Trevel Privacy and Cookie Statement

Effective: 14 September 2022

We know that sharing your personal information with us is based on trust. We take this seriously and are committed to ensuring that we respect your privacy when you visit our website or use our services. Please review this Statement carefully to learn about our privacy practices.

We operate an online service that provides users with recommendations for travel and travel planning, including hotels, holiday rentals and other accommodations, attractions and experiences, restaurants, flights, cruises, travel insurance, travel guides and lots more. In this Statement, these are collectively referred to as our Services.

Our Services are owned and operated by Trevel, Inc. By visiting our website (our “Website” or our “Sites”) and related applications, whether on a computer, phone, tablet, or similar device (these are all referred to as a “Device”), you are accepting the practices described below.

As a global company, we may operate in a number of countries and territories where the laws and customs differ. This Statement provides a general overview of our privacy practices; you can view certain country/state-specific information below.

Information Collected

When you access or use our Services, we collect information from and about you to provide a more personalized and relevant experience. Some information we collect automatically. Other information we collect from different sources, including affiliated entities, business partners, and other independent third-party sources. When you use our Services by “clicking-through” from a third-party site or when you visit third-party sites via our Services, those third-party sites may share information with us about your use of their service. Information collected may include the following:

• Personal details (such as your name, age, birthday, gender)
• Contact information (such as email address, address, phone number)
• Booking information (such as, for each traveler, the traveler's name, frequent flyer details, passport number, redress control number, country of citizenship, booking reference number, and itinerary, which may include name of airline or carrier, hotel accommodation and/or vessel, port of destination, port of arrival, date and time of departure and/or check-in, date and time of arrival and/or check-out, meal preferences, luggage information, and layover information)
• Account information (such as login credentials, including email address and password, and account settings)
• Social media data (if you choose to link your Trevel account with a social media account, Trevel may collect personal information such as name, age, gender, photograph, and other personal information relating to your social media account)
• Billing information (such as credit, debit, or other payment card information and billing address)
• Your contacts (such as contact information of people you add to, or notify of, your reservations or itineraries through our Services)
• Your travel plans and preferences (such as your home airport, seating preferences, meal preferences, communication preferences, and other preference information you provide us)
• Reviews you submit (including any screenname you publish under or any personal information you include about yourself or others in such review)
• Content you publish (including your travel recommendations and any personal information you include about yourself or others, or in content you publish in your Guide or other mediums provided by us)
• Photos of you (such as when you add a photo of yourself to your profile, upload photos to a review, or link your social media account to your Trevel account)
• Communications you send us (such as questions, conversations, complaints, or other information that you may submit to our support team)
• Promotion information (if you choose to participate in a contest, sweepstakes, or similar campaign, we will collect any information you provide in relation to such activity, such as photos, images, captions, or other content, in accordance with the terms provided at that time)
• Other information you may provide (including other information you provide about yourself or others through our Services or to which you provide us with access via third-party platforms)
• Geolocation information
• Device information, such as when you accessed our Services and information about the Device used (for example, IP address, software or internet browser used, preferred languages, unique Device identifiers and advertising identifiers)
• Online activity, including pages you have visited, content reviewed, and apps reviewed
• Purchasing history

We may also collect, in instances where you have provided it, information about other travelers, including their email address and other travel-related information. If you are sharing information with us about other individuals, you must obtain their consent. You must obtain the consent of any other individuals if you are providing their data to us.

In addition to the categories noted above, we may also collect location information if you have instructed your Device to send such information via the privacy settings on that Device, or, for example, if you have uploaded photos tagged with location information. We may use your location information directly and/or share your location with third-parties. We collect and share location information in order to provide you with relevant content, to analyze your use of our Services, to improve our Services and to provide contextual advertising or recommendations. For example, we may use your location to show you reviews of hotels, restaurants or attractions near you when you are traveling.

You can change the privacy settings of your Device at any time in order to turn off the functionality that collects and shares location information and/or the functionality to tag your photos with location information. However, turning off location-sharing may affect certain features we offer. If you have any questions about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.

Please see the section on Cookies below for more information regarding the use of cookies and other technology described in this section, including regarding your choices relating to such technologies.

Information Uses

We are committed to providing you with relevant content on our Services and respect the data privacy laws of the different jurisdictions which we operate in. We use information about you so we can help you enjoy and use our Services, including in the following ways:

• Register and manage your account, including to allow you access to and use of our Services
• Facilitate your bookings
• Measure interest in and improve our Services
• Notify you about special offers and products or services available from us, our affiliates, or our partners that may be of interest to you
• Communicate with you
• Enable communication between registered users and owners/representatives of listings on our Services
• Enable us to publish your reviews, forum posts, photos, videos and other content
• Customize your experience, including customizing the ads shown to you on our Services and across the internet
• Make inferences about your interests or preferences
• Provide you with an optimized experience and to group users of our Services based on, for example, usage and demographics
• Send you survey or market research invitations
• Respond to your questions and comments
• Resolve disputes or troubleshoot problems
• Prevent potentially prohibited or unlawful activities
• Enforce our terms of use and notices; and as otherwise described to you at the point of collection

Please note some information about you is required in order for us to provide you with relevant offerings from us, our affiliates, and our partners and to enable you to enjoy other benefits of being a registered user. Please review the “Information Choices” section below with respect to your choices related to the collection and use of your information.

Personal Information Generated By Us. As you use our Services, we generate certain personal information about you, including through automatic data collection and by inferences based on the information we collect about you and your activity. We may automatically collect information about your interactions with the Services or communications you receive (such as email) using certain technologies, such as cookies, web beacons and other technologies (see our Cookies Policy section below for more details). We generate the following categories of personal information about you:

• Device information. When you visit or use our Services, we automatically collect certain information about your device (e.g., your mobile device, computer, or tablet), including information about your hardware and software, device configuration, and nearby networks. Such data may include data about your device operating systems, browsers, and other software installed on your device; such as IP address or other device identifier; country of origin, region and language settings; and information about domain servers and wireless or network access points near your device.
• Usage and performance information. We also automatically collect personal information about your usage of the Services, including information about your searches, statistics about the travel itineraries you share with us, how you interact with the features of our Services and the links you click, your preferences, access times, referring URL, and performance of our Services.
• Location information. If you use our Services, we automatically collect approximate location information about you (such as your city) or, with your consent, precise geographic location data from your mobile device when the app is running and when it is not running, depending on the choices you make when you are asked to consent to our collection of location information. The technologies we use to determine your location may include IP address mapping, cell tower position, Wi-Fi position and GPS signals. We may use and store this information to provide and improve features of our Services, for example, to tailor our Services on a needs-based manner to better facilitate your requests (such as helping you find the hotel closest to you) and to provide you with more relevant content in the cities you visit (such as sending you marketing communications relating to goods or services in your current city, including local accommodations and travel options). Trevel does not have control over your device settings, but we do recommend enabling location services on your device so you can take advantage of the location-based features and functionality offered.
• Inferences about you. We combine the information we collect, generate, or otherwise obtain to draw inferences about your preferences and interests in order to provide and personalize our Services and tailor the advertising we and our partners display or offer to you.
• Emails you synchronize with your Trips account. If you sign up to synchronize your email inbox to your Trips account, you authorize us to access the emails in the email accounts you have connected to your Trips account in order to create travel itineraries. This involves automatically scanning your inbox at regular intervals to identify emails that are booking confirmations, which are then parsed automatically or manually for relevant travel details and imported into our Trips service (along with a copy of the email, which is saved to your Trips account). 

Information Sharing

In order to provide some of our Services, we may need to share information with certain other third-parties, including our group of companies, in the following circumstances:

• Our Group of Companies. We share information with companies in our corporate family so we can provide you with information about products and services, both travel-related and others, which might interest you. These companies and websites will comply with this Statement and all applicable laws governing the transmission of promotional communications.
• Suppliers. We share information with suppliers, including but not limited to hotel, airline, cruise, car rental, or activity providers, or vacation rental managers or owners who fulfil your travel reservations. Throughout our Website, all products and services provided by third-party suppliers are described as such. Information that we share with suppliers to facilitate reservations will be treated according to applicable suppliers’ privacy policies, except for payment information. We share payment information only when it is necessary for travel reservations facilitated through or made on Trevel, and we restrict suppliers’ use of payment information for these purposes. We encourage you to review the privacy policies, terms of use, and other policies of any travel supplier whose products and services you may purchase through Trevel. Please note that these suppliers also may contact you as necessary to obtain additional information about you or your travel plans, to facilitate your travel reservations, or for other purposes consistent with the practices described in their privacy policies and terms of use.
• Business Partners. We may share information about you, your Devices and your use of our Services with our trusted business partners. For example, we may share information so that we can provide you with relevant content or in order to facilitate payment for products or services you may purchase on the websites of our partners. This sharing is generally pursuant to written agreements which include confidentiality, privacy and security obligations; however, note that we do not control the privacy practices of these third-party business partners.
• Third-party vendors who provide services or functions on our behalf, including business analytics, payment processing, customer service, marketing, public relations, and fraud prevention. For example, our Website uses certain Google analytics and other services and certain pages use the Google Client ID API, which allows users to log in with their Google account information. We may also authorize third-party vendors to collect information on our behalf, including, for example, as necessary to operate features of our Website or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
• Social Media Sites. When you use our Services and elect to share information with third-party social media sites, the information you share will be governed by the privacy policies of those social media sites and the privacy settings you have set with those social media websites.
• Advertising Networks. We collect and share information about your interests with advertising networks. Some of these companies are members of the Network Advertising Initiative, or the Digital Advertising Alliance, which offer a single location to opt-out of ad targeting from member companies. To learn more, please click here.
• Other third-parties, such as referring websites. Third-parties may also assist us in collecting information by, for example, operating features of our website or facilitating the delivery of online advertising tailored to your interests. We may share audience segments and other information with third-parties that use that information for tailored advertising to you.

Third-parties may only collect or access information as needed to perform their permitted functions.

Certain Device operating system versions permit you to opt out of certain types of information sharing, including to certain advertising networks. Please check your Device settings if you want to limit such tracking.

We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:

• To comply with legitimate and enforceable subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us.
• To investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Trevel, our customers, or others; and in connection with our Terms of Use and other agreements.
• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Information Choices

You have options with respect to the collection and use of your information. You can access, update and even close your account by visiting your Member Profile page on our Website.

Your options:

●    You may choose the way we communicate with you. You can choose not to provide us with certain information, although it may be needed to take advantage of certain features offered on our websites.

●    You can prevent the collection of geolocation information, but note that turning off location sharing may affect certain features of our Services.

●    You also can add or update information and close your account. If you close your account, we will deactivate your account and remove your profile information from active view. We may retain some information associated with your account (including past transactions) for internal purposes including backups, fraud prevention, dispute resolution, investigations, and legal compliance for the period necessary to fulfill the purposes outlined in this Statement.

●    As a registered member, you can modify your marketing subscriptions, including email subscription choices at any time within your member settings. You also will be given the opportunity to unsubscribe from promotional messages, including emails with travel-related opportunities, in any such email we send.

●    Trevel wants to make it easy for you to take advantage of travel-related opportunities on our Website. One way we do this is by sending you email messages that contain information about your apparent travel-related interests. For example, if you search for a flight to New York, or New York hotels or reviews on Trevel, we may send you an email message reminding you about special airfare or hotel offers in New York. Similarly, if you receive an email about New York travel and demonstrate an interest in New York hotels, flights, or local travel reviews by affirmatively clicking on a link about New York hotels in the email, you may receive an email about New York hotel or flight offers. We believe these email messages will provide you with useful information about travel-related special offers available through our sites. Please note that you will have the opportunity to choose not to receive these email messages in any such email we send.

●    The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if you refuse to accept cookies from Trevel, you will not be able to access portions of our site.

Information Transfers

We are a global company and operate in many different jurisdictions. If we transfer your information to other countries, we will use and protect that information as described in this Statement and in accordance with applicable law.

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.

Children's Privacy

Trevel is a general audience site and does not offer services directed to children. Should an individual whom we know to be a child under age 13 send personal information to us, we will delete or destroy such information as soon as reasonably possible.

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.

Do Not Track Signals

Our website is not designed to currently respond to “Do Not Track” (“DNT”) signal requests from browsers. This is due to the lack of global standardized interpretation that defines “Do Not Track” signals. Once the industry has settled on standards related to this issue, we may re-evaluate this approach.

Cookies

We want your access to our Services to be as easy, efficient and useful as possible. To help us do this, we use cookies and similar technologies to improve your experience, to enhance site security and to show you relevant advertising.

What are cookies? Cookies are small text files that are automatically placed on your Device when you visit almost any website. They are stored by your internet browser and contain basic information about your internet use. Your browser sends these cookies back to a website every time you revisit it, so it can recognize your Device and improve your experience by, among other things, providing you with personalized content. We also use cookies to remember your login details, so you don’t have to re-enter them repeatedly when you use our Services. Other cookies help us understand your preferences.

The cookies we use fall into three categories.

Category

Example
 

Essential

These cookies are necessary to help you access and move around the website and use all its features. Without these cookies, the website would not work properly and you would not be able to use certain important features. For example, we use a cookie to keep you logged in during your visit, so the site does not require you to log in repeatedly to access different pages. We may also use essential cookies for fraud detection and prevention purposes.

You cannot turn off essential cookies through the Cookie Consent Tool, as such cookies are necessary for you to access and use the features of the website.
 

Analytics and customization

We use these cookies to help us understand how the website is being used and how we can improve your experience on it. These cookies can provide us with information to help us understand which parts of the website interest our visitors and if they experience any errors. We use these cookies to test different designs and features for our sites and we also use them to help us monitor how visitors reach the website.

We also use cookies to save your settings and preferences on the website, such as language preference and information you've previously entered when searching for travel options. Some customization cookies are essential if you want to use certain features of the website.
 

Advertising

Advertising cookies help ensure that the advertisements you see are as relevant to you as possible. For example, some advertising cookies help select ads that are based on your interests. Others help prevent the same ad from continuously reappearing for you.

We also use cookies to make it easy to share content from the website with your friends through your favorite social networks. Social media sites, may set cookies that recognize you when you view content on the website and allow you to share content across both the website and the social media site via the use of sharing settings. For further details, please check your social media site’s terms of use and privacy policy.

We also work with third-party advertisers to give you access to travel content that might be of interest, and may set cookies on our Services to provide you with advertising that matches your interests and preferences. These "third-party cookies" collect information about your browsing behavior and interaction with ads or the Services more generally. This information also helps us limit the number of times you may see the same ads and improve your online experience.

Our Advertising Cookies

We work with third parties that place cookies on our Sites to provide their services, including:

1. Ad Targeting. We work with third-party advertising companies to serve ads while you are visiting our Sites and to permit these companies to place and access their own cookies on your computer in the course of serving advertisements on our Sites.

These companies may use information obtained through their cookies about your visits to our Sites and other websites, in combination with information about your purchases and interests from other online sites in order to provide advertisements about goods and services of interest to you.

We also allow certain third parties to collect web log data from you (which may include IP address, where permitted, and information about your browser or operating system), when you visit our Sites, or to place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified usage data or other data linked to data you voluntarily have submitted to us, for example, your email address, that we may share with third parties solely in hashed, non-human readable form.

1. Advertising Analytics/Measurement. We make use of analytics cookies as part of our online advertising campaigns to learn how users interact with our Sites after they have been shown an online advertisement, which may include advertisements on third-party websites. In particular, our Sites use Google Analytics 360 Suite, including Google Analytics Advertising, which are web analytics and analytics advertising services provided by Google, Inc., which use third party cookies. Where required, our Sites have activated the IP address anonymization functionality so that the IP address of the user is shortened by Google. Our Sites also use the following Google Analytics Advertising features: Google Remarketing, Google Segments, Google Ads Manager and Google Ads. These features use third party cookies to collect information about our website traffic by tracking users across websites and across time and generating reports for us to better understand our website users and to create audiences for our advertisements based on such understanding.
2. Remarketing Pixel Tags. In addition, we may share website usage information about visitors to our Sites with third-party advertising companies for the purpose of managing and targeting advertisements and for market research analysis on our Sites and other sites. For these purposes, we and our third-party advertising companies may place pixel tags (also called clear gifs) on some of the pages you visit on our Sites. We will then use the information that is collected using these pixel tags to serve you relevant advertisements when you are visiting other sites on the Internet. These advertisements may be based on your interests, for example, on the basis of specific searches you conducted on our Sites during earlier browsing sessions.
3. Other Cookies: Our partners, who provide certain features on our Sites or display advertising based on your browsing activity, also use Local Storage such as HTML5, to collect and store content information and preferences. Please note that different web browsers offer their own management tools for removing HTML5 local storage.

Mobile Devices, Anonymous Device Identifiers and Hashed IDs. We and/or third parties that we have engaged may collect and store a unique identifier matched to your mobile device, in order to deliver customized ads or content while you use applications or surf the internet, or to identify you in a unique manner across other devices or browsers. In order to customize these ads or content, we or a third party may collect de-identified usage data or other data about you which you have either voluntarily submitted to us, for example, your email address, or has been passively collected from you, such as your device identifier or IP address, where permitted. However, if we share your email address, we share it solely in hashed, non-human-readable form.

Cookie Consent 

You can manage cookies through the settings of your internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies.

Most advertising networks offer you a way to opt out of advertising cookies. See www.aboutads.info/choices/ and www.youronlinechoices.com for useful information on how to do this.

If you delete your cookies, your access to some functionality and areas of our Services might be degraded or restricted.

Our use of any information we collect through cookies is subject to this Statement, which is linked on every page of our website.

Statement Changes and Notification

We may update this Statement in the future. If we believe any changes are material, we will let you know by doing one or more of the following: sending you a communication about the changes, placing a notice on the website and/or posting an updated Statement on the website. We will note at the top of this Statement when it was most recently updated. We encourage you to check back from time to time to review the most current version and to periodically review this Statement for the latest information on our privacy practices.

Contact

If you have a data privacy request, such as a request to delete or access your data, please contact us via email at contact@trevel.co.  For general data privacy inquiries or questions concerning our Privacy and Cookies Statement, please contact us via email at contact@trevel.co.

Visiting our Website from outside the United States

If you are visiting our Website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that Trevel does take steps pursuant to laws in the United States to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.

California

California Consumer Privacy Act Privacy Statement (“CCPA Statement”)

This CCPA Statement is provided pursuant to the California Consumer Privacy Act (“CCPA”) and applies to California residents and supplements our overall Statement with additional disclosures and rights.

Your rights under CCPA

As of January 1, 2020, California law permits residents of California to request certain details about how their personal information is shared with third-parties or affiliated companies for direct marketing purposes.

California residents may also take advantage of the following rights:

• You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
• You may request that we delete any personal information that we have collected from or about you. As described in more detail in our Statement, there are some reasons we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation. You can also access, update, and remove your information by visiting your Member Profile page on our website.
• You may request to opt out of our sale of your personal information to third-parties for their direct marketing purposes. This means that, if you opt out, going forward, we will not share your information with such third-parties to use for their purposes unless you later direct us to do so. To effect the opt out, please submit a request in writing by emailing us at contact@trevel.co.

To take advantage of your disclosure and deletion rights, please contact us via email at contact@trevel.co. We may need to verify your identity to enable us to process your request. We value your privacy and will not discriminate in response to your exercise of privacy rights. We will respond to your request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.

Disclosures

For purposes of compliance with the CCPA, in addition to the further details as described in the Statement, we make the following disclosures:

• We collect the following categories of personal information:  Identifiers/Contact Information, transactional information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.
• We sell the following categories of personal information:  Identifiers/Contact Information, Internet or other electronic network activity information, and inferences drawn from the above.
• We disclose the following categories of personal information for a business purpose:  Identifiers/Contact Information, commercial information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above. 

Changes to this Privacy Policy

Trevel may change or modify this Privacy Policy in the future. We will note the date that revisions were last made to this Privacy Policy at the top of this page, and any revisions will take effect upon posting. We will notify our members of material changes to this Privacy Policy by either sending a notice to the email address you provided to us or by placing a notice on our Website. We encourage you to check this Privacy Policy from time to time to review the most current version.

How you can contact us

If you have questions about this Privacy Policy, please contact us via email at contact@trevel.co or by postal mail at:

Trevel, Inc.
Attn: Legal Department, Privacy Officer
2404 Broadway, Suite 150
San Diego, CA 92102, USA

Please be aware that calls to and from Trevel may be recorded.  We may use the call recordings to monitor our customer service for quality or compliance purposes, to check the accuracy of the information you provide us, for fraud prevention purposes, or to provide training to our staff.  We will retain the call recordings for as long as reasonably necessary to perform such activities and then delete them.  Any personal information obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.

Translations of this Policy

This Policy is written in the English language. If any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.

©2023 Trevel, Inc. All rights reserved.

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