Updated Privacy Policy and Notice

Welcome! Thank you for visiting an offering owned and operated by Vacation Express, USA Corp., doing business as Vacation Express. To help inform you, we provide this notice explaining our information practices and the choices you can make about the collection and use of information you submit or we collect through our website www.vacationexpress.com and our other related mobile websites, mobile applications ["mobile apps"], services, tools, and other applications [the "Site"]. This Policy is also applicable to data provided to us through our call center and in-person meetings with our personnel. A reference to "Vacation Express," "our," "we," or "us" includes Vacation Express USA Corp.

Effective Date: June 30, 2020

CONTENTS & SUMMARY

A table summarizing the contents of this privacy policy notice ["Privacy Policy"] appears below, followed by the Privacy Policy in full. Should there be any discrepancy between the table and the full Privacy Policy, the language of the full Privacy Policy shall govern.

Full Privacy Policy

1: Scope and Consent
When you use the Site, you are contracting with Vacation Express located at Vacation Express, 3500 Piedmont Road, Suite 600, Atlanta, GA 30305, USA. If you reside outside of the United States, Vacation Express is your data controller. By using the Site, you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy, Terms of Use, Terms and Conditions, Cookies and Tracking Technologies Policy and our Terms and Conditions for Electronic Funds Transfer Payment.

2: Information We Collect
When you use the Site, we or third-party service providers [e.g., those providing fraud or security protection or enabling our website] may collect the following information:

• [a] Registration and Account Information: You can browse the Site without telling us who you are or revealing any personal information [i.e., name, email address, telephone number, mobile telephone number, payment information and physical contact information] about yourself. When you register an account or create a profile, you choose to give us personal information such as name, telephone number, physical address and email address. In addition to personal information, you may also provide us with non-personal information [e.g., airport preferences and tour preferences]. If you are a Travel Agent, you agree to provide your and/or the Travel Agency's name, the IATA, CLIA or TRUE number, consortia details, agency type, business contact details and tax identification numbers.
• [b] Travel Plans: When you initiate Travel Plans, including package deals, flights, hotels, excursions or tour plans, you voluntarily give us personal information including your name, phone number, email address, date of birth, physical and billing address, emergency contact name and contact information, unique identifiers, i.e., frequent flyer information or known traveler number, calendar information for your dates of travel and location data [duration of stay and travel details]. In addition, if you choose to make any special requests including notes about allergies, preferences and health risks, we store the information to help your travel]. When you call us or otherwise interact with our Site, we may collect call log information. Our forms do not request this information, but if you voluntarily provide information to us regarding your race/ethnicity/religion when you book travel, we will have this. You may also provide us with your credit or debit card information, PayPal, Groupon and/or voucher certificate numbers if you are making a purchase.
  
  If you are a Travel Agent making reservations on behalf of your customers, you confirm that you have the appropriate permissions from your customers to share their data with us.
• [c] Subscriptions and Information to Respond to Your Requests: You may give us your personal information such as your name, email address, zip code and other information such as airport preferences so we can send you newsletters, travel deals and other communications you request. Details of how you can opt-out of receiving any communications from us are detailed in Section 5 of this Privacy Policy.
• [d] Social Media Information: When you use social networking plug-ins on our site, the social networks may configure their plug-ins to share your profile ID page with us, which contains certain information stored on those social media sites [e.g. your public profile, friend list, people you follow or who follow you, your email address, birthday, work history, education history, interests, current city, website, personal description, and likes, and your friends' birthdays, education histories, personal descriptions and likes]. We may also receive other information [e.g., content viewed and information about the advertisements or sponsored listings within the content you have been shown or may have clicked on, etc.] from your interaction with our Site. The information we have access to from the third-party social media websites varies by website and is controlled by your privacy settings on that website and by your consent. By associating an account managed by a third-party with your Vacation Express account or otherwise engaging with the Site through a social network and authorizing us to have access to this information, you agree that we may collect, use, and store information from these websites in accordance with this Privacy Policy.
• [e] Mobile Information: We or third-parties may collect additional information from you if you access our Site through a mobile device [e.g., your unique device identifier, unique device token to facilitate push notifications through mobile apps, device's operating system, identifiers associated with equipment or systems used in connection with your device [e.g., an identifier of a Wi-Fi router or Internet access point], mobile manufacturer or carrier, mobile or data network systems or operators, other providers of other apps or code on your device, anyone who has administrative privileges to devices you use, location or GPS/geo-location, mobile number, your email address, user name, passwords, financial or payment information], stored photos and videos on your mobile devices if you choose to share them with us. You agree to our collection of this data [including geo-location data] and the sharing of same with the third-parties described in this Privacy Policy [e.g., web analytics companies; Vacation Express's affiliate companies; social networks or other third-parties operating on our behalf].
• [f] Technical Usage Information: When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Sites ["usage information"]. We may use tracking technologies [including unique identifiers, unique device tokens, HTML5, cookies, flash cookies, web beacons/GIFs, embedded scripts, e-tags/cache browsers, and cross device tracking through deterministic techniques and probabilistic approaches] to collect usage information. We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.
  
  Our goal is to collect and use only that information that we think is required for our legitimate business interests, in order to better understand your interests and improve your experience of using the Site. To learn more about how we use tracking technologies and cookies, see Section 6 of this Privacy Policy and our Cookies and Tracking Technologies Policy.
• [g] Geolocation Information: When you visit the Site, we may collect geo-location information to provide certain location-based services that you request [e.g., maps] or any of the reasons set forth in Section 3 of this Privacy Policy. We disclose the geolocation data in the manner set forth in Section 4 of this Privacy Policy.
• [h] Browsing History: We collect and store your browsing and transactional history to analyze and improve user experience on our Site. We may also use your browsing history for targeted advertising purposes.
• [i] Other Data: You may decide to provide us with other information regarding your travel such as data about your racial or ethnic origin, religious and political beliefs and sexual orientation. If you give us this information, we may store it as long as required for your travel and our business purpose. The information we collect may be combined with information from outside records [e.g., demographic information, navigation information, additional contact information] that we have acquired in accordance with the law.
• [j] Financial Information: When you complete your reservation, you may give us your financial information to pay for your travel plans. When you initiate the payment, you may provide your full name, credit card number, expiry date and CVV to complete the transaction[s]. We store the last four digits of your credit card number and the expiry date.
• [k] Audio: When you call our help desk services, we store your telephone numbers, voice messages, orders placed via voice and any call back done by automated machines and/or personnel. By providing your number you agree to receive calls and messages from Vacation Express on phones that are capable of autodialing at the number provided. Data, message and call rates may apply.
• [l] Information from Other Sources: The information we collect may be combined with information from outside records [e.g., demographic information, navigation information, additional contact information] that we have acquired in accordance with the law.

3: Uses and Retention

• [a] Operate Our Site: We use the information collected to: [i] respond to your requests; [ii] provide customer service [e.g., to resolve disputes, problems with your account/profile, or the Site]; [iii] personalize your experience by providing content on the Site, including targeted advertising, that we believe may be of most interest to you; [iv] improve the Site; [v] give you information about your account; [vi] manage Site traffic; [vii] assess promotional effectiveness; [viii] administer surveys, clubs, promotions [e.g., contests, sweepstakes, reward and loyalty programs]; [ix] manage your purchases [e.g., remember shopping cart information]; [x] marketing purposes; [xi] to improve products and services; and [xii] provide you with a safe, efficient, and customized experience.
• [b] Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information to analyze Site and user behavior and prepare aggregated reports [e.g., total number of visitors, IP addresses, browser types, access times, pages viewed and referring website addresses].
• [c] Prevent Fraud: We use information from the Site, collected by us or third-party service providers that work on our behalf, to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, and enforce our Terms of Use.
• [d] Communicate With You: We use your information to contact you to maintain the Site, your account, or to comply with your stated communication preferences [e.g., for newsletters, deals], or to provide other services requested by you, as described at the time when we collect the information from you, or to contact you for other purposes authorized by law.
• [e] Mobile Data: When you access the Site on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy. For example, by virtue of your use of the Site, you expressly consent to our use of location information to provide you with location-based services, such as advertising, coupons, search results, and other personalized content. We also seek permissions to access your photos, video/media and files to effectuate your request to upload content to us.
• [f] Data Retention: You expressly consent to our lawful worldwide use of your personal information and that we may retain information as long as it is necessary and relevant for our operations, including to effectuate your requests. Further you consent to the ability of third-party service providers working on our behalf to collect and retain personal information and non-personal usage information for Site operation purposes [e.g., fraud prevention]. Further, you consent to our retention of your video viewing tracking data for at least two years or until permission is withdrawn.

4: Disclosure of Information
Information collected on the Site may be shared with:

• [a] Vacation Express: We may share the information we collect about you with affiliated entities. We will use this information to send you marketing communications and you will have the opportunity to opt-out in email communications.
• [b] Service Providers, Suppliers and Other Third-Parties: We may disclose your information to service providers under contract who help with our business operations [such as, but not limited to, fraud investigations, bill collection, payment processing, voucher certificate support, transportation, tour activities, webinars, cloud, ad service providers, targeted advertising to provide offers that we think may be of most interest to you, site analytics and operations], suppliers such as hotels, flight operators, tour providers, insurance providers and similar entities that offer services that help us serve you better. We may also facilitate our Site to permit third-party service providers to collect information from you for security and fraud prevention purposes. Your information may be disclosed to service providers to: [i] provide joint content and our services [e.g., registration, transactions, analytics and customer support]; [ii] help detect and prevent potentially illegal acts, violations of our policies, fraud, and/or data security breaches; and [iii] guide decisions about Vacation Express or third-party products, sites, applications, services, tools, and communications. We may also work with suppliers [e.g., hotels] to deliver marketing opportunities to you that might be of most interest. If you have questions or want further information, please contact us per Section 14 of this Privacy Policy.
• [c] Other Entities with Your Consent: Other third-parties to whom you explicitly ask us to send your information [or about whom you are otherwise explicitly notified and consent to when using a specific service]. On the Site, you may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third-parties, or parties working on their behalf, to implement your request.
• [d] Legal and Law Enforcement: Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Vacation Express user to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, ZIP code, telephone number, email address, user ID history, IP address, fraud complaints, and anything else we may deem relevant to the investigation.
• [e] Change of Control—New Owners: Other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this Privacy Policy, we will request that you receive prior notice.
• [f] Digital Advertising and Other Service Providers: On the Site, we may work with third-parties to provide us with data collection, reporting, ad response measurement, and site analytics and assist with delivery of relevant marketing messages and advertisements. These third-parties may view, edit or set their own tracking technologies/cookies. The use of these technologies by these third-parties is subject to their own privacy policies and is not covered by this Privacy Policy. They might also obtain information about other applications that you have downloaded to your mobile device, the mobile websites you visit and other information about you or your device in order to analyze and serve anonymous targeted advertising on the Site and elsewhere. For more information about third-party ad servers at our Site and your ability to opt-out of targeted advertising from such third-parties, please visit Cookies and Tracking Technologies Policy.
• [g] Companies in the Mobile App Industry: If you access the Site through a mobile device or app, we may also share your information with carriers, operating systems, and platforms.

5: Your Choices
You can control how and when you want to receive notifications from Vacation Express on the Site or by following instructions within the notices.

• [a] Information You Share: You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites' privacy policies and terms of use to learn more about their privacy practices, which we do not control.
• [b] Communication Preferences and Marketing [Opt-out]: We do not disclose your personal information to third parties for their marketing purposes without your consent. We may enter into agreements with third parties for us to send advertising to you. When we do this your personal information is not disclosed. We may combine your information with information we collect from other companies and use it to improve and personalize the Site. If you do not wish to receive marketing communications from us, you can contact us or indicate your communications preference within the direct communication from us. You may click on "unsubscribe" in the emails sent to you to stop receiving communications. You may not opt-out of administrative emails [e.g., emails about your transactions or policy changes] for your registered account.

6: Tracking Technologies [Cookies]
When you visit the Site, we and our business partners may use tracking technologies to enhance your online experience or customize our offerings.

A few additional important things you should know about our use of tracking technologies [cookies]:

• We offer certain features that are available only through the use of tracking technologies.
• We use both session and persistent tracking technologies. Tracking technologies [e.g. cookies] can either be persistent [i.e., they remain on your computer until you delete them] or temporary [i.e., they last only until you close your browser]. You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
• We encode and protect the tracking technologies that Vacation Express sets, so that only we can interpret the information stored in them.
• You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our site that assist us with various aspects of our web site operations and services, such as Google Analytics.
• You also may encounter tracking technologies from third-parties on certain pages of the websites that we do not control and have not authorized [e.g., if you view a web page created by another user, there may be a cookie placed by that web page].
• We may target and track the videos you view. You consent to our tracking of your video viewing through third-party social media for up to two years or as permitted by applicable law.

7: Accessing, Reviewing, and Changing Your Personal Information
Registered members can review and change personal information that is then visible on the Site at any time by accessing their accounts on the Site or by contacting us as indicated in Section 14 of this Privacy Policy. You should promptly update your personal information if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. We may also retain certain transaction history and other non-personal information to analyze user behavior. Likewise if your account or membership is terminated or suspended, we may maintain some information to prevent re-registration. Unfortunately, if you close your account, we cannot reactivate it, but you are always welcome to open a new one.

8: Notice to California Residents
This Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California. We adopted this notice to comply with the California Consumer Privacy Act of 2018 ["CCPA"] and any terms defined in the CCPA have the same meaning when used in this notice.

• 8.1 Information We Collect: In connection with the CCPA, the following table summarizes our personal information collection, use and sharing practices in the preceding twelve [12] months since we last updated this notice on May 5, 2019:

  Categories of Personal Information	Categories of Sources	Commercial/Business Purpose[s] for Collection	Categories of Vendors [including third parties and service providers] to which Personal Information is Disclosed/Sold
  Identifiers Examples: Name, email address, telephone numbers, payment information, physical address, airport preferences, tour preferences, date of birth, emergency contact name and contact information, frequent flyer information or known traveler number	You, your mobile devices and computers used to access our Site	Operate our Site Prevent Fraud Communicate with you with your consent Marketing and advertising Analytics regarding use of Site Internal research As more particularly set out in Section 3	Ad networks Ad tech vendors Social networks Marketing and advertising vendors Service provider
  Internet or Other Electronic Network Activity Information Examples: Domain information, cookie information, browsing and transactional history, information from third-party social media websites	Your mobile devices and computers used to access our Site	Operate our Site Prevent Fraud Communicate with you Marketing and advertising Analytics regarding use of Site Internal research As more particularly set out in Section 3	Ad networks Ad tech vendors Social networks Marketing and advertising vendors
  Geolocation Information Examples: Location of mobile device	Your mobile device or computer used to access our Site	Analytics regarding use of Site Internal research As more particularly set out in Section 3	Ad networks Ad tech vendors Social networks Marketing and advertising vendors
  Commercial Information Examples: Travel and location data [duration of stay and travel details], airport preferences	You	Marketing and advertising Analytics regarding use of Site Internal research As more particularly set out in Section 3	Ad networks Ad tech vendors Social networks Marketing and advertising vendors
  Legally Protected Classifications Examples: Gender	You	Analytics regarding use of Site Internal research As more particularly set out in Section 3	Service provider
  Payment Information [Information under California Civil Code 1798.80] Examples: Billing data	You	Process payments Prevent fraud As more particularly set out in Section 3	Service provider
  Inferences Examples: Characteristics, interests and trends	Derived from above sources/types of information	Maintaining and improving the Site and our products and services As more particularly set out in Section 3	Ad networks Ad tech vendors Social networks

  Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like certain health or medical information and other categories of information protected by different laws.

  We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Site.

• 8.2 Your Rights and Choices: The CCPA provides consumers [California residents] with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

  Access to Specific Information and Data Portability Rights
  You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we've collected about you.
  • The categories of sources for the personal information we've collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we've collected about you [also called a data portability request].
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

  Deletion Request Rights
  You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete [and direct our service providers to delete] your personal information from our records, unless an exception applies.
  We may deny your deletion request if retaining the information is necessary for us or our service provider[s] to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Comply with the California Electronic Communications Privacy Act [Cal. Penal Code § 1546 seq.].
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

  Exercising Access, Data Portability, and Deletion Rights
  To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at 1.800.309.4717 option 9
  • Emailing us at [email protected]

  Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

  You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we've collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
  
  Making a verifiable consumer request does not require you to create an account with us.
  
  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

  Response Timing and Format
  We endeavor to respond to a verifiable consumer request within forty-five [45] days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
  
  We will deliver our written response by mail or electronically, at your option.
  
  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
  
  We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  Personal Information Sales
  We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

• 8.3 Non-Discrimination

  We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

• 8.4 Financial Incentives

  We may offer you certain financial incentives permitted by the CCPA. They include the following:

  • Periodic Contests or Sweepstakes. Each contest or sweepstake have their own terms and conditions that describe how an eligible consumer can opt-in as well as withdraw from the contest or sweepstake.
  • Loyalty Program. Travel agents can earn points for qualifying purchases. A member of the loyalty program can opt-in by creating a VERewards rewards account, and can withdraw at any time from this program by emailing [email protected] and supplying the email address associated with your account.

• 8.5 Other California Privacy Rights

  California's "Shine the Light" law [Civil Code Section § 1798.83] permits users of our Site 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 email to [email protected] or write to us at Vacation Express, 3500 Piedmont Road, Suite 600, Atlanta, GA 30335, USA.

9: Third-Parties
Our Site may contain links to other third-party websites. We are not responsible for the privacy practices or the content of these third-party sites.

10: Security
We store and process your information on our servers located in the United States and around the world. We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use include data encryption, firewalls, regular security assessments of IT infrastructure, access controls to physical, network-based and data assets. It is your responsibility to make sure that your personal information is accurate and that your passwords and account registration information is secure and not shared with third parties.

11: Children's Privacy
The Site is a general audience site and it is not intended for children under the age of 13. We do not knowingly collect personal information via our websites, applications, services, or tools from users in this age group. If you believe your child has provided personal information to us, please contact us via the email listed in Section 14 below.

12: International Transfer
As we operate internationally, and many of our computer systems are currently based in the United States and elsewhere, your personal information may be processed in the United States and elsewhere where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you create an account/profile, you consent to the collection and/or processing in the United States of your personal information and tracking technologies/cookies as described in this Privacy Policy. You understand that your data may be accessed by the United States government if necessary for a governmental investigation.

13: Notification Regarding Updates
From time to time, we may update this Privacy Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the Site. You should check the Site frequently for updates.

If we or any third-party we disclose your personal information to is required to provide notice of a security breach, you consent to receiving notice through this Site or via the email address you have provided to us, at our discretion.

14: Contact Us
If you have any questions or comments about this Privacy Policy, please do not hesitate to contact us at 1.800.309.4717 option 9, or [email protected].