to cover only customers and other users residing in the United States. If you are outside of the United States, by visiting our Website and by providing us with your Personal Information or data, you acknowledge and agree that we may use the Personal Information or data collected in the course of our relationship for the purposes identified in this Privacy notice or in our other communications with you, including the transmission of information outside your resident jurisdiction. In addition, please understand that such Personal Information and data may be stored on servers located in the United States. By providing us with your Personal Information or data, you consent to the transfer of your Personal Information and other data to our servers, which may be located anywhere in the world. Personal Information may be transferred, accessed and stored globally as necessary in accordance with this notice.

Information Sent Abroad

HelloVacay provides global services. In certain circumstances, sharing data cross-border is essential to the services you receive from us.

I. Special Requirements under EU Data Protection Laws (GDPR):

In order to complete your booking, complete analysis, or for other legitimate purposes we transfer, process and store information about you outside of the EEA on servers located in the United States by HelloVacay and its affiliates located at:

3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States

Therefore, your information may be transferred to, stored, or processed in the United States. We will ensure that in terms of Data Security Standards, our systems in the US will have the same level of data protection that is required of our EU affiliate. If we transfer your Personal Information to agencies or third parties outside the EEA, we require similar, binding EU Standard Contractual Clauses, and we monitor compliance with such. Our affiliated or related entities, associates and partners have also agreed to adopt equivalent measures. Copies of these measures can be obtained by contacting us as detailed under Contact Information below. You may lodge a complaint with the UK Information Commissioner’s Office if you consider that our processing of your Personal Information infringes applicable law.

II. Special Requirements under Mexican Data Protection Laws

In accordance with the requirements of the Mexican Federal Law on the Protection of Personal Information Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (the “Mexican DP Law”), We inform our users and subscribers located in Mexico of Our compliance with the Mexican DP Law. Under Mexican DP Law, We do not need to obtain your consent for the processing of your Personal Information for the purposes that give rise and are necessary for the fulfillment of our relationship (e.g. personal information required in order for you to subscribe to our vacation programs). In case you do not agree with the processing of your personal information for such purposes and as described in this notice, please abstain from acquiring or using our services.

Our Website users and subscribers located in Mexico should note that:

  • The Personal Information provided by you to us through email, fax, websites, online services, enrollment or subscription forms and agreements, telephone calls or any other means, is processed by us for the purposes set forth in this notice; in the understanding that, in order to comply with the Mexican DP Law, below we have set forth those purposes that are not required to fulfill the relationship between us, commonly known as “additional or secondary purposes”:
  • To provide you with updates about discounted availability, special offers, new services and products which may be of interest to you and other noteworthy news items.
  • Send advertisements, promotions and brochures.
  • To contact you about our and third parties’ goods and services that may be of interest to you.
  • To ask for ratings and reviews of services or products. Should you not wish that your personal information be used for the purposes listed immediately above, please send an email to contact@hellovacay.com with subject line “Request for Restriction on the use of My Personal Information for Secondary Purposes / Mexico”.
  • That this privacy notice applies to all your personal information that we may have access to, including: name, nationality, birthdate and birthplace, age, address, telephone number, cell phone number, email, tax identification number, hand written signature, as well as personal information that may be considered sensitive and related to recorded video or photographs, health condition, economic and financial data, including your bank account information and information of your credit or debit cards, as well as any other Personal Information listed in this notice.
  • As described above, we also collect information using various technologies, such as cookies and web beacons.
  • That your personal information will be solely treated in accordance with the terms and conditions of this privacy notice.
  • In order for you to: (i) exercise your rights to Access, Rectify, Cancel, and Object to the use of your personal information (known as “ARCO Rights”), and (ii) to limit the use and disclosure or to revoke your consent to the use of your personal information for the secondary purposes described above, please send an email to contact@hellovacay.com with subject line “Exercise of ARCO Rights / Mexico”. The request should include, as minimum:
    • Copy of your official ID and/or of your legal representative. Such documents should be scanned and attached to the corresponding email communication. For legal representative, please also attach a copy of his/her power-of-attorney.
    • Clear and precise description of the personal information about which the ARCO Rights are to be exercised, as well as the right or rights you wish to exercise. This description could be included in the email cover letter or in a document attached thereto, scanned and initialized in each of its pages.
    • Expressly state your agreement to receive our response through an email communication, specifying the corresponding email address.
    • Any other data that allows us to locate your Personal Information.

We will issue a response within the following 20 business days after we receive your request. Once you receive our response, you will have a 15 business day period to respond to our communication. In case you do not reply to our response within the mentioned period, we will understand in good faith that you agree with our response. We may refuse the exercise of your ARCO Rights in the cases permitted by applicable law, and shall inform you about such decision. The refusal may be partial, in which case We will carry out the access, rectification, cancellation or objection in the corresponding part. As mentioned below, you can also review and change your personal information by logging into the Website and visiting your account profile page.

See the section Purpose of Collection and Use for information regarding the manner in which we share your personal information with third parties and data-processors. Please note that we require your consent to transfer your Personal Information to third parties to market their own products or services to you. Should you not wish that your Personal Information be transferred to third parties for their own marketing purposes please send an email to contact@hellovacay.com with subject line “Request for Restriction on the Transfer of Personal Information to Third Parties for their Own Marketing Purposes / Mexico”.

This privacy notice may be modified as described in the section “Changes to the Privacy Notice” set forth below.

Minors

Our Services are not directed to minors, we do not market to minors, and we do not knowingly collect Personal Information from anyone under the age of 18. If you believe that we have mistakenly or unintentionally collected Personal Information of a minor without appropriate consent, please notify us so that we may immediately delete the information from our servers and make any other necessary corrections.

Dispute Resolution

You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities. If you have any complaints regarding our compliance with this Notice, you should first contact us at contact@hellovacay.com or by mail at:

HelloVacay
Attn: Privacy Notice Manager
3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States

We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with this Notice.

California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to contact@hellovacay.com or by mail at:

HelloVacay
Attn: Privacy Notice Manager
3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States

Customers in the state of California may request a list of categorized third parties and in some cases affiliates to whom we may have disclosed their personal information specifically for those third parties’ and/or affiliates’ own marketing purposes, as well as the type of personal information disclosed to those parties. HelloVacay does not disclose your personal information to third parties or affiliates for those third parties’ or affiliates’ own marketing purposes. If you are a California resident and would like to more information about our compliance with this law, please email us at: contact@hellovacay.com or by mail at:

HelloVacay
Attn: Privacy Notice Manager
3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States

You must include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided address listed.

Changes to our Privacy Notice

It is our policy to post any changes we make to our privacy notice on this page with a notification that the privacy notice has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Website home page. The date the privacy notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy notice to check for any changes.

Contacting Us and Updating Your Communication Preferences

If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from HelloVacay in the future, you can contact us at contact@hellovacay.com or by mail at:

HelloVacay
Attn: Privacy Notice Manager
3090 Bristol Street
Suite #255
Costa Mesa, CA 92626
United States